ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION BNP PARIBAS v. B Peters Case No. D2025-2975 1. The Parties The Complainant is BNP PARIBAS, France, represented by Nameshield, France. The Respondent is B Peters, United Kingdom. 2. The Domain Name and Registrar The disputed domain name (the “Disputed Domain Name”) is registered with Name SRS AB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 25, 2025. On July 25, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On July 28, 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 (Protected Protected, Shield Whois) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 28, 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 July 29, 2025 and a second amended Complaint on August 5, 2025. 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on August 6, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 26, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 27, 2025.
page 2 The Center appointed Monica Novac as the sole panelist in this matter on September 4, 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 BNP PARIBAS, an international banking group with worldwide presence. The Complainant is one of the largest banks in the world and as of December 2024, it has reported EUR 48.8 billion in revenues and EUR 11.7 billion in net profit. The Complainant owns several trademarks for BNP PARIBAS, including the following: - International Trademark Registration No. 728598 BNP PARIBAS (word) registered on February 23, 2000 in classes 35, 36, and 38, designating numerous jurisdictions; - International Trademark Registration No. 745220 BNP PARIBAS (figurative), registered on September 18, 2000 in classes 9, 35, 36, and 38, designating numerous jurisdictions; - International Trademark Registration No. 876031 BNP PARIBAS (word), registered on November 24, 2005 in classes 9, 35, 36, and 38, designating numerous jurisdictions. The Complainant also owns the following domain names: - , registered on September 2, 1999; - , registered on December 29, 1999; and - , registered on July 23, 2008. The Respondent is B Peters, reportedly located in the United Kingdom. The Respondent registered the Disputed Domain Name on July 18, 2025 through a privacy service. According to the information and evidence provided by the Complainant, the Respondent used the Disputed Domain Name to pass itself off as an employee of the Complainant’s London Branch Anti-Fraud team and send deceptive communications via e-mail to a third party. On the dates of filing the Complaint and respectively, of this Decision, the Disputed Domain Name directs to an inactive 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 Name. Notably, the Complainant contends that: - The Disputed Domain Name is confusingly similar to the Complainant’s BNP PARIBAS trademark as it entirely contains said trademark. The misspelling in the Disputed Domain Name (i.e. the addition of the letter “a”) is not sufficient to prevent the finding of its confusing similarity with the BNP PARIBAS trademark. The Complainant states that the obvious misspelling of its BNP PARIBAS trademark within the Disputed Domain Name is a clear case of typosquatting. Lastly, the Complainant asserts that the addition of the generic Top-Level Domain (“gTLD”) “.com” does not prevent the likelihood of confusion between the Disputed Domain Name and the Complainant, its trademarks and its associated domain names.
page 3 - the Respondent has no rights or legitimate interests in the Disputed Domain Name. The Complainant states that the Respondent is not identified in the WhoIs database as the Disputed Domain Name, but as “B Peters”, and “past panels have held that a respondent was not commonly known by a disputed domain name if the WhoIs information was not similar to the disputed domain name”. The Complainant contends that the Respondent is not affiliated or authorized by the Complainant in any way and that the Complainant did not grant any license or authorization to the Respondent to make use of the Complainant’s trademarks or to register the Disputed Domain Name. Additionally, the Complainant claims that the Disputed Domain Name is a typosquatted version of the Complainant’s BNP PARIBAS trademark which can prove the Respondent’s lack of rights and legitimate interests in the Disputed Domain Name. Lastly, the Complainant points out that the Disputed Domain Name leads to an inactive webpage and it has been used in phishing schemes, such usage being neither a bona fide offering of goods or services, nor a noncommercial or fair use as per the Policy. - the Disputed Domain Name has been registered and it is being used in bad faith. The Complainant states that in previous UDRP cases (see, for example, BNP Paribas v. Ronan Laster, WIPO Case No. D2017-2167), the BNP PARIBAS trademark has been found to be well known. In the Complainant’s view, the Respondent was aware of the Complainant’s trademark due to its well-known character, and the registration of the Disputed Domain Name was therefore made in bad faith. The Complainant claims that the misspelling of the BNP PARIBAS trademark within the Disputed Domain Name was aimed at creating confusion with the Complainant’s trademark and “previous UDRP panels have seen such actions as evidence of bad faith”. Moreover, the Respondent’s use of the Disputed Domain Name for sending phishing emails to a third party is evidence of bad faith use. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, a complainant to succeed must satisfy the panel that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which complainant has rights; and (ii) the respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name was registered and is being used in bad faith. 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 Selected UDRP Questions, Third Edition, (“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 that the Complainant’s BNP PARIBAS mark is recognizable within the Disputed Domain Name. The only difference between the Complainant’s trademark and the Disputed Domain Name is the addition of the letter “a” in the Disputed Domain Name, which is an obvious misspelling of the Complainant's mark. This is a practice known as typosquatting. UDRP panels held that a domain name which consists of a common, obvious, or intentional misspelling of a trademark is considered to be confusingly similar to the relevant mark for purposes of the first element of the Policy. WIPO Overview 3.0, section 1.9.
