ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Paco Rabanne v. John Doe Case No. D2025-3872 1. The Parties The Complainant is Paco Rabanne, France, represented by Zacco Sweden AB, Sweden. The Respondent is John Doe, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain names , , , , , and (collectively referred to as the “Domain Names”) are registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 23, 2025. On September 24, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Names. On September 24, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Names which differed from the named Respondent (Privacy User #43335052, PrivacyGuardian.org) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 26, 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 the same date. 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 October 7, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 27, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 28, 2025.
page 2 The Center appointed Piotr Nowaczyk as the sole panelist in this matter on October 31, 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 a French luxury fashion house established in 1966 by designer Paco Rabanne. In 1986, it was acquired by the company group Antonio Puig S.A. (“Puig”). Puig is a global company in the clothing, fashion, fragrances, and skincare sector. It employs over 12,100 people worldwide and sells its products in more than 150 countries. The Complainant is the owner of numerous RABANNE trademark registrations, including: - the International Trademark Registration for RABANNE (word) No. 1664553, registered on December 27, 2021; - the European Union Trade Mark Registration for RABANNE (word) No. 010039105, registered on October 19, 2011; and - the Chinese Trademark Registration for RABANNE No. 66345478, registered on May 7, 2023. The Complainant also owns the domain name which incorporates its RABANNE trademark. The Domain Names were registered on May 7, 2025. On September 12, 2025, the Complainant sent a cease-and-desist letter to the Respondent, requesting the transfer of the Domain Names. No response was received from the Respondent. At the time of filing the Complaint, the Domain Names resolved to websites displaying pay-per-click (“PPC”) links related to the Complainant’s products, as well as links to competing brands (the “Websites”). As of the date of this Decision, the Domain Names do not resolve to any active websites. 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 Domain Names. First, the Complainant contends that the Domain Names are confusingly similar to the RABANNE trademark in which the Complainant has rights. Second, the Complainant argues that the Respondent has neither rights nor legitimate interests in the Domain Names. Third, the Complainant submits that the Domain Names were registered and are being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions.
page 3 6. Discussion and Findings Paragraph 4(a) of the Policy places a burden on the Complainant to prove the presence of three separate elements, which can be summarized as follows: (i) the Domain Names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in the Domain Names; and (iii) the Domain Names have been registered and are being used in bad faith. The requested remedy may only be granted if the above criteria are met. At the outset, the Panel notes that the applicable standard of proof in UDRP cases is the “balance of probabilities” or “preponderance of the evidence”. See section 4.2 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”). A. Identical or Confusingly Similar Under the first element, the Complainant must establish that the Domain Names are identical or confusingly similar to the trademark in which the Complainant has rights. The Complainant holds valid registrations for the RABANNE trademark. The Domain Names incorporate this trademark in its entirety. As numerous UDRP panels have held, incorporating a trademark in its entirety is sufficient to establish that a domain name is identical or confusingly similar to that trademark (see PepsiCo, Inc. v. PEPSI, SRL (a/k/a P.E.P.S.I.) and EMS COMPUTER INDUSTRY (a/k/a EMS), WIPO Case No. D2003-0696). The addition of the terms “-ecommerce”, “-fashions”, “-marketplace”, “-productcollection”, “-productlisting” and “-remote” in the Domain Names does not prevent a finding of confusing similarity between the Domain Names and the RABANNE trademark. Panels have consistently held that where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element. See section 1.8 of the WIPO Overview 3.0. The generic Top-Level Domain “.com” in the Domain Names is viewed as a standard registration requirement and as such is typically disregarded under the first element test. See section 1.11.1 of the WIPO Overview 3.0. Given the above, the Panel finds that the Domain Names are confusingly similar to the Complainant’s RABANNE trademark for purposes of the Policy. In sum, the Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Under the second element, the Complainant must prove that the Respondent has no rights or legitimate interests in the Domain Names. A right or legitimate interest in the Domain Names may be established, in accordance with paragraph 4(c) of the Policy, if the Panel finds any of the following circumstances: (i) that the Respondent has used or made preparations to use the Domain Names or a name corresponding to the Domain Names in connection with a bona fide offering of goods or services prior to the dispute; or
