ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION L’Oréal v. Alexandru Draghici, Petrisor Calusaru and Name Redacted Case No. DRO2025-0010 1. The Parties The Complainant is L’Oréal, France, represented by Dreyfus & associés, France. The Respondents are Alexandru Draghici, Romania, Petrisor Calusaru, Romania, and Name Redacted1. 2. The Domain Names and Registry The Disputed Domain Names , and are registered with ROTLD (the “Registry”). 3. Procedural History The Complaint against the Disputed Domain Name was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on September 24, 2025. On September 25, 2025, the Center transmitted by email to the Registry a request for registry verification in connection with this Disputed Domain Name. On September 26, 2025, the Registry transmitted by email to the Center its verification response disclosing registrant and contact information for this Disputed Domain Name which differed from the named Respondent (Private Person) 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 Registry, and inviting the Complainant to submit an amendment to the Complaint. On the same date, the Center also informed the parties in Romanian and English, that the language of the registration agreement for this Disputed Domain Name is Romanian. On September 29, 2025, the Complainant filed an amended Complaint and also confirmed its request that English be the language of the proceeding. 1 The Respondent appears to have used the name of a third-party when registering the disputed domain name . In light of the potential identity theft, the Panel has redacted the Respondent’s name from this Decision. However, the Panel has attached as Annex 1 to this decision an instruction to the Registry regarding transfer of the disputed domain name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registry as part of the order in this proceeding and has indicated Annex 1 to this decision shall not be published due to the exceptional circumstances of this case.
page 2 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 in English and Romanian of the Complaint, and the proceedings commenced on September 30, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 20, 2025. The Center received a submission via email on October 8, 2025, from a third-party claiming identity theft. On the same date, the Complainant requested the Center the suspension of the proceeding. On October 9, 2025, the Center sent an email communication to the Parties in English and Romanian informing that the proceeding is suspended until November 9, 2025. The Complainant requested the Center on October 17, 2025, to reinstitute the proceeding. On the same date, the Center communicated (in English and Romanian) the reinstitution of the proceeding to both Parties. On October 29, 2025, the Complainant submitted a supplemental filing, requesting the addition of the Disputed Domain Name to the Complaint and the consolidation of this new domain name to the ongoing dispute. On November 5, 2025, the Complainant submitted another supplemental filing, requesting the addition of the Disputed Domain Name to the Complaint and the consolidation of this new domain name to the ongoing dispute. The Center appointed Monica Novac as the sole panelist in this matter on November 7, 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. In order to decide on the two consolidation requests, the Panel considered suitable to proceed to a registry verification in connection with the Disputed Domain Names and . On November 11, 2025, the Center transmitted by email to the Registry a request for registry verification in connection with these Disputed Domain Names. On November 11, 2025, the Registry transmitted by email to the Center its verification response disclosing registrants and contact information for these Disputed Domain Names which differed from the named Respondents (Private Persons) and contact information in the two supplemental filings submitted by the Complainant. The Registry also informed that the language of the registration agreement for these two additional Disputed Domain Names is Romanian. Further to the revealed information, on November 14, 2025, the Panel issued the Procedural Order No. 1 granting the request for consolidation and inviting the Complainant to submit the corresponding amendment to the Complaint by November 19, 2025, respectively inviting the Respondents to submit their comments by November 24, 2025. On November 17, 2025, the Complainant filed the amended Complaint. The Respondents did not comment on the Complainant’s submission. 4. Factual Background The Complainant is a French industrial group specialized in the field of cosmetics and beauty. Being the first cosmetics group worldwide, the Complainant has 21 research centers and it operates in 150 countries through 36 brands and 86,000 employees. Since 1997, the Complainant is also present in Romania (where the Respondents are apparently located), being one of the leading companies on the beauty market, with a portfolio of 20 brands.