page 4 According to the WIPO Overview 3.0, section 1.11.1, the gTLD “.com” in the Disputed Domain Name is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. Further to all the above, 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. It is accepted by the Panel that the Respondent is not related to the Complainant in any way and that the Complainant has not licensed nor authorized the Respondent to use the Complainant’s trademark or to apply for the registration of the Disputed Domain Name. There is also no evidence that the Respondent is commonly known by the Disputed Domain Name. The Disputed Domain Name is a typosquatted version of the Complainant’s BNP PARIBAS trademark which reflects the Respondent’s ultimate intent to confuse Internet users into believing that the Disputed Domain Name is operated or associated with the Complainant. In this sense, it has been established that “respondent’s use of a domain name will not be considered “fair” if it falsely suggests affiliation with the trademark owner; the correlation between a domain name and the complainant’s mark is often central to this inquiry”. WIPO Overview 3.0, section 2.5. On the dates of filing the Complaint and respectively, of this Decision, the Disputed Domain Name directs to an inactive website. However, the Disputed Domain Name was used in a phishing scheme, where the Respondent, pretending to be an employee of the Complainant’s London Branch Anti-Fraud team, used the email address “[...]@bnpparibaas.com” (which is similar to the real and official one “[...]@bnpparibas.com”) to send deceiving communications to a third party. The Respondent’s use of the Disputed Domain Name for illegal activities (e.g. phishing, impersonation/passing off or other types of fraud) does not confer rights or legitimate interests to the Respondent. WIPO Overview 3.0, section 2.13.1. The Respondent did not respond to the Complainant’s contentions, thus the Respondent did not present any evidence for supporting any rights or legitimate interests in the Disputed Domain Name. Further to all the above, the Panel finds the second element of the Policy has been established.
page 5 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. 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 be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1. In the present case, the Panel notes that the Complainant registered and used its BNP PARIBAS trademark long before the Respondent registered the Disputed Domain Name. In view of the reputation of the Complainant, the recognition and well-known character of its trademark and the composition of the Disputed Domain Name, it is unlikely that the Respondent was not aware of the Complainant’s trademark and business when registering the Disputed Domain Name. The Panel considers that the Respondent’s registration of the Disputed Domain Name which is a typosquatted variation of the Complainant’s trademark signals an intention on the part of the Respondent to confuse users seeking or expecting the Complainant and it is a clear proof of the Respondent’s bad faith. In view of the nature of the Disputed Domain Name which is a typosquatted version of the Complainant’s BNP PARIBAS trademark, the Panel considers that the Respondent targeted the Complainant when registering the Disputed Domain Name. The evidence filed in this case shows that the Respondent, pretending to be an employee of the Complainant’s London Branch Anti-Fraud team, used the e-mail address “[...]@bnpparibaas.com” to send deceiving communications to a third party. The Panel considers that the Respondent’s acts mislead the recipient into believing that the communication originates from the Complainant or is endorsed by the Complainant, especially as the sender’s electronic signature also contains the Complainant’s logo, as well as its real and official e-mail address “[...]@bnpparibas.com”. The Panel is of the opinion that the Respondent’s use of the Disputed Domain Name in connection to the above illegitimate activities (i.e. phishing, impersonation) constitutes bad faith. WIPO Overview 3.0, section 3.4. Finally, the Respondent hid its identity when registering the Disputed Domain Name by using a privacy shield service. As per WIPO Overview 3.0, section 3.6, there are recognized legitimate uses of privacy and proxy registration services; the circumstances in which such services are used, including whether the respondent is operating a commercial and trademark-abusive website, can impact a panel’s assessment of bad faith. The Panel is of the opinion that in view of all circumstances of this case, the Respondent’s use of privacy service constitutes further evidence of bad faith registration and use of the Disputed Domain Name. Further to all the above, 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 be transferred to the Complainant. /Monica Novac/ Monica Novac Sole Panelist Date: September 15, 2025
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