Bvlgari.baby, Bvlgari.bar

The timeline behind bvlgari.baby

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

How each disputed name was decided in this proceeding.

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 Bulgari S.p.A v. xiaoye wang Case No. D2026-2222 1. The Parties The Complainant is Bulgari S.p.A, Italy, represented by SafeNames Ltd., United Kingdom. The Respondent is xiaoye wang, China. 2. The Domain Names and Registrar The disputed domain names <bvlgari.baby> and <bvlgari.bar> are registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 22, 2026. On May 22, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On May 22, 2026, the Registrar transmitted by email to the Center its verification response, disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 28, 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 28, 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 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. Accordingly, the Center notified the Respondent’s default on June 22, 2026. The Center appointed Reyes Campello Estebaranz as the sole panelist in this matter on June 25, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and page 2 Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background Founded in 1884, the Complainant is an Italian company that operates internationally in the luxury goods and hotel markets, and is particularly known for its high-end jewelry. It has more than 320 retail locations and, since 2001, has operated several hotels jointly with the Luxury Group (a division of Marriott International) across all five continents. The Complainant operates globally under the BULGARI and BVLGARI brands, which derive from its founder’s surname, “Voulgaris”, written in the modern alphabet and the classic Latin alphabet, respectively. The Complainant, its affiliates, subsidiaries, and associated companies hold trademark registrations for these brands in numerous jurisdictions, including: - Chinese Trademark Registration No. 341625, BULGARI, registered on March 10, 1989; - Australian Trademark Registration No. 338663, BULGARI (word), registered on October 5, 1979; - International Trademark Registration No. 452694, BULGARI (figurative), registered on May 15, 1980; - Mexican Trademark Registration No. 503494, BULGARI (word), registered on September 12, 1995; - United States of America Trademark Registration No. 1694380, BVLGARI (word), registered on June 16, 1992; - Canadian Trademark Registration No. TMA312178, BVLGARI (word), registered on March 14, 1986; - International Trademark Registration No. 494237, BVLGARI (word), registered on July 5, 1985; - Italian Trademark Registration No. 0000984147, BVLGARI (figurative), registered on November 18, 2005; and - European Union Trade Mark Registration No. 007138101, BVLGARI (word), registered on June 3, 2009. Hereinafter collectively referred to as the “BULGARI Mark” and the “BVLGARI Mark”, respectively. The disputed domain names were registered on February 25, 2026, and are currently inactive, resolving to black pages. On April 8, 2026, the Complainant sent a cease-and-desist letter to the Respondent through the Registrar’s email and contact form. The Respondent did not reply to this communication. 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 names. Notably, the Complainant contends that the BULGARI and BVLGARI Marks are well known, as has been recognized by various prior decisions under the Policy, including: Bulgari S.p.A. v. Hettinger Edgar, WIPO Case No. D2025-5357; Bulgari S.p.A. v. Nicholas Akins, TWS, WIPO Case No. D2025-2221; Bulgari S.p.A page 3 v. he jingwen, WIPO Case No. D2024-5101; Bulgari S.p.A. v. Che Kane Jose, WIPO Case No. D2023-3212; Bulgari S.p.A v. Fang Miao, WIPO Case No. D2022-3905; and Bulgari S.p.A. v. Aydin Genc, WIPO Case No. D2021-4247. This reputation is also established on social media by the number of the Complainant’s followers (approximately 4.7 million on Facebook; 840,000 on X; 14.2 million on Instagram; and 623,800 on TikTok). The Complainant further contends that the disputed domain names are identical to its BVLGARI Mark. The disputed domain names encompass the entirety of the BVLGARI Mark without alteration, and the Top-Level Domains (“TLDs”) “.baby” and “.bar” are standard registration requirements that are disregarded under the first element’s confusing similarity test. The Complainant further asserts that the Respondent has no rights or legitimate interests in respect of the disputed domain names. To the best of the Complainant’s knowledge, the Respondent is not commonly known by and holds no registered or unregistered trademark rights to the terms “bvlgari” or “bulgari”, nor has it ever received any license or authorization from the Complainant to use its well-known trademarks. The disputed domain names are inactive, which does not constitute a bona fide offering of goods or services, nor does it amount to a legitimate noncommercial or fair use. Furthermore, the Complainant’s trademarks