Westmore · UDRP DecisionLancomepg.com
The Panel ordered transfer of <lancomepg.com>. It found the domain confusingly similar to L’Oréal’s LANCÔME/LANCOME mark because the mark remained recognizable despite the added suffix “pg”. The unrebutted record established no rights or legitimate interests. Given L’Oréal’s earlier Cambodian trademark registration, Lancôme’s Phnom Penh boutique, the mark’s reputation, and the domain’s use for an online gambling and gaming website, the Panel found intentional attraction of Internet users for commercial gain through confusion under paragraph 4(b)(iv) of the Policy.
The timeline behind lancomepg.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 lancomepg.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates a straightforward paragraph 4(b)(iv) transfer where an entire established mark was combined with a short suffix and used for an unrelated commercial gambling website. The local Cambodian trademark and boutique were especially relevant because they connected the Complainant’s rights and business presence to the Respondent’s country before registration.
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. LATY KHEANG Case No. D2026-1791 1. The Parties The Complainant is L’Oréal, France, represented by Dreyfus & associés, France. The Respondent is LATY KHEANG, Cambodia. 2. The Domain Name and Registrar The disputed domain name <lancomepg.com> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 27, 2026. On April 28, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 29, 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 (Domains By Proxy, LLC / DomainsByProxy.com) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 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 May 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 May 20, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 9, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 10, 2026. The Center appointed Keiji Kondo as the sole panelist in this matter on June 17, 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. page 2 4. Factual Background The Complainant is a French industrial group specialized in the field of cosmetics and beauty. It has a portfolio of 37 brands, employs 86,000 employees, and is present in 150 countries. The Complainant’s subsidiary, Lancôme, was founded in 1935. Over the decades, the Complainant spreads its vision of French spirit and elegance, and it has become the leading luxury beauty brand in the world. Lancôme officially entered the Cambodian market by opening its first boutique at AEON Mall Phnom Penh in May 2025, marking a significant step in the country’s growing demand for luxury beauty products. The Complainant is the owner of the following trademark registrations for LANCÔME and LANCOME: • Cambodian trademark registration No. KH/1992/1796 for class 3, registered on October 12, 1992; • United States of America trademark registration No. 3022836 for classes 3, 35, and 44, registered on December 6, 2005; and • Brazilian trademark No. 790503263 for class 3, registered on December 17, 1985. In addition, the Complainant operates the following domain name reflecting its trademark: • <lancome.com> registered on July 8, 1997. The disputed domain name is <lancomepg.com>, registered on January 23, 2026. The disputed domain name resolves to an online gambling and gaming website in Portuguese and English titled “LANGOMEPG”, which offers games and slots to play on the website. Furthermore, the website has an option to register or log in which requires the input of personal data of potential users, including their real names and passwords. 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 or confusingly similar to the Complainant’s trademark. (Policy, paragraph 4(a)(i); Rules, paragraphs 3(b)(viii), (b)(ix)(1)). The disputed domain name reproduces the Complainant’s trademark in its entirety, with the mere addition of the suffix “pg”. The dominant and immediately recognizable element of the disputed domain name remains identical to the Complainant’s trademark. The addition of “pg” may be interpreted in multiple ways commonly associated with online activity, including but not limited to “promo giveaway”, “promotional group”, “prize game”, or “promotion gateway”. Each of these interpretations reinforces the impression that the disputed domain name is connected to an official promotional initiative conducted under the Complainant’s name. Such construction increases the likelihood of confusion and creates a misleading association with the Complainant. page 3 In many UDRP decisions, it is well established that “Where a domain name incorporates the entirety of a trademark, or where at least a dominant feature of the relevant mark is recognizable in the domain name, the domain name will normally be considered confusingly similar to that mark” (L’Oréal, Lancôme Parfums et Beauté & Cie v. Jack Yang, WIPO Case No. D2011-1627; RapidShare AG, Christian Schmid v. InvisibleRegistration.com, Domain Admin, WIPO Case No. D2010-1059; and The Stanley Works and Stanley Logistics, Inc. v. Camp Creek Co., Inc., WIPO Case No. D2000-0113). Finally, the generic Top-Level Domain (“gTLD”) “.com” is not to be taken into consideration when examining the identity or similarity between the Complainant’s trademarks and the disputed domain name (Accor v. Noldc Inc., WIPO Case No. D2005-0016). The mere adjunction of a gTLD such as “.com” is irrelevant for the purposes of the first element. For all of the above-mentioned reasons, the disputed domain name is identical or confusingly similar to the Complainant’s trademark. Therefore, the condition of paragraph 4(a)(i) is fulfilled. The Respondent has no rights or legitimate interests in respect of the disputed domain name. (Policy, paragraph 4(a)(ii); Rules, paragraph 3(b)(ix)(2)). The Respondent is neither affiliated with the Complainant in any way nor has he been authorized by the Complainant to use and register its trademark, or to seek