ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION TELEVISION FRANCAISE 1 v. Bernard Admin and Reagen Dev Case No. D2025-2947 1. The Parties The Complainant is TELEVISION FRANCAISE 1, France, represented by AARPI Scan Avocats, France. The Respondents are Bernard Admin, Ukraine and Reagen Dev, Hong Kong, China. 2. The Domain Names and Registrar The disputed domain names , and are registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 24, 2025. On July 24, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On July 25, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (Unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 25, 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 an amended Complaint on August 4, 2025. 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, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 25, 2025. On August 7, 2025, the Complainant sent a second amended Complaint to the Center and requested the addition of the disputed domain name to the present UDRP proceeding. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on August 26, 2025.
page 2 The Center appointed Pablo A. Palazzi as the sole panelist in this matter on August 29, 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. On September 8, 2025, the Panel issued an Administrative Panel Procedural Order No. 1 (“Panel Order”), in which the Panel invited the Respondents to confirm if they intend to comment on the Complainant’s second amended Complaint, in particular the consolidation request, by September 23, 2025. The Respondents did not submit any comment. 4. Factual Background The Complainant, which was founded in 1974, known as TF1, is one of the European leading companies in the field of production and broadcasting TV programs. In 1987, the Complainant integrated the TF1 Group, which includes several generalist and thematic television channels, including TF1, as well as production and distribution companies for the film and television industries. Since then, it has continuously expanded, both in France and internationally. According to the Complainant, it is considered the most watched television channel in France. The Complainant has further been developing for several years its digital services on its online platforms, notably “MYTF1”, allowing access to replays as well as video-on-demand services. The Complainant carries out its online activities through its official websites, notably located at domain name , registered on December 3, 1995, and , registered on March 24, 2010. The Complainant further owns since April 2, 1998, as well as since March 9, 2006. The Complainant owns numerous trademarks consisting in all or in part of the acronym TF1, both in France and internationally, such as: - International Registration no. 556537 in classes 9, 16, 25, 28, 35, 38, and 41, registered on July 30, 1990; - French trademark no. 1290436 in all classes, registered on November 22, 1984; - French trademark no. 1489724 in all classes, registered on November 30, 1988. The disputed domain names and were both registered on May 28, 2025 and June 10, 2025 respectively. The disputed domain name was registered on August 4, 2025. At the time of filing the complaint, the disputed domain names directed to a slavish reproduction of the Complainant's official website. 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 names. B. Respondent The Respondents did not reply to the Complainant’s contentions.
page 3 6. Discussion and Findings 6.1 Preliminary Matters The Panel notes that the Respondent Bernard Admin is located in Ukraine, which is subject to an international conflict at the date of this decision that may impact case notification. It is appropriate for the Panel to consider, in accordance with its discretion under paragraph 10 of the Rules, whether the proceeding should continue (see Wilshire Refrigeration & Appliance, Inc. v. Oleksandr Kliuiev, Henryslist.com, WIPO Case No. D2024-0962). Having considered all the circumstances of the case, the Panel is of the view that it should. The Panel notes that the Center has used the Respondent’s email address as registered with the Registrar for the purpose of notifying the Complaint. There is no evidence that the case notification email to this email address was not successfully delivered. Furthermore, the Complainant has selected as the mutual jurisdiction the courts at the location of the principal offices of the concerned Registrar, such courts not being subject to an international conflict and thus the Panel finds that proceeding with this Decision does not preempt the Respondent from asserting its rights under paragraph 4(k) of the Policy to submit this dispute to the courts at the applicable mutual jurisdiction. Accordingly, the Panel considers it is able to proceed to determine this Complaint and to draw inferences from the Respondent’s failure to file any Response. 6.2 Addition of domain names following complaint notification A few days after filing the Complaint, the Complainant noticed the registration of the third domain name on August 4, 2025. The Complainant requested the addition of the domain name on August 6, 2025. The Policy and the Rules do not explicitly provide for a Complaint to be amended after the commencement of proceeding to include additional domain names. Accordingly, it is for the Panel to determine whether or not to accept the addition of new domain names to the Complaint and order further procedural steps, if any. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.12.2. In those cases where panels would grant such a request, the complainant would need to hold relevant trademark rights and the proposed additional domain names would need to be prima facie registered by the same or related respondent. Moreover, in the event a panel would grant such a request, it may also order partial or full re-notification of the proceeding (which may impact case timelines). WIPO Overview 3.0, section 4.12.2 The Complaint was originally filed in July 2025 for the first two domain names, then amended on August 6, 2025 to include the third domain name that was registered on August 4, 2025. On August 8, 2025, the Center transmitted by email to the Registrar, a request for registrar verification in connection with the Additional Domain Name. On the same day, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Additional Domain Name. The Panel issued a Procedural Order pursuant to paragraphs 10 and 12 of the Rules, granting the Complainant five days to file an amended Complaint addressing the newly identified registrant details of the Additional Domain Name and the consolidation request, while providing the Respondents fifteen days to comment on any such submission, thereby ensuring equality of treatment and affording each Party a fair opportunity to present its case. The Complainant contends the third domain name should be included as it shares the same registrant, infrastructure, nameservers, naming pattern, fraudulent redirect destination, and represents a continued evasion tactic following enforcement actions against the initial two domain names. The Complainant argues this demonstrates a pattern of systematic trademark infringement by the same
