Westmore · UDRP decision
WIPO · Case No. D2026-2095

Bulgari-billing.net, Bulgari-invoice.com, Bvlgari-billing.com

TransferWIPO-indexed · informational, not legal advice

The Panel consolidated the disputes against the nominally different registrants after finding that the three domain names were under common control. Each domain incorporated the Complainant’s BULGARI or BVLGARI mark with the finance-related term “billing” or “invoice”. The Panel found confusing similarity, no rights or legitimate interests, and bad-faith registration and use. Although the domain names did not resolve to active webpages, their passive holding did not prevent a finding of bad faith given the worldwide reputation of the marks, the domain compositions, and the targeting of the Complainant. Transfer of all three domain names was ordered.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-07-29
Panelist(s)
Mansfield, Gill
Complainant
Bulgari S.p.A
Respondent
Garini sarabi Garini sarabi, Novéo Clinic payam basiri, rn mark
Disputed domain(s)
bulgari-billing.net, bulgari-invoice.com, bvlgari-billing.com
Domain history UDRP Intelligence

The timeline behind bulgari-billing.net

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 bulgari-billing.net — 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
Outcome by domain

How each disputed name was decided in this proceeding.

bulgari-billing.netTransferred
bulgari-invoice.comTransferred
bvlgari-billing.comTransferred
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of bulgari-billing.net.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a panel may assess a coordinated group of inactive, finance-themed domains registered under nominally different identities. Common naming structure, close registration timing, shared service providers, overlapping technical infrastructure, and connected registrant information supported consolidation. The case also shows that passive holding can satisfy the bad-faith element where widely known marks are deliberately combined with terms suggesting official billing or invoicing functions.

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
2026-07-29
Panel
Mansfield, Gill
Full decision
18 min read · hosted by Westmore

ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Bulgari S.p.A v. Garini sarabi, payam basiri, rn mark, Garini sarabi, Novéo Clinic Case No. D2026-2095 1. The Parties The Complainant is Bulgari S.p.A, Italy, represented by Saf eNames Ltd., United Kingdom. The Respondents are Garini sarabi, United Arab Emirates, payam basiri, rn mark, United Arab Emirates, and Garini sarabi, Novéo Clinic, United Arab Emirates. 2. The Domain Names and Registrar The disputed domain names <bulgari-billing.net>, <bulgari-invoice.com>, and <bvlgari-billing.com> are registered with Key-Systems Gmb H (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 15, 2026. On May 15, 2026, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain names. On May 18, 2026, the Registrar transmitted by email to the Center its verif ication response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (REDACTED FOR PRIVACY) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on May 20, 2026 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar(s), requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with dif f erent underlying registrants or alternatively, demonstrate that the underlying registrants are in f act the same entity and/or that all domain names are under common control. The Complainant f iled amended Complaints on May 21, 2026 and on June 2, 2026. The Center verif ied that the Complaint together with the amended Complaints satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondents of the Complaint, and the proceedings commenced on June 16, 2026. In accordance with the Rules, paragraph 5, the due date f or Response was July 6, 2026. The Respondent payam basiri, rn mark sent email communications to the Center on June 3, 2026, June 16, 2026, and on July 7, 2026. The Center appointed Gill Mansfield as the sole panelist in this matter on July 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 is an Italian company founded in 1884 by Sotirios Voulgaris. The Complainant operates in the luxury goods and hotels markets, and is particularly well-known f or high-end jewellery, watches, handbags and fragrance products. It is headquartered in Rome, Italy, and has more than 320 retail locations worldwide. The BULGARI trademark is derived f rom the f ounder’s name (Vougaris). The Complainant’s trademark is written both as BVLGARI in the classic Latin alphabet and BULGARI in the modern alphabet, and the two are used synonymously. The Complainant uses the BVLGARI/BULGARI trademark as part of its brand logo and to promote its services via social media, and engages in significant promotion of the brand worldwide using the trademarks. The Complainant has a portfolio of international trademark registrations f or the BULGARI and BVLGARI trademarks, including (inter alia) the f ollowing: International trademark registration number 452694 for BULGARI (word mark) registered on May 15, 1980 in classes 11, 14, 20, and 21. International trademark registration number 494237 for BVLGARI (f igurative mark) registered on July 5 1985 in classes 3, 8, 11, 14, 16, 18, 20, 21, 25, and 34. United States of America trademark registration number 1694380 f or BVLGARI (word mark) registered on June 16, 1992 in class 18. The Complainant registered the domain name <bulgari.com> on February 17, 1998. This domain name directs to the Complainant’s official website, “www.bulgari.com”, where Internet users are able to access all of the Complainant’s product lines, and locate the Complainant’s stores and authorised retailers worldwide. The Complainant’s official website receives over two million visits per month f rom users around the world. The disputed domain names <bulgari-invoice.com> (registered by Garini Sarabi) and <bvgari-billing.com> (registered by Garini sarabi, Novéo Clinic) were registered on January 1, 2026 and the disputed domain name <bulgari-billing.net> (registered by payam basiri, rn mark) was registered on January 20, 2026. At the time of the Complaint the disputed domain names did not resolve to active webpages. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy f or a transf er of the disputed domain names. Notably, the Complainant contends that the disputed domain names are conf usingly similar to the Complainant’s BVLGARI/BULGARI marks. The Complainant refers to the multiple trademarks that it holds in the terms BVLGARI/BULGARI across multiple jurisdictions, and highlights the goodwill and recognition that those marks have attained. It argues that the disputed domain names encompass the entirety of either the Complainant’s BVLGARI or BULGARI mark with the addition of the keyword “billing” or “invoice”, separated f rom the mark by a hyphen. It contends that the BVLGARI/BULGARI marks are the dominant and only page 3 distinctive element in the disputed domain names, and that the additional terms do not alleviate the likelihood of confusion between the Complainant’s marks and the disputed domain names. The Complainant also contends that the generic Top-Level Domains (gTLD) are standard registration requirements and, as such, are to be disregarded under the f irst element conf using similarity test. The Complainant further contends that the Respondents have no rights or legitimate interests in respect of the disputed domain names. It submits that, to the best of the Complainant’s knowledge, the Respondents do not have any registered or unregistered trademark rights to the terms BVLGARI or BULGARI. It als o submits that the Respondents have never received any licence from the Complainant to use domain names f eaturing the BVLGARI/BULGARI mark. The Complainant argues that the disputed domain names do not resolve to active webpages and that such non-use should not be considered to constitute a bona fide offering of goods or services. It f urther contends that the terms used in the disputed domain names are not phrases a trader would legitimately choose unless seeking to create an impression of association with the Complainant. The Complainant submits that the Respondents are not commonly known by the disputed domain names, are not of f ering any genuine goods or services, and that there is no evidence that the Respondents