page 3 The Complainant owns several L’ORÉAL trademarks worldwide, including the following: - International Trademark Registration No. 230114 , registered on March 28, 1960, in classes 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33 and 34, designating numerous jurisdictions, including Romania; and - European Union Trademark Registration No. 018217416 L'OREAL (word), registered on July 14, 2020, in classes 3 and 5. Previous UDRP panels have already recognized the well-known character of the L’ORÉAL trademarks. The Complainant and its Romanian affiliate company L’OREAL România SRL also hold the following domain names which are used in connection to the Complainant’s business activities: - , registered on October 24, 1997; and - , registered before 2001. The Disputed Domain Name was registered on June 30, 2025. On the date of filing the Complaint, this Disputed Domain Name resolved to an authentication webpage reproducing the Complainant’s name and trademark/logo. At the date of rendering this Decision, when accessed by the Panel, this Disputed Domain Name resolves to an inactive website. The Respondent Alexandru Draghici, apparently located in Romania, registered the Disputed Domain Name on April 28, 2025. At the date of rendering this Decision, this Disputed Domain Name resolves to an inactive website. However, as per the evidence filed by the Complainant, it seems that in the past, this Disputed Domain Name was actively used in a fraudulent job offering scheme, where selected candidates were invited to access the webpage at in order to be granted access to a free training supposedly organized by the Complainant. The Respondent Petrisor Calusaru, apparently located in Romania, registered the Disputed Domain Name on October 27, 2025. At least until the beginning of November 2025, this Disputed Domain Name resolved to an authentication webpage reproducing the Complainant’s name and trademark/logo. However, at the date of rendering this Decision, when accessed by the Panel, this Disputed Domain Name resolves 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 Names. Notably, the Complainant contends that: - the Disputed Domain Names are confusingly similar to the Complainant’s L’ORÉAL trademarks; - the Respondents have no rights or legitimate interests in the Disputed Domain Names; and - the Disputed Domain Names have been registered and are being used in bad faith. B. Respondents In respect to the Disputed Domain Name , a third-party seemingly in receipt of the Center’s written notice of the dispute filed a reply to the Complainant’s contentions in Romanian, explaining
page 4 that the only communication she received in relation to this dispute is that sent to her by the Center via courier. In particular, this third-party contends that the email addresses used by the Center in the communication with her do not belong to her and that the communications using said email addresses did not reach her. This third-party explains that further to accessing a Facebook ad, she applied for a job as remote back-office operator with the Complainant. After several discussions via Facebook messenger and WhatsApp with various people allegedly working for the Complainant, this person was invited to take part in a free training aimed at preparing her for this new position. In order to proceed in this respect, she was requested to create an account on the Complainant’s platform. For the purpose of confirming the successful creation of this account, she was asked to access the link at “https://lorealadmin.ro/login” and to authenticate herself by using a given email address and password, by also providing her ID card and videos with her profile; she proceeded as per the above. Until the account was supposedly activated, this person and the Complainant’s alleged recruiting agent engaged in some WhatsApp conversation on the person’s necessity to create a bank account to be used for the payment of her salary. The Respondent refused to create a bank account and decided not to pursue the job opportunity anymore due to, among others, the uncertainties that arose from the communication with her interlocutor. The third-party states that once she refused to open the bank account, her interlocutor deleted from the conversation the details of the link https://lorealadmin.ro/login, as well as the authentication email address and password. This third-party notes that she never used the email addresses mentioned in the Complaint (verified by the Registry) and that her only interaction with the Complainant was through this job application attempt. During the authentication process, she was told her account was blocked and that technical support would fix it. She furthermore says that she has no connection to Disputed Domain Name or any fraudulent activity. The reply submitted by this third-party to the Center is accompanied by screenshots from the Facebook and WhatsApp communications between her and the people allegedly working for the Complainant, in Romanian language. The two Respondents (registrants of the Disputed Domain Names and ) did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Consolidation The Complainant requests the addition of two domain names to the Complaint and the consolidation of the disputes pursuant to paragraph 10(e) of the Rules, claiming that the Respondents appear to be the same person or to be subject to common control. The Panel notes that the Complainant’s consolidation request was made after the Complaint was notified to the initial Respondent and the proceedings have formally commenced. In order to assess if such request should be granted, the Panel will mainly consider whether (i) the Complainant holds relevant trademark rights and (ii) the proposed additional domain names are prima facie registered by the same or related respondent (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.12.2). The Panel contends that the registrants of the Disputed Domain Names and , although different individuals, have been revealed by the Registry to have the same phone number, so they are most likely related. As for the Disputed Domain Name , the evidence filed by the Complainant shows that it used to direct to a webpage having the same content/layout as the website found at the Disputed Domain Name , which cannot be a mere coincidence.
