ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION JCDECAUX SE v. li didi Case No. D2025-2686 1. The Parties The Complainant is JCDECAUX SE, France, represented by Nameshield, France. The Respondent is li didi, Hong Kong, China. 2. The Domain Name and Registrar The disputed domain name is registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on July 8, 2025. On July 9, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 10, 2025, 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 (Redacted for privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 18, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed the amended Complaints in English on July 22, 2025, and July 24, 2025 respectively. On July 18, 2025, the Center informed the Parties in Chinese and English, that the language of the Registration Agreement for the disputed domain name is Chinese. On July 24, 2025, the Complainant requested English to be the language of the proceeding in its second amended Complaint. The Respondent did not submit any comment on the Complainant’s submission. 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”).
page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent in Chinese and English of the Complaint, and the proceedings commenced on July 24, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 13, 2025. The Respondent sent an email communication in Japanese to the Center on July 24, 2025 (the “July 24 email”). On the same day, the Center sent an email to the Parties regarding the possible settlement, indicating if the Parties wished to explore settlement options, a request for suspension was to be filed by the Complainant by July 31, 2025. The Complainant requested the Center to continue the proceeding on July 24, 2025. On August 14, 2025, the Center informed the Parties that it would proceed with panel appointment. The Center appointed Francine Tan as the sole panelist in this matter on August 21, 2025. 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 is a global outdoor advertising company. Established in 1964, the Complainant has been offering solutions that combine urban development and provision of public services in more than 80 countries, for over 60 years. The Complainant states that it is currently the only group present in the three principal segments of outdoor advertising market, namely, street furniture, transport advertising and billboard advertising. The Complainant has over 1,091,811 advertising panels in airports, rail and metro stations, shopping malls, on billboards and street furniture. The Complainant is listed on the Euronext Paris stock exchange and is part of the Euronext 100 index. It employs over 12,026 people across 80 different countries and 3,894 cities. It generated EUR 3,935.3 million in 2024. The Complainant owns the trade mark JCDECAUX, including International trade mark registration No. 803987, registered on November 27, 2001. The Complainant states that it owns and operates a large portfolio of domain names, including its primary domain name, , registered on June 23, 1997. The disputed domain name was registered on July 3, 2025. At the time of filing the Complaint, the disputed domain name resolved to a login page displaying the Complainant’s JCDECAUX trade mark. 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 the Complainant’s JCDECAUX trade mark. The disputed domain name incorporates the Complainant’s trade mark with the addition of the suffix “-uzb”. “UZB” is a contraction for Uzbekistan. The addition of the suffix is insufficient to escape a finding of confusing similarity between the disputed domain name and the Complainant’s trade mark; in fact, it worsens the likelihood of confusion as the Complainant operates in Uzbekistan through its subsidiary, JCDecaux Uzbekistan. The addition of the generic Top-Level Domain (“gTLD”) “.com” does not change the overall impression of the disputed domain name as being connected to the Complainant’s JCDECAUX trade mark.
page 3 - The Respondent has no rights or legitimate interests in respect of the disputed domain name. There is no evidence that the Respondent is commonly known by the disputed domain name. The Respondent is not affiliated with or authorized by the Complainant, and is not related in any way to the Complainant’s business. The Complainant does not carry out any activity for, nor has any business with the Respondent. The Respondent does not have any licence or authorization to make use of the Complainant’s JCDECAUX trade mark, or to register the disputed domain name. The disputed domain name resolves to an authentication page displaying the Complainant’s trade mark. This page may be used to collect personal information from the Complainant’s customers or partners. Such use of the disputed domain name cannot be considered a bona fide offer of services or legitimate use of the dispute domain name as the disputed domain name misleads consumers into believing that they are accessing the Complainant’s website. - The disputed domain name was registered and is being used in bad faith. At the time of registration of the disputed domain name, the Complainant’s JCDECAUX trade mark was already known for decades and protected in several countries. The Complainant’s JCDECAUX trade mark is a well-known mark. The addition of the suffix “-uzb” cannot be a coincidence as the Complainant operates in Uzbekistan. The Respondent registered the disputed domain name with full knowledge of the Complaint’s trade mark. The Respondent has intentionally attempted to attract, for commercial purposes, Internet users to his website by creating a likelihood of confusion with the Complainant’s trade mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s website. Further, the Respondent may collect personal information through his website, including passwords. B. Respondent The Respondent did not formally reply to the Complainant’s contentions. Based on a Google translation of the July 24 email undertaken by the Panel, that the Respondent requested to know how to resolve the dispute, whether the Complainant would transfer USD 1,000 to the Respondent or how the Complainant’s rights are infringed. 6. Discussion and Findings 6.1 Preliminary issue: Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including the fact that: - English is the language most widely used in international relations and is one of the working languages of the Center; - The disputed domain name is formed by words in Roman characters and not in the Chinese script; and - In order to proceed in Chinese, the Complainant would have had to retain specialized translation services at a cost very likely to be higher than the overall cost of these proceedings. The use of Chinese in this case would therefore impose a burden on the Complainant which must be deemed significant in view of the low cost of these proceedings. The Respondent did not make any submissions with respect to the language of the proceeding.