intended to use the disputed domain names in a legitimate noncommercial way. Finally, the Complainant submits that the disputed domain names were registered and are being used in bad f aith. It states that the Complainant’s earliest trademark registrations pre-date the creation date of the disputed domain names by approximately 47 years. It argues that substantial goodwill has accrued in the marks since the establishment of the Complainant in 1884 and that the BVLGARI/BULGARI name has become synonymous with high-end and stylistically unique luxury accessories. The Complainant contends that Panels have consistently f ound that the mere registration of a domain name that is identical or conf usingly similar to a famous or widely known trademark by an unaf f iliated entity can by itself create a presumption of bad faith, and argues that this is the case here. The Complainant also argues that the addition of the words “billing” and “invoice”, separated f rom the mark by a hyphen, only reinf orce the connection to the Complainant, as Internet users may perceive the disputed domain names as associated with the Complainant’s financial departments. The Complainant notes that the disputed domain names do not resolve to active webpages and submits that non-use would not prevent a f inding of bad f aith. B. Respondents The Respondents did not formally reply to the Complainant’s contentions. Ho wever, the Respondent who is the registrant of the disputed domain name <bulgari-billing.net> sent email communications to the Center on June 3, 2026, June 16, 2026, and on July 7, 2026. In the email of June 3, 2026 the Respondent acknowledged receipt of the Complaint. That email states that “without admitting any liability, wrongdoing, bad faith, or control over any domain name not registered under my name and/ or under my control, I confirm that I do not wish to contest the Complaint”. The email goes on to offer to transfer any disputed domain name registered under their name and under their control, f ree of charge. The email also says that the sender of the email does not admit ownership, management, or control of domains registered with other registrant details but has no objection to the transf er of all of the disputed domain names. That email comes f rom a Gmail address that comprises a series of numbers rather than a named or identifiable individual. The emails of June 16, 2026 and July 7, 2026, which come f rom the same email address, both repeat the above request to know who to transf er the domains, ref erred to in that email, to. page 4 6. Discussion and Findings Under paragraph 4(a) of the Policy the Complainant carries the burden of proving: (i) that the disputed domain name is identical or conf usingly similar to a trademark or service mark in which the Complainant has rights, (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name, and (iii) that the disputed domain name has been registered and is being used in bad f aith. A. Consolidation: Multiple Respondents The amended Complaint was f iled in relation to nominally dif f erent domain name registrants. The Complainant alleges that the domain name registrants are the same entity or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. The Panel will address this procedural issue bef ore moving to consideration of the criteria set out in paragraph 4(a) of the Policy Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. In addressing the Complainant’s request, the Panel will consider whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.11.2. As regards common control, the Panel notes the following factors f rom the available record indicating common control: - The disputed domain names all share a common structure: comprising the Complainant’s mark (used in f ull), f ollowed by a hyphen, and a descriptive term relating to finance or payment (“billing” for two of the disputed domain names and “invoicing” f or the other), and the TLD. - The disputed domain names were all registered within a short period of each other in January 2026, with two of the disputed domain names being registered on the same date (January 1, 2026) and the third only a f ew weeks later (January 20, 2026). - The disputed domain names were all registered with the same Registrar (Key-Systems GmbH, Germany). - The disputed domain names were all hosted using the same hosting provider (Leaseweb Deutschland GmbH) at the point of registration, and the disputed domain names <bulgari-billing.net> and <bvlgari- billing.com> were both hosted in the exact same IP address, mail and name servers at the point of registration. - The registrant addresses for all of the disputed domain names are in United Arab Emirates. To the extent that there are inconsistencies in the registrant addresses the Panel accepts the Complainant’s contention that the discrepancies suggest that the registration details for the disputed domain names are likely associated with f alse, incomplete or stolen details. - The registrant name f or two of the disputed domain names <bulgari-invoice.com> and <bvlgari- billing.com> is identical: Garini Sarabi. The admin, technical and billing address is also identical f or both of these domains. Again, to the extent that there are inconsistencies between the registrant details the Panel accepts the Complainant’s contention that the discrepancies suggest that the registration details for the disputed domain names are likely associated with false, incomplete or stolen details. page 5 The disputed domain name registrants did not comment on the Complainant’s request f or consolidation. The Panel notes the inf ormal email correspondence f rom the Respondent which is the registrant of the disputed domain name <bulgari-billing.net>, set out above. However, the Panel f inds that the f acts above support the conclusion that the disputed domain names are under common control. As regards fairness and equity, the Respondents have not presented any arguments as to why consolidation would be unfair or inequitable, and the Panel sees no reason why consolidation of the disputes would be unf air or inequitable to any Party. Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (ref erred to below as “the Respondent”) in a single proceeding. B. Identical or Confusingly Similar It is well accepted that the f irst element f unctions 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 f inds the mark is recognizable within the disputed domain names. Accordingly, the disputed domain names are conf usingly similar to the mark f or the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms (here, the addition of the terms “-billing” and “-invoice”) may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a f inding of confusing similarity between the disputed domain names and the mark f or the purposes of the Policy. WIPO Overview 3.1, section 1.8. The applicable Top-Level Domain (TLD) in a domain name is a standard registration requirement and as such the TLDs “.net” and “.com” in the disputed domain names are disregarded under the f irst element conf using similarity test. WIPO Overview 3.1, section 1.11.1. The Panel f inds the f irst element of the Policy has been established. C. 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 dif f icult 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 f orward 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 f ails to come f orward with such relevant evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie case that the Respondent lacks rights or legitimate interests in the disputed domain names. The Respondent has not rebutted the Complainant’s prima facie showing and has not come f orward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain names such as those enumerated in the Policy or otherwise. page 6 In particular, the Complainant has not licensed or permitted the Respondent to use the BVLGARI/BULGARI trademarks. There is no evidence that the Respondent is commonly known by the disputed domain name. There is also no evidence of use, or demonstrable preparations to use, the disputed domain name for a bona f ide offering of goods or services, or of any legitimate noncommercial or f air use of the disputed domain names without intent f or commercial gain to misleadingly divert customers. The disputed domain names consist of the use of the Complainant’s marks in their entirety with the addition of a hyphen f ollowed by the descriptive terms “billing” or “invoice”. These are both terms which are commonly used as extensions in connection with, or to denote, finance or payment f unctions. As such the disputed domain names could be perceived as an extension of the Complainant’s legitimate domain name. The Panel f inds that the composition of the disputed domain names is such as to carry a risk of implied af f iliation with the Complainant’s trademark which cannot constitute fair use as it effectively impersonates the Complainant, or suggests af f iliation with or sponsorship or endorsement by the Complainant (WIPO Overview 3.1, section 2.5.1). In addition, according to paragraph 14(b) of the Rules, the Panel may draw from the lack of response of the Respondent such inf erences as it considers appropriate. The Panel is of the view that the lack of a substantive response to the Complainant’s contentions f rom the Respondent f urther corroborates the absence of any rights or legitimate interests of the Respondent in the disputed domain names. The Panel f inds the second element of the Policy has been established. D. Registered and Used in Bad Faith The Panel notes that, f or 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 f aith. 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 be relevant in assessing whether a respondent’s registration and use of a domain name is in bad f aith. WIPO Overview 3.1, section 3.2.1. In the present case, the Panel notes that the Complainant’s trademark registrations f or the BVLGARI/BULGARI marks pre-date the Respondent’s registration of the disputed domain names by almost 47 years. The Panel also notes the long history of the Complainant, dating back to 1884, and the international reputation and distinctiveness of the Complainant’s trademark, and f inds that the BVLGARI/BULGARI marks are widely-known worldwide. Panels have consistently found that the mere registration of a domain name that is identical or conf usingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a f amous or widely-known trademark, and particularly in the case of coined or fanciful marks, by an unaffiliated entity can by itself create a presumption of bad f aith. WIPO Overview 3.1, section 3.1.4. Given the reputation in the Complainant’s trademark it is inconceivable that the Respondent was unaware of the Complainant’s mark at the date on which the disputed domain names were registered, and the Panel f inds that the Respondent has targeted the Complainant’s well-known mark. In making this f inding, the Panel again notes the composition of the disputed domain names, which incorporate the entirety of either the BVLGARI or the BULGARI mark, with the addition of a hyphen, followed by the descriptive words “billing” or “invoice”. As noted above, these are descriptive terms that Internet users may perceive as extensions likely to be used by the finance or commercial teams of the Complainant, and f or which the Panel considers that there is no plausible legitimate use in conjunction with the Complainant’s marks. As noted above, the disputed domain names do not resolve to an active website or webpage. page 7 Panels have f ound that the non-use of a domain name 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 f aith f or 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, and the composition of the disputed domain names, and f inds that in the circumstances of this case the passive holding of the disputed domain names does not prevent a f inding of bad f aith under the Policy. The Panel f inds that the Complainant has established the third element of the Policy. 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain names <bulgari-billing.net>, <bulgari-invoice.com>, and <bvlgari- billing.com> be transf erred to the Complainant. /Gill Mansfield/ Gill Mansfield Sole Panelist Date: July 24, 2026

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

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