ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Vinci Construction v. Julia Eirout Case No. D2025-3804 1. The Parties The Complainant is Vinci Construction, France, represented by Cabinet Regimbeau, France. The Respondent is Julia Eirout, United Kingdom. 2. The Domain Name and Registrar The disputed domain name is registered with Squarespace Domains LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 18, 2025. On September 19, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 19, 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 September 23, 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 24, 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 25, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 15, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 17, 2025. The Center appointed Luca Barbero as the sole panelist in this matter on October 24, 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, which was formerly known as Eurovia, is a global leader in the construction sector, with expertise mainly concentrated in three specific fields: i) infrastructure dedicated to water (water and wastewater treatment plants), energy (solar and wind farms, hydroelectric facilities) and mobility (railroad lines, bicycle paths, etc.); ii) construction and renovation of buildings, and more generally, support for public and private-sector entities in relation to urban development and regeneration; and iii) civil engineering structures, such as bridges, tunnels, dams and major industrial facilities. The Complainant currently comprises 1,300 companies and 119,000 employees spread across over 100 countries around the world and works on over 69,000 construction sites every year. The Complainant is the owner of numerous trademark registrations for EUROVIA, including the following: - International trademark registration No. 675408 for EUROVIA (word mark), registered on April 21, 1997, in classes 2, 4, 19, 35, 36, 37, 40 and 42; - International trademark registration No. 521073 for EUROVIA (word mark), registered on February 16, 1998, in classes 2, 4, 19, 37, 40 and 42; - French trademark registration No. 1439722 for EUROVIA (word mark), filed on October 21, 1987, and registered on May 13, 1988, in classes 2, 4, 19, 37, 40 and 42; - French trademark registration No. 96646529 for EUROVIA (word mark), filed on October 17, 1996, and registered on March 28, 1997, in classes 35, 36, 42 and 45; - French trademark registration No. 96647986 for EUROVIA (word mark), filed on October 25, 1996, and registered on April 4, 1997, in classes 2, 4, 19, 35, 36, 37, 40, 42, 45. The Complainant is also the owner of numerous domain names encompassing EUROVIA, including , registered on February 25, 1998, and registered on August 26, 1998, both redirected to the Complainant’s website “www.eurovia.fr”, used by the Complainant to promote its services under the trademark EUROVIA. The disputed domain name was registered on August 13, 2025, and is pointed to a registrar parking page indicating that the website is under construction. 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 nearly identical, and confusingly similar, to the trademark EUROVIA in which the Complainant has rights as it reproduces the trademark in its entirety with the mere difference that the letter “u” is substituted by the letter “i” and the addition of the generic Top-Level Domain (“gTLD”) “.com”. The Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name since: i) the Respondent has no connection with the Complainant in any way, is not an authorized dealer, distributor or licensee of the Complainant, nor has it been permitted by the Complainant to make use of its trademark; ii) the Respondent has no prior rights nor is the Respondent commonly known as Eirovia or Eurovia; iii) the EUROVIA mark is highly distinctive and has been extensively
page 3 used by the Complainant, as a company name and as a trademark in relation to construction and civil engineering, not only in France but across the whole world, for the past 40 years; and iv) the use of the disputed domain name in connection with a website under construction cannot be considered as use in connection with a bona fide offer of goods or services or a legitimate non-commercial or fair use. With reference to the circumstances evidencing bad faith, the Complainant indicates that given its worldwide reputation and the ubiquitous presence of the EUROVIA marks on the Internet, the Respondent was or should have been aware of such mark at the time of registration of the disputed domain name. Additionally, the Complainant contends that the disputed domain name almost identically reproduces the trademark EUROVIA, with only the letter “u” being changed into an “i” and submits that in view of the Complainant’s worldwide presence, it seems unlikely that this registration by the Respondent is the result of chance and not an informed choice, especially considering that a simple Google search on “eirovia” would have yielded results related to the Complainant’s existence, reputation and prior rights. As to the use of the disputed domain name, the Complainant states that, since the Respondent redirected the disputed domain name to a webpage under construction operated by the Registrar, the Respondent is deliberately attempting to attract Internet users familiar with the Complainant’s marks on its own website by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation or endorsement of the website. The Complainant further submits that the circumstance that the Respondent concealed its identity via a privacy service when registering the disputed domain name and the fact that the registration constitutes typosquatting further demonstrate the Respondent’s bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to paragraph 15(a) of the Rules: “A Panel shall decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable.” Paragraph 4(a) of the Policy directs that the Complainant must prove each of the following: (i) that the disputed domain name registered by the Respondent is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been 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. Indeed, the Complainant has provided evidence of ownership of valid trademark registrations for EUROVIA.
page 4 The Panel finds the mark is recognizable within the disputed domain name, as it is entirely reproduced in the disputed domain name with the mere substitution of the letter “u” of the mark with the letter “i”. WIPO Overview 3.0, section 1.7. A domain name which consists of a common, obvious, or intentional misspelling of a trademark is considered by panels to be confusingly similar to the relevant mark for purposes of the first element. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.9. The applicable TLD in a domain name, such as the gTLD “.com” in this case, is viewed as a standard registration requirement and is thus disregarded under the first element confusing similarity test. WIPO Overview 3.0, section 1.11.1. Therefore, 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 Panel notes that there is no relation, disclosed to the Panel or otherwise apparent from the record, between the Respondent and the Complainant. The Respondent is not affiliated to, or licensed by, the Complainant, nor has the Respondent obtained authorization to use the Complainant’s trademark or to register the disputed domain name. Moreover, there is no element from which the Panel could infer the Respondent’s rights over the disputed domain name, or that the Respondent might be commonly known by the disputed domain name. Furthermore, the disputed domain name resolves to a webpage indicating that the website is under construction and, based on the records, there is no evidence of use of the disputed domain name in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use without intent for commercial gain to misleadingly divert consumers or to tarnish the Complainant’s trademark. Therefore, the Panel finds the second element of the Policy has also 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.
page 5 In the present case, in view of the Complainant’s prior registration and use of the trademark EUROVIA in connection with the Complainant’s construction services in the fields of infrastructure, building construction and renovation and civil engineering, provided in several countries of the world and promoted online, amongst others, via the Complainant’s website “www.eurovia.fr”, and considering even a cursory online search for “eirovia” would have revealed the presence of the Complainant’s well-known trademark, the Panel finds that the Respondent knew or should have known the Complainant’s trademark at the time of registration of the disputed domain name. WIPO Overview 3.0, section 3.2.2. Moreover, the composition of the disputed domain name, which appears to be a clear case of typosquatting of the Complainant’s EUROVIA mark and its domain name , supports the conclusion that the Respondent registered the disputed domain name to target the Complainant and its trademark. As indicated above, the disputed domain name resolves to a Registrar parking page indicating that the website is under construction. Panels have found that the non-use of a domain name (including coming soon pages) would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness of the Complainant’s trademark, the composition of the disputed domain name, the Respondent’s failure to submit a response to provide any evidence of actual or contemplated good-faith use, and the implausibility of any good faith use to which the disputed domain name may be put, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Therefore, the Panel finds that the Complainant has established the third element of the Policy as well. 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. /Luca Barbero/ Luca Barbero Sole Panelist Date: November 7, 2025
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