page 5 Moreover, the composition of all three Disputed Domain Names follows the same pattern (i.e., the Complainant’s L’ORÉAL trademark plus a descriptive term). The Panel is of the opinion that the above represents a strong indication that the Disputed Domain Names are under common control. Thus, the Panel considers that it is reasonable to accept the addition of and to the Complaint as all Disputed Domain Names have a similar composition and have been registered by related holders within a rather short period of time. The Panel believes that in this case, the addition of the Disputed Domain Names and to the present proceeding is efficient, fair and equitable to all the parties. Moreover, the Respondents have not raised any objection to the Complainant’s consolidation request. For all the above reasons, consolidation is ordered. B. Language of the Proceeding The language of the Registration Agreement for all the Disputed Domain Names is Romanian. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including the following: (i) the location of the Complainant and the fact that it has no knowledge of Romanian; (ii) the principle of fairness towards the parties, which implies avoiding the Complainant’s burden of ordering translations and incurring additional costs thereof, as well as avoiding unnecessary delays in the proceedings; and (iii) English is the primary language for international relations. The Respondents did not make any specific submissions with respect to the language of the proceeding. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to the parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs. WIPO Overview 3.0, section 4.5.1. The Panel is familiar with both Romanian and English languages. The Panel notes that the Complainant and its representative are French companies and none of them has knowledge of Romanian language. The Respondents did not comment on the Complainant’s request. The Panel believes that the adoption of English as language of this proceeding would not negatively affect the Respondents’ ability to defend themselves or the equality of the parties. The Panel is of the opinion that the adoption of English as the language of the proceeding would be fair and would contribute to conducting the proceeding with due expedition and without an unreasonable increase of costs. Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. C. 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 Names. WIPO Overview 3.0, section 1.7.
page 6 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 entirety of the L’ORÉAL trademark is reproduced within the Disputed Domain Names. The Panel finds that the L’ORÉAL trademark is recognizable within the Disputed Domain Names. Accordingly, the Disputed Domain Names are confusingly similar to the Complainant’s trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The Disputed Domain Names also contain the terms “manager”, “admin” (which is most likely an abbreviation for “administrative” or “administration”), respectively “platforma” (in English: “platform”), however the Panel finds that the addition of these elements does not prevent a finding of confusing similarity between the Disputed Domain Names and the Complainant’s trademark for the purposes of the Policy. According to the WIPO Overview 3.0, section 1.8, 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. According to the WIPO Overview 3.0, section 1.11.1, the country code Top-Level Domain (“ccTLD”) “.ro” in the Disputed Domain Names 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. D. 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 Respondents lack rights or legitimate interests in the Disputed Domain Names. The Respondents have not rebutted the Complainant’s prima facie showing and have 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. It is accepted by the Panel that the Respondents are not related to the Complainant in any way and that the Complainant has not authorized the Respondents to use and register the Complainant’s trademark or to apply for the registration of the Disputed Domain Names. There is also no evidence that the Respondents are commonly known by the Disputed Domain Names or by the name “L’Oréal”. The Disputed Domain Names contain the Complainant’s L’ORÉAL trademark, plus the descriptive terms “manager”, “admin”, respectively “platforma”. The Panel is of the opinion that the Respondents registered the Disputed Domain Names with the ultimate intent to mislead the Internet users and to erroneously make them believe that the Disputed Domain Names are operated by or associated with the Complainant.
