Westmore · UDRP DecisionKalliope-laws.com
The Panel ordered transfer of <kalliope-laws.com>. It found the domain confusingly similar to the Complainant’s KALLIOPÉ mark, that the Respondent lacked rights or legitimate interests, and that registration and use were in bad faith. The record stated that an email address at the domain was used to impersonate a founding partner of the Complainant and send fraudulent emails offering legal assistance to the Complainant’s clients.
The timeline behind kalliope-laws.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 kalliope-laws.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that an undeveloped website does not insulate a respondent where the domain is configured and actually used for impersonation email. The close variation of a law firm’s official domain, combined with active MX records and use of a copied partner identity, supplied a direct evidentiary link between confusing similarity and fraudulent targeting.
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 Kalliopé v. Bernard Germanier Case No. D2026-2824 1. The Parties The Complainant is Kalliopé, France, internally represented. The Respondent is Bernard Germanier, Switzerland. 2. The Domain Name and Registrar The disputed domain name <kalliope-laws.com> is registered with Network Solutions, LLC (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 29, 2026. On June 29, 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 30, 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 f rom the named Respondent (PERFECT PRIVACY, LLC]) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on July 2, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amended Complaint on July 2, 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 July 3, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 23, 2026. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on July 24, 2026. The Center appointed Willem J. H. Leppink as the sole panelist in this matter on July 27, 2026. The Panel f inds 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. page 2 4. Factual Background The f ollowing f acts are undisputed. The Complainant is a French law f irm f ounded in 2007, with its head of f ice in Paris, France. The Complainant is an independent firm providing legal advice and representation to companies, public entities, and private clients, on a national and an international level. It has a wide range of practice areas including business law, intellectual property law, public law, and urban planning law. The Complainant is the owner of the French trademark registration KALLIOPÉ (wo rd mark) with registration number 4527768, registered on August 9, 2019, f or services in classes 36 and 45. The Complainant is also the owner of the domain name <kalliope-law.co m>, registered on July 23, 2007, which resolves to its of f icial website. The disputed domain name was registered on June 10, 2026. At the time of rendering this decision the disputed domain name resolves to a page mentioning that “the site that is under construction and coming soon”. Mail Exchange (“MX”) servers are activated in relation to the disputed domain name. The email address “[...]@kalliope-laws.com” associated with the disputed domain name was used to send fraudulent emails impersonating one of the founding partners of the Complainant, purporting to of f er legal assistance to the Complainant’s clients. The Complainant sent a f ormal notice to the Registrar on June 23, 2006, which remained unanswered. 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. Notably, the Complainant contends t hat the disputed domain name has been used f or sending f raudulent emails to the Complainant’s clients and of f ering legal assistance. In such email, the Respondent impersonated the identity of a partner at the firm of the Complainant, using his email signature (including the street address and official website address of the Complainant) and making a proposal on behalf of the Complainant. The disputed domain name incorporates the Complainant’s trademark in its entirety. The disputed domain name is a direct typosquatting imitation of the Complainant’s registered domain name <kalliope-law.com> which resolves to its official website, differing only by the addition of the letter “s” at the end of “law”. The addition of a single letter does not prevent a f inding of conf using similarity. On the contrary, consumers will readily understand the disputed domain name to be directly related to the Complainant, as the letter “s” is positioned at the end of the domain name and is unlikely to be noticed by Internet users. The Respondent has no rights or legitimate interests in the disputed domain name. The Complainant has not granted any license, nor any authorization to use its trademark, included as a domain name. The Respondent’s use of the disputed domain name does not qualify as bona fide off er of goods and services. The disputed domain name was registered and is being used in bad f aith. First, its trademark is a well- known trademark, as the Complainant is a renowned law firm in France, widely known among the public f or its expertise and reputation in legal advice and counsel. Second, even though the disputed domain name page 3 does not lead to an active website, the Respondent is using the disputed domain name to send f raudulent emails to the Complainant’s clients. Such conduct clearly constitutes bad-faith use of the disputed domain name. Thirdly, the f act that the disputed domain name is conf igured with MX records, enabling the Respondent to create email addresses using the disputed domain name, gives rise to a signif icant risk of phishing attacks. This risk has materialized, as an email has been sent from the disputed domain name to one of the Complainant’s clients. This demonstrates moreover that the Respondent has already taken active steps to exploit the MX records activation f or f raudulent purposes. The meticulous reproduction of the Complainant’s identity, f ar f rom being accidental, demonstrates a deliberate intent on the part of the Respondent to deceive the recipient into believing that the email genuinely originated from the Complainant. 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 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 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. WIPO Overview 3.1, section 1.2.1. The entirety of the mark is reproduced within the disputed domain name, with the exception of the accent over the letter “é”. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms here, “laws” may bear on assessment of the second and third elements, the Panel f inds the addition of such term d oes not prevent a f inding of conf using similarity between the disputed domain name and the mark f or the purposes of the Policy. WIPO Overview 3.1, section 1.8. 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 page 4 demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. Panels have held that the use of a domain name f or illegal activity here, claimed phishing/identity thef t, passing off, or other types of fraud, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel f inds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel ref ers to its considerations under section 6.B. 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. In the present case, the Panel notes that the Respondent with the registration and use of the disputed domain name has intentionally attempted to attract, f or commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark and has also engaged in a pattern of bad f aith conduct. Panels have held that the use of a domain name f or illegal activity here, claimed phishing/identity thef t, passing off, or other types of fraud, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel f inds that the Respondent's registration and use of the disputed domain name constitutes bad f aith within the meaning of paragraph 4(a)(iii) of the Policy. The Panel f inds the third element of the Policy has been established. 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 <kalliope-laws.com> be transf erred to the Complainant. /Willem J. H. Leppink/ Willem J. H. Leppink Sole Panelist Date: August 4, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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