Westmore · UDRP decision
WIPO · Case No. DIO2026-0038

Replicapatekphilippe.io

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <replicapatekphilippe.io>. It found the domain confusingly similar to the Complainant’s PATEK PHILIPPE mark because it reproduced the mark in its entirety, with the added term “replica” not preventing confusing similarity. The Respondent lacked rights or legitimate interests because the domain was used to redirect to a website offering counterfeit watches. The domain’s composition and use demonstrated awareness of the Complainant’s well-known brand and constituted bad-faith registration and use under the .IO Policy.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-18
Panelist(s)
Willem J. H. Leppink
Complainant
Patek Philippe SA Geneve, Switzerland
Respondent
Papa Doma
Counsel
Cabinet Vidon – Marques · Juridique PI
Disputed domain(s)
replicapatekphilippe.io
Domain history UDRP Intelligence

The timeline behind replicapatekphilippe.io

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 replicapatekphilippe.io — 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 replicapatekphilippe.io.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates the strong evidentiary significance of combining a trademark in full with the term “replica” and using the resulting domain to direct users to a replica-goods website. That combination supported findings on all three elements: recognizable incorporation of the mark, absence of legitimate interests, and knowledge and bad faith. The decision also highlights the .IO Policy’s disjunctive third element, while finding both bad-faith registration and bad-faith use on the facts presented.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered or 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
2026-09-18
Panel
Willem J. H. Leppink
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Patek Philippe SA Geneve v. Papa Doma Case No. DIO2026-0038 1. The Parties The Complainant is Patek Philippe SA Geneve, Switzerland, represented by Cabinet Vidon Marques & Juridique PI, France. The Respondent is Papa Doma, United Kingdom. 2. The Domain Name and Registrar The disputed domain name <replicapatekphilippe.io> is registered with Backorder OÜ (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 24, 2026. On July 27, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 28, 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 backorder.com) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 29, 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 30, 2026. The Center verified that the Complaint together with the amended Complaint satisfied the formal requirements of the .IO Domain Name Dispute Resolution Policy (the “Policy”), the Rules for .IO Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for .IO 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 11, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 31, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 1, 2026. The Center appointed Willem J. H. Leppink as the sole panelist in this matter on September 9, 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 following facts are undisputed. The Complainant is a prominent and recognized company in the luxury watchmaking industry, marketing its high-end watches under the trademark PATEK PHILIPPE. Founded in 1839, the brand has its origin in the name of two of the founders: Antoine Norbert de Patek and Jean-Adrien Philippe. The Complainant offers high-end watches and accessories to connoisseurs around the world. Its official website can be found at “www.patek.com”. The Complainant owns a number of registrations in Switzerland and globally for marks including the element PATEK PHILIPPE for watch products, including the International Trademark Registration No. 594078, PATEK PHILIPPE, registered on October 21, 1992, for products in classes 9, 14, 16, and 34, and the Swiss Trademark Registration No. 396660, PATEK PHILIPPE, registered on October 21, 1992, for a range of products and services in classes 9, 14, 16 and 34. The disputed domain name was registered on June 17, 2026. On July 21, 2026, the disputed domain name redirected to the domain name <replicapatekphilippe.to> which resolved to a website purportedly offering Patek Philippe replica watches. On August 11, 2026, the disputed domain name redirected to the domain name <replicapatekphilippe.to> which resolved to a website purportedly offering Patek Philippe replica watches. The website at that time shows the copyright notice “Copyright 2026 © Replica Patek Philippe”. 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 the following. The disputed domain name consists of the trademark PATEK PHILIPPE preceded by the word “replica”, which does not prevent a finding of confusing similarity. The Respondent is not making any legitimate use of the disputed domain name as the disputed domain name redirects to the domain name <replicapatekphilippe.to> which resolves to a website featuring copyright protected digital images and protected designs of the Complainant’s watches and offers the users the possibility of ordering counterfeit “replicas”, which is an illegal activity. The mere construction of the disputed domain name demonstrates a knowledge of the Complainant’s trademark. The Respondent registered the disputed domain name using the well-known trademark PATEK PHILIPPE in its entirety, with the addition of the term “replica” preceding the trademark. Such configuration shows that the website is dedicated to the sale of PATEK PHILIPPE counterfeit watches. Therefore, there can be no doubt that the Respondent had knowledge, at the time of registration of the disputed domain name, of the Complainant’s trademarks, given that intention to replicate numerous models of the Complainant’s watches and sell them by trading on the trademark’s renown. As a result, the disputed domain name was necessarily registered in bad faith. As the disputed domain name leads to an active website that offers the users the possibility of ordering counterfeit products, “replicas” of the Complainant’s watches, the use of the disputed domain name manifestly constitutes bad faith. 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. 1 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. 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 “replica”, 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 The Policy contains a non-exhaustive list of circumstances that may demonstrate when a respondent has rights or legitimate interests in a domain name. The list includes: (1) using the domain name in connection with a bona fide offering of goods and services; (2) being commonly known by the domain name; or (3) making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers. Policy, paragraphs 4(c)(i)-(iii). Although the overall burden of proof in .IO 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 (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. To the contrary, the Respondent is using the disputed domain name to offer for sale counterfeit watches. 1 The Panel notes that the .IO Domain Name Dispute Resolution Policy (the Policy) adopted by the Internet Computer Bureau Limited (NIC.IO) on June 1, 2020, is similar to the Uniform Domain Name Dispute Resolution Policy (the “UDRP”) with the notable exception that the third element operates in the disjunctive, requiring a showing of either registration or use in bad faith for a complainant to sustain its burden there. Thus, the Panel, has referred to the WIPO Overview 3.1, where appropriate. page 4 Panels have held that the use of a domain name for illegitimate activity here, the sale of counterfeit goods, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel finds the second element of the Policy has been established. C. Registered or 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 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 also 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. The configuration of the disputed domain name demonstrates a knowledge of and familiarity with the Complainant’s well-known brand and business by registering a domain name that incorporates the PATEK PHILIPPE mark in its entirety with the addition of the term “replica” appended in front of the Complainant’s mark. It is therefore implausible that the Respondent was not aware of the Complainant’s PATEK PHILIPPE mark and its association with high-end watches, given the Respondent’s apparent intention to “replicate” numerous models of the Complainant’s watches. Panels have held that the use of a domain name for illegitimate activity, here the sale of counterfeit goods, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under 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 <replicapatekphilippe.io> be transferred to the Complainant. /Willem J. H. Leppink/ Willem J. H. Leppink Sole Panelist Date: September 18, 2026

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

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