registration of any domain name incorporating the Complainant’s trademark. Furthermore, the Respondent has no prior rights or legitimate interest in the disputed domain name. The registration of the Complainant’s trademark preceded the registration of the disputed domain name for years. The Respondent is not commonly known by the disputed domain names or the Complainant’s trademark. There is simply no evidence that the Respondent may be commonly known by the disputed domain name or the Complainant’s trademark. In previous decisions, panels found that in the absence of any license or permission from the complainant to use widely-known trademarks, no actual or contemplated bona fide or legitimate use of the domain name could reasonably be claimed. (Groupe Auchan v. Gan Yu, WIPO Case No. D2013-0188; LEGO Juris A/S v. DomainPark Ltd, David Smith, Above.com Domain Privacy, Transure Enterprise Ltd, Host master, WIPO Case No. D2010-0138). The Respondent did not demonstrate, use, or demonstrable preparations for use, of the disputed domain name in connection with a bona fide offering of goods or services. On the contrary, the disputed domain name resolved to an online gambling website where users could place bets, which cannot be considered a legitimate commercial use. Therefore, by diverting traffic, the Respondent uses the Complainant’s trademark for its own commercial purposes. Consequently, the disputed domain name was not used in any type of legitimate business or services. It deceives consumers, who incorrectly understand that they are referred to the Complainant’s bona fide goods and services. (L’Oréal v. Domain Admin, Privacy Protect, LLC (PrivacyProtect.org) / zhou mu yao, WIPO Case No. D2021-1943). For all of the above-cited reasons, it is undoubtedly established that the Respondent has no rights or legitimate interests in respect to the disputed domain name. The domain name was registered and is being used in bad faith. (Policy, paragraphs 4(a)(iii), 4(b); Rules, paragraph 3(b)(ix)(3)). Paragraph 4(a) (iii) of the Policy requires a complainant to prove that the respondent registered or used the disputed domain name in bad faith. The language of paragraph 4(a)(iii) of the Policy requires that both bad faith registration and bad faith use be proven. 1) Registration in bad faith page 4 Bad faith can be found where the respondent “knew or should have known” of the complainant’s trademark rights and, nevertheless registered a domain name in which he had no rights or legitimate interest. (Research In Motion Limited v. Privacy Locked LLC/Nat Collicot, WIPO Case No. D2009-0320; and The Gap, Inc. v. Deng Youqian, WIPO Case No. D2009-0113). It is implausible that the Respondent was unaware of the Complainant when he registered the disputed domain name. Firstly, the Complainant is well known throughout the world, including Brazil. In this regard, many panels (for example, L'Oréal and Lancôme Parfums et Beauté et Compagnie v. Deco Trends & Art, K. Plooyer, WIPO Case No. D2011-0524) have previously acknowledged the Complainant’s reputation worldwide, making it unlikely that the Respondent was not aware of the Complainant’s rights in the Complainant’s trademark. Secondly, considering the composition of the disputed domain name, which entirely reproduces the Complainant’s trademark, only with the addition of the two letters “pg” at its end, it is impossible that the Respondent did not have the Complainant’s trademark and company name in mind while registering the disputed domain name. In fact, bad faith has already been found where a domain name is so obviously connected with a well-known trademark that its very use by someone with no connection to the trademark suggests opportunistic bad faith. (LEGO Juris A/S v. store24hour, WIPO Case No. D2013-0091; and Lancôme Parfums et Beauté & Cie, L’Oréal v. 10 Selling, WIPO Case No. D2008-0226,). Given the reputation of the Complainant’s trademark, registration in bad faith can be inferred. Thirdly, the Complainant’s trademark registration significantly predates the registration date of the disputed domain name. In this regard, previous panels have established that knowledge of the complainant’s intellectual property rights, including trademarks, at the time of registration of the disputed domain name proves bad faith registration. (Alstom v. Domain Investments LLC, WIPO Case No. D2008-0287; and NBC Universal Inc. v. Szk.com, WIPO Case No. D2007-0077). Under Section 2 of the Policy, it is established that when someone registers a domain name, he represents and warrants to the registrar that, to his knowledge, the registration of the domain name will not infringe the rights of any third party, which means that it was the registrant’s duty to verify that the registration of the disputed domain name would not infringe the rights of any third party before registering said domain name. (Compagnie Gervais Danone contre Gueorgui Dimitrov / NETART, WIPO Case No. D2009-0901; Carolina Herrera, Ltd. v. Alberto Rincon Garcia, WIPO Case No. D2002-0806; and Nike, Inc. v. B.B. de Boer, WIPO Case No. D2000-1397). Furthermore, the website content evidences an attempt to capitalize on the Complainant’s reputation, either by misleading consumers or by exploiting the goodwill attached to the trademark. This demonstrates bad faith intent, as the Respondent could not have plausibly registered the disputed domain name without knowledge of the Complainant’s rights and without an intention to take unfair advantage of them. A quick trademark search would have revealed to the Respondent the existence of the Complainant’s trademark. The Respondent’s failure to do so is a contributory factor to its bad faith. (Lancôme Parfums et Beauté & Cie, L’Oréal v. 10 Selling, WIPO Case No. D2008-0226). Even supposing that the Respondent was not aware of the possibility of searching trademarks online before registering the domain name, a simple search via Google or any other search engine using the