Compagnie Générale des Etablissements Michelin v. Lin Lin

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Compagnie Générale des Etablissements Michelin v. Lin Lin

Case No. D2025-5145

1. The Parties

The Complainant is Compagnie Générale des Etablissements Michelin, France, represented by Dreyfus & associés, France.

The Respondent is Lin Lin, China.

2. The Domain Names and Registrar

The disputed domain names <michelin-eu25.com>, <michelin2025.com>, <michelin2025eu.com> and <michelin2025sale.com> are registered with Dynadot Inc (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 10, 2025. On December 11, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On December 12, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 12, 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 December 18, 2025.

The Center verified that the Complaint together with the amended Complain 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 December 19, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 8, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 9, 2026.

The Center appointed Áron László as the sole panelist in this matter on January 21, 2026. 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 company established in 1889 in Clermont-Ferrand, France, which manufactures and sells tires for a wide range of vehicles, produces road maps and publishes restaurant guides. The Complainant is present in around 170 countries, has more than 124,000 employees and operates 117 tire manufacturing facilities. The Complainant's Michelin Guide, which uses stars to rate the quality of restaurants, was first published in 1926 and has since sold more than 30 million copies.

The Complainant is the owner of the following trademarks for the word sign MICHELIN (the Trademark):

- International registration MICHELIN No. 771031, registered on June 11, 2001, designating various jurisdictions in Europe, Asia and Africa, including China;

- United States of America trademark MICHELIN No. 892045, registered on June 2, 1970; - United States of America trademark MICHELIN No. 4126565, registered on April 10, 2012.

In addition, the Complainant operates, among others, under the domain name <michelin.com>, which was registered on December 1, 1993, as well as <michelin.com.cn> registered on June 16, 2001.

The disputed domain names were registered on the following dates:

- <michelin2025.com> registered on October 23, 2025;

- <michelin2025sale.com> registered on October 24, 2025;

- <michelin2025eu.com> registered on October 25, 2025;

- <michelin-eu25.com> registered on November 19, 2025.

The Complainant provided screenshots taken on November 3, 2025, that show that the disputed domain names <michelin2025.com> and <michelin2025sale.com> used to resolve to a website offering car tyres. This website used the Complainant's MICHELIN trademarks as well as its mascot, the “Michelin Man”. As of December 10, 2025, no content was available at these disputed domain names, and this remains the case today.

The same content was available under the disputed domain name <michelin-eu25.com> on December 10, 2025. Currently, this disputed domain name does not resolve to any content.

The disputed domain name <michelin2025eu.com> resolved to an error page and is currently also inactive.

The Complainant sent notifications to the Registrar and hosting provider of the disputed domain names, requesting that they block them. The disputed domain names were subsequently blocked.

According to information provided by the registrar, the Respondent is an individual residing in China.

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 feature the MICHELIN trademark alongside the numbers “2025” and “25”, the geographic indicator “eu” (commonly associated with the European Union) and the term “sale”. This is insufficient to avoid any likelihood of confusion. These terms

suggest that the websites available through the disputed domain names will provide information relating to the products of the Complainant and the possibility of purchasing them at discounted prices. This could mislead Internet users due to the confusing similarity between the disputed domain names and the trademarks of the Complainant, as well as the legitimate domain names of the Complainant.

Concerning the second element, the Complainant contends that the Respondent is not affiliated with the Complainant in any way, nor has the Complainant authorised the Respondent to use or register its trademark or seek registration of any domain name incorporating said mark. Furthermore, the Respondent has no prior rights or legitimate interest in the disputed domain names.

The disputed domain names, which incorporate the Complainant’s trademark in its entirety, initially directed users either to an error page or, more prominently, to a page reproducing the Complainant’s logo and official mascot, the Michelin Man, without authorisation. This created the false impression of an affiliation with the Complainant and offered tires for sale, directly targeting the Complainant’s main field of activity. Due to the presence of the Complainant’s logo and mascot on the website, internet users were likely to mistakenly believe that these were official websites. This cannot be considered a bona fide use of the disputed domain name in connection with the offering of goods and services.

