ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Television Française 1 v. Tay Du Ki and JAY SON, JAY SON COMPANY Case No. D2025-4028 1. The Parties The Complainant is Television Française 1, France, represented by AARPI Scan Avocats, France. The Respondents are Tay Du Ki, Viet Nam, and JAY SON, JAY SON COMPANY, Viet Nam. 2. The Domain Names and Registrars The disputed domain name is registered with NameCheap, Inc. The disputed domain name is registered with Dynadot Inc (hereinafter collectively the “Registrars”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 1, 2025. On October 2, 2025, the Center transmitted by email to the Registrars requests for registrar verification in connection with the disputed domain names. On October 3 and October 4, 2025, the Registrars transmitted by email to the Center their verification responses, disclosing registrant and contact information for the disputed domain names which differed from the named Respondents (Unknown / Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf, and REDACTED FOR PRIVACY (DT), Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 6, 2025 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on October 6, 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 Respondents of the Complaint, and the proceedings commenced on October 10, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 30, 2025. The Respondents did not submit any response.
page 2 Accordingly, the Center notified the Respondents’ default on October 31, 2025. The Center appointed Emre Kerim Yardimci as the sole panelist in this matter on November 10, 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 operates in the field of production and broadcasting TV programs in Europe. 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. The Complainant is using “MYTF1” platform, 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 the following domain names: - registered on December 3, 1995; and - registered on March 24, 2010. The Complainant further owns following domain names: - since April 2, 1998; and - since March 9, 2006. The Complainant owns numerous trademarks consisting of TF1 such as: - MY TF1, French semi-figurative trademark filed on June 5, 2019, and registered on November 15, 2019 under No. 4557291 in classes 9, 16, 35, 38, 41, and 42; - MY TF1, French word trademark filed on April 1, 2009, and registered on September 4, 2009 under No. 3640969 in classes 9, 16, 35, 38, 41, and 42; - TF1, International Trademark No. 556537 in classes 9, 16, 25, 28, 35, 38, and 41, registered on July 30, 1990; - TF1, French trademark No. 1290436 in classes 1 – 42, registered on November 22, 1984; and - TF1, French trademark No. 1489724 in classes 1 – 45, registered on March 10, 1989. The Respondents registered the disputed domain names on September 11 and September 25, 2025. The disputed domain names resolve to websites written in French with a similar layout, reproducing the Complainant’s trademarks. They offer a “guide” to watching the Complainant’s television content online and replay TV services and contain a link to a third-party streaming website. The bottom of the website associated with the disputed domain name reads: “Find us also on: mytf1.online”. 5. Parties’ Contentions A. Complainant The Complainant asserts that the disputed domain names are identical the Complainant’s trademark MYTF1. The Complainant considers that the Respondents have no rights or legitimate interests in respect of the disputed domain names, mainly because the Complainant has neither licensed nor otherwise authorized the
page 3 Respondents to use its trademarks or to apply for or use any domain name incorporating the trademarks of the Complainant and the Respondents do not appear to be known by the disputed domain names. Instead, the Respondents have registered the disputed domain names utilizing a privacy-shielding service to redirect Internet traffic to a website that provides competing illegal streaming services to the Complainant’s services. The Complainant contends that the Respondents have registered and are using the disputed domain names in bad faith. It is clear that the Respondents were aware of the rights the Complainant has in the trademark at the time of the registration of the disputed domain names. The Complainant claims that the Respondents are using the disputed domain names by impersonating the Complainant and redirecting to illegal streaming services with the aim to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s trademarks and for the purpose of disrupting the Complainant’s business and targeting the Complainant’s trademarks. The Respondents also have hidden their identity by providing false and inaccurate WhoIs information. B. Respondents The Respondents did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1. Preliminary Issue – 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 disputes against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. The Complainant argues that the disputed domain names are under common control, inter alia, as they were registered with identical nameservers and identical proxy hosting provider within a few days of each other and resolve to almost identical websites in French reproducing the Complainant’s trademarks and containing a link to the same competing streaming service. 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 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 of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.11.2. As regards common control, the Panel notes that, in addition to the above, the bottom of the website associated with the disputed domain name reads “Find us also on: mytf1.online”, which further supports a finding that the disputed domain names are under common control. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party. 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.
page 4 6.2. Substantive Issues Pursuant to paragraph 4(a) of the Policy, the Complainant is required to prove the presence of each of the following three elements to obtain the remedy it has requested: (i) the disputed 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 respect of the disputed domain names; and (iii) the disputed domain names have been registered and are 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 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 disputed domain names incorporate the Complainant’s TF1 and MYTF1 trademarks in their entirety. As regards the generic Top-Level Domain (“gTLD”), it is typically disregarded under the confusing similarity test. For the reasons mentioned above, the Panel finds that the disputed domain names are identical to the Complainant’s MYTF1 trademark. 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.
page 5 The Panel finds that the use of a domain name for illegal activity, here, claimed as 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. C. Registered and Used in Bad Faith The Panel accepts the Complainant’s assertions that the trademarks TF1 and MY TF1s are well-known trademarks. The incorporation of a well-known trademark into a domain name by a registrant having no legitimate reason for doing so, can, in and of itself, create a presumption of bad faith. As the Complainant submits, it is inconceivable that the Respondent would not have known of the Complainant’s mark giving that the disputed domain names resolve to websites which the Respondent is using for offering a service for watching the Complainant’s content online and replay service alternative to the Complainant’s MYTF1 platform. It is clear that the Respondent has targeted the Complainant and their trademark to benefit from its own commercial activities. Moreover, Panel holds that the use of the disputed domain names for illegal activities, such as claimed in the present case impersonation/passing off, constitutes use in bad faith. WIPO Overview 3.0, section 3.4. The Panel holds that by using the disputed domain names, the Respondent intentionally attempted to attract, for commercial gain, Internet users to its websites, by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of its websites in the sense of Policy, paragraph 4(b)(iv). Based on the evidence submitted with the Complaint, it is unequivocally clear that the Respondent was well aware of the Complainant’s trademarks and its activity. Considering all above facts, there is no doubt that the Respondent had the Complainant’s trademarks in mind when registering and using the disputed domain names. Therefore, the Panel is convinced that the Respondent has registered and is using the disputed domain names in bad faith. 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. /Emre Kerim Yardimci/ Emre Kerim Yardimci Sole Panelist Date: November 24, 2025
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