page 7 Although at the time of this Decision, the three Disputed Domain Names resolve to an inactive website, as per the evidence filed by the Complainant, the Disputed Domain Names and used to resolve to an authentication webpage unlawfully reproducing the Complainant’s name and trademark/logo, while the Disputed Domain Name was actively used in a fraudulent job offering scheme, where selected candidates were invited to access the webpage at in order to be granted access to a free training supposedly organized by 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. Moreover, a respondent’s use of a 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 Panel considers that the composition of the Disputed Domain Names, coupled with their recent use for websites that clearly target the Complainant and its business, signals the Respondents’ intention of taking unfair advantage of the Complainant’s mark. Further to the above, the Panel is of the opinion that the Respondents do not use the Disputed Domain Names in connection with a bona fide offering of goods or services, nor do they make a legitimate noncommercial or fair use of the Disputed Domain Names as per the Policy. Further to all the above, the Panel finds the second element of the Policy has been established. E. 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 L’ORÉAL trademark long before the Respondents registered the Disputed Domain Names. In view of the worldwide reputation of the Complainant (including in Romania, where the Respondents are apparently located), the well-known character of its trademark and the composition of the Disputed Domain Names, it is unlikely that the Respondents were not aware of the Complainant’s trademark and business when registering the Disputed Domain Names. The Panel considers that the Respondents targeted the Complainant when registering the Disputed Domain Names. The Panel is of the opinion that the Respondents’ registration of the Disputed Domain Names which contain the Complainant’s L’ORÉAL trademark plus a descriptive term, signals an intention on the part of the Respondents to confuse users seeking or expecting the Complainant and it is a clear proof of the Respondents’ bad faith. Moreover, the evidence accompanying the Complaint shows that the Disputed Domain Names and used to resolve to an authentication webpage unlawfully reproducing the Complainant’s name and trademark/logo, without any notable disclaimer, while the Disputed Domain Name was actively used in a fraudulent job offering scheme, where selected candidates were invited to access the webpage at in order to be granted access to a free training supposedly organized by the Complainant. This indicates the Respondents’ intent to mislead Internet users into believing that the websites are affiliated with or endorsed by the Complainant, which supports an inference of bad faith registration and use of the Disputed Domain Names on behalf of the Respondents.
page 8 Paragraph 4(b)(iv) of the Policy provides that the use of a domain name to intentionally attempt “to attract, for commercial gain, Internet users to [the respondent’s] web site or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of [the respondent’s] web site or location or of a product or service on [the respondent’s] web site or location” is evidence of registration and use in bad faith. In view of all the above, the Panel is of the opinion that the Respondents’ intention was to attract Internet users to the webpages at the Disputed Domain Names, by creating confusion and making them believe that said webpages are held, controlled or related to the Complainant, for the Respondents’ commercial gain. Moreover, the Panel considers that the use of the Disputed Domain Names in connection to the above illegitimate activities (i.e., phishing, impersonation, fraudulent schemes) constitutes bad faith. WIPO Overview 3.0, section 3.4. The Panel notes that more likely than not the registrant of the Disputed Domain Name used the name of a third-party when registering the Disputed Domain Name, who explained her experience with the supposed job application with the Complainant. The Panel also notes the Respondents’ failure to submit a response in the present proceeding. The above may be considered as a further indication of the Respondents’ bad faith. Having reviewed the record, the Panel finds the Respondents’ registration and use of the Disputed Domain Names constitutes bad faith under the Policy. 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 Names , , and be transferred to the Complainant. /Monica Novac/ Monica Novac Sole Panelist Date: November 30, 2025
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