page 4 respondent using the same methods, justifying consolidation into a single proceeding despite the later registration date. The Respondents did not reply to the Complainant’s contentions. The Panel has reviewed the case file and notes that it is fair to add the third domain name (the “Additional Domain Name”) into this proceeding considering the procedural order complied above, and the commonalities of the disputed domain names described in the following section. The Panel notes that after the filing of the Complaint, the Respondents registered this additional domain name that is confusingly similar to its trademark. The timing and circumstances of this registration form part of an obvious pattern of conduct intended to evade or frustrate these proceedings. In the view of the Panel, this constitutes an exceptional circumstance warranting departure from the ordinary procedural framework. In the interests of justice, and to ensure that the Respondent’s conduct is properly addressed, the Panel determines that this additional disputed domain name should be included within the scope of the present case. 6.3 Consolidation: Multiple Respondents The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the domain name registrants are the same entity or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. The disputed domain name registrants did not comment on the Complainant’s request. Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the disputed domain names are registered by the same domain name holder. In addressing the Complainant’s request, the Panel will consider whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview 3.0, section 4.11.2. As regards common control, the Panel notes that the disputed domain names: - share the same Registrar; - share the same hosting provider, namely DigitalOcean masked by the Cloudflare proxy; - were registered in a close time frame; - target the same trademark TF1; - two disputed domain names redirected to the same fraudulent website reproducing the Complainant’s trademarks and official website; - the disputed domain names were registered with identical nameservers and identical proxy hosting provider; - the disputed domain names and share the same structure with the addition of 2025 in the second case; - the “Additional Domain Name” redirects to the same infringing website corresponding to a slavish reproduction of the Complainant's official website; - two of the disputed domain names and share the same name and contact details for the Registrant; - the email addresses provided for the three disputed domain names are constructed in exactly the same way. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party.
page 5 Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding. 6.3 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 trademark and the disputed domain name. WIPO Overview 3.0, section 1.7. The 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 mark is recognizable within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms, here “nouvelle” (news in French language), “info” and “france” and “2025” may bear on assessment of the second and third elements, the Panel finds the addition of such terms 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. 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 names. 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 names such as those enumerated in the Policy or otherwise. Panels have held that the use of a domain name for illegal activity, here, claimed impersonation/passing off can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Panel finds the second element of the Policy has been established.
page 6 C. Registered and Used in Bad Faith The registration of the Complainant’s trademark pre-dates the registration of the disputed domain names by several decades. - The disputed domain names incorporate the Complainant’s trademark in its entirety, with the addition of terms related to the Complainant’s services; - Several UDRP panels have acknowledged the reputation of the TF1 trademark (Télévision Française 1 contre Stanley TAMODARIN, ITBS, WIPO Case No. D2021-3956; Télévision Française 1 v. Host Master, Transure Enterprise Ltd, WIPO Case No. D2022-1121); - As a result, it is inconceivable that the Respondent would not have been aware of the TF1 trademark when it chose to register the disputed domain names incorporating the said trademark with related descriptive terms; - The Respondent is in default; and - The website at the disputed domain names targets the Complainant’s trademark and is evidence of bad faith. The disputed domain names demonstrate registration and use in bad faith pursuant to paragraph 4(b)(iv) of the UDRP Policy. The Respondent has deliberately created fraudulent websites that faithfully reproduce the Complainant's official website “www.tf1info.fr” with the purpose of confusing Internet users and redirecting them for fraudulent purposes. This conduct constitutes an intentional attempt to attract users for commercial gain by creating confusion with the Complainant's trademark. According to the WIPO Overview 3.0, , the use of a domain name confusingly similar to a registered trademark to direct users to a site that fraudulently impersonates the trademark holder's legitimate site constitutes clear evidence of bad faith. 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 names , and be transferred to the Complainant. /Pablo A. Palazzi/ Pablo A. Palazzi Sole Panelist Date: October 2, 2025
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