Westmore · UDRP decision
WIPO · Case No. D2026-1716

Junot.com

Complaint deniedWIPO-indexed · informational, not legal advice

The three-member Panel denied the Complaint. It found <junot.com> identical to the Complainant’s JUNOT trademark but did not reach rights or legitimate interests because the Complainant failed to establish bad-faith registration. The domain name was registered in 2000, 14 years before the Complainant obtained its first registered JUNOT rights, and the Panel found no evidence that the Respondent knew of or targeted the Complainant or its subsidiary at registration. The Panel accepted as plausible the Respondent’s explanation that “Junot” was selected as a surname for a proposed personalized email and website service. It also found Reverse Domain Name Hijacking because the legally represented Complainant must have known it could not establish the third UDRP element.

Outcome
Denied
At a glance
Provider
WIPO
Outcome
Complaint denied
Decision date
2026-07-02
Panelist(s)
Cabell, Diane · Féral-Schuhl, Christiane · Kennedy, Matthew (Presiding)
Complainant
K Holding
Respondent
M. Thestrup, Best Identity
Disputed domain(s)
junot.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind junot.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 junot.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 denied. junot.com remained with the respondent.
Reverse Domain Name Hijacking
Reverse Domain Name Hijacking: found.
Westmore Insight

This decision illustrates the central importance of the registration-date inquiry under the UDRP’s conjunctive bad-faith requirement. Current trademark rights and an exact domain match established standing, but they could not establish bad-faith registration where the domain predated those rights by 14 years and the evidence did not show targeting of an earlier unregistered identifier. It also demonstrates the RDNH risk of pursuing a complaint after failed purchase negotiations when the historical evidence does not support respondent awareness or targeting at registration.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsnot_reached
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
Complaint denied
Decision date
2026-07-02
Panel
Cabell, Diane · Féral-Schuhl, Christiane · Kennedy, Matthew (Presiding)
Full decision
18 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION K Holding v. M. Thestrup, Best Identity Case No. D2026-1716 1. The Parties The Complainant is K Holding, France, represented by SAS Illouz Avocats, France. The Respondent is M. Thestrup, Best Identity, Denmark, represented by Lewis & Lin, LLC, United States of America. 2. The Domain Name and Registrar The disputed domain name <junot.com> is registered with eNom, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 23, 2026. On the same day, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On the same day, 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 (The RDAP server redacted the value) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 24, 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 April 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 May 1, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 21, 2026. The Response was filed with the Center on May 21, 2026. On June 8, 2026, the Complainant submitted a supplemental filing to the Center. On June 15, 2026, the Respondent submitted a reply to the Complainant’s supplemental filing. page 2 The Center appointed Matthew Kennedy, Christiane Féral-Schuhl, and Diane Cabell as the Administrative Panel in this matter on June 19, 2026. The Panel finds that it was properly constituted. Each member of 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, a French company registered in 2009, is the holding company of Junot Investissements, a French company registered in 1985. Junot Investissements has operated since 1985 in the field of high-end real estate brokerage, property investment, and related financial services in Paris and its surrounding areas. Its registered office is in Avenue Junot in Paris. The Complainant holds registrations for multiple trademarks, including the following: French trademark registration number 4066865 for JUNOT, registered on May 30, 2014, specifying services in class 36; French trademark registration number 4066871 for JUNOT INVESTISSEMENTS, registered on May 30, 2014, specifying services in class 36; and European Union trademark registration number 018049064 for a figurative JUNOT mark, registered on August 13, 2019, specifying services in class 36. The above trademark registrations all specify services in class 36, including real estate affairs; real estate management; and valuation of property. The domain name <junotinvest.com> was registered on June 23, 2000, presumably by Junot Investissements. The Complainant registered the domain name <junot.fr> on February 26, 2014, which it has used since that time with a website presenting information about the Junot group and its services. According to the website, the Junot group is now composed of 25 luxury real estate agencies in Paris, the west of Paris, Lille, and Brussels. The Respondent is Michael Thestrup Sandfort, aka Michael Sandfort, and his company “Best Identity”, based in Denmark. Mr. Sandfort was previously director of Global E Services Ltd, a company incorporated in the United Kingdom on September 18, 2000 that was dissolved in 2003. The Respondent currently holds a large portfolio of domain names. The disputed domain name was created on July 3, 2000. It does not resolve to any active website; rather, it is passively held. On December 16, 2024, the Complainant submitted, via a brokerage, an anonymous offer of USD 310 for the disputed domain name. The Respondent declined this offer on the following day and made no counter offer. On December 25, 2024, the negotiation was closed without an agreement. 