are highly distinctive and non-generic, meaning the disputed domain names could only have been chosen to falsely imply an association with the Complainant. The Respondent’s sole motive is to exploit the goodwill and reputation of the Complainant’s trademarks. Finally, the Complainant contends that the Respondent registered and is using the disputed domain names in bad faith. The Complainant’s trademark registrations predate the disputed domain names by many years, and the BVLGARI and BULGARI Marks have enjoyed substantial global goodwill since 1884 as highly distinctive, non-generic terms synonymous with luxury accessories, including in China, where the Respondent is located according to the Registrar’s verification. The mere registration of an identical or confusingly similar domain name incorporating a famous mark by an unaffiliated entity creates a presumption of bad faith, and the addition of the TLDs (“.bar” and “.baby”) does not mitigate this targeting. Although the disputed domain names resolve to inactive websites, this passive holding constitutes bad faith use under the doctrine established in Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003. The Respondent’s failure to reply to the Complainant’s cease-and-desist communication further supports an inference of bad faith behavior. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings The Complainant has submitted all relevant assertions under the Policy, and the dispute properly falls within its scope. The Panel has the authority to decide the dispute by examining the three elements set forth in paragraph 4(a) of the Policy, taking into account all relevant evidence, annexed materials, and submissions. The Panel may also conduct limited independent research pursuant to its general powers, as provided, inter alia, in paragraph 10 of the Rules. 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, namely the BULGARY and BVLGARI Marks. WIPO Overview 3.1, section 1.2.1. page 4 The Panel finds that the Complainant’s trademarks are recognizable within the disputed domain names. Additionally, it is well-established that the TLDs - in this case, “.baby” and “.bar”- are viewed as a standard technical registration requirement and, as such, are typically disregarded under the confusing similarity test. Accordingly, the disputed domain names are identical to the BVLGARI Mark and confusingly similar to the BULGARI Mark for the purposes of the Policy. WIPO Overview 3.1, Sections 1.7 and 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 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 names. 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 names such as those enumerated in the Policy or otherwise. The Panel finds that the Complainant’s BVLGARI and BULGARI Marks are highly distinctive and globally recognized. The Panel further observes that there is no evidence in the record suggesting that the Respondent is commonly known by the disputed domain names or owns any corresponding trademark rights. In this respect, the Panel has corroborated, through independent searches in the WIPO Global Brand Database, 1 that - consistent with the Complainant’s allegations - the Respondent holds no trademark registrations for the terms “bvlgari”, “bulgari”, or any other combination of terms included in the disputed domain names. Furthermore, according to the uncontested evidence, the disputed domain names are inactive and resolve to black pages. It is well-established by UDRP panels that the passive holding of a domain name incorporating – in particular identical to – a famous and distinctive trademark - without any operational website or demonstrable preparations for a bona fide use - may not constitute a bona fide offering of goods or services under paragraph 4(c)(i) of the Policy, nor a legitimate noncommercial or fair use under paragraph 4(c)(iii) of the Policy. See, e.g., Vueling Airlines v. leon zhigalo, WIPO Case No. D2026-1430 (“[...] The Panel notes that the Disputed Domain Name resolves to an inactive webpage, and finds that this does not represent a bona fide offering of goods or services, or a legitimate noncommercial or fair use, given the substantial reputation and goodwill of the Complainant’s mark or capacity to otherwise mislead Internet users.”). 1 Under the general powers articulated in paragraphs 10 and 12 of the Rules, a panel may undertake limited factual research into public records if such information is useful to assessing the case merits and reaching a decision. WIPO Overview 3.1, section 4.8. page 5 Given the Respondent’s default and the total lack of any explanation or evidence to the contrary, the Respondent has failed to rebut the Complainant’s prima facie case. Accordingly, 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. 