Concerning the third element, the Complainant contends that it is implausible that the Respondent was unaware of the Complainant when registering the disputed domain names. Firstly, the Complainant is well known throughout the world, including in China, where the Respondent is located. Many Panels have previously acknowledged the Complainant's worldwide reputation, which makes it unlikely that the Respondent was unaware of the Complainants' rights in the said trademark. Secondly, as the disputed domain names reproduce Complainant’s MICHELIN trademark in full, it cannot be inferred that the Respondent was unaware of the Complainant when registering the disputed domain names. Previous panels have ruled that bad faith can be established when a domain name is clearly linked to a well-known trademark, suggesting opportunistic bad faith on the part of someone with no connection to the trademark. Thirdly, the Complainant's MICHELIN trademark registrations significantly predate the registration date of the disputed domain names.

Most of the disputed domain names previously resolved to live websites explicitly referencing the MICHELIN name and reproducing the Michelin Man mascot. The Michelin Man is one of the most distinctive and globally recognised brand assets of the Complainant. Panels have repeatedly held that the unauthorised use of a complainant’s logos, imagery and brand stylisation constitutes strong evidence of bad faith, as it demonstrates clear knowledge of the complainant and a deliberate intent to impersonate or make it appear that the website is affiliated with the trademark owner. The websites linked to the disputed domain names were structured as e-commerce or promotional platforms offering tire-related products and purported discounts, and promoted the sale of tires. Their overall layout, color schemes, typography and visual elements were designed to mimic the appearance of a legitimate MICHELIN website, thereby enhancing their authenticity. This is a textbook example of fraudulent impersonation intended to mislead consumers into believing that they are interacting with an authorised MICHELIN retailer or promotional portal.

Even if one or more of the disputed domain names currently resolve to an inactive or blocked page, passive holding does not preclude a finding of bad faith under the “passive holding doctrine” recognised in the Telstra decision (Telstra Corporation Ltd. v. Nuclear Marshmallows, WIPO Case No. D2000-0003).

B. Respondent

The Respondent did not reply to the Complainant’s contentions.

6. Discussion and Findings

Paragraph 15(a) of the Rules instructs this Panel to “decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”.

Paragraph 4(a) of the Policy requires that a complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:

i. the domain name registered by the respondent is identical or confusingly similar to a trademark or service mark in which the complainant has rights; and

ii. the respondent has no rights or legitimate interests in respect of the domain name; and iii. the domain name has been registered and is being used in bad faith.

In view of the Respondent’s failure to submit a Response, the Panel shall decide this administrative proceeding on the basis of the Complainant’s undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences as it considers appropriate pursuant to paragraph 14(b) of the Rules.

The Panel is entitled to accept all reasonable allegations set forth in a complaint. However, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 4.3.

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 Panel finds the mark is recognizable within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7.

Although the addition of other terms here, “25”, “2025”, “eu” and “sale” may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain names and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8.

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.

Panels have held that the use of a domain name for illegitimate activity here, claimed 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 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.

In this case, the Panel has found that the Respondent intentionally attempted to attract Internet users for commercial gain by creating a likelihood of confusion with the Complainant’s trademark. The Complainant has been in business for over 100 years and has held trademarks for more than 50 years. It is inconceivable that the Respondent was unaware of the Complainant’s trademarks when registering the disputed domain names, which incorporate the Complainant’s trademarks fully, with some additions referencing the year 2025 (“25” and “2025”), European Union (“eu”), and general commercial practices (“sale”). Furthermore, three of the four disputed domain names previously resolved to a website that makes heavy use of the Complainant’s trademarks and well-known mascot without permission. This lets the Panel conclude that the disputed domain names were registered 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.

Although, the disputed domain name <michelin2025eu.com> apparently never showed any content, panels have found that the non-use of a domain name 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 or reputation of the Complainant’s trademark, and the composition of the disputed domain name, containing the MICHELIN mark in its entirety, 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.

Panels have held that the use of a domain name for illegitimate activity here, claimed impersonation/passing off, in the case of the disputed domain names <michelin2025.com>, <michelin2025sale.com> and <michelin-eu25.com>, constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names constitutes bad faith under the Policy.

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 <michelin-eu25.com>, <michelin2025.com>, <michelin2025eu.com> and <michelin2025sale.com> be transferred to the Complainant.

/Áron László/

Áron László

Sole Panelist

Date: February 4, 2026

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