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 identical to its JUNOT mark, and confusingly similar to its other JUNOT-formative marks. page 3 The Respondent has no rights or legitimate interests in respect of the disputed domain name. The disputed domain name has not been used for any bona fide offering of goods or services since its registration in 2000. It has never been used for a legitimate business purpose. The disputed domain name has been registered and is being used in bad faith. The disputed domain name is identical to the Complainant’s JUNOT trademark and likely to cause confusion among consumers seeking the Complainant’s services. The Complainant has actively conducted business under the JUNOT brand for many years since 1984. The Respondent’s attempt to sell the disputed domain name capitalizes on the established reputation of the Complainant and its JUNOT brand. The Respondent has effectively prevented the Complainant from using the disputed domain name, despite its well-established rights, its ongoing business and its ownership of the domain name <junot.fr>. The prolonged inactivity of the disputed domain name, combined with the Respondent’s refusal of multiple reasonable offers to purchase it, demonstrates that the Respondent’s intention is to exploit the Complainant’s well-established brand. In its supplemental filing, the Complainant alleges that when the Respondent registered the disputed domain name, it did not select a neutral or generic term, but rather the core distinctive identifier through which the Complainant had already been known for many years. The Respondent claims that the disputed domain name was registered as part of a project operated through Global E Services Ltd, but that company was not incorporated until September 18, 2000, two months after the disputed domain name was registered. The complete absence of implementation of the Respondent’s business model is inconsistent with any bona fide business purpose and strongly supports the conclusion that the disputed domain name was acquired and retained for speculative purposes. If the Respondent had conducted the searches that he claims, he would necessarily have encountered the Complainant’s prior rights. The Respondent intentionally targeted names originating from French linguistic and commercial contexts. The Respondent’s own evidence demonstrates the accumulation of a large portfolio of domain names, including surnames, commercial terms, and other categories of identifiers. The absence of any meaningful counter-offer to the Complainant’s offer for the disputed domain name, or any genuine negotiation by the Respondent, confirms his speculative intent. B. Respondent The Respondent contends that the Complainant has not satisfied the elements required under the Policy for a transfer of the disputed domain name. Notably, the Respondent alleges that he was living in the United Kingdom when he started a business that later started to trade under the name Global E Services Ltd. In 2000, he anticipated an eventual demand for personalized email addresses (e.g., “firstname@surname.com”) that could be made into a business. He went through telephone books, including French telephone books, and checked if the surnames were available for registration. He registered roughly 3,000 domain names comprised of surnames. He also registered other categories of domain names, including potential future business names. During that time, he had no intention of selling any domain name. He ran a European Union trademark search before registering each one, including the disputed domain name. In 2003, he moved from the United Kingdom to Denmark, and the activities of Global E Services Ltd were transferred to a new trading name, Best Identity. From 2010, he offered many generic and surname domain names for sale on a broker’s website. The Respondent does not dispute that the disputed domain name is identical or confusingly similar to trademarks in which the Complainant currently has rights, but argues that the Complainant failed to allege any facts or submit any evidence indicating that it had gained enforceable trademark rights, or used JUNOT in any capacity in commerce in the United Kingdom or Denmark, nor sole use of JUNOT anywhere in the world, prior to the time when the disputed domain name was registered. The Respondent registered the disputed domain name as part of a bona fide business. He dedicated himself full time roughly 16 months to making his vision of a surname and business email business a reality, and then part time during the years thereafter and until the present. Accordingly, long before any notice of this dispute, the Respondent made use of, and demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of services. In 2010, after years of paying renewal fees without page 4 generating revenues and without selling any domain names, he listed his collection of surnames and potential business names with a domain name broker. The disputed domain name was not registered and is not being used in bad faith. The disputed domain name was registered by the Respondent more than a decade before the Complainant even had registered trademark rights to JUNOT in its own country, let alone in Europe. The record indicates that, as of July 2000, the Complainant was known only by the trademark JUNOT INVESTISSEMENTS, and only in France. The Respondent registered the disputed domain name in good faith with no intention of selling or renting it to the Complainant. The Respondent, a Danish national then living in London, was not even aware of the Complainant, a French company, at the time of the disputed domain name’s registration. He registered the disputed domain name as a part of his vanity email business because Junot is a name and surname found in a French phonebook and shared by roughly 35,000 people, globally. There are over 100 trademark applications and registrations around the world, and well over 100 businesses worldwide that incorporate “Junot” in their business name. The Complainant’s argument that the Respondent’s refusal to sell the disputed domain name to an anonymous bidder – for