Westmore · UDRP decision
WIPO · Case No. D2026-3229

Promo-kerastase.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered the transfer of <promo-kerastase.com> to L’Oréal. It found the domain confusingly similar to the KERASTASE trademark, found no rights or legitimate interests where the domain was used for an online store displaying the Complainant’s mark and logo without disclosing the lack of affiliation, and found bad-faith registration and use based on deliberate targeting and an attempt to attract users for commercial gain through confusion.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-15
Panelist(s)
Alexandre Nappey
Complainant
L’Oréal, France
Respondent
mathieu sucueur, France
Counsel
Dreyfus · associés
Disputed domain(s)
promo-kerastase.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind promo-kerastase.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 promo-kerastase.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 promo-kerastase.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates how an online store’s presentation can be decisive across the second and third UDRP elements. Incorporation of a trademark with a promotional term established confusing similarity, while prominent brand and logo use, checkout functionality, discounted purported branded goods, and the absence of an affiliation disclaimer supported both the lack of legitimate interests and bad-faith commercial targeting.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
Registration and use 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
2026-09-15
Panel
Alexandre Nappey
Full decision
7 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION L’Oréal v. mathieu sucueur Case No. D2026-3229 1. The Parties The Complainant is L’Oréal, France, represented by Dreyfus & associés, France. The Respondent is mathieu sucueur, France. 2. The Domain Name and Registrar The disputed domain name <promo-kerastase.com> is registered with Tucows Domains Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 22, 2026. On July 23, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 23, 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 (Contact Privacy Inc. Customer 0178804116) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 24, 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 July 27, 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 August 5, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 25, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 27, 2026. The Center appointed Alexandre Nappey as the sole panelist in this matter on September 2, 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. page 2 4. Factual Background The Complainant is a French cosmetics group. It owns and uses the KERASTASE trademark for professional haircare products. The Kérastase brand was launched in 1964. The Complainant owns numerous registrations for the KERASTASE trademark, including International Trademark Registration No. 283650, registered on May 15, 1964, for goods including cosmetics and haircare products in class 3, and French Trademark Registration No. 4836745, registered on January 24, 2022, in classes 3, 9, 35, and 41. The Complainant also operates the domain name <kerastase.fr>, registered on March 31, 2003. The disputed domain name was registered on July 7, 2026. At the time of filing the Complaint, it resolved to a French-language online store prominently displaying the Complainant’s KERASTASE trademark and logo and offering purported KERASTASE products at discounted prices. The website included a checkout page and did not disclose the Respondent’s lack of relationship with the Complainant. Its footer displayed “© 2026, Kerastase”. Following a notice to the hosting provider, the content was removed. As of July 27, 2026, the disputed domain name resolved to a page indicating that the online store was unavailable. 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. The Complainant contends that the disputed domain name is confusingly similar to its KERASTASE trademark because it reproduces the mark in its entirety, with the addition of the term “promo”. The Complainant further contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant has not authorized the Respondent to use its trademark, and the Respondent’s use of the disputed domain name for an online store impersonating the Complainant is not a bona fide offering of goods or services. Finally, the Complainant contends that the disputed domain name was registered and is being used in bad faith. It submits that the Respondent was necessarily aware of the KERASTASE trademark and used the disputed domain name to attract Internet users for commercial gain by creating confusion with the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“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 “promo”, 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 recognized that proving 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. 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 Complainant has not authorized the Respondent to use its KERASTASE trademark, and there is no evidence that the Respondent is legitimately known by the disputed domain name. The listing of “Kerastase” in the registrant’s organization field does not, in the circumstances of this case, establish any right or legitimate interest. The use of the disputed domain name for an online store prominently displaying the Complainant’s trademark and logo and failing to accurately and prominently disclose the Respondent’s lack of relationship with the Complainant, does not constitute a bona fide offering of goods or services. WIPO Overview 3.1, section 2.8.1. Panels have held that the use of a domain name for illegal activity, here claimed impersonation or passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. 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. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel finds that the Respondent registered the disputed domain name in bad faith. The Complainant’s KERASTASE trademark long predates the registration of the disputed domain name. The composition of the disputed domain name, the identification of the registrant’s organization as “Kerastase”, and the content of the website demonstrate that the Respondent was aware of, and deliberately targeted, the Complainant and its trademark. The Panel further finds that the Respondent used the disputed domain name in bad faith. By using it for an online store that displayed the Complainant’s trademark and logo and offered purported KERASTASE products, the Respondent intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the website, within the meaning of paragraph 4(b)(iv) of the Policy. See WIPO Overview 3.1, section 3.4; and L’Oréal v. Hegavi Patrocinios, HEGAVI, WIPO Case No. D2026-0305. The apparent inconsistencies in the registrant’s contact details further support the Panel’s finding of bad faith. WIPO Overview 3.1, section 3.6. The subsequent removal of the website content does not alter the conclusion arising from the Respondent’s prior use. page 4 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 <promo-kerastase.com> be transferred to the Complainant. /Alexandre Nappey/ Alexandre Nappey Sole Panelist Date: September 15, 2026

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

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