Michelinamericas.com, Michelinnorth.com

The timeline behind michelinamericas.com

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 Compagnie Générale des Etablissements Michelin v. Marshall Booth Case No. D2026-2571 1. The Parties The Complainant is Compagnie Générale des Etablissements Michelin, France, represented by Dreyfus & associés, France. The Respondent is Marshall Booth, United States of America (“United States”). 2. The Domain Names and Registrars The disputed domain names <michelinamericas.com> and <michelinnorth.com> are registered with Wild West Domains, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 12, 2026. On June 15, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On June 15, 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 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 17, 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 paragraphs 2 and 4 of the Rules, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on June 19, 2026. In accordance with paragraph 5 of the Rules, the due date for Response was July 9, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 10, 2026. page 2 The Center appointed Yuji Yamaguchi as the sole panelist in this matter on July 21, 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 paragraph 7 of the Rules. 4. Factual Background The Complainant is a leading tire company which is present in 170 countries, has more than 124,000 employees and operates 117 tire manufacturing facilities and sales agencies in 26 countries. The MICHELIN Guide was first launched in 1920 to help motorists plan their trips, began to award stars for fine dining establishments in 1926, and now rates over 30,000 establishments in over 30 territories across three continents. The Complainant also operates in the United States, Canada and Mexico with headquarter operations and plants in each country known as Michelin North America, Inc. (“Michelin North America”). Michelin North America is a USD 10.76 billion a year company operating 19 plants in 16 locations and employs 22,000 people and manufactures and sells tires for airplanes, automobiles, farm equipment, heavy duty trucks, motorcycles, and bicycles. The Complainant owns numerous registrations for the MICHELIN trademarks (the “MICHELIN Trademarks”) around the world, including International Trademark No. 771031 (registered on June 11, 2001) and United States trademarks Nos. 892045 (registered on June 2, 1970), 3329924 (registered on November 6, 2007), and 4126565 (registered on April 10, 2012). The Complainant is notably the owner of the domain name <michelin.com> registered on December 1, 1993, reflecting the MICHELIN Trademarks to promote its services. The disputed domain name <michelinamericas.com> was registered on June 5, 2026, and the disputed domain name <michelinnorth.com> was registered on June 3, 2026. Both disputed domain names were actively used in a phishing and financial fraud scheme targeting the Complainant’s clients. The disputed domain names resolve to inactive webpages. 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’s contentions may be summarized as follows: The Complainant has consistently used the MICHELIN Trademarks in connection with a wide variety of products and services around the world. Consequently, the public has learnt to perceive the goods and services offered under the MICHELIN Trademarks as being those of Complainant. Therefore, the public would reasonably assume that the disputed domain names would be owned by the Complainant or at least assume that they are related to the Complainant. Accordingly, by registering the disputed domain names, the Respondent created a likelihood of confusion with the Complainant’s MICHELIN Trademarks. It is likely that the disputed domain names could mislead Internet users into thinking that they are, in some way, associated with the Complainant. page 3 The Respondent is neither affiliated with the Complainant in any way, nor has the Respondent been authorized by the Complainant to use and register its MICHELIN Trademarks, or to seek registration of any domain names incorporating the MICHELIN Trademarks. The Respondent cannot claim prior rights or legitimate interests in the disputed domain names, as the MICHELIN Trademarks precede the registration of the disputed domain names for years. The Respondent is not commonly known under the disputed domain names or under the name Michelin. The Complainant is well known throughout the world, including the United States where the Respondent is located. Considering that the disputed domain names entirely reproduce the Complainant’s MICHELIN Trademarks, combined with the terms “americas” and “north” directly targeting its North American subsidiary, it is evident that the Respondent must have had the Complainant’s MICHELIN Trademarks and company name in mind when registering the disputed domain names. The current state of inactivity does not mean that the disputed domain names are used in good faith. Indeed, passive holding does not preclude a finding of bad faith. Moreover, both disputed domain names were actively used to perpetrate a phishing and financial fraud scheme against the Complainant’s clients. The sending of fake billing requests to the Complainant’s clients as part of an identity theft and financial fraud scheme directly exposed them to financial harm. