Westmore · UDRP decision
WIPO · Case No. D2026-3018

Ceraveimlthailand.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <ceraveimlthailand.com> to L’Oréal. It found the domain confusingly similar to the CERAVE mark because it incorporated the mark in full with the terms “iml” and “thailand”; found no rights or legitimate interests based on Complainant’s unrebutted prima facie case and the risk of implied affiliation; and found bad-faith registration and use because Respondent knew of the well-known, coined CERAVE mark and used the domain for an unrelated gambling website to attract Internet users through confusion for commercial gain.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-08-21
Panelist(s)
Colin T. O'Brien
Complainant
L’Oréal
Respondent
ERIKKO ERIKKO
Counsel
Dreyfus · associés
Disputed domain(s)
ceraveimlthailand.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

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

The decision illustrates the treatment of a domain that combines an entire well-known, coined cosmetics mark with an unexplained term and a geographic identifier, then uses the resulting domain for unrelated gambling content. The outcome rested not merely on Respondent’s default, but on the recognizable incorporation of CERAVE, substantially earlier trademark rights, the risk of implied affiliation, and commercial diversion to unrelated gambling services.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-08-21
Panel
Colin T. O'Brien
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION L’Oréal v. ERIKKO ERIKKO Case No. D2026-3018 1. The Parties Complainant is L’Oréal, France, represented by Dreyfus & associés, France. Respondent is ERIKKO ERIKKO, Indonesia. 2. The Domain Name and Registrar The disputed domain name <ceraveimlthailand.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 July 9, 2026. On July 9, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 10, 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 Complainant on July 10, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed amended Complaints on July 10, 2026 and July 13, 2026. The Center verified that the Complaint together with the amended Complaints 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 Respondent of the Complaint, and the proceedings commenced on July 14, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 3, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on August 4, 2026. page 2 The Center appointed Colin T. O'Brien as the sole panelist in this matter on August 7, 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 Complainant is a French industrial group specialized in the field of cosmetics and beauty which sells its products globally. Complainant is the owner of CeraVe which was founded in 2005 and offers a range of advanced skincare products, specifically cleansers, moisturizers, sunscreens, healing ointments and a dedicated baby line. Complainant owns numerous CERAVE trademark registrations around the world including: Indonesian Trademark CERAVE No. IDM000420874, registered on December 2, 2021, covering goods in class 3; European Union Trade Mark CERAVE No. 016162752, registered on June 21, 2017, covering goods in class 3; and Thai Trademark Registration CERAVE No. C390517 dated January 12, 2015, duly renewed, and covering goods in class 3. The disputed domain name was registered on May 29, 2026 and resolves to a gambling website. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, Complainant contends that the disputed domain name reproduces the trademark CERAVE followed by the additional generic term “iml” and the geographic term “thailand”. Complainant has used the trademark CERAVE in connection with specific cosmetic products around the world, including in Indonesia. Consequently, the public has learnt to perceive the goods offered under this trademark as being those of Complainant. Therefore, the public would reasonably assume that the disputed domain name would be owned by Complainant or at least assume that it is endorsed or in other way related to Complainant. Respondent is neither affiliated with Complainant in any way nor has he been authorized by Complainant to use and register its trademark, or to seek registration of any domain name incorporating said mark. Furthermore, Respondent has no prior rights or legitimate interests in the disputed domain name. The registration of the CERAVE trademarks preceded the registration of the disputed domain name for years. Respondent is not commonly known by the disputed domain name or the name “Cerave”. There is simply no evidence that Respondent may be commonly known by the name “Cerave”. Respondent did not demonstrate, use of, or demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. On the contrary, the disputed domain name resolved to an online gambling website where users could place bets, which cannot be considered a legitimate commercial use. Therefore, by diverting traffic, Respondent uses Complainant’s trademark for its own commercial purposes. page 3 It is implausible that Respondent was unaware of Complainant when it registered the disputed domain name. Complainant’s CERAVE mark is well-known throughout the world, including Indonesia. In this regard, many panels have previously acknowledged Complainant’s reputation worldwide, making it unlikely that Respondent was not aware of Complainant’s rights in said trademark. Considering the composition of the disputed domain name, which entirely reproduces