Westmore · UDRP decision
WIPO · Case No. D2026-2534

Fr-lactalls.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <fr-lactalls.com>. It found the domain confusingly similar to the Complainant’s LACTALIS trademark because it combined the geographic term “fr” with a misspelled but recognizable version of the mark. The Respondent lacked rights or legitimate interests, and the domain was registered and used in bad faith through an email scheme seeking to redirect payments owed to the Complainant.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-07-14
Panelist(s)
Samuel, Adam
Complainant
Groupe Lactalis
Respondent
quandoan.nt
Counsel
Nameshield
Disputed domain(s)
fr-lactalls.com
Domain history UDRP Intelligence

The timeline behind fr-lactalls.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 fr-lactalls.com — 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 fr-lactalls.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates that a domain need not resolve to a website for actionable bad-faith use to occur. A typosquatted domain used through email to impersonate a trademark owner and redirect customer payments can establish both the absence of legitimate interests and bad-faith registration and use. The same-day timing between registration and deceptive email use was especially probative.

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
2026-07-14
Panel
Samuel, Adam
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Groupe Lactalis v. quandoan.nt Case No. D2026-2534 1. The Parties The Complainant is Groupe Lactalis, France, represented by Nameshield, France. The Respondent is quandoan.nt, Ukraine. 2. The Domain Name and Registrar The disputed domain name <fr-lactalls.com> is registered with Zoho Corporation Private Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 11, 2026. On June 12, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 16, 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 (not identified) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 16, 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 16, 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 17, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 7, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 8, 2026. page 2 The Center appointed Adam Samuel 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. Further Procedural Considerations Under paragraph 10 of the Rules, the Panel is required to ensure that the Parties are treated with equality and that each Party is given a fair opportunity to present its case, and also that the administrative proceedings take place with due expedition. Since the Respondent’s mailing address is stated to be in Ukraine (whether this is indeed accurate is not clear), which is subject to an international conflict at the date of this Decision that may impact case notification, it is appropriate for the Panel to consider, in accordance with its discretion under paragraph 10 of the Rules, whether the proceedings should continue. Having considered all the circumstances of the case, the Panel is of the view that they should. The Panel notes that the Center has sent the Notification of Complaint by email to the Respondent at its email address as registered with the Registrar and to a postmaster email address as specified by the Rules. There is no evidence that the case notification email to the first email address was not successfully delivered. As regards the notification by postal mail, the Panel also notes that the postal address provided to the Registrar includes a city name which does not appear to correspond to any genuine city name in Ukraine. The Panel concludes that the Parties have been given a fair opportunity to present their case, and so that the administrative proceedings take place with due expedition the Panel will proceed to a Decision accordingly. 5. Factual Background The Complainant is a French multinational company engaged in the food industry particularly the dairy sector. The Complainant owns a United States of America trademark registration number 6824877 for LACTALIS registered on August 23, 2022. The Complainant markets its services through the domain name <lactalis.com>, registered on January 9, 1999. The disputed domain name was registered on June 9, 2026. It has never resolved to an active website. On the same date, someone used an email address linked to the disputed domain name to persuade clients of the Complainant to pay amounts due to the Complainant to another bank account. 6. 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. The disputed domain name includes the Complainant’s trademark with the substitution of the letter “i” by the letter “l” and the addition of the term “fr ” which is an abbreviation of France. These variations do not change the overall impression that the disputed domain name is connected to the Complainant’s trademark. The addition of “fr ” may increase the risk of confusion as it directly reflects the Complainant and the email addresses used by its employees, namely [...]