Westmore · UDRP decision
WIPO · Case No. D2026-2199

Stadetoulousain.shop

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <stadetoulousain.shop> to Stade Toulousain Rugby. It found the domain confusingly similar to the Complainant’s ST STADE TOULOUSAIN & Shield Device mark, found no rights or legitimate interests, and found bad faith under the passive-holding doctrine. The Panel could not make a finding based on the Complainant’s allegation that the domain had previously hosted an unauthorized purported official store because the Complainant produced no evidence of that alleged use.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-07
Panelist(s)
Sebastian M.W. Hughes
Complainant
Stade Toulousain Rugby, France
Respondent
李桂兰(guilan li)
Disputed domain(s)
stadetoulousain.shop
Domain history UDRP Intelligence

The timeline behind stadetoulousain.shop

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 stadetoulousain.shop — 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 granted. Panel ordered transfer of stadetoulousain.shop.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates that an unsupported allegation of prior impersonation may be rejected as a factual basis for bad faith, while transfer may still be ordered under the passive-holding doctrine when the record supports bad faith through other circumstances. It also underscores the importance of preserving website evidence promptly before allegedly infringing content disappears.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
Registration and use 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
2026-09-07
Panel
Sebastian M.W. Hughes
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Stade Toulousain Rugby v. 李桂兰(guilan li) Case No. D2026-2199 1. The Parties The Complainant is Stade Toulousain Rugby, France, represented by ALTIJ & Oratio Avocats, France. The Respondent is 李桂兰(guilan li), China. 2. The Domain Name and Registrar The disputed domain name <stadetoulousain.shop> is registered with Chengdu West Dimension Digital Technology Co., Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on May 21, 2026. On May 21, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 22, 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 (Registration Private) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 22, 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 in English on July 27, 2026. On July 22, 2026 the Center informed the Parties in Chinese and English, that the language of the Registration Agreement for the disputed domain name is Chinese. On July 27, 2026, the Complainant confirmed its request that English be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. 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 in English and Chinese of the Complaint, and the proceeding commenced on July 28, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 17, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 19, 2026. page 2 The Center appointed Sebastian M.W. Hughes as the sole panelist in this matter on August 26, 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 A. Complainant The Complainant is a French company established in 1998, carrying on the business of the successful French rugby club Stade Toulousain under the trade mark ST STADE TOULOUSAIN & Shield Device (the “Trade Mark”). The Complainant is the owner of several registrations for the Trade Mark, including French registration No. 98747455 , with a registration date of August 26, 1998; European Union registration No. 002345502 , with a registration date of February 25, 2003; and International registration No. 1830168 , with a registration date of October 24, 2023. The Complainant is also the owner of several domain names comprising the Trade Mark, including <stadetoulousain.fr>, registered on December 3, 2000; <stadetoulousain.com>, registered on March 7, 2012; and <stadetoulousain.net>, registered on October 31, 2007. B. Respondent The Respondent is reportedly an individual located in China. C. The Disputed Domain Name The disputed domain name <stadetoulousain.shop> was registered on November 8, 2025. D. Use of the Disputed Domain Name The disputed domain name is not resolved to an active website. 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 was previously resolved to a website which unlawfully presented itself as the Complainant’s official online store. However, the website was taken down before the Complainant was able to instruct a bailiff to draw up a report with evidence of the website. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including the fact that the costs of translating the Complaint into Chinese would outweigh the overall costs of this proceeding; and the fact the Respondent is likely conversant in English as (i) the disputed domain name consists of Latin characters; (ii) the generic Top-Level Domain for the disputed domain name is the English word “shop”; and (iii) the Respondent uses a Hotmail email address. The Respondent did not make any submissions with respect to the language of the proceeding. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. 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 trade mark and the disputed domain name. WIPO Overview 3.1, section 1.7. The Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds the mark is recognizable within the disputed domain name – the disputed domain name containing the wording component of the Trade Mark (“stade toulousain”, minus the letters “st”) in its entirety. Accordingly, the disputed domain name is confusingly similar to the mark 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. page 4 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 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, as the Complainant has not been able to produce any evidence as to the alleged prior use by the Respondent of the disputed domain name, the Panel is unable to make any findings as to bad faith registration and use on this particular ground relied upon by the Complainant. Panels have found 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 faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the well-known nature and reputation of the Complainant’s Trade Mark, and the composition of the disputed domain name, and finds that in the circumstances of this case the current passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. The Respondent’s failure to participate in these proceedings and to refute the Complainant’s allegations or to invoke any rights or legitimate interests in the disputed domain name, further supports this finding. 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 <stadetoulousain.shop> be transferred to the Complainant. /Sebastian M.W. Hughes/ Sebastian M.W. Hughes Sole Panelist Date: September 7, 2026

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

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