Westmore · UDRP DecisionLoreal.agency, Loreal.app, Loreal.support
The Panel ordered the transfer of all three disputed domain names. It found them confusingly similar to the Complainant’s L’ORÉAL trademark, found no evidence of Respondent rights or legitimate interests, and concluded that the domains were registered and used in bad faith. The bad-faith finding rested primarily on the registration of three domains incorporating the well-known mark within seconds of one another and their resolution to parking and for-sale pages, with passive holding providing additional support.
The timeline behind loreal.agency
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 loreal.agency — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how a coordinated cluster of exact-mark domain registrations can strengthen findings across consolidation, legitimate interests, and bad faith. The combination of a well-known mark, three registrations made within seconds, common registrant details, and for-sale parking pages enabled the Panel to find deliberate targeting and bad faith under paragraph 4(b)(i), while passive holding supplied additional support rather than an obstacle.
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 L’Oréal v. Fabio Principe, Vision Prince Case No. D2026-0182 1. The Parties The Complainant is L’Oréal, France, represented by Dreyfus & associés, France. The Respondent is Fabio Principe, Vision Prince, Brazil. 2. The Domain Names and Registrar The disputed domain names <loreal.agency>, <loreal.app>, and <loreal.support> are registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 16, 2026. On January 19, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On January 20, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names, which differed from the named Respondent (Not disclosed) and contact information in the Complaint. The Center sent an email communication to the Complainant on January 21, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on January 22, 2026. The Center verified that the Complaint together with the amended 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 18, 2026. page 2 The Center appointed Nesrine Roudane as the sole panelist in this matter on February 20, 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. 4. Factual Background The Complainant is a French company founded in 1909 and active worldwide in the field of beauty and cosmetics. The record shows that the Complainant is one of the leading beauty groups operating internationally, including in Brazil, where it has been present since 1959. The Complainant is the owner of trademark rights in L’ORÉAL, including, inter alia: - International Trademark Registration No. 184970 for L’ORÉAL, registered on May 23, 1955; - International Trademark Registration No. 1532645 for L’OREAL, registered on April 29, 2020; - International Trademark Registration No. 1681541 for L’ORÉAL, registered on June 1, 2022, designating, inter alia, Brazil; and - Brazilian Trademark registration for L’OREAL, Registration No. 919589790, registered on March 9, 2021; (collectively the “L’ORÉAL trademark”). The record further shows that the Complainant owns numerous trademark registrations for L’ORÉAL in various jurisdictions around the world, including in the jurisdiction where the Respondent is located. These trademark registrations cover, inter alia, cosmetics, beauty care, hair care, and related goods and services. The Complainant also owns domain names incorporating its L’ORÉAL mark, including <loreal.com>. The disputed domain names <loreal.agency>, <loreal.app>, and <loreal.support> were registered on January 8, 2026. The registrar-disclosed record indicates that <loreal.app> was registered at 4:29:26 PM, <loreal.support> at 4:29:33 PM, and <loreal.agency> at 4:29:34 PM, all on the same day. The record shows that the disputed domain names resolved to parking / for-sale landing pages, including an Afternic page stating that the domain name is registered but may still be available. The record also contains technical information showing parking-related DNS configuration. The record does not contain evidence sufficient to establish that the disputed domain names were used for an active website offering the Complainant’s products. According to the registrar-disclosed information, the disputed domain names are registered in the name of Fabio Principe, Vision Prince, Brazil, with the same email address and telephone number associated with all three disputed domain names. The record contains no evidence that the Respondent is affiliated with the Complainant, has been authorized by the Complainant to use its mark, or has been commonly known by the disputed domain names. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the three elements required under paragraph 4(a) of the Policy and requests the transfer of the disputed domain names. page 3 First, the Complainant asserts that the disputed domain names <loreal.agency>, <loreal.app>, and <loreal.support> are identical or, at a minimum, confusingly similar to its L’ORÉAL trademark, which is reproduced in its entirety in each of the disputed domain names. The Complainant submits that the applicable Top-Level Domains (“TLDs”) “.agency”, “.app”, and “.support” do not prevent a finding of confusing similarity and, if anything, may reinforce an impression of affiliation with the Complainant. Second, the Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain names. The Complainant states, inter alia, that it has not licensed, authorized, or otherwise permitted the Respondent to use the L’ORÉAL trademark or to register domain names incorporating that mark. The Complainant further submits that the Respondent is not commonly known by the disputed domain names and has not made any bona fide offering of goods or services, or any legitimate noncommercial or fair use of the disputed domain names. According to the Complainant, the disputed domain names resolve to parking / for-sale landing pages, which do not confer rights or legitimate interests under the Policy. Third, the Complainant contends that the disputed domain names were registered and are being used in bad faith. In particular, the Complainant relies on the reputation and longstanding use of its L’ORÉAL mark, which it submits is well known worldwide and particularly unlikely to have been selected by coincidence. The Complainant argues that the Respondent must have been aware of the Complainant and its trademark rights when registering the disputed domain names, all of which wholly incorporate the Complainant’s mark. The Complainant further points to the fact that the disputed domain names were registered on the same day, within seconds of each other, and are associated with the same underlying registrant information. The Complainant submits that these circumstances support a finding of a deliberate pattern of targeting the Complainant’s mark. The Complainant also relies on the fact that the disputed domain names resolve to parking / for-sale landing pages, including