ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Mistral AI, v. hhhhm kk Case No. D2025-2807 1. The Parties Complainant is Mistral AI, France, represented by Blanche Avocats, France. Respondent is hhhhm kk, China. 2. The Domain Name and Registrar The disputed domain name is registered with CloudFlare, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 16, 2025. On July 17, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 18, 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 named Respondent (DATA REDACTED) and contact information in the Complaint. The Center sent an email communication to Complainant on July 18, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on July 18, 2025, and a second amended Complaint on July 22, 2025. The Center verified that the Complaint together with the amended Complaint and the second 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 Respondent of the Complaint, and the proceedings commenced on July 23, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 12, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on August 13, 2025. Respondent sent an email communication to the Center on August 13, 2025.
page 2 The Center appointed Gabriel F. Leonardos as the sole panelist in this matter on August 25, 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 Complainant is a French company founded in 2023 that operates in the technology market, being recognized as a leading European company in generative artificial intelligence (“AI”). Complainant’s reputation has been recognized in several press articles and TV channels around the world. Besides developing large language models (“LLMs”), Complainant has developed a multilingual conversational assistant and an optical character recognition service (“OCR”), both based on MISTRAL AI’s models. Complainant is the owner of trademark registrations for MISTRAL AI and is the owner of domain names composed by the mark, such as ; ; ; ; and . Some examples of Complainant’s trademark registrations can be found below: Registration Trademark Jurisdictions International Class Registration Date 1794809 MISTRAL AI International 09, 35 and 42 December 15, 2023 018942618 MISTRAL AI European Union 42 February 14, 2024 4970012 MISTRAL AI France 09, 35 and 42 November 10, 2023 The disputed domain name was registered on March 7, 2025, and redirect users to a website that provides a service of OCR, similarly to what is offered by Complainant. 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 consists of a reproduction of terms “mistral” and “ocr”, which is the name of a service provided by Complainant. Also, the disputed domain name reproduces the “mistral” element from the MISTRAL AI trademark and the Complainant’s domain name. Therefore, according to Complainant, the disputed domain name is confusingly similar with Complainant’s trademark MISTRAL AI and owned domain name , fulfilling paragraph 4(a)(i) of the Policy and paragraphs 3(b)(viii) and (b)(ix)(1) of the Rules. Complainant states that Respondent lacks any rights or legitimate interest in the disputed domain name. This is supported by the fact that there is no current or past relationship between the Parties. Also, Complainant states that has neither authorized, nor somehow given its consent to Respondent to register or use the disputed domain name in any way. Complainant affirms that Respondent is not making a legitimate noncommercial or fair use of the disputed domain name as it redirects Internet users to a fraudulent website that falsely suggests affiliation with
page 3 Complainant through impersonation. Thus, Complainant argues that Respondent is taking an unfair commercial advantage of the MISTRAL AI trademark and intends to generate undue profit from such use. In this manner, Complainant states that no legitimate use of the disputed domain name could be reasonably claimed by Respondent, fulfilling paragraph 4(a)(ii) of the Policy and paragraph 3(b)(ix)(2) of the Rules. Complainant argues that Respondent registered the disputed domain name in bad faith, since it resolves to a website that falsely related to its OCR services and was registered just a day after its new service was announced. Additionally, Complainant contends that Respondent tries to hide its identity by providing an incomplete address, a fake name, and a shadowy e-mail address. Thus, according to Complainant, the requirements for the identification of a bad faith registration and use of the disputed domain name have been fulfilled, pursuant to paragraphs 4(a)(iii) and 4(b) of the Policy and paragraph 3(b)(ix)(3). Accordingly, Complainant requests that the disputed domain name be transferred to Complainant. B. Respondent Respondent did not formally reply to Complainant’s contentions. However, Respondent sent an email communication to the Center explaining that they did not intend to infringe Complainant’s intellectual property, but rather to create a product similar to Complainant’s capabilities, and that Respondent was interested in reaching an amicable solution with Complainant. Complainant requested the Center proceed with Panel appointment, providing a copy of a communication from Respondent offering to transfer of the disputed domain name for the fee of USD 500, which Complainant contended further supports a finding of bad faith in this proceeding. 6. Discussion and Findings To succeed in a UDRP complaint, Complainant must demonstrate that all the elements listed in paragraph 4(a) of the Policy have been satisfied, as following: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (ii) Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. The burden of proving these elements is upon Complainant. 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 Complainant’s trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.7. Based on the available record, the Panel finds Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The Panel finds the MISTRAL AI mark is recognizable 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.