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 faith. WIPO Overview 3.1, section 3.2.1. The Panel notes that numerous prior decisions under the Policy have recognized the well-known character of the BVLGARI and BULGARI Marks. The Panel concurs with this assessment. See, e.g., Bulgari S.p.A. v. Hettinger Edgar, supra; Bulgari S.p.A. v. Nicholas Akins, TWS, supra; Bulgari S.p.A v. he jingwen supra; Bulgari S.p.A v. Fang Miao, supra; and Bulgari S.p.A. v. Aydin Genc, supra. Accordingly, given the extensive reputation and long-standing global fame of the Complainant’s BVLGARI and BULGARI Marks, which predated the registration of the disputed domain names by decades, the Panel finds it inconceivable that the Respondent was unaware of the Complainant’s trademarks at the time of registration. The terms “bvlgari” and “bulgari” derive from the Complainant’s founder’s surname, and the disputed domain names are identical to the Complainant’s highly distinctive BVLGARI Mark. It is well-established that the registration of a domain name that is identical or confusingly similar to a well- known mark by an unrelated entity without authorization can by itself create a presumption of bad faith targeting (see WIPO Overview 3.1, section 3.1.4). The addition of the TLDs “.baby” and “.bar” does nothing to diminish this finding; rather, it confirms that the Respondent deliberately targeted the Complainant’s brand in connection with TLDs that may indicate different business lines related to the Complainant’s main activities in the luxury jewelry, retail, and hotel sectors. The TLD “.baby” combined with the identical BVLGARI Mark may suggest a line of jewelry and luxury articles for infants originating from or affiliated with the Complainant, and the gTLD “.bar” may suggest a business line that operates bars within the Complainant’s hotels. Consequently, the Panel finds that the disputed domain names were registered in bad faith, deliberately targeting the Complainant and its well-known trademarks to generate confusion or a false affiliation to unfairly profit from their reputation. As noted above, the disputed domain names currently resolve to inactive websites. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, looking at the totality of the circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for the 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 trademarks, as well as the composition of the disputed domain names, and finds that, under the circumstances of this case, the passive holding of the disputed domain names does not prevent a finding of bad faith under the Policy. Particularly, the Panel notes that: (i) the Complainant’s trademarks have an exceptionally strong global reputation; (ii) the disputed domain names are identical to the BVLGARI Mark; (iii) the Respondent has provided no evidence of any actual or contemplated good faith use; and (iv) it is almost impossible to conceive of any plausible, legitimate active use of the disputed domain names by the Respondent that would not infringe upon the Complainant’s rights or generate a false affiliation with the Complainant and its trademarks. Consequently, the Panel finds that the Respondent’s passive holding of the disputed domain names would not prevent a finding of bad faith under the Telstra doctrine, as the page 6 Complainant’s marks possess an overwhelming global reputation, and the Respondent has failed to provide any response or explanation for its choice of the disputed domain names. Furthermore, the Respondent’s failure to respond to the Complainant’s cease-and-desist letter and to the Complaint reinforces the conclusion that the Respondent is acting in bad faith and has no legitimate defense to offer. See Robert Bosch GmbH v. Above.com Domain Privacy, Above.com Domain Privacy / David Woo Case No. D2018-1549; and Encyclopaedia Britannica, Inc. v. John Zuccarini and The Cupcake Patrol a/ka Country Walk a/k/a Cupcake Party, WIPO Case No. D2000-0330. Accordingly, based on the totality of the circumstances, the Panel concludes that the Respondent’s passive holding of the disputed domain names constitutes bad faith. Finally, the Panel finds that the Respondent has engaged in a pattern of conduct designed to prevent the Complainant from reflecting its trademarks in corresponding domain names, pursuant to paragraph 4(b)(ii) of the Policy. UDRP panels have consistently held that a pattern of bad faith conduct can be established with as few as two instances of abusive registration, including where a respondent registers multiple confusingly similar domain names targeting a single complainant brought within the same proceeding. Such a pattern is frequently found where a respondent simultaneously or otherwise registers multiple trademark-abusive domain names corresponding to a brand or distinct marks from the same or different brand owners. WIPO Overview 3.1, section 3.1.2; and, e.g., Autodesk, Inc. v. Bayram Fatih Aksoy, WIPO Case No. D2016-2000. Therefore, 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 names <bvlgari.baby> and <bvlgari.bar> be transferred to the Complainant. /Reyes Campello Estebaranz/ Reyes Campello Estebaranz Sole Panelist Date: July 2, 2026

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