Westmore · UDRP decision
WIPO · Case No. D2026-2622

O2fr.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <o2fr.com> after finding all three UDRP elements established. The domain incorporated the Complainant’s O2 mark with the term “fr”. The Respondent presented no evidence of rights or legitimate interests. Considering the mark’s distinctiveness and fame in France, the domain’s correspondence with the Complainant’s <o2.fr> domain and geographic-domain naming pattern, a phishing warning, the Respondent’s default and false contact details, and the implausibility of good-faith use, the Panel found bad faith under the passive-holding doctrine.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-08-10
Panelist(s)
Taylor, Adam
Complainant
O2 Developpement
Respondent
Juan Martinez
Counsel
Casalonga
Disputed domain(s)
o2fr.com
Domain history UDRP Intelligence

The timeline behind o2fr.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 o2fr.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 o2fr.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a panel may find bad faith from passive holding where several corroborating circumstances point in the same direction. In this case, inactivity was assessed together with the mark’s French reputation, the domain’s close correspondence to <o2.fr> and the Complainant’s geographic naming pattern, a phishing warning, false contact details, default, and the absence of any plausible good-faith explanation.

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
2026-08-10
Panel
Taylor, Adam
Full decision
7 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION O2 Developpement v. Juan Martinez Case No. D2026-2622 1. The Parties The Complainant is O2 Developpement, France, represented by CASALONGA, France. The Respondent is Juan Martinez, Afghanistan. 2. The Domain Name and Registrar The disputed domain name <o2fr.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 16, 2026. On June 17, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 18, 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 (Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 19, 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 24, 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 25, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 15, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 17, 2026. page 2 The Center appointed Adam Taylor as the sole panelist in this matter on July 27, 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 has offered a range of personal and household services in France under the mark O2 since 1996. The Complainant currently has some 18,000 employees and 74,000 customers. In 2025, the Complainant’s turnover was approximately EUR 50 million. The Complainant owns a number of registered trade marks for O2 including French trade mark No. 4770042, registered on April 8, 2022. The Complainant operates a website at “www.o2.fr”. The Complainant owns a number of other domain names that comprise the term “o2” plus a geographical identifier, e.g., <o2-polynesie.com> and <o2reunion.com>, and redirect to the Complainant’s main website. The disputed domain name was registered on August 21, 2025. The disputed domain name has generated a phishing warning when accessed. When visited by the Panel, the disputed domain name did not resolve 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. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 of WIPO Panel Views on Select UDRP Questions (“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 entirety of the mark is reproduced 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. page 3 Although the addition of other terms (here, “fr”) may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. 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 recognised 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 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. As to paragraph 4(c)(i) of the Policy, there is no evidence that the disputed domain name is being, or ever has been, used for an active website, let alone for a bona fide offering of goods or services. Nor is there any evidence that paragraphs 4(c)(ii) or (iii) of the Policy are relevant in the circumstances of this case. The Panel finds the second element of the Policy has been established. C. Registered and Used 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. Panels have found that, in looking at the totality of circumstances, the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy under the doctrine of passive holding. WIPO Overview 3.1, section 3.3. Having reviewed the record, the Panel considers that the following circumstances are indicative of passive holding in bad faith: 1. the distinctiveness and fame of the Complainant’s mark in France; 2. the correspondence between the disputed domain name and (a) the Complainant’s domain name, namely <o2.fr>, and (b) the Complainant’s pattern of domain names that comprise the term “o2” plus a France-related geographical identifier (see section 4 above); 3. the fact that the disputed domain name generated a phishing warning; 4. the failure of the Respondent to submit a response or to provide any evidence of actual or contemplated good faith use; page 4 5.the Respondent’s use of plainly false contact details, e.g., combining Spanish geographical references with Afghanistan as the country of residence; and 6.taking the above factors into consideration, the implausibility of any potential good faith use to which the disputed domain name may be put in light of its composition. 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 <o2fr.com> be transferred to the Complainant. /Adam Taylor/ Adam Taylor Sole Panelist Date: August 10, 2026

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

Beyond the decision

What Westmore sees around o2fr.com

The decision is only the record. Westmore connects it to the cases, authorities, panelists, parties and domain evidence surrounding it.

Connected to Westmore UDRP Intelligence
115,979 decisions · citations · panelists · parties · domain history
Eleanor · UDRP intelligence
Ask Eleanor about this decision
Ask Eleanor about this decision

A short, grounded explanation drawn only from this decision's record — not legal advice or a prediction.

Unlocking Eleanor for this case uses 1 of your complimentary Intelligence unlocks· 3 remaining

Grounded in the Westmore record for this decision. Research/informational only — not legal advice or a prediction of any outcome.

Westmore Professional · Unlock the intelligence

The decision is only the beginning.

You've seen what happened. Now discover the deeper intelligence behind the case, the panelist, the parties and the authorities that matter.

Citation Intelligence
How this decision is cited and treated across the corpus.
Panelist Intelligence
The panel's tendencies, outcomes and reasoning patterns.
Domain History
Ownership chronology — creation vs. respondent acquisition.
Opposing-Party Research
Complainant, counsel and portfolio context.
Independent Case Review
Eleanor challenges your filing before the other side does.
Professional Matters
Open, research and manage matters end to end.
$395/month
Unlock Westmore Professional Annual & firm seats available · cancel anytime
Take the next step
Westmore UDRP · find the right service

Westmore UDRP records draw on WIPO-indexed decisions and are provided for research and informational purposes only. Not legal advice, a clearance opinion, or a prediction of any outcome.

Essential cookies only. Nothing is sold or shared.