less than the amount the Respondent had spent on registration and renewal fees – somehow reflects a bad faith use of the disputed domain name is baseless. In his supplemental filing, the Respondent argues that the Complainant fails to offer more than conjecture that the Respondent targeted the Complainant’s alleged JUNOT trademark. The Complainant failed to provide any evidence that the Respondent specifically targeted the Complainant’s trademark when he registered the disputed domain name some 25 years ago. The fact that the Respondent’s principal began registering domain names before registering an entity does not somehow make his registration of domain names predating the Respondent’s incorporation improper. His trademark clearance process involved searching a European Union trademark database. He searched for individual surnames in telephone directories and then searched for any trademark registrations for those surnames. His search revealed that “Junot” was a surname not registered as a trademark anywhere in the European Union. The mere fact that the Respondent did not respond to the Complainant’s low-ball offer is not evidence of bad faith; had the Respondent responded, the Complainant would no doubt be arguing that the counter-offer was evidence of bad faith. 6. Discussion and Findings 6.1. Procedural Issue: Supplemental Filings The Complainant submitted a supplemental filing after receipt of the Response. The Respondent submitted a supplemental filing in reply, before the appointment of the Panel. The Complainant seeks to justify its supplemental filing on the ground that the Response introduces a number of factual assertions and supporting documents that the Complainant alleges could not reasonably have been addressed in the Complaint. The Respondent submits that the Panel should disregard the Complainant’s supplemental filing because it does not provide any newly discovered evidence or information but merely rebuts arguments that it reasonably should have anticipated in the Complaint. Nevertheless, should the Panel consider the Complainant’s supplemental filing, the Respondent provides his own supplemental filing. Paragraph 10(b) of the Rules requires the Panel to ensure that the Parties are treated with equality and that each Party is given a fair opportunity to present its case. Paragraph 10(d) of the Rules requires the Panel to determine the admissibility, relevance, materiality and weight of the evidence. Although paragraph 12 of the Rules empowers the Panel, in its sole discretion, to request further statements or documents from either of the Parties, this does not preclude the Panel from accepting unsolicited filings. See Delikomat Betriebsverpflegung Gesellschaft m.b.H. v. Alexander Lehner, WIPO Case No. D2001-1447. page 5 The Panel notes that the Complainant’s supplemental filing rebuts the assertion that it lacks prior registered trademark rights in JUNOT, even though that issue was already addressed in the Complaint, and it discusses the fact that Junot is a surname, which could reasonably have been anticipated in the Complaint. However, the Complainant also comments on the Respondent’s factual evidence, some of which could not have been reasonably anticipated in the Complaint, and it replies to the claim of Reverse Domain Name Hijacking. The Respondent has taken the opportunity to respond to the Complainant’s supplemental filing, in full, in his own supplemental filing. Both supplemental filings were made before the appointment of the Panel, and accepting them will not delay this proceeding. Therefore, the Panel exercises its discretion to admit both Parties’ supplemental filings and will take them into consideration in this Decision according to their respective relevance, materiality and weight as part of the record. 6.2. Substantive Issues Paragraph 4(a) of the Policy provides that a complainant must prove each of the following elements with respect to the disputed domain name: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights; (ii) the respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. The burden of proof of each element is borne by the Complainant. Failure to demonstrate any element will result in denial of the Complaint. 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. See 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 JUNOT trademark, among others, for the purposes of the Policy. Given the global nature of the Internet, the jurisdictions in which those rights exist are not considered relevant to the assessment under the first element of the Policy. Further, it is sufficient for the purposes of the first element of the Policy that those rights existed at the time when the Complaint was filed, as is the case here. See WIPO Overview 3.1, sections 1.1.2, 1.1.3 and 1.2.1. The JUNOT trademark is wholly reproduced within the disputed domain name. The only additional element is a generic Top-Level Domain (“gTLD”) extension (“.com”) which, as a standard requirement of domain name registration, may be disregarded in the assessment of identity or confusing similarity for the purposes of the Policy. Accordingly, the disputed domain name is identical to the mark for the purposes of the Policy. See WIPO Overview 3.1, sections 1.7 and 1.11.1. Therefore, the Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Given the Panel’s findings regarding the third element of paragraph 4(a) of the Policy in Section 6.2C below, it is unnecessary to consider the second element. page 6 C. Registered and Used in Bad Faith The Panel notes that the third element of paragraph 4(a) of the Policy contains two requirements that apply conjunctively. A complainant must show both that the disputed domain name has been registered in bad faith and also that it is being used in bad faith. The former requires a demonstration that the Respondent knew, or should have known of the Complainant and/or the Complainant’s trademark at the time when it registered or acquired the disputed domain name and