@fr.lactalis.com. The addition of a geographic abbreviation does not prevent a finding of confusing similarity between the disputed domain name and the Complainant’s mark, as the Complainant's mark remains clearly recognizable within the disputed domain name. Where a relevant trademark is recognizable within the disputed domain page 3 name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not preclude a finding of confusing similarity under the first element. The Complainant contends that the addition of the generic Top-Level Domain “.com” does not change the overall impression of the designation as being connected to the Complainant’s trademark. It does not prevent the likelihood of confusion between the disputed domain name and the Complainant, its trademark and its domain names associated. The Respondent is not identified in the WhoIs database as the disputed domain name. The Respondent is neither affiliated with nor authorized by the Complainant in any way. The Complainant does not carry out any activity or have any business with the Respondent. The disputed domain name resolves to an inactive page and has been used in a phishing scheme. Impersonation of a complainant, by using its trademark in a disputed domain name and seeking to defraud or confuse users, indicates a lack of rights or legitimate interests by a Respondent. Given the distinctiveness of the Complainant's trademark and reputation, the Complainant can state that the Respondent has registered the disputed domain name with full knowledge of the Complainant’s trademark LACTALIS. The Respondent has used an email address associated with the disputed domain name to attempt to pass itself off as an employee of the Complainant to disrupt the Complainant’s business and for financial gain. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings To succeed, the Complainant must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. A. Identical or Confusingly Similar The disputed domain name consists of the term “fr ”, the country code for the country, France, where the Complainant originates, the Complainant’s trademark, with the letter “l” substituted for the letter “i” and the generic Top-Level Domain (“gTLD”) “.com.” The gTLD is irrelevant here as it is a standard registration requirement. See section 1.11.1 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”). The insertion of the letters “fr ” does not prevent the finding of confusing similarity between the disputed domain name and the Complainant’s trademark. Section 1.8 of the WIPO Overview 3.1 says: “Where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element.” page 4 Section 1.9 of the WIPO Overview 3.1 says: “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 confusingly similar to the relevant mark for purposes of the first element. This stems from the fact that the domain name contains sufficiently recognizable aspects of the relevant mark ... Examples of such variations include ...(ii) substitution of similar-appearing characters (e.g., ...numbers used to look like letters).” Here, the insertion in the disputed domain name of the letter “l” in place of the “i” in the Complainant’s trademark does not prevent a finding of confusing similarity between the disputed domain name and the Complainant’s trademark. The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Based on the available record, the Respondent is not called or commonly known by “fr -lactalls” or anything similar. There is no evidence that the Complainant has ever authorised the Respondent to use its trademarks or that the Respondent has made a bona fide offering or a legitimate noncommercial or fair use of the disputed domain name. The Panel further notes that, on the day on which the Respondent registered the disputed domain name, the disputed domain name was used for an email that sought to impersonate the Complainant and divert payments due to the Complainant to someone else’s bank account. For these reasons, the Panel concludes that the Complainant has met this element. See sections 2.1 and 2.13.1 of the WIPO Overview 3.1. C. Registered and Used in Bad Faith On the date on which the Respondent registered the disputed domain name, it appears to have emailed a customer of the Complainant indicating that the customer should stop making payments to the Complainant’s bank account and instead make their payments to a bank account presumably controlled by the Respondent or someone connected to it, in order “not to delay further deliveries”. The reference that the customer was expected to use incorporated the Complainant’s trademark without the typographical error which appears in the disputed domain name. Section 3.1.4 of the WIPO Overview 3.1 says of this type of phishing activity: “... Given that the use of a domain name for per se illegitimate activity such as ... phishing can never confer rights or legitimate interests on a respondent, such behavior is manifestly considered evidence of bad faith.” Section 3.4 of the WIPO Overview 3.1 adds: “Panels have held that the use of a domain name for purposes other than to host a website may constitute bad faith. Such active (‘behind the scenes’) uses ... can include a range of bad faith activity or scams such as sending email, phishing.... Many such cases involve the respondent’s use of the domain name to send deceptive emails, e.g., to obtain sensitive or confidential personal information ... or to solicit payment of fraudulent invoices by the complainant’s actual or prospective customers.” This is also a typo-squatting case of which section 1.9 of the WIPO Overview 3.1 says: “Under the second and third elements, panels will normally find that employing a misspelling in this way signals an intention on the part of the respondent ... to confuse users seeking or expecting the complainant.” page 5 For all these reasons, the Panel concludes that the Respondent registered and uses the disputed domain name in bad faith. 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 <fr-lactalls.com> be transferred to the Complainant. /Adam Samuel/ Adam Samuel Sole Panelist Date: July 14, 2026

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

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