Westmore · UDRP decision
WIPO · Case No. D2026-3773

Labonbrosse.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <labonbrosse.com>. It found the domain confusingly similar to the Complainant’s LA BONNE BROSSE mark because it reproduced the mark’s dominant elements while omitting the final letters “ne” from “bonne.” The Respondent did not rebut the Complainant’s prima facie case on rights or legitimate interests. The Panel also found that the Respondent knew of and targeted the Complainant, using the domain to promote competing products and free ride on the Complainant’s trademark and goodwill for commercial gain under paragraph 4(b)(iv) of the Policy.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-10-15
Panelist(s)
Vincent Denoyelle
Complainant
LA BONNE BROSSE, France
Respondent
hoaquynh, hoa quynh
Disputed domain(s)
labonbrosse.com
Domain history UDRP Intelligence

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

The decision illustrates how a minor letter omission does not avoid confusing similarity where the trademark remains readily recognizable. It also shows the significance of post-registration use that directly competes with the trademark owner: the same conduct supported the Panel’s conclusions on both legitimate interests and bad faith. A later change to a default webpage did not erase the significance of the earlier commercial use documented in the proceeding.

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
2026-10-15
Panel
Vincent Denoyelle
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION LA BONNE BROSSE v. hoaquynh, hoa quynh Case No. D2026-3773 1. The Parties The Complainant is LA BONNE BROSSE, France, represented by TAoMA Partners, France. The Respondent is hoaquynh, hoa quynh, France. 2. The Domain Name and Registrar The disputed domain name <labonbrosse.com> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 24, 2026. On August 25, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 25, 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 GUARDIAN, Privacyguardian.org) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 28, 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 August 31, 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 September 2, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 22, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 23, 2026. page 2 The Center appointed Vincent Denoyelle as the sole panelist in this matter on October 1, 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 manufactures and sells premium hairbrushes made in France. The Complainant is the owner of several LA BONNE BROSSE trade marks (the “LA BONNE BROSSE trade mark”) including the following: • French figurative trade mark LA BONNE BROSSE LA BONNE BROSSE BB registered on August 12, 2022 under registration number 4848024; and • European Union trade mark (figurative) LA BONNE BROSSE LA BONNE BROSSE BB registered on September 5, 2023 under registration number 018702696. The disputed domain name was registered on July 12, 2026. At the time of filing, the disputed domain name pointed to website purporting to sell products in direct competition with the Complainant and presenting itself as an alternative to the Complainant and its products. At the time of this Decision, the disputed domain name resolves to a default webpage stating “This is the default index.html, this page is automatically generated by the system”. 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. Notably, the Complainant contends that the disputed domain name is confusingly similar to its LA BONNE BROSSE trade mark as a dominant part of the trade mark is reproduced in the disputed domain name which is essentially a case of typosquatting of the Complainant’s trade mark. The Complainant confirms the absence of relationship with the Respondent. The Complainant submits that it is not aware of any trade mark rights owned by the Respondent corresponding to the disputed domain name and that the available evidence does not indicate that the Respondent is commonly known by the names “La Bonne Brosse” or “La Bon Brosse”. The Complainant highlights the fact that the disputed domain name is used to direct to a website offering products in direct competition with the Complainant to conclude that the Respondent cannot assert that its use of the disputed domain name is connected with a bona fide offering of goods or services or that it could qualify as a legitimate noncommercial or fair use. The Complainant asserts that the Respondent registered the disputed domain name with full knowledge of the Complainant and its trade mark and with the intention to target the Complainant. The Complainant contends that the use of the disputed domain name indicates that the Respondent has intentionally attempted to attract Internet users to its website for commercial gain by creating a likelihood of confusion with the Complainant’s LA BONNE BROSSE trade mark as to the source, sponsorship, affiliation or endorsement of the website or of the products offered thereon. The Complainant further argues that the Respondent has deliberately used incorrect registration data for the disputed domain name and an email address that did not allow the successful delivery of the Complainant’s cease-and-desist letter to the Respondent. page 3 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 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 trade mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds that the LA BONNE BROSSE trade mark is recognizable within the disputed domain name as it reproduces the dominant elements of the Complainant’s trade mark, in the same order, with the mere omission of the two final letters (“ne”) in the second element “bonne”. Accordingly, the disputed domain name is confusingly similar to the LA BONNE BROSSE trade mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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 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. Based on the available evidence and in the absence of a response from the Respondent, the Panel finds that the Respondent’s purpose in registering and using the disputed domain name is solely to free ride off the Complainant’s trade mark and associated goodwill and this cannot qualify as either a bona fide offering of goods or services or a legitimate non-commercial or fair use. The Panel finds the second element of the Policy has been established. page 4 C. Registered and Used in Bad Faith The Panel notes that, for 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 faith. In the present case, the Panel finds that the Respondent must have been aware of the Complainant and its trade mark at the time of registering the disputed domain name given (i) the composition of the disputed domain name which is closely similar to the LA BONNE BROSSE trade mark of the Complainant, (ii) the reputation of the Complainant and its trade mark, especially in France where the Respondent appears to be based and (iii) the use of the disputed domain name shortly after registration which clearly seeks to compete with the Complainant as an alternative to the Complainant. Turning to use of the disputed domain name in bad faith, based on the evidence available and in the absence of a response from the Respondent, the Panel finds that the Respondent’s sole purpose in registering and using the disputed domain name is to free ride off the Complainant’s trade mark and associated goodwill which falls squarely within the meaning of paragraph 4(b)(iv) of the Policy. 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 <labonbrosse.com> be transferred to the Complainant. /Vincent Denoyelle/ Vincent Denoyelle Sole Panelist Date: October 15, 2026

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

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