page 4 Although the addition of the terms “ocr” and “app” in the disputed domain name may bear on assessment of the second and third elements, the Panel finds that such addition does not prevent a finding of confusing similarity between the disputed domain names and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. Therefore, based on the available record, 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 Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings is on 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 Respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on Complainant). If Respondent fails to come forward with such relevant evidence, Complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent has not rebutted Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain names such as those enumerated in the Policy or otherwise. Based on the available record, Respondent is not entitled to any trademark, trade name, or any other right associated with the disputed domain name. Additionally, Respondent has not been authorized by Complainant to use the MISTRAL AI trademark, and there is no commercial relationship between the Parties. Respondent is not recognized by the disputed domain name, and the Panel notes that Respondent offered to sell the disputed domain name. In light of these circumstances, the Panel finds that no rights or legitimate interests can be found on behalf of Respondent. Accordingly, 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 disputed domain name in bad faith. In the present case, the Panel notes that Respondent has registered the disputed domain name that is confusingly similar to Complainant’s trademark MISTRAL AI, as explained above in 6.A. Also, based on the available record, the Panel finds that it is established that Respondent has no affiliation with Complainant and the trademark MISTRAL AI, nor has it sought authorization or a license to utilize the referred trademark. Also, there is no evidence Respondent owns any trademarks containing the term MISTRAL AI, nor any rights over a similar trademark or any related terms, as explained in 6B. Furthermore, considering Complainant’s significant worldwide reputation appearing as one of the most prolific AI companies in the world, Respondent evidently knew or should have known of the existence of Complainant’s prior trademark rights and domain names, which were matters of public record, before registering the disputed domain names. Other than this, considering Respondent’s documented use of the disputed domain name, which includes the clear intent to create a likelihood of confusion with Complainant
page 5 and their services, Respondent must have had knowledge of Complainant’s pre-existing rights to the MISTRAL AI trademark. The registration of the disputed domain name was carried out by Respondent, who had the responsibility to verify the existence of the referred trademarks. Therefore, considering the use of the disputed domain name, it may be inferred that there is a clear intent to financially benefit off Complainant’s reputation. Panels have held that the use of a domain name for illegal activity (in this case passing off), constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. The bad faith is also noticeable considering that the disputed domain name was registered just a day after Complainant’s OCR services were announced. In addition, the website’s content (i) resembled an identical product; (ii) included highlights of the platform being related to Complainant’s MISTRAL AI trademark; (iii) reproduced the same visual elements; and (iv) utilized the same examples presented by Complainant when its own service was introduced. These elements, summed with the proposal to sell the domain name, demonstrate the intention of financially benefiting from Complainant’s previous rights. Furthermore, in accordance with paragraph 4(b)(i) of the Policy it is an indication of bad faith the fact that Respondent registered the disputed domain name “primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the domain name”. In this case, Respondent offered the disputed domain name for sale to Complainant for USD 500, which is likely more than the cost for obtaining the registration. Respondent tried to justify the amount charged by arguing that it was less than the cost of this proceeding, which in these circumstances is a conduct that also shows bad faith. Therefore, considering all of the above, the Panel finds that the circumstances of the present case allow for a finding of bad faith in the registration and use of the disputed domain name. Based on the available record, the Panel finds that 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 be transferred to the Complainant. /Gabriel F. Leonardos/ Gabriel F. Leonardos Sole Panelist Date: September 8, 2025
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