Westmore · UDRP DecisionLaccitane.com + 23 more domains
The Panel ordered the transfer of all 24 disputed domain names. It found them to be typosquatted variations of the Complainant’s L’OCCITANE mark, held that the unrebutted record established the Respondent’s lack of rights or legitimate interests, and found bad-faith registration and use based on the portfolio of misspellings, targeting of the mark, and redirection to skincare information and pay-per-click links for commercial gain.
The timeline behind laccitane.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 laccitane.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
This decision is a clear example of portfolio-scale typosquatting in which numerous closely related misspellings, concentrated registration dates, common redirection, and pay-per-click content collectively demonstrated deliberate targeting. It also illustrates that allegations such as phishing should be kept distinct from the narrower conduct the Panel expressly found.
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 Laboratoires M&L v. Zhichao Case No. D2026-0966 1. The Parties The Complainant is Laboratoires M&L, France, represented by Strategic IP Information Pte Ltd., Singapore. The Respondent is Zhichao, China. 2. The Domain Names and Registrar The disputed domain names <laccitane.com>, <lccitane.com>, <leoccitane.com>, <loccatane.com>, <locciane.com>, <locciatane.com>, <locciltane.com>, <loccintane.com>, <loccitanc.com>, <loccitaner.com>, <loccitanew.com>, <loccitann.com>, <loccitano.com>, <loccitanre.com>, <loccitante.com>, <loccitanw.com>, <loccitany.com>, <loccitiane.com>, <loccitine.com>, <loccitone.com>, <loccitune.com>, <loccsitane.com>, <locicitane.com>, and <olccitane.com> are registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 6, 2026. On March 6, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On March 9, 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 (Dynadot Privacy Service, Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 9, 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 11, 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on March 12, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 1, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 7, 2026. The Center appointed Uwa Ohiku as the sole panelist in this matter on April 10, 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 1976 and manufactures natural and organic ingredient-based cosmetics and wellness products sold in over 90 countries, under the L’OCCITANE trademark, which it has used extensively for many years. The Complainant owns the L’OCCITANE trademark in many jurisdictions, some of which are: -International Trademark Registration No. 533941 registered on February 27, 1989. -International Trademark Registration No. 579875 registered on November 5, 1991. -International Trademark Registration No. 1741986 registered on March 2, 2023. The Complainant is also the owner of the domain name <loccitane.com>, registered on April 7, 1997. The Respondent appears to be an individual with an address in China. The disputed domain names: <locciane.com>, <lccitane.com> and <loccitanw.com> were registered on July 2, 2025, and all other disputed domain names: <laccitane.com>, <leoccitane.com>, <loccatane.com>, <locciatane.com>, <locciltane.com>, <loccintane.com>, <loccitanc.com>, <loccitaner.com>, <loccitanew.com>, <loccitann.com>, <loccitano.com>, <loccitanre.com>, <loccitante.com>, <loccitany.com>, <loccitiane.com>, <loccitine.com>, <loccitone.com>, <loccitune.com>, <loccsitane.com>, <locicitane.com>, and <olccitane.com>, respectively, were registered on July 7, 2025. According to evidence supplied by the Complainant at the time of filing the Complaint, the disputed domain names redirected to a website: “www.totalmd.org”, with information on skin-related matters as well as pay- per-click links. 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 names. Identical or Confusingly Similar Notably, the Complainant contends amongst other contentions, that the disputed domain names are confusingly similar to its trademark L’OCCITAINE in which the Complainant holds earlier registered and established rights. The Complainant further contends as follows: that the alterations or misspellings in the disputed domain names do not eliminate confusing similarity and Internet users would be misled into believing that these disputed domain names are associated with or endorsed by the Complainant, which is not the case; that the applicable Top-Level Domain (“TLD”) is disregarded under the first element of confusing similarity. WIPO Overview of Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.11. In addition, the page 3 Complainant asserts that it has garnered substantial use, reputation and goodwill in the L’OCCITANE mark, long before the registration of the disputed domain names and that the L’OCCITANE mark has become well- known. No Rights or Legitimate Interests The Complainant contends, among other contentions, that the Respondent has no rights or legitimate interests in respect of the disputed domain names, which incorporate the L’OCCITANE trademark; that the Complainant has not authorized the Respondent