Complainant’s trademark CERAVE, which is a highly distinctive mark, with the addition of the generic term “iml” and the geographic term “thailand”, it is impossible that Respondent did not have Complainant’s trademark and company name in mind while registering the disputed domain name. In fact, bad faith has already been found where a domain name is so obviously connected with a well-known trademark that its very use by someone with no connection to the trademark suggests opportunistic bad faith. Respondent’s primary motive in registering and using the disputed domain name was to capitalize on or otherwise take advantage of Complainant’s trademark rights, through the creation of initial interest of confusion. Indeed, the disputed domain name directs users to a website purportedly offering online gaming/gambling services, with a login button that redirects users to a login page where users are prompted to log into their accounts for online gaming. Such use of the disputed domain name demonstrates Respondent’s intention to abusively benefit from Complainant’s reputation and potentially collect users’ sensitive data for phishing purposes. The disputed domain name directs users to an online gambling website. This deceptive use demonstrates Respondent’s bad faith, as the disputed domain name exploits Complainant’s trademark to mislead users, undermine their trust, and generates illicit commercial gain. Such conduct, involving redirection to unrelated gambling platform, clearly indicates that Respondent is not making a legitimate use of the disputed domain name but is instead intentionally attempting to attract users for financial benefit by creating a false association with Complainant. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Complainant has demonstrated it owns registered trademark rights in the CERAVE mark in both Thailand and Indonesia. The disputed domain name reproduces Complainant’s mark in its entirety with the terms “iml” and “thailand”. The generic Top-Level Domain (“gTLD”) “.com” is viewed as a standard registration requirement and as such is typically disregarded under the first element confusing similarity test. The Panel finds the addition of the terms “iml” and “thailand” 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. Accordingly, the disputed domain name is confusingly similar to the mark in which Complainant has rights and the first element of the Policy is established. B. Rights or Legitimate Interests Complainant has presented a prima facie case that Respondent has no rights or legitimate interests in respect of the disputed domain name and has not been commonly known by the disputed domain name. The fact that Respondent registered the disputed domain name which incorporates Complainant’s registered and globally known CERAVE trademark and merely adds the terms “iml” and “thailand”, indicates to the Panel that Respondent likely sought to impersonate Complainant and piggyback on the mark for potential illegitimate purposes. page 4 After a complainant has made a prima facie case, the burden of production shifts to a respondent to present evidence demonstrating rights or legitimate interests in the domain name. See, e.g., Croatia Airlines d.d. v. Modern Empire Internet Ltd., WIPO Case No. D2003-0455 and WIPO Overview 3.1, section 2.1. Here, Respondent has failed to participate in the proceedings and as such, it did not provide any evidence of any rights or legitimate interests in the disputed domain name. Moreover, the Panel finds that the nature of the disputed domain name carries a risk of an implied affiliation as it effectively impersonates or suggests sponsorship or endorsement by Complainant. See WIPO Overview 3.1, section 2.5.1. In the absence of any evidence rebutting Complainant’s prima facie case indicating Respondent’s lack of rights or legitimate interests in respect of the disputed domain name, the Panel finds that Complainant has satisfied paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith The disputed domain name was registered years after Complainant first registered and used the CERAVE mark. The evidence on the record provided by Complainant is sufficient to satisfy the Panel that, at the time the disputed domain name was registered, Respondent undoubtedly knew of Complainant’s CERAVE mark. Further, the Panel finds the use of the disputed domain name by Respondent is in bad faith. Paragraph 4(b)(iv) of the Policy states that evidence of bad faith may include a respondent’s use of a domain name to intentionally attempt to attract, for commercial gain, Internet users to the respondent’s website or other online location, by creating a likelihood of confusion with the complainant’s mark. Having the disputed domain name, which incorporates the Complainant’s well-known and coined trademark, resolve to an unrelated gambling website indicates to the Panel that Respondent registered and used the disputed domain name in bad faith. In the absence of any evidence or explanation from Respondent, the Panel finds that the registration and use of the disputed domain name have been for bad faith purposes. Accordingly, the Panel finds that Complainant has satisfied paragraph 4(a)(iii) 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 <ceraveimlthailand.com> be transferred to Complainant. /Colin T. O'Brien/ Colin T. O'Brien Sole Panelist Date: August 21, 2026

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

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