that it registered the disputed domain name with a bad faith intention targeting the Complainant and/or its mark. In the present case, it appears that the current registrant individual has been the registrant of the disputed domain name since its creation. His Danish company, Best Identity, was added as the registrant organization later. As such, the disputed domain name has been the subject of an unbroken chain of possession, and the Panel will assess registration in bad faith in light of the circumstances prevailing at the time of its original registration. The disputed domain name was registered in 2000, many years before the Complainant obtained its first trademark registrations in 2014. The Panel recalls that where a respondent registers a domain name before a complainant’s trademark rights accrue, panels will not normally find bad faith on the part of the respondent. See WIPO Overview 3.1, section 3.8.1. The Panel sees no exceptional circumstances that might establish that the Respondent’s intent in registering the disputed domain name was to unfairly capitalize on the Complainant’s nascent, as yet unregistered, trademark rights in 2000. See WIPO Overview 3.1, section 3.8.2. The Panel accepts that the Complainant’s subsidiary “Junot Investissements” has operated a real estate business in Paris since 1985. The evidence shows that the subsidiary was registered in 1985, rented a property in Avenue Junot in 1998, listed three apartments for sale from 1992 to 1994 and another in 2000, all in Paris, with only offline contact details. While the Complainant seems to imply that it was Junot Investissements who registered the domain name <junotinvest.com> in June 2000 (ten days before the Respondent registered the disputed domain name), there is no evidence that this domain name was associated with an active website or that Junot Investissements had any online presence in 2000. Meanwhile, the Respondent, who is a Danish national, was resident in the United Kingdom and not engaged in real estate. In view of these circumstances, there is no indication that Junot Investissements was so well-known that the Respondent would have been aware of it or its trade name when he registered the disputed domain name. The Respondent provides a plausible good faith explanation for his decision to register “Junot” in the disputed domain name, based on the fact that it is a surname. His original idea was to create a customized email and website service in the form “firstname@surname.com”, which required domain names consisting of surnames. While “Junot” appears to be French or Latin in origin, awareness of that surname does not give rise to the inference that the Respondent must have known of Junot Investissements, as the Respondent provides evidence that multiple other businesses use “Junot” in their names. Based on the above considerations, the Panel finds that the Respondent did not register the disputed domain name in bad faith targeting of the Complainant or its trademark rights because the Complainant had no trademark rights at the time when the Respondent registered the disputed domain name. See WIPO Overview 3.1, section 3.8.1. Therefore, the Panel finds the third element of the Policy has not been established. D. Reverse Domain Name Hijacking Paragraph 15(e) of the Rules provides that, if after considering the submissions, the Panel finds that the Complaint was brought in bad faith, for example in an attempt at Reverse Domain Name Hijacking or to harass the domain-name holder, the Panel shall declare in its decision that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding. The mere lack of success of the complaint page 7 is not, on its own, sufficient to constitute reverse domain name hijacking. See WIPO Overview 3.1, section 4.16. The Respondent alleges that the Complaint is an attempt at Reverse Domain Name Hijacking. After failing in its attempt to purchase the disputed domain name, the Complainant commenced this proceeding. The Complainant is aware that it did not possess a registered trademark anywhere in the world until 2014, that Junot is a French name and surname, and that the Respondent is not from France. The Complainant knew or reasonably should have known that its Complaint was filed in bad faith. The Complainant replies that attempts to purchase a domain name prior to filing a UDRP complaint are common and constitute a legitimate effort to resolve disputes amicably. The Complaint is supported by substantial evidence and is therefore clearly grounded and cannot reasonably be characterized as abusive. The Respondent replies that, confronted with indisputable and overwhelming evidence demonstrating the fundamental weakness of its claims, the Complainant has doubled down on its attempt to reverse hijack the disputed domain name. The Panel notes that the Complainant has legal representation. It filed the Complaint after an unsuccessful attempt to acquire the disputed domain name. It presents no circumstances from which the inference could be drawn that the Respondent had any awareness of the Complainant when he registered the disputed domain name 14 years before the Complainant acquired trademark rights. It argues, implausibly, that the Respondent’s passive holding combined with his unwillingness to negotiate a sale with the Complainant demonstrated an intention to exploit the Complainant’s brand. In the Panel’s view, the Complainant must have known that it could not succeed on the third element of the Policy. See WIPO Overview 3.1, section 4.16. Therefore, the Panel finds that the Complaint has been brought in bad faith and constitutes an attempt at Reverse Domain Name Hijacking. 7. Decision For the foregoing reasons, the Complaint is denied. /Matthew Kennedy/ Matthew Kennedy Presiding Panelist /Diane Cabell/ Diane Cabell Panelist /Christiane Féral-Schuhl/ Christiane Féral-Schuhl Panelist Date: July 2, 2026

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

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