Complainant’s trademark as keyword demonstrates that all first results relate to the Complainant’s products or news. In this day and age of the Internet and advancement in information technology, the reputation of brands and trademarks transcends national borders. Taking into account the worldwide reputation of the Complainant and its trademarks, as well as the high level of notoriety of the Complainant, it is hard to believe that the Respondent was unaware of the existence of the Complainant and its trademark at the time of registration of the disputed domain name. The Complainant submits that given its goodwill and renown, and the nature of the disputed domain name, the Respondent could simply not have chosen the disputed domain name for any reason other than to deliberately cause confusion amongst Internet users as to its source in order to take unfair advantage of the Complainant’s goodwill and reputation, which clearly constitutes bad faith. page 5 Hence, in view of the above-mentioned circumstances, it is inconceivable that the Respondents did not have the Complainant’s trademark in mind at the time of registration of the disputed domain name. Consequently, it is established that the Respondent registered the disputed domain name in bad faith. 2) Use in bad faith Some elements may be put forward to support the finding that the Respondent also uses the disputed domain name in bad faith. Previous panels have considered that in the absence of any license or permission from a complainant to use its trademark, no actual or contemplated bona fide or legitimate use of the disputed domain name could reasonably be claimed. (Alstom, Bouygues v. Webmaster, WIPO Case No. D2008-0281; and Guerlain S.A. v. Peikang, WIPO Case No. D2000-0055). The disputed domain name is confusingly similar to the Complainant’s trademark, and previous panels have ruled that “a likelihood of confusion is presumed, and such confusion will inevitably result in the diversion of Internet traffic from the Complainant’s site to the Respondent’s site”. (MasterCard International Incorporated (“MasterCard”) v. Wavepass AS, WIPO Case No. D2012-1765; and Edmunds.com, Inc. v. Triple E Holdings Limited, WIPO Case No. D2006-1095). Consequently, it is more likely than not, that the Respondent’s primary motive in registering and using the disputed domain name was to capitalize on or otherwise take advantage of the Complainant’s trademark rights, by creating a likelihood of confusion between the disputed domain name and the Complainant’s brand. Indeed, the disputed domain name directs users to an online gambling website. This deceptive use demonstrates the Respondent’s bad faith, as the disputed domain name exploits the Complainant’s trademark to mislead users, undermine their trust, and generates illicit commercial gain. Such conduct, involving redirection to an unrelated gambling platform, clearly indicates that the Respondent is not making a legitimate use of the disputed domain name but is instead intentionally attempting to attract users for financial benefit by creating a false association with the Complainant. All aforementioned circumstances confirm that the disputed domain name is being used in bad faith. Consequently, it is established that the Respondent has registered and has been using the disputed domain name in bad faith in accordance with paragraph 4(a)(iii) of the Policy. 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 trademark registrations for the Complainant’s trademark. The entirety of the Complainant’s trademark is reproduced within the disputed domain name. Although the disputed domain name has a suffix “pg” added to the Complainant’s trademark, it does not prevent the Complainant’s trademark from being recognized in the disputed domain name. page 6 Accordingly, the disputed domain name is confusingly similar to the Complainant’s trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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. 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. In addition, as it will be discussed in relation to the third element, the Respondent should have registered and have been using the disputed domain name in an attempt to create a likelihood of confusion with the Complainant’s trademark. Such attempt itself proves that the Respondent does not have rights to, or legitimate interests in, the disputed domain name. 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 was registered on January 23, 2026. On the other hand, the Complainant registered the Complainant’s trademark in Cambodia on October 12, 1992. In addition, the Complainant opened a boutique in Phnom Penh in May 2025. These facts demonstrate that the Respondent should have been aware of the Complainant’s business when the Respondent registered the disputed domain name. The disputed domain name has been used to direct Internet users to an online gambling and gaming website in Portuguese and English titled “LANGOMEPG”, which offers games and slots to play on the website. Considering the reputation and size of the Complainant’s business in the world and the distinctiveness and reputation of the Complainant’s trademark, the Panel concludes that the Respondent registered and has been using the disputed domain name intentionally to attract, for commercial gain, Internet users to his website by creating a likelihood of confusion with the Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of his website, which constitutes bad faith under paragraph 4(b)(iv) of the Policy. Accordingly, the Panel concludes that the disputed domain name was registered and has been used in bad faith. The Panel finds that the Complainant has established the third element of the Policy. page 7 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 <lancomepg.com> be transferred to the Complainant. /Keiji Kondo/ Keiji Kondo Sole Panelist Date: July 1, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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