Westmore · UDRP DecisionRevente-24h-lemans.com
The Panel ordered transfer of <revente-24h-lemans.com>. It found the domain confusingly similar to the Complainant’s 24 H LE MANS mark, that the Respondent lacked rights or legitimate interests because its website falsely presented itself as an official ticket-resale platform, and that the domain was registered and used in bad faith to attract Internet users for commercial gain through confusion. The Panel also found that the Respondent appeared to have used a third party’s identity when registering the domain. Although the Complainant alleged that counterfeit tickets were sold, the Panel expressly noted that no supporting evidence had been submitted and did not rely on that allegation to establish the second element.
The timeline behind revente-24h-lemans.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 revente-24h-lemans.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates that an unauthorized reseller cannot establish legitimacy merely by purporting to offer products or tickets connected with a trademark owner. Where the domain and website claim official status and fail to disclose the lack of affiliation, the reseller framework does not protect the use. The case also shows that a panel may find all three elements without proof that the offered items were counterfeit when the record independently establishes impersonation and commercial confusion.
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 Automobile Club de l’Ouest (A.C.O.) v. Name Redacted, Revente Officielle 24h Du Mans Case No. D2026-1794 1. The Parties The Complainant is Automobile Club de l’Ouest (A.C.O.), France, represented by ARDAN, France. The Respondent is Name Redacted, 1 Revente Officielle 24h Du Mans. 2. The Domain Name and Registrar The disputed domain name <revente-24h-lemans.com> is registered with Tucows Domains Inc. (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 the same date, 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 (DATA REDACTED / Contact Privacy Inc. Customer 0177799203) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 29, 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 the same date. 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”). 1 The Respondent appears to have used the name of a third party when registering the disputed domain name. In light of the potential identity theft, the Panel has redacted the Respondent’s name from this Decision. However, the Panel has attached as Annex 1 to this Decision an instruction to the Registrar regarding transfer of the disputed domain name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in these proceedings, and has indicated Annex 1 to this Decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST- 12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. 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 May 1, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 21, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 22, 2026. The Center appointed Andrea Mondini as the sole panelist in this matter on May 29, 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 1906 and has been organizing car races in the French department of Sarthe under the 24H LE MANS trademark since 1923. The “24h Le Mans” race has become one of the world’s leading endurance car races, is one of the most prestigious races in the world and receives extensive media coverage. The Complainant owns numerous trademark registrations in several jurisdictions, including: TRADEMARK JURISDICTION REGISTRATION NUMBER REGISTRATION DATE 24 HEURES DU MANS (fig.) France 1459441 September 16, 1988 24 H LE MANS (fig.) European Union 012594677 August 13, 2014 The Complainant holds the domain name <24h-lemans.com> which hosts its main website. The Respondent did not file a Response. Therefore, not much is known about the Respondent. The disputed domain name was registered on March 20, 2026. According to the evidence submitted with the Complaint, the disputed domain name resolves to a website in the French language displaying the Complainant’s trademark and purporting to be the official ticket reseller for car races organized by the Complainant. 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 as follows: The trademark 24H LE MANS has been extensively used to identify the Complainant and its legendary car races. The disputed domain name is confusingly similar to the trademark in which the Complainant has rights, because it incorporates this trademark in its entirety, and the addition of the term “revente” (which means “resale” in French) is not sufficient to prevent a finding of confusing similarity. The Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent has not been authorized by the Complainant to use this trademark, is not commonly known by the disputed domain name, and there is no evidence of the Respondent’s use, or demonstrable preparation to use, the disputed domain name in connection with a bona fide offering of goods or services. On the contrary, the Respondent falsely presents itself as the official reseller of tickets for “24h Le Mans” racing events. Moreover, the Respondent used the identity of a third party to register the disputed domain name. page 3 The disputed domain name was registered in bad faith because it is obvious that the Respondent had knowledge of both the Complainant and its well-known trademark at the time it registered the disputed domain name. The Respondent is using the disputed domain name in bad faith, by impersonating the Complainant to intentionally attract for commercial gain Internet users to its website and defraud them by selling them counterfeit tickets. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to paragraph 4(a) of the Policy, in order to succeed, a complainant must establish each of the following elements: (i) the disputed domain name is identical or confusingly similar to the 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. 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 Panel finds the entirety of the textual element of the mark 24 H LE MANS is reproduced within the disputed domain name. Although the addition of other terms such as here “revente” (“resale” in French) may bear on assessment of the second and third elements, the Panel finds that the addition of such term 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 addition of the generic Top-Level Domain (“gTLD”) “.com” in the disputed domain name is a standard registration requirement and as such may be disregarded under the confusing similarity test under the Policy, paragraph 4(a)(i). WIPO Overview 3.1, section 1.11.1. 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 for a complainant to prove 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 page 4 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. The Complainant has shown that the Respondent posted a website under the disputed domain name purporting to offer tickets, representing itself as an “official resale” platform for events organized by the Complainant. The Complainant alleges that the Respondent attempts to defraud Internet users by selling them counterfeit tickets but has not submitted evidence in support of this allegation. However, even if the Respondent were to resell genuine tickets for events organized by the Complainant, t he Respondent’s use of the disputed domain name would not meet the “Oki Data Test”, established on Oki Data Americas, Inc. v. ASD, Inc., WIPO Case No. D2001-0903, because the website does not disclose the lack of relationship between the Respondent and the Complainant, but on the contrary falsely purports that the Respondent is an official ticket reseller for such events. WIPO Overview 3.1, section 2.8. Furthermore, the Panel notes that the registrant organization identified in the registration details of the disputed domain name is “Revente Officielle 24h Du Mans” (in English “Official Resale of 24h Du Mans”), however, there is no evidence before the Panel that the Respondent is actually commonly known by the disputed domain name or “Revente Officielle 24h Du Mans”. Rather, it appears most likely that such details were specifically chosen to falsely suggest an affiliation with the Complainant. Based on the available record, 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. WIPO Overview 3.1, section 3.2.1. In the view of the Panel, noting that the Complainant’s trademark predates the registration of the disputed domain name and considering that the Complainant’s trademark is well known and that the disputed domain name resolves to a website featuring the Complainant’s trademark and purporting to be the official ticket reseller for events organized by the Complainant, it is inconceivable that the Respondent could have registered the disputed domain name without knowledge of the Complainant’s well-known trademark. Moreover, the Respondent appears to have committed identity theft by using the name of a third party when registering the disputed domain name, which is also evidence of registration in bad faith. The similarity of the disputed domain name to the Complainant’s domain name hosting its official website, and the impression given by th e website posted under the disputed domain name would cause Internet users to believe that the Respondent is somehow associated with the Complainant when, in fact, it is not. The Panel holds that by using the disputed domain name, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website, by creating a likelihood of confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement of its website in the sense of Policy, paragraph 4(b)(iv). Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. page 5 The Panel thus finds that the Complainant has established the third element of the Policy with regard to the disputed domain name. 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 <revente-24h-lemans.com> be transferred to the Complainant. /Andrea Mondini/ Andrea Mondini Sole Panelist Date: June 5, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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