ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Manufacture Jean Rousseau v. Jacob Bredin Case No. D2025-3645 1. The Parties The Complainant is Manufacture Jean Rousseau, France, represented by Novagraaf France, France. The Respondent is Jacob Bredin, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 9, 2025. On September 9, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 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 (Unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 17, 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 September 19, 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 September 22, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 12, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 14, 2025. The Center appointed Jeremy Speres as the sole panelist in this matter on October 17, 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.
page 2 4. Factual Background The Complainant has traded under the JEAN ROUSSEAU mark since the early 1950s in relation to luxury watch straps and leather goods. It has retail stores in France, England, the United States, and Japan, and also trades through its website hosted at its domain name , which the Complainant has owned and used since 2000. The Complainant’s annual turnover is roughly EUR 30 million, having a total staff compliment of around 400 employees. In addition to JEAN ROUSSEAU, the Complainant also trades under the ATELIER JEAN ROUSSEAU mark in France, England, the United States, and Japan. The Complainant’s marks are registered in various jurisdictions, including International Trademark Registration No. 1111160 ATELIER JEAN ROUSSEAU in class 35, having a registration date of February 1, 2012, designating the United States amongst others. The disputed domain name was registered on April 9, 2025, and currently resolves to a website entitled “Shopify – This store does not exist.” 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 was registered and has been used in bad faith in order to take advantage of confusion with the Complainant’s marks. 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 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 the mark is recognizable within the disputed domain name. While each case is judged on its own merits, in cases where at least a dominant feature of the relevant mark is recognizable within the domain name, the domain name will normally be considered confusingly similar to that mark for purposes of UDRP standing. Here, the two dominant features of the Complainant’s ATELIER JEAN ROUSSEAU mark, being ATELIER and ROUSSEAU, are incorporated 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. The Panel finds the first element of the Policy has been established.
page 3 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. For the reasons discussed in relation to bad faith below, it is likely that the Respondent registered the disputed domain name to take advantage of confusion with the Complainant’s mark. The Respondent’s registration and use of the disputed domain name in these circumstances cannot represent a bona fide offering of goods or services under paragraph 4(c)(i) of the Policy and cannot confer rights or legitimate interests. Sistema de Ensino Poliedro Vestibulares Ltda., Editora Poliedro Ltda. v. Anonymize, Inc. / STANLEY PACE, WIPO Case No. D2022-1981. 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. For the following reasons, the Panel finds that it is more likely than not that the Respondent registered and has used the disputed domain name to take advantage of confusion with the Complainant’s mark for the Respondent’s commercial gain, falling squarely within paragraph 4(b)(iv) of the Policy. The Complainant has used its marks for luxury leather goods since the 1950s. Internet searches for the Complainant’s marks overwhelmingly return results relating to the Complainant1. The Panel therefore accepts that the Complainant enjoys a reputation in its marks, at least within the leather and luxury goods markets. The Panel has independently established, through viewing the Internet Archive records for the disputed domain name, that it has been used for a website offering, amongst others, leather clothing and leather footwear under the name “L'Atelier de Rousseau”. The website claims that the business is based in Paris. Given the Complainant’s reputation within the leather goods market, the fact that the Respondent has adopted the dominant parts of the Complainant’s marks - ATELIER and ROUSSEAU - and the fact that the Complainant is strongly associated with Paris, it is likely that users would assume some connection with the 1In accordance with its powers articulated inter alia in paragraphs 10 and 12 of the Rules, the Panel is entitled to conduct limited independent research into matters of public record. WIPO Overview 3.0, section 4.8.
page 4 Complainant. This is supported by the fact that Internet searches for the second-level portion of the disputed domain name - “rousseau-atelier” - as well as for “L'Atelier de Rousseau” return results largely relating to the Complainant. It is unlikely that the Respondent was not aware of this risk, given its operation in the leather goods market and the Complainant’s presence within the Respondent’s country of the United States. At least, the Respondent should have known of this risk in these circumstances. WIPO Overview 3.0, section 3.2.2. The Panel draws an adverse inference from the Respondent’s failure to take part in the present proceeding where an explanation is certainly called for. WIPO Overview 3.0, section 4.3. 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. /Jeremy Speres/ Jeremy Speres Sole Panelist Date: October 24, 2025
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