page 4 (ii) that the Respondent is commonly known by the Domain Names, even if the Respondent has not acquired any trademark rights; or (iii) that the Respondent is making a legitimate noncommercial or fair use of the Domain Names without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark. In the present case, the Complainant’s RABANNE trademark registrations predate the Respondent’s registration of the Domain Names. There is no evidence in the case record that the Complainant has licensed or otherwise permitted the Respondent to use the RABANNE trademark or to register the Domain Names incorporating this trademark. Moreover, it results from the evidence on record that the Respondent does not make use of the Domain Names in connection with a bona fide offering of goods or services, nor does it make a legitimate noncommercial or fair use of the Domain Names. At the time the Complaint was submitted, the Domain Names resolved to the Websites displaying PPC links. While specific case factors have led previous panels to find that fair use need not always be categorically noncommercial in nature, unambiguous evidence that the site is not primarily intended for commercial gain, e.g., the absence of commercial or PPC links, would tend to indicate a lack of intent to unfairly profit from the complainant’s reputation. See section 2.5.3, WIPO Overview 3.0. In the present case, the Domain Names resolved to websites hosting PPC sponsored links related to the Complainant’s products, as well as to competing brands. These links allow the Respondent to profit from the attracted web traffic and collect click-through revenue. Such use demonstrates that the Respondent has used the Domain Names to derive a commercial benefit. Given the above, there are no circumstances in evidence which could demonstrate, pursuant to paragraph 4(c) of the Policy, any rights or legitimate interests of the Respondent in respect of the Domain Names. Thus, there is no evidence in the case record that refutes the Complainant’s prima facie case. In sum, the Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith Under the third element, the Complainant must prove that the Domain Names have been registered and are being used in bad faith. Bad faith under the UDRP is broadly understood to occur where a respondent takes unfair advantage of or otherwise abuses a complainant’s mark. See section 3.1 of the WIPO Overview 3.0. Under paragraph 4(b) of the Policy, evidence of bad faith registration and use includes, without limitation: (i) circumstances indicating the domain name was registered or acquired primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the owner of a trademark or to a competitor of the trademark owner, for valuable consideration in excess of the documented out-of-pocket costs directly related to the domain name; or (ii) circumstances indicating that the domain name was registered in order to prevent the owner of a trademark from reflecting the mark in a corresponding domain name, provided it is a pattern of such conduct; or (iii) circumstances indicating that the domain name was registered primarily for the purpose of disrupting the business of a competitor; or
page 5 (iv) circumstances indicating that the domain name has intentionally been used in an attempt to attract, for commercial gain, Internet users to a website or other online location, by creating a likelihood of confusion with a trademark as to the source, sponsorship, affiliation, or endorsement of the website or location or of a product or service on a website or location. As indicated above, the Complainant’s rights in the RABANNE trademark predate the registration of the Domain Names. This Panel finds that the Respondent was or should have been aware of the Complainant’s trademark at the time of registration. This finding is supported by the inclusion of the RABANNE trademark in the Domain Names, as well as their subsequent use for the Websites displaying PPC links referring to the Complainant’s products and those of its competitors. Moreover, it has been proven to the Panel’s satisfaction that the Complainant’s RABANNE trademark is well-known and unique to the Complainant, at least within the fashion industry. Thus, the Respondent could not reasonably ignore the reputation of goods under this trademark. In sum, the Respondent registered the Domain Name with the expectation of taking advantage of the reputation of the Complainant’s RABANNE trademark. Furthermore, at the time of submitting the Complaint, the Domain Names were used by the Respondent to attract Internet users to the parking pages featuring PPC links, including those related to the Complainant’s competitors, which is a clear indicator of the Respondent’s bad faith. With respect to “automatically” generated PPC links, panels have held that a respondent cannot disclaim responsibility for content appearing on the website associated with its domain name. Neither the fact that such links are generated by a third party such as a registrar or auction platform (or their affiliate), nor the fact that the respondent itself may not have directly profited, would by itself prevent a finding of bad faith. See section 3.5, WIPO Overview 3.0. Finally, the Respondent’s failure to reply to the Complainant’s cease-and-desist letter dated September 12, 2025, constitutes further evidence of bad faith. For the reasons discussed above, the Panel finds the third element of the Policy has been established. 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 Domain Names , , , , , and be transferred to the Complainant. /Piotr Nowaczyk/ Piotr Nowaczyk Sole Panelist Date: November 12, 2025
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