Westmore · UDRP DecisionVa1eo.com
The Panel ordered transfer of <va1eo.com>. It found the domain confusingly similar to the VALEO mark because the numeral “1” replaced the visually similar lowercase letter “l”. The Complainant established an unrebutted prima facie case that the Respondent lacked rights or legitimate interests. On bad faith, the Panel did not regard the configuration of MX servers alone as sufficient, but found that the Respondent deliberately targeted the Complainant’s well-known mark and that passive holding did not prevent a bad-faith finding in light of the mark’s reputation and the domain’s composition.
The timeline behind va1eo.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The decision distinguishes between evidence that may create concern and evidence sufficient to prove bad faith. MX records were configured, but the Panel expressly declined to treat that fact alone as establishing bad faith. Transfer instead rested on the targeted numeric substitution, the well-known and distinctive character of the VALEO mark, the inferred prior knowledge and intent to target it, and passive holding assessed under the totality of the circumstances.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Valeo v. annie Macedo, LuxairGroup Case No. D2026-2432 1. The Parties The Complainant is Valeo, France, represented by Tmark Conseils, France. The Respondent is annie Macedo, LuxairGroup, Bulgaria. 2. The Domain Name and Registrar The disputed domain name <va1eo.com> is registered with Hostinger Operations, UAB (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 4, 2026. On June 5, 2026, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On June 8, 2026, the Registrar transmitted by email to the Center its verif ication response, disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Unknown / The RDAP server redacted the value) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on June 9, 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 June 11, 2026. The Center verif ied that the Complaint together with the amended Complaint 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”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on June 12, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 2, 2026. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on July 6, 2026. page 2 The Center appointed Áron László as the sole panelist in this matter on July 14, 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 Valeo, a European company registered in France since February 25, 1955. The Complainant is a worldwide automotive supplier and technology company that designs innovative solutions f or smart mobility. The Complainant also provides and distributes spare parts f or carmakers and independent af termarket operators. The Complainant has used the mark VALEO in connection with automotive and mobility activities and goods since 1980. The Complainant is the owner of numerous registered trademarks for VALEO worldwide. The Complainant relies, inter alia, on the f ollowing trademark registrations: - United States of America trademark VALEO, Registration No. 1353733, registered on August 13, 1985; - French trademark VALEO, Registration No. 1336046, registered on December 23, 1985; and - European Union trademark VALEO, Registration No. 005758412 (f igurative), registered on July 2, 2007. The Complainant operates the domain name <valeo.com>, created on March 25, 1997, which directs to the Complainant’s of f icial website. The disputed domain name <va1eo.com> was registered on April 23, 2026. The disputed domain name does not resolve to an active website. Mail Exchange (“MX”) records were conf igured in relation to the disputed domain name. According to the Registrar's verification response, the Respondent is “annie Macedo”, with the organisation listed as “LuxairGroup”, located in Bulgaria. 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 name. The Complainant contends that the disputed domain name <va1eo.com> is identical or, at the very least, conf usingly similar to the VALEO trademark. The Complainant argues that the disputed domain name wholly incorporates and imitates its earlier well-known, and famous trademark. The Complainant notes that the only modification in the disputed domain name consists of the substitution of the letter “l” with the numeral “1” between the letters “a” and “e”, which qualif ies as typosquatting. The Complainant relies on prior UDRP panel decisions which have f ound that such substitutions of visually similar characters amount to typosquatting. The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. VALEO is not a generic term but a registered, distinctive, and well-known trademark, and the Complainant’s prior rights significantly predate the registration of the disputed domain name. At the time of registration of the disputed domain name, the Respondent was not known as “valeo” and there is no legitimate reason why the Respondent would incorporate the Complainant’s well-known trademark in the page 3 disputed domain name. The disputed domain name does not resolve to any active website, which does not give a legitimate reason f or the Respondent to have reserved the disputed domain name, and that the Respondent of f ers no evidence of a bona f ide of f er of goods or services. The Complainant contends that the disputed domain name was registered and is being used in bad f aith. The Complainant asserts that, given the decades-long and worldwide protection and use of the VALEO denomination as a trademark, company name, and domain name, it is inconceivable that the Respondent registered the disputed domain name by coincidence. The Complainant submits that the substitution of the letter “l” with the numeral “1” in the word “valeo” is a common and deliberate practice of typosquatting intended to intercept and divert Internet users who mistype “valeo” when attempting to access the Complainant’s official website. The Complainant contends that the numeral “1” was specifically chosen because of its visual resemblance to the lowercase letter “l”, and that this deliberate misspelling is itself evidence of bad f aith at the time of registration. The Complainant f urther contends that, although the disputed domain name does not currently resolve to any active website, passive holding does not preclude a f inding of bad faith. The Complainant additionally draws attention to the configuration of MX servers on the disputed domain name, contending that this constitutes evidence of an intention to conduct phishing or scamming activities impersonating the Complainant. It f urther submits that the risk of confusion between the Complainant’s genuine email addresses and fraudulent addresses based on the disputed domain name is high, given that both share the same email address architecture. The Complainant draws the Panel’s attention to the prior UDRP proceeding, Rocsys B.V. v. annie Macedo, LuxairGroup, WIPO Case No . D2023- 4824, in which the same Respondent was f ound to have registered a domain name reproducing a complainant’s trademark with the same registrar and to have used it for fraudulent email purposes, resulting in an order to transf er the domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules instructs this Panel to “decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. Paragraph 4(a) of the Policy requires that a complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transf erred: i.the domain name registered by the respondent is identical or conf usingly similar to a trademark or service mark in which the complainant has rights; and ii.the respondent has no rights or legitimate interests in respect of the domain name; and iii.the domain name has been registered and is being used in bad f aith. In view of the Respondents’ failure to submit a Response, the Panel shall decide this dispute on the basis of the Complainant’s undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inf erences as it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations set forth in a complaint. However, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.3. page 4 A. 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 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 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. A domain name which consists of a variation of a trademark (typically a common, obvious, or intentional misspelling, referred to as typosquatting) is considered by panels to be conf usingly similar to the relevant mark f or purposes of the first element. Examples of such variations include substitution of similar-appearing characters (e.g., upper vs lower-case letters or numbers used to look like letters). WIPO Overview 3.1, section 1.9. The Panel f inds the f irst 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 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 name. 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 name such as those enumerated in the Policy or otherwise. The Panel f inds the second element of the Policy has been established. C. 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. The Panel does not consider that bad f aith has been established simply because the Respondent has conf igured MX servers using the disputed domain name. page 5 On the other hand, the Panel considers that the Respondent deliberately chose the disputed domain name due to its resemblance to the Complainant’s well-known trademark, given that the numeral “1” resembles the letter “l”. Panels have consistently f ound 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 well-known trademark, and particularly in the case of coined or fanciful marks, can by itself create a presumption of bad f aith. The Panel concludes on the balance of probabilities that the Respondent registered the disputed domain name with prior knowledge of the Complainant’s trademark and with the intent to target it. 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 or reputation of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name 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 name <va1eo.com> be transf erred to the Complainant. /Áron László/ Áron László Sole Panelist Date: July 28, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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