Westmore · UDRP decision
WIPO · Case No. D2026-1578

Barnes-internafional.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <barnes-internafional.com> to Barnes Europe Consulting Kft. It found the domain confusingly similar to the Complainants’ BARNES marks, that the Respondent lacked rights or legitimate interests, and that the typo-based domain had been registered and passively held in bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-07-21
Panelist(s)
Kariņa-Bērziņa, Ingrīda
Complainant
Barnes Europe Consulting Kft Heidi Barnes-Watson
Respondent
Michael Duplantis
Counsel
MIIP – Made in IP
Disputed domain(s)
barnes-internafional.com
Domain history UDRP Intelligence

The timeline behind barnes-internafional.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 barnes-internafional.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 barnes-internafional.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a single-letter typo that closely imitates both a trademark and the complainant’s established business domain can support all three UDRP elements even when the disputed domain has never hosted an active website. The Panel’s reasoning depended on the combined circumstances of prior rights, the targeted domain composition, lack of a plausible legitimate-interest explanation, and passive holding.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-07-21
Panel
Kariņa-Bērziņa, Ingrīda
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Barnes Europe Consulting Kft. and Heidi Barnes-Watson v. Michael Duplantis Case No. D2026-1578 1. The Parties The Complainants are Barnes Europe Consulting Kft., Hungary, and Heidi Barnes-Watson, United States of America (“United States”), represented by MIIP – MADE IN IP, France. The Respondent is Michael Duplantis, United States. 2. The Domain Name and Registrar The disputed domain name <barnes-internafional.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 14, 2026. On April 15, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 15, 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 April 16, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 6, 2026. The Respondent sent an email communication to the Center on May 7, 2026. On May 11, 2026, the proceedings were suspended until June 10, 2026, upon the Complainant’s request. On June 16, 2026, the Complainants requested an extension of the suspension, and the proceedings were further suspended until July 10, 2026. On July 10, 2026, the Complainants requested reinstitution of the proceedings, and the proceedings were reinstituted on the same day. page 2 The Center appointed Ingrīda Kariņa-Bērziņa as the sole panelist in this matter on July 14, 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 Complainants operate real estate agencies and offer luxury services, such as private jet and yacht charter, art advisory, and interior decoration, to clients worldwide. They are the joint proprietors of several trademarks, including the following: - French Trademark No. 3861673 for BARNES (word mark), registered on January 20, 2012 for services in classes 36, 37 and 42; - International Trademark Registration No. 1690818 for B BARNES INTERNATIONAL (device mark), registered on May 30, 2022 for goods and services in classes 9, 16, 35, 36, 37, 39, 42, and 43; and - United States Trademark Registration No. 6855266 for BARNES (word mark), registered on September 27, 2022 for services in classes 35, 36, 37, 39, and 42, claiming first use in 2004. The Complainants operate their primary business website at the domain name <barnes-international.com>, which they registered in 2007. The disputed domain name was registered on December 4, 2025. At the time of the Complaint and of this Decision, it did not resolve to an active website. 5. Parties’ Contentions A. Complainants The Complainants’ contentions may be summarized as follows: The Complainants contend that they have satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainants state that, founded over 20 years ago, the BARNES agencies are a leading international player in high-end residential real estate, established in the world’s most popular cities and top holiday destinations, with operations and licensed affiliates in 15 countries. The BARNES group comprises 158 agencies established in 21 countries. In addition to real estate and property management services, the Complainants offer consulting services related to attaining a lifestyle of French “Art de vivre”. The Complainants contend that the disputed domain name wholly incorporates the Complainant’s BARNES mark followed by the misspelled word “internafional” for “international” (the “t” being replaced by a “f”). This misspelling is barely visible and is a typical example of typosquatting. The Respondent has no rights in the BARNES mark. The nature of the domain name carries a risk of implied affiliation with the Complainants’ well-known BARNES mark, which enjoys an international reputation and has been recognized as well known by UDRP panels. The only reason for having registered this domain name is to create confusion in the public’s mind, to carry out unlawful activities. The Respondent is the registrant of 259 domain names, including those that are obvious misspellings of third-party marks. The disputed domain name, which is not being used, is identical in construction to the Complainants’ own domain name. The Complainants request transfer of the disputed domain name to the Complainant Barnes Europe Consulting Kft. page 3 B. Respondent The Respondent did not substantively reply to the Complainants’ contentions. In his email communication of May 7, 2026, he merely inquired what he “should do.” 6. Discussion and Findings Paragraph 4(a) of the UDRP requires the Complainants to make out all three of the following: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainants have rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the Respondent has registered and is using the disputed domain name in bad faith. Under paragraph 15(a) of the Rules, “[a] Panel shall decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. 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 Complainants’ trademark and the disputed domain name. WIPO Overview 3.1, section 1.7. The Complainants have 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 BARNES 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. Further, the Panel notes that the disputed domain name comprises a deliberate misspelling of a dominant element of the Complainant’s B BARNES INTERNATIONAL mark, wherein the second letter “t” is replaced by the letter “f”, constituting typosquatting. 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 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 Complainants have established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainants’ prima facie showing and has not come forward with any relevant evidence page 4 demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. In particular, the Panel notes that the disputed domain name reflects the entirety of the Complainants’ BARNES mark, followed by an obvious misspelling of the word “international” which is also an element of the Complainant’s B BARNES INTERNATIONAL mark. Such a composition, on balance, signals an intention on the part of the Respondent to confuse users seeking or expecting the Complainants and cannot lead to a finding that the Respondent had rights or legitimate interests in the disputed domain name. The disputed domain name does not resolve to an active website. The Panel does not find that the record supports a finding that the Respondent is commonly known by the disputed domain name or is making legitimate noncommercial use of it. 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. The Complainants’ rights in the BARNES mark predate the registration of the disputed domain name by nearly 15 years. The disputed domain name contains the Complainants’ established BARNES mark together with a misspelling of the word “international,” which is an element of the Complainant’s B BARNES INTERNATIONAL mark. The inference of targeting is further strengthened by the fact that the disputed domain name is nearly identical in structure to the domain name used by the Complainant for its primary business website. Accordingly, the Panel finds that the disputed domain name was registered in bad faith. At time of filing the Complaint, the disputed domain name resolved to an error page, which essentially equates to passive holding. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) 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 absence of 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. 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 <barnes-internafional.com> be transferred to the Complainant Barnes Europe Consulting Kft. /Ingrīda Kariņa-Bērziņa / Ingrīda Kariņa-Bērziņa Sole Panelist Date: July 21, 2026

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

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