Westmore · UDRP DecisionKeratasesbr.com
The Panel ordered transfer of <keratasesbr.com> to L’Oréal. It found the domain confusingly similar to the KERASTASE mark, held that the unrebutted record established no rights or legitimate interests, and concluded that the Respondent registered and used the domain in bad faith. The Panel relied particularly on the typographical variation of the mark, the prior unauthorized product website, the intentional attraction of users for commercial gain through confusion, and the later redirection to an adult-content website.
The timeline behind keratasesbr.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
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This decision illustrates how a typographical variation of a distinctive mark, combined with geographically suggestive letters, may satisfy confusing similarity where the domain’s actual use reinforces targeting. The progression from an unauthorized branded sales website to unrelated adult-content redirection supplied mutually reinforcing evidence against legitimate interests and in favor of bad faith.
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. Emilie Megan Case No. D2026-0306 1. The Parties The Complainant is L’Oréal, France, represented by Dreyfus & associés, France. The Respondent is Emilie Megan, Brazil. 2. The Domain Name and Registrar The disputed domain name <keratasesbr.com> is registered with Squarespace Domains LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 26, 2026. On January 26, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 26, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (SP) and contact information in the Complaint. The Center sent an email communication to the Complainant on January 27, 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 28, 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 30, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 19, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on February 20, 2026. page 2 The Center appointed Gonçalo M. C. Da Cunha Ferreira as the sole panelist in this matter on February 27, 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 L’Oréal, a multinational company specializing in cosmetics and beauty products and one of the leading cosmetics groups worldwide. The Complainant owns numerous trademark registrations for KERASTASE, namely: International Trademark KERASTASE, No. 283650, registered on May 15, 1984; International Trademark KERASTASE, No. 1686528, registered on July 14, 2022; United States Trademark KERASTASE, No. 7161652, registered on September 12, 2023. The Complainant also operates domain names incorporating its trademark, including <kerastase.com>, registered on October 21, 1996. The disputed domain name <keratasesbr.com> was registered on April 3, 2025. The record shows that the disputed domain name previously resolved to a Portuguese-language website displaying the Complainant’s trademark and offering purported KERASTASE products for sale without authorization. The website was subsequently deactivated. The disputed domain name later redirected Internet users to an unrelated third-party website promoting adult industry services. Prior to initiating the present proceeding, the Complainant attempted to resolve the matter amicably by contacting the registrar and the hosting provider requesting the deactivation and blocking of the disputed domain name, but without success. 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 disputed domain name. In particular, the Complainant contends that: - the Complainant’s KERASTASE trademark enjoys worldwide reputation and is supported by numerous trademark registrations. - the Complainant also operates domain names reflecting its trademark, including the official domain name <kerastase.com>. - the disputed domain name is confusingly similar to the Complainant’s KERASTASE trademark and official domain name. - the disputed domain name reproduces the Complainant’s trademark with a slight typographical - deviation (“keratases” instead of KERASTASE), which constitutes typosquatting. - the addition of the letters “br”, corresponding to the ISO country code and ccTLD abbreviation for Brazil, does not prevent confusing similarity and rather increases the likelihood of confusion. - the generic Top-Level Domain “.com” is irrelevant when assessing confusing similarity. page 3 - the disputed domain name is likely to mislead Internet users into believing that it is associated with the Complainant. - the Respondent has no rights or legitimate interests in respect of the disputed domain name. - the Complainant’s trademark rights predate the registration of the disputed domain name by many years. - the Respondent is not commonly known by “KERASTASE”, is not affiliated with the Complainant, and has not been authorized or licensed to use the Complainant’s trademark or to register any domain name incorporating it. - the Respondent has not used, or made demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. - the disputed domain name previously resolved to a website reproducing the Complainant’s trademark and logo without authorization and offering purported KERASTASE products for sale, thereby creating a false affiliation with the Complainant. - the Respondent is not an official reseller of the Complainant’s products. - the current redirection of the disputed domain name, after the display of a phishing warning page, to an unrelated third-party website relating to adult industry services further shows the absence of rights or legitimate interests. - the Respondent registered and is using the disputed domain name in bad faith, with knowledge of the Complainant’s trademark rights and with the intention of taking unfair advantage of the reputation of the Complainant’s trademark and misleading Internet users. 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 disputed domain name. 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 for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel notes that the disputed domain name incorporates the Complainant’s KERASTASE trademark with the addition of the letter “s”, resulting in the term “keratases”, followed by the letters “br”. This constitutes a typical case of typosquatting. See WIPO Overview 3.1, section 1.9. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is 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, the letter “s” and the letters “br”) may bear on assessment of the second and third elements, the Panel finds that the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. The Panel finds that the first element of the Policy has been established. page 4 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, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the disputed 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 disputed domain name. 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 name such as those enumerated in the Policy or otherwise. Panels have held that the use of a domain name for illegitimate activity, here claimed as passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. 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 disputed domain name incorporates the Complainant’s KERASTASE trademark with a minor typographical variation and the addition of the letters “br”. Given the distinctiveness and reputation of the Complainant’s trademark, the Panel finds it implausible that the Respondent registered the disputed domain name without knowledge of the Complainant’s rights. Paragraph 4(b) of the Policy sets out a list of non-exhaustive 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. The Panel considers that the Respondent’s conduct constitutes an intentional attempt to attract, for commercial gain, Internet users to the Respondent’s website by creating a likelihood of confusion with the Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of the website or the products offered on it within the meaning of paragraph 4(b)(iv) of the Policy. Previous UDRP panels have consistently recognized the well-known status of the Complainant’s KERASTASE trademark. See, for example, L’Oréal v. Arfah Husaifah, WIPO Case No. D2012-2255; L’Oréal v. Tina Smith, WIPO Case No. D2013-0820; and L’Oréal v. Privacy Protection Service / Kadir Tekdogan, WIPO Case No. D2014-1049. The Panel also notes that the disputed domain name redirected Internet users to a third-party website containing adult content, which further supports the conclusion that the Respondent registered and used the disputed domain name in bad faith. page 5 Panels have held that the use of a domain name for illegitimate activity, here claimed as passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. Accordingly, the Panel finds that the disputed domain name has been registered and is being used 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 disputed domain name <keratasesbr.com> be transferred to the Complainant. /Gonçalo M. C. Da Cunha Ferreira/ Gonçalo M. C. Da Cunha Ferreira Sole Panelist Date: March 10, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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