to use marks that are confusingly similar to the L’OCCITANE trademark or trade name, in whole or in part, in any manner whatsoever, including as domain names and that the use of terms confusingly similar to the L’OCCITANE trademark as a part of the disputed domain names is in bad faith and solely intended to give the impression of an association or relationship with the Complainant. Further, the Complainant asserts that the disputed domain names redirected to a website “www.totalmd.org”, with an intention to commercially freeride on the Complainant’s well-known L’OCCITANE trademark; that such fraudulent and deceptive practices pose a serious security risk to consumers and sullies the reputation of the Complainant’s business under the L’OCCITANE trademark, which is further evidence of the Respondent’s lack of rights or legitimate interests in the disputed domain names. Registered and Used in Bad Faith The Complainant also alleges, among several others, that the Respondent has not used or demonstrated preparations to use the disputed domain names in connection with bona fide offering of goods or services, but to disrupt the Complainant’s business; that the Respondent deliberately chose the disputed domain names to trade off the reputation and goodwill associated with the Complainant’s L’OCCITANE mark, to cause confusion amongst Internet users and the Complainant’s customers and to benefit from misdirected traffic; that the website to which all the disputed domain names redirect, is a phishing site allegedly related to cosmetics, which clearly shows an intention to commercially freeride on the Complainant’s trademark L’OCCITANE, which reflects opportunistic bad faith. . The Complainant further asserts that the registration of disputed domain names incorporating well-known marks by an entity unrelated to the mark is evidence of bad faith and that the Respondent intentionally chose and registered disputed domain names that are similar to the Complainant’s trademark. 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 names, to assess whether the mark is recognizable within the disputed domain names. WIPO Overview 3.1, section 1.7. The Complainant has shown that it has registered rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. page 4 The Panel finds the mark is recognizable within all the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. The disputed domain names consist of variations (common, obvious or intentional misspellings) of the Complainant’s L’OCCITANE trademark, a form of typosquatting, which does not prevent a finding of the confusing similarity between the disputed domain names and the Complainant’s L’OCCITANE trademark. WIPO Overview 3.1, section 1.9. 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 provide 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 names, such as enumerated in the Policy or otherwise, and the Respondent has failed to rebut the same or to come forward with any relevant evidence demonstrating such rights or legitimate interests in the disputed domain names. 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 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 also be relevant in making the assessment. WIPO Overview 3.1, section 3.2.1. In the present case, the Panel notes, among several others, that the Respondent registered 24 disputed domain names which are all variations of the famous L’OCCITANE mark of the Complainant, which shows that the Respondent was clearly aware of the Complainant and its L’OCCITANE mark. The typosquatting nature of the disputed domain names creates a presumption of bad faith. WIPO Overview 3.1, section 3.1.4. In addition, all the disputed domain names redirect to a website featuring skincare information as well as pay-per-click links, which supports the Complainant’s contention that the Respondent has registered and is using the disputed domain names intentionally to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s mark. WIPO Overview 3.1, section 3.1.4. The Respondent did not respond to the Complaint and limited checks of previous WIPO decisions revealed several decisions against the Respondent (e.g., Barracuda Networks, Inc. v. Zhichao, WIPO Case No. D2022-4659; Fenix International Limited v. Zhichao, WIPO Case No. D2025-0806 and Laboratoires M&L v. Zhichao, WIPO Case No. D2025-2680, etc.). page 5 Given the foregoing, in the Panel’s view, the Respondent was aware of the Complainant and its mark and clearly targeted the Complainant in registering and using the disputed domain names. 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 <laccitane.com>, <lccitane.com>, <leoccitane.com>, <loccatane.com>, <locciane.com>, <locciatane.com>, <locciltane.com>, <loccintane.com>, <loccitanc.com>, <loccitaner.com>, <loccitanew.com>, <loccitann.com>, <loccitano.com>, <loccitanre.com>, <loccitante.com>, <loccitanw.com>, <loccitany.com>, <loccitiane.com>, <loccitine.com>, <loccitone.com>, <loccitune.com>, <loccsitane.com>, <locicitane.com>, and <olccitane.com> be transferred to the Complainant. /Uwa Ohiku/ Uwa Ohiku Sole Panelist Date: April 24, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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