Westmore · UDRP decision
WIPO · Case No. D2026-0884

Jurlique-cn.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <jurlique-cn.com>. It found the domain confusingly similar to the Complainant’s JURLIQUE trademark, that the unrebutted record established no rights or legitimate interests, and that the domain was registered and used in bad faith. The bad-faith finding rested on the trademark’s priority, distinctiveness and reputation, the domain’s composition, the likelihood that the Respondent knew of the mark, passive holding, the Respondent’s default, and the domain’s previous use for websites concerning third-party Chinese corporations and links with adult themes.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-22
Panelist(s)
Kalafatoğlu, Mehmet Polat
Complainant
Jurlique International Pty Ltd
Respondent
miao wen bin
Disputed domain(s)
jurlique-cn.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind jurlique-cn.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 jurlique-cn.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of jurlique-cn.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining an entire distinctive trademark with a country-related abbreviation may support not only confusing similarity but also an implied-affiliation finding under the second element. It also demonstrates that current inactivity does not cure bad faith where the totality of circumstances includes earlier trademark rights, likely awareness, a respondent default, and problematic prior use.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used in Bad FaithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-22
Panel
Kalafatoğlu, Mehmet Polat
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Jurlique International Pty Ltd v. miao wen bin Case No. D2026-0884 1. The Parties The Complainant is Jurlique International Pty Ltd, Australia, represented by SafeNames Ltd., United Kingdom. The Respondent is miao wen bin, United States of America (“US”). 2. The Domain Name and Registrar The disputed domain name <jurlique-cn.com> is 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 February 27, 2026. On March 2, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 4, 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 (Redacted for privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 4, 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 March 5, 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 March 11, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 31, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 4, 2026. page 2 The Center appointed Mehmet Polat Kalafatoğlu as the sole panelist in this matter on April 8, 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 was founded in 1985 and originally created as a niche natural skincare brand in Australia. The Complainant notes that the “Jurlique” name derives from the phonetic combination of the founders’ names: Dr. Jurgen Klein and Ulrike Klein. The Complainant offers a range of skincare products. The Complainant also offers their products and spa services across more than 170 land-based stores in different parts of the world. The Complainant owns several trademark registrations for its JURLIQUE trademark, including the following: - the Australian trademark No. 444600 for JURLIQUE, registered on April 30, 1986; - the International trademark registration No. 930145 for JURLIQUE, registered on July 6, 2007; and, - the US trademark registration No. 3771355 for JURLIQUE, registered on April 6, 2010. The Complainant also notes that it is the registrant of several domain names which incorporate the JURLIQUE trademark, including the domain names <jurlique.com> and <jurlique.com.au>. The disputed domain name was registered on July 8, 2022. At the time of filing the Complaint and this Decision, it resolves to an inactive page. However, the record includes archived screenshots related to the disputed domain name dated November 29, 2025, and September 24, 2025. These screenshots show that it was previously resolved to different websites appearing to pertain to third-party Chinese corporations, together with various links that include adult themes. 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. Notably, the Complainant contends that the disputed domain name is confusingly similar to the JURLIQUE trademark; the Respondent has no rights or legitimate interests in respect of the disputed domain name; and the disputed domain name was registered and is being used in bad faith. Moreover, the Complainant asserts that the disputed domain name was previously owned by the Complainant following a transfer pursuant to a UDRP decision in its favor (Jurlique International Pty Ltd v. Domains by Proxy, Inc. / troy ho, WIPO Case No. D2011-1237). The Complainant notes that the disputed domain name was then “snapped” by a third-party registrant in July 2022, before being transferred to another registrant around October/November 2022. The Complainant notes that the disputed domain name was then transferred to a new registrar in August 2023, and it is likely that, on or around that time, the Respondent became the owner of the disputed domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 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 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 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, a hyphen and the letters “cn” (which appear to be an abbreviation for China), may bear on assessment of the second and third elements, the Panel finds 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 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, 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 disputed domain name. In particular, the Panel notes that the disputed domain name fully incorporates the Complainant’s distinctive trademark JURLIQUE with the addition of a hyphen and the letters “cn”, which appear to be an abbreviation for China. In the Panel’s view, the composition of the disputed domain name creates a risk of implied affiliation with the Complainant. WIPO Overview 3.1, section 2.5.1. By failing to submit a Response, 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. Accordingly, 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. page 4 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. In the present case, the Panel notes that the Complainant’s registered trademark largely predates both the registration of the disputed domain name and the date (as asserted by the Complainant) on which the Respondent likely became the owner of the disputed domain name. The Panel also notes that the disputed domain name fully incorporates the distinctive JURLIQUE trademark with the addition of the term “-cn”. Furthermore, the Panel notes that the JURLIQUE trademark is also protected in the US, where the Respondent is purportedly located. Under these circumstances, the Panel finds it very likely that the Respondent was aware of the Complainant’s trademark when registering the disputed domain name. 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. To the contrary, in looking at the totality of circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, the composition of the disputed domain name, and the failure of the Respondent to submit a Response, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Lastly, the Panel considers the previous use of the disputed domain name described above as a further element in establishing the Respondent’s bad faith. Based on the available record, the Panel concludes that the disputed domain name has been registered and is being used in bad faith. 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 name <jurlique-cn.com> be transferred to the Complainant. /Mehmet Polat Kalafatoglu/ Mehmet Polat Kalafatoglu Sole Panelist Date: April 22, 2026

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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