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings In accordance with paragraph 4(a) of the Policy, the Complainant must assert and prove the following three elements are present: (i) the disputed domain names are 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 names; and (iii) the disputed domain names have been registered and are being used in bad faith. A. Identical or Confusingly Similar It is well accepted that the first element in paragraph 4(a) of the Policy 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 names. See section 1.7 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”). The Complainant has shown rights in respect of the MICHELIN Trademarks for the purposes of the Policy. See section 1.2.1 of the WIPO Overview 3.1. The disputed domain names incorporate the Complainant’s MICHELIN Trademarks in their entirety with the addition of the term “americas” or “north” and a generic Top-Level Domain (“gTLD”) “.com”. In cases where the disputed domain name incorporates the entirety of the relevant trademark, or where at least a dominant feature of the relevant trademark is recognizable in the disputed domain name, the disputed domain name will normally be considered confusingly similar to the relevant trademark. See section 1.7 of the WIPO Overview 3.1. 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 in paragraph 4(a) of the Policy. See section 1.8 of the WIPO Overview 3.1. page 4 The Panel finds that the MICHELIN Trademarks are clearly recognizable within the disputed domain names and the mere addition of “americas” or “north” does not prevent a finding of confusing similarity with the MICHELIN Trademarks. See Deloitte Touche Tohmatsu v. Hattied Davis, WIPO Case No. D2022-1811; International Business Machines Corporation (IBM) v. Carolina Rodrigues, Fundacion Comercio Electronico, WIPO Case No. D2023-2572; Brokertec Americas, LLC and CME Group Inc. v. Hector Fernandez Zepeda, WIPO Case No. D2023-3127; Inter-Continental Hotels Corporation v. Reservation Booking, booking, WIPO Case No. D2024-3988; Cochlear Limited v. Summer Bradley, WIPO Case No. D2026-1290; Compagnie Générale des Etablissements Michelin v. second second, WIPO Case No. D2024-5312; Compagnie Générale des Etablissements Michelin v. second second, WIPO Case No. D2025-2071. Finally, the applicable gTLD in the disputed domain names (in this case, “.com”) should be disregarded in assessing confusing similarity under the first element in paragraph 4(a) of the Policy, as it is viewed as a standard registration requirement. See section 1.11.1 of the WIPO Overview 3.1. See also Compagnie Générale des Etablissements Michelin v. Phil Howard, Kithcen 47, WIPO Case No. D2025-3162. Accordingly, the Panel finds that the disputed domain names are confusingly similar to the Complainant’s MICHELIN Trademarks and the first element in paragraph 4(a) 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. As the Complainant asserts, the Respondent cannot claim prior rights or legitimate interests in the disputed domain names, as the Complainant’s MICHELIN Trademark registrations significantly predate the registration dates of the disputed domain names. There is no evidence that the Respondent may be commonly known under the disputed domain names or under the name Michelin pursuant to paragraph 4(c)(ii) of the Policy. The Respondent is neither affiliated with the Complainant, nor has the Respondent been authorized by the Complainant to use or register its MICHELIN Trademarks, or to seek registration of any domain names incorporating the MICHELIN Trademarks. Since both disputed domain names were actively used to conduct a phishing scheme against the Complainant’s clients, such use of the disputed domain names does not constitute a legitimate noncommercial or fair use under paragraph 4(c)(iii) of the Policy or a bona fide offering of goods or services within the meaning of paragraph 4(c)(i) of the Policy. Although the overall burden of proof in the proceedings is on the complainant, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on the second element in paragraph 4(a) of the Policy shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the disputed domain names (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 in paragraph 4(a) of the Policy. See section 2.1 of the WIPO Overview 3.1. 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. Consequently, the Panel finds that the Respondent has no rights or legitimate interests in respect of the disputed domain names and the second element in paragraph 4(a) of the Policy has been established. page 5 C. Registered and Used in Bad Faith The Complainant has established the Complainant’s worldwide reputation and the disputed domain names incorporate the Complainant’s MICHELIN Trademarks in their entirety, making it unlikely that the Respondent registered the disputed domain names without knowledge of the Complainant and its rights. See Compagnie Générale Des Etablissements Michelin v. John Smith, Michelin guide, WIPO Case No. D2026-0164. Bad faith is established where the disputed domain names are so clearly connected to a well-known trademark that its use by an entity that has no relationship to the trademark suggests opportunistic intent. See Compagnie Generale des Etablissements Michelin v. Name Redacted, WIPO Case No. D2026-1134. Given the global reputation of the MICHELIN Trademarks, registration of the disputed domain names in bad faith can therefore be inferred. According to the evidence submitted by the Complainant, phishing emails relating to ACH (Automated Clearing House) payment instructions were sent to the Complainant’s clients using email addresses associated with the disputed domain names, in an attempt to impersonate Michelin North America’s Accounts Receivable department. Such active fraudulent use by the Respondent also constitutes bad faith. See section 3.4 of the WIPO Overview 3.1. See also Compagnie Générale des Etablissements Michelin v. Second Second, WIPO Case No. D2024-2299. In view of the abovementioned circumstances, the Panel finds that the Respondent has both registered and used the disputed domain names in bad faith and the third element in paragraph 4(a) of the Policy has been established. 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 <michelinamericas.com> and <michelinnorth.com> be transferred to the Complainant. /Yuji Yamaguchi/ Yuji Yamaguchi Sole Panelist Date: August 4, 2026

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