Westmore · UDRP DecisionMichelinjobsites.com, Michelinproject.com
The Panel ordered the transfer of <michelinjobsites.com> and <michelinproject.com>. It found both domain names confusingly similar to the Complainant’s MICHELIN mark, found no rights or legitimate interests, and concluded that the Respondent registered and used the domain names in bad faith. The bad-faith finding relied on the reputation of the MICHELIN mark, the Respondent’s inferred knowledge of the Complainant, prior UDRP proceedings involving the same parties, and websites that displayed the MICHELIN mark and Bibendum mascot in a manner the Panel considered impersonation.
The timeline behind michelinjobsites.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
Westmore reconstructs the full history behind michelinjobsites.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The case combines several recurring UDRP indicators: wholesale incorporation of a recognized mark, brand-specific website content, use of a distinctive mascot, respondent default, and prior disputes involving the same parties. The decision is particularly useful as an example in which website content—not merely the domain strings—provided direct support for findings of targeting, impersonation, and bad-faith use.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Compagnie Générale Des Etablissements Michelin v. John Smith, Michelin guide Case No. D2026-0164 1. The Parties The Complainant is Compagnie Générale Des Etablissements Michelin, France, represented by Tmark Conseils, France. The Respondent is John Smith, Michelin guide, Malaysia. 2. The Domain Name and Registrar The disputed domain names <michelinjobsites.com> and <michelinproject.com> (the “Domain Names”) are registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 14, 2026. On January 16, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Names. On January 19, 2026, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that the Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on January 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 16, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on February 17, 2026. The Center appointed Ana María Pacón as the sole panelist in this matter on February 24, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. Page 2 4. Factual Background The Complainant is a French multinational company founded in 1889 and headquartered in Clermont- Ferrand, France. The Complainant is widely recognized as one of the world’s leading manufacturers of tires and sustainable mobility solutions and operates in the automotive, road, and specialized sectors (including mining, aircraft, and two-wheelers), employing more than 125,000 people worldwide. The Complainant is also known for the publication of travel and restaurant guides, including the well-known Michelin Guide. The Complainant owns numerous trademark registrations worldwide for the mark MICHELIN, including the following: - International Trademark Registration No. 1254506 for MICHELIN, registered on December 10, 2014, covering goods and services in classes 9, 35, 38, 39, 41, and 42; - International Trademark Registration No. 1713161 for MICHELIN, registered on June 13, 2022, covering goods and services in classes 6, 7, 9, 12, 16, 20, 35, 37, 39, 41, and 42; - European Union Trademark Registration No. 009914731 for MICHELIN, registered on September 27, 2011, covering goods and services in classes 9, 35, 37, 38, 39, 41, 42, and 43; - European Union Trademark Registration No. 013558366 for MICHELIN, registered on April 17, 2015, covering goods and services in classes 9, 35, 37, 38, 39, 41, and 42; - United States of America Trademark Registration No. 5775734 for MICHELIN, registered on June 11, 2019, covering goods and services in classes 9, 39, and 42. The Complainant is also the registrant of numerous domain names incorporating its MICHELIN trademark, including <michelin.com>, registered since December 1, 1993. The Domain Names were registered on December 10, 2025. At the time the Complaint was filed, the websites to which the Domain Names resolved displayed the Complainant’s MICHELIN mark in connection with login sites for culinary content relating to the Michelin Guide and included a reproduction of the well- known Michelin “Bibendum” mascot (also known as the “Michelin Man”) used for Bib Gourmand listings. At the time of this Decision, the Domain Names do not resolve to active websites. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Names. Notably, the Complainant contends that the Domain Names are confusingly similar to the Complainant’s MICHELIN trademark because they incorporate the mark in its entirety. The MICHELIN trademark is well- known due to its long and intensive use and promotions for more than a century. The addition of other descriptive terms like “sites; job; project” do not prevent a finding of confusing similarity with the mark MICHELIN. The Complainant further contends that the Respondent has no rights or legitimate interests in respect of the Domain Names. The Respondent has not been authorized or otherwise permitted by the Complainant to use the MICHELIN trademark and is not commonly known by the Domain Names. The term “Michelin” is neither descriptive nor generic, but rather constitutes a distinctive and well-known trademark owned by the Complainant. Accordingly, the Complainant submits that there is no plausible legitimate reason for the Respondent to incorporate the MICHELIN mark into the Domain Names. Finally, the Complainant asserts that the Domain Names were registered and are being used in bad faith. According to the Complainant, the Respondent must have been aware of the Complainant’s well-known MICHELIN trademark at the time of registration. The incorporation of the MICHELIN trademark in its Page 3 entirety in the Domain Names further supports the inference that the Respondent targeted the Complainant’s mark and that no plausible good-faith use of the Domain Names by the Respondent can be inferred. The Complainant requests a transfer of the Domain Names. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the Domain Names. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The entirety of the mark is reproduced within the Domain Names. Accordingly, the Domain Names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms here, “jobsites” and “project” may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the Domain Names and the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. Then there is the addition of the generic Top-Level Domain (“gTLD”), here “.com”. As is generally accepted, the addition of a gTLD such as “.com” is merely a technical registration requirement and as such is typically disregarded under the first element confusing similarity test. WIPO Overview 3.1, section 1.11.1, and Accenture Global Services Limited v. Fan zhi, WIPO Case No. D2024-0285. The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a domain name. Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving that a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the Domain Names. Page 4 The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the Domain Names such as those enumerated in the Policy or otherwise. In particular, the Panel notes the following: - The Complainant asserts - and there is no evidence to the contrary - that it has not licensed or otherwise authorized the Respondent to use its well-established MICHELIN trademark or to register any domain name incorporating that mark. - There is no evidence that, prior to notice of this dispute, the Respondent used or made demonstrable preparations to use the Domain Names in connection with a bona fide offering of goods or services within the meaning of paragraph 4(c)(i) of the Policy, and WIPO Overview 3.1, section 2.2. - Domain names identical or confusingly similar to a complainant’s trademark may carry a high risk of implied affiliation. WIPO Overview 3.1, section 2.5.1. - The Respondent (as an individual, business, or other organization) has not been commonly known by the Domain Names within the meaning of paragraph 4(c)(ii) of the Policy. WIPO Overview 3.1, section 2.3. - There is no evidence that the Respondent is making a legitimate noncommercial or fair use of the Domain Names without intent for commercial gain to misleadingly divert consumers or to tarnish the Complainant’s trademark within the meaning of paragraph 4(c)(iii) of the Policy. WIPO Overview 3.1, section 2.4. The record contains no other factors demonstrating rights or legitimate interests of the Respondent in the Domain Names. In the absence of a Response, the Respondent has failed to rebut the Complainant’s prima facie case. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. In the present case, the Panel notes that the Complainant has demonstrated that its MICHELIN trademark is registered worldwide and enjoys a significant reputation and global recognition. Previous UDRP panels have consistently recognized the well-known character of the MICHELIN mark. See, for example, Compagnie Générale des Établissements Michelin v. WhoisGuard, Inc., WhoisGuard Protected / Saad Zaeem, Caramel Tech Studios, WIPO Case No. D2017-0234; Compagnie Générale des Etablissements Michelin v. WhoisGuard, Inc., WhoisGuard Protected / Zeeshan Shafiq, Caramel Tech, WIPO Case No. D2018-0374; and Compagnie Générale des Établissements Michelin v. World Industrial, LNQ, WIPO Case No. D2019-0553. Panels have repeatedly held that the registration of a domain name incorporating a well-known trademark with knowledge of another company’s rights may in itself constitute evidence of bad faith registration (see Digital Spy Limited v. Moniker Privacy Services and Express Corporation, WIPO Case No. D2007-0160; PepsiCo, Inc. v. “null”, aka Alexander Zhavoronkov, WIPO Case No. D2002-0562; and The Gap, Inc. v. Deng Youqian, WIPO Case No. D2009-0113). Page 5 Given the reputation of the MICHELIN trademark and the fact that the Domain Names incorporate the mark in its entirety, the Panel finds it implausible that the Respondent registered the Domain Names without knowledge of the Complainant and its rights. The Panel further notes that the Complainant’s trademark registrations long predate the registration of the Domain Names and that the Complainant operates its principal website at <michelin.com>. The Panel also notes that the Respondent appears to have engaged in a pattern of abusive domain name registrations. In particular, the Respondent has been the subject of previous UDRP decisions involving the Complainant, including Compagnie Générale des Établissements Michelin v. John Smith, Michelin guide, WIPO Case No. D2025-4120 and Compagnie Générale des Établissements Michelin v. John Smith, Michelin guide, WIPO Case No. D2025-4268. Such conduct further supports a finding of bad faith. With respect to use, the evidence on record shows that the Domain Names resolved to websites displaying the Complainant’s MICHELIN mark in connection with culinary activities related to the MICHELIN Guide and reproducing the well-known MICHELIN “Bibendum” mascot. In the Panel’s view, this conduct indicates an attempt to impersonate the Complainant and to mislead Internet users into believing that the websites are affiliated with or endorsed by the Complainant. It is well accepted that the impersonation of a complainant through the use of its trademark in a domain name and on the associated website constitutes evidence of bad faith registration and use. See, for example, Ares Management LLC v. Omelchenko Aleksei, WIPO Case No. D2023-0836; FLRish IP, LLC v. prince zvomuya, WIPO Case No. D2019-0868. In light of the above circumstances, the Panel finds that the Respondent registered and is using the Domain Names in bad faith. The Panel finds that the Complainant has established the third element of the Policy. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the Domain Names <michelinjobsites.com> and <michelinproject.com> be transferred to the Complainant. /Ana María Pacón/ Ana María Pacón Sole Panelist Date: March 10, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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