Afternic pages indicating that the domain names may still be available for purchase. According to the Complainant, such use supports a finding that the disputed domain names were registered primarily for sale and therefore in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings The Panel has reviewed the record, including the Complaint, the amended Complaint, and the annexes submitted by the Complainant, as well as the applicable provisions of the Policy, the Rules, and the Supplemental Rules. Under paragraph 4(a) of the Policy, the Complainant must establish, on the balance of probabilities, each of the following: (i) that the disputed domain names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain names; and (iii) that the disputed domain names were registered and are being used in bad faith. The Panel notes that the Respondent did not submit a Response. Pursuant to paragraph 14(b) of the Rules, the Panel may draw such inferences from the Respondent’s default as it considers appropriate. The Complainant, however, must still establish each of the three elements required under paragraph 4(a) of the Policy. page 4 The language of the Registration Agreement is English. Accordingly, pursuant to paragraph 11 of the Rules, the language of the proceeding is English. Consolidation / Identity of the Respondent Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.11.1. The Panel notes that the registrar-disclosed information identifies the registrant of all three disputed domain names as Fabio Principe, Vision Prince, Brazil. The three disputed domain names share the same registrant’s name, organization, email address, telephone number, city, state, postal code, and country. In the circumstances, the Panel is satisfied that the disputed domain names are subject to common control. Accordingly, the Panel decides to consolidate the disputes regarding the disputed domain names in a single proceeding. The Panel addresses each of the three elements of paragraph 4(a) of the Policy in turn. 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 disputed domain names. 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. Each of the disputed domain names <loreal.agency>, <loreal.app>, and <loreal.support>, incorporates the Complainant’s L’ORÉAL trademark in its entirety, omitting only the apostrophe and accent marks, which does not prevent a finding of confusing similarity. The Panel finds that the mark is clearly recognizable within each of the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the Complainant’s mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. The applicable TLDs (“.agency”, “.app”, and “.support”) are generally disregarded for the purposes of the first element confusing similarity test. WIPO Overview 3.1, section 1.11.1. In any event, their presence does not prevent a finding of confusing similarity. The Panel finds that 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 disputed 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 in a domain name, 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. page 5 Having reviewed the available record, the Panel finds that the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain names. In particular, the record contains no evidence that the Complainant has licensed, authorized, or otherwise permitted the Respondent to use the L’ORÉAL trademark or to register domain names incorporating that mark. There is also no evidence that the Respondent has been commonly known by the disputed domain names or by any corresponding name. Further, the disputed domain names resolve to parking / for-sale landing pages, including pages indicating that the domain names may still be available for purchase. On the present record, such use does not constitute a bona fide offering of goods or services, nor a legitimate noncommercial or fair use under the Policy. 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 disputed domain names such as those enumerated in the Policy or otherwise. Accordingly, the Panel finds that 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 sets out circumstances which, without limitation, 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 finds that the record supports a finding of bad faith under paragraph 4(b)(i) of the Policy. The disputed domain names wholly incorporate the Complainant’s well-known L’ORÉAL trademark and resolve to parking / for-sale landing pages, including Afternic pages indicating that the domain names are registered but may still be available for purchase. In the circumstances of this case, the Panel finds that the Respondent registered the disputed domain names primarily for sale, in circumstances supporting a finding of bad faith under paragraph 4(b)(i) of the Policy. The Panel also considers relevant the overall circumstances of the case. The Complainant’s L’ORÉAL trademark is longstanding and widely known. The disputed domain names each wholly incorporate that mark and were registered on the same day, within seconds of each other. The registrar-disclosed information further shows that the disputed domain names are associated with the same underlying registrant details. In the absence of any Response or any plausible explanation from the Respondent, the Panel finds it highly unlikely that the disputed domain names were registered without awareness of the Complainant and its trademark rights. Even if the primary bad faith ground in this case lies in paragraph 4(b)(i) of the Policy, the Panel also considers that the deliberate registration of three domain names incorporating the Complainant’s well-known mark across different TLDs within seconds of each other further supports a finding that the Respondent sought to capitalize on the Complainant’s mark and reputation. Paragraph 4(b) of the Policy sets out a non-exhaustive list of circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.1, section 3.2.1. To the extent the disputed domain names have not been used for any active website other than parking / for- sale landing pages, panels have found that the non-use of a domain name would not by itself prevent a finding of bad faith under the doctrine of passive holding. Rather, panels look at the totality of the circumstances in each case. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes in particular the distinctiveness and reputation of the Complainant’s trademark, the composition of the disputed domain names, the simultaneous registration of the three disputed domain names, and hence finds absence of any plausible good-faith use. In these circumstances, the passive holding of the disputed domain names does not prevent a finding of bad faith under the Policy. page 6 Accordingly, 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 disputed domain names <loreal.agency>, <loreal.app>, and <loreal.support> be transferred to the Complainant. /Nesrine Roudane/ Nesrine Roudane Sole Panelist Date: March 6, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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