Westmore · UDRP DecisionAirbus-europe.com
The Panel ordered transfer of <airbus-europe.com> to Airbus SAS. It found the AIRBUS mark recognizable in the domain name, held that the addition of the hyphenated term “europe” did not prevent confusing similarity, and concluded that the Respondent lacked rights or legitimate interests. Evidence that the domain name had been used for phishing and passing off supported findings of both illegitimate use and bad-faith registration and use.
The timeline behind airbus-europe.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 airbus-europe.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that an inactive website does not insulate a domain registrant where the domain is actively used for phishing email. It also reinforces that combining a recognizable trademark with a geographic term such as “europe” generally does not avoid confusing similarity, particularly where the associated conduct impersonates a company or its subsidiary.
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 Airbus SAS v. jean robert gillet Case No. D2026-2177 1. The Parties The Complainant is Airbus SAS, France, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is jean robert gillet, France. 2. The Domain Name and Registrar The disputed domain name <airbus-europe.com> is registered with Hostinger Operations, UAB (the 3. Procedural History On May 20, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 20, 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 (Registrant Information Redacted/Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 21, 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 the amended Complaints on May 22, 2026, and May 28, 2026, respectively. The Center verified that the Complaint together with the amended Complaints satisfied the formal Uniform Domain Name Dispute Res In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on June 1, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 21, 2026. The Respondent did not submit any response. June 23, 2026. page 2 The Center appointed Louis-Bernard Buchman as the sole panelist in this matter on June 30, 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 aerospace company incorporated in France. The Complainant has designed, manufactured and delivered industry-leading commercial aircraft, helicopters, military transports, satellites and launch vehicles for over 50 years. since delivered over 13,500 aircraft to airlines worldwide and 12,000 helicopters. The Complainant has a wide global presence in approximately 180 locations across Europe, the Americas, Africa, the Middle East and Asia, with more than 157,000 employees. The Complainant holds trademark registrations for AIRBUS in multiple jurisdictions, including International Trademark No. 1112012, registered on June 24, 2011, and International Trademark No. 1247403, registered on June 18, 2014 (together referred to hereinafter as ). , registered on May 23, 1995, which received 2.7 million visits in September 2025 alone. The Respondent is apparently located in France. The disputed domain name was registered on July 11, 2025, and resolved to an inactive page at the time of filing of the Complaint. The Complainant submitted evidence that the disputed domain name was used to send phishing emails to at least one third party. At the time of this Decision, the disputed domain name does not resolve to any active website. 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: (i) The disputed domain name reproduces the Mark, in which the Complainant has rights, and is confusingly similar to the Mark insofar as the disputed domain name contains the Mark in its entirety. The europepreceded by a hyphen does not serve to distinguish the disputed domain name from the Mark. (ii) The Respondent has no rights or legitimate interests in respect of the disputed domain name, by which he is not commonly known. Furthermore, the Complainant contends that it has never licensed the Respondent to use the Mark in any manner or consented to such use, and that the Respondent has never had any business connection or affiliation with the Complainant. (iii) The Respondent knew of the Mark when registering the disputed domain name and is using it in bad faith by sending out phishing emails. The Complainant requests that the disputed domain name be transferred to the Complainant. page 3 B. Respondent 6. Discussion and Findings 6.1. Procedural Aspects Failure to Respond As aforementioned, no Response was received from the Respondent. Under the Rules, paragraphs 5(f) and 14(a), the effect of a default by the Respondent is that, in the absence of exceptional circumstances, the Panel shall proceed to a decision on the basis of the Complaint. The Panel does not find any exceptional circumstance in this case which would cause the Panel to proceed differently. criteria for a transfer of the disputed domain name have been met, even in the event of a default. Under paragraph 14(b) of the Rules, the Panel is empowered to draw such inferences from the In this case, the Panel finds that as a result of the default, the Respondent has failed to rebut any of the reasonable factual assertions that are made and supported by evidence submitted by the Complainant. In particular, by defaulting and failing to respond, the Respondent has failed to offer the Panel any of the types of evidence set forth in paragraph 4(c) of the Policy or otherwise, from which the Panel might conclude that the Respondent has any rights or legitimate interests in the disputed domain name, such as making legitimate noncommercial or fair use of the disputed domain name. Moreover, as discussed below, the Respondent has failed to provide any exculpatory information or acted in bad faith. 6.2. Requirements of Paragraph 4(a) of the Policy 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 isputed domain name. WIPO Overview of WIPO Panel WIPO Overview 3.1 Based on the available record, the Panel finds 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 that the Mark is recognizable 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. europe assessment of the second and third elements, the Panel finds 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. page 4 Regarding the generic Top- established that a gTLD does not generally affect the assessment of a domain name for the purpose of determining identity or confusingly similarity. WIPO Overview 3.1, section 1.11.1. Based on the available record, 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 a respondent lacks rights or legitimate interests in a domain name may result in the difficult mation 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 owing 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. Panels have held that the use of a domain name for illegal activity, here claimed as applicable to this case: passing off and phishing, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Complainant has provided evidence showing that the disputed domain name has been used to send phishing emails, passing off as owholly-owned German subsidiaries. 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. confusingly similar to the Mark, which prior URDP panels have found to be well known (see for instance Airbus SAS, Airbus Operations GmbH v. Alesini Pablo Hernan / PrivacyProtect.org, WIPO Case No. D2013-2059), his clear intent to capitalize attract Internet users, for commercial gain, affirmed by using the disputed domain name to send phishing emails to third parties. Such conduct falls squarely into bad faith pursuant to paragraph 4(b)(iv) of the Policy. Moreover, panels have held that the use of a domain name for illegal activity such as phishing constitutes bad faith. WIPO Overview 3.1, section 3.4. page 5 Finally, some UDRP panels have held that in certain circumstances, registrants of domain names have a duty to abstain from registering and using a domain name which is either identical or confusingly similar to a prior trademark held by others, and which would infringe upon or otherwise violate the rights of a third party. See Policy, paragraph 2(b); Nike, Inc. v. B. B. de Boer, WIPO Case No. D2000-1397; Nuplex Industries Limited v. Nuplex, WIPO Case No. D2007-0078; Mobile Communication Service Inc. v. WebReg, RN, WIPO Case No. D2005-1304; BOUYGUES v. Chengzhang, Lu Ciagao, WIPO Case No. D2007-1325; Media General Communications, Inc. v. Rarenames, WebReg, WIPO Case No. D2006-0964; and mVisible Technologies, Inc. v. Navigation Catalyst Systems, Inc., WIPO Case No. D2007-1141. name constitutes 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 <airbus-europe.com> be transferred to the Complainant. /Louis-Bernard Buchman/ Louis-Bernard Buchman Sole Panelist Date: July 7, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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