page 4 In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. 6.2 Substantive issues 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 trade mark and the disputed domain name. WIPO Overview 3.0, section 1.7. The Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy. WIPO Overview 3.0, 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 3.0, section 1.7. Although the addition of another term, here, “-uzb”, may bear on assessment of the second and third elements, the Panel finds the addition of such a 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 3.0, 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 (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 3.0, 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. The Respondent was not licensed or authorized by the Complainant to use the latter’s JCDECAUX trade mark or to register a domain name incorporating the trade mark. There is no evidence that the Respondent is using or preparing to use the disputed domain name for any legitimate noncommercial or fair use, without intent for commercial gain.
page 5 The Panel understands, based on a Google translation of the July 24 email undertaken by the Panel, that the Respondent requested to know how to resolve the dispute, whether the Complainant would transfer USD 1,000 to the Respondent or how the Complainant’s rights are infringed. The Panel is persuaded, in view of the absence of any formal response from the Respondent, and from the contents of the July 24 email, that he does not have any rights or legitimate interests in the disputed domain name. The Respondent appeared to be ready and prepared to transfer the disputed domain name to the Complainant for a consideration of USD1,000 and did not assert any rights to the disputed domain name. Moreover, the Complainant’s JCDECAUX trade mark is highly distinctive and associated exclusively with the Complainant. The disputed domain name, which includes the Complainant’s trade mark together with the additional term “-uzb”, may be perceived by Internet users as the Complainant’s domain name for its operations in Uzbekistan. Accordingly, it is not at all conceivable that the Respondent would be able to demonstrate that he has rights or legitimate interests in the disputed domain name. The Panel finds the second element of the Policy has been established. 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. The disputed domain name incorporates the entirety of the Complainant’s distinctive JCDECAUX trade mark with the addition of the suffix “-uzb”, a common contraction denoting the country of Uzbekistan. The Complainant’s JCDECAUX mark has been registered for many years. Given the length of time of registration, the distinctiveness and reputation of the Complainant’s JCDECAUX mark, and the fact that the disputed domain name resolves to a landing page displaying the Complainant’s JCDECAUX trade mark, the Panel agrees that the Respondent knew of the Complainant and its JCDECAUX mark at the time he registered the disputed domain name. The addition of the suffix “-uzb” in the disputed domain name was clearly a deliberate attempt to mislead Internet users by creating confusion with the Complainant’s official Uzbekistani website located at the URL “www.jcdecaux.uz”. The Panel’s decision is in line with the principles set forth in WIPO Overview 3.0, section 3.2.1, which states: “Particular circumstances panels may take into account in assessing whether the respondent’s registration of a domain name is in bad faith include: (i) the nature of the domain name (e.g., a typo of a widely-known mark, or a domain name incorporating the complainant’s mark plus an additional term such as a descriptive or geographic term, or one that corresponds to the complainant’s area of activity or natural zone of expansion), (ii) the chosen top-level domain (e.g., particularly where corresponding to the complainant’s area of business activity or natural zone of expansion), … (vi) a clear absence of rights or legitimate interests coupled with no credible explanation for the respondent’s choice of the domain name, or (vii) other indicia generally suggesting that the respondent had somehow targeted the complainant”. At the time of filing the Complaint, the disputed domain name resolved to a login page displaying the Complainant’s JCDECAUX trade mark. The website required certain personal information to access. It is possible that the Respondent attempted to collect personal data for illegal purposes. Although the disputed domain name is no longer active, considering the distinctiveness and reputation of the Complainant’s trade mark and the composition of the disputed domain name clearly targeting the Complainant, the Panel finds that the current non-use of the disputed domain name does not change the Panel’s finding of the Respondent’s bad faith. The Panel finds that the Complainant has established the third element of the Policy.
page 6 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 be transferred to the Complainant. /Francine Tan/ Francine Tan Sole Panelist Date: September 1, 2025
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