Bureau Veritas, Société Anonyme v Kamala MAMMADOVA

Case

WIPO Case No. DQA2025-0002

14-08-2025

No judgment structure available for this case.

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Bureau Veritas, Société Anonyme v. Kamala MAMMADOVA

Case No. DQA2025-0002

1. The Parties

The Complainant is Bureau Veritas, Société Anonyme, France, represented by Dennemeyer & Associates

SAS, France.

The Respondent is Kamala MAMMADOVA, Azerbaijan.

2. The Domain Name and Registrar

The disputed domain name <bureauveritas.qa> is registered with QHost Technologies (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 25, 2025. connection with the disputed domain name. On June 29, 2025, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details.

The Center verified that the Complaint satisfied the formal requirements of the Qatar Domains Registry
Domain Name Dispute Resolution Policy (the “Policy”), the Rules for Qatar Domains Registry Domain Name
Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Qatar Domains Registry
Domain Name Dispute Resolution Policy (the “Supplemental Rules”).

In accordance with the Rules, paragraphs 2(a) and 4(a), the Center formally notified the Respondent of the Complaint, and the proceedings commenced on July 3, 2025. In accordance with the Rules, paragraph 5(a), the due date for Response was July 23, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 28, 2025.

The Center appointed Anita Gerewal as the sole panelist in this matter on July 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.

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4. Factual Background

The Complainant, founded in 1828 is a joint-stock company organized under the laws of France. The has more than 82,000 employees in more than 1,600 offices and laboratories worldwide.

The Complainant has been active in the Middle East for over 40 years and has a local subsidiary in Qatar, the head office of which is located in Doha. The Complainant operates in various fields which include agri- commodities, certification, industry, marine, and offshore.

The Complainant is the owner of numerous BUREAU VERITAS trademark registrations worldwide, including the following:

• Qatar Trademark Registration No. 046842 for BUREAU VERITAS word mark in class 42, registered on July 21, 2009, designating Qatar;

Qatar Trademark Registration No. 101944 for BUREAU VERITAS word mark in class 42, registered

on May 15, 2017;

Qatar Trademark Registration No. 101943 for mark for in class 42, registered on May 15, 2017;
and

• International Trademark Registration No. 311819 for BUREAU VERITAS figurative mark in classes 1,

2, 6, 7, 8, 9, 10, 11, 12, 13, 14, 16, 17, 18, 19, 22, 24, and 42, registered on April 12, 1966, designating inter
alia Azerbaijan.

The Complainant is also the owner of inter-alia the following domain names: <bureauveritas.com>,
<bureauveritas.fr>, <bureauveritas.de>, and <bureauveritas.jp>.

The disputed domain name was registered on April 17, 2025 and resolves to a page which appears to be inactive and displays the message “This domain name is registered with Netim”. The Complainant provided evidence that the disputed domain name has been used to send email communications purporting to come from the Complainant.

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 confusingly similar to the Complainant’s BUREAU VERITAS trademarks. The disputed domain name reproduces the verbal elements “BUREAU” and “VERITAS” of the Complainant’s trademarks and company name in its entirety. The said terms remain perfectly identifiable and understandable by the public. Hence, there is a clear risk of confusion and association for the public who might think that the disputed domain name belongs to the Complainant or is the local representation in Qatar of its domain name. This risk is heightened by the fact that the Complainant’s corporate website domain name is constructed in an identical manner, with no space between the two terms.

The Complainant also asserts that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent is not an employee of or linked to the Complainant, nor has the Respondent ever been authorized or otherwise permitted to register a domain name that is identical or similar to its trademarks. The Complainant further contends that the nature of the disputed domain name is

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inherently misleading as it effectively impersonates or suggests sponsorship or endorsement by the
Complainant due to its almost identical nature. The disputed domain name is inactive and redirects to a
message indicating “this domain name is registered with Netim” which clearly demonstrates that the
Respondent has no rights or legitimate interests in respect of the disputed domain name.

The Complainant further submits that the disputed domain name has been registered or is being used in bad faith. It is inconceivable that the Respondent registered the disputed domain name without prior knowledge of the Complainant and the Complainant’s well-known marks. The Respondent is therefore making unlawful and unfair use of the domain name with the intention of diverting customers by creating confusion about the origin of the services and thus tarnishing the Complainant's aforementioned trademarks and damaging the Complainant's image and reputation.

The Complainant further submits that the disputed domain name has been used to create an email address impersonating an employee of the Complainant’s. This email address has been used in emails bearing the Complainant’s logo in the signature line and requesting the recipient to make payments to a bank account

different from the bank account of the Complainant’s group company. This is a clear indication of fraudulent use of the disputed domain name. Thus, the disputed domain name is used for illegal activity (here, claimed, impersonation/phishing, and other types of fraud) and therefore, constitutes bad faith.

B. Respondent

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

6. Discussion and Findings

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. [1]

[1]In light of the substantive and procedural similarities between the Policy and the Uniform Domain Name Dispute Resolution

The Complainant has shown rights in respect of its BUREAU VERITAS trademark for the purposes of the
Policy. WIPO Overview 3.0, section 1.2.1.

The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical to the BUREAU VERITAS mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7.

The “.qa” country code Top-Level Domain is a standard registration requirement and as such is disregarded under the first element confusing similarity test.

The Panel finds the first element of the Policy has been established.

B. Rights or Legitimate Interests

Paragraph 3(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name.

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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 Complainant has asserted that the Respondent has no connection or affiliation with the Complainant, nor has the Complainant consented to the Respondent’s use of the disputed domain name, which incorporates the Complainant’s trademark in its entirety. 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.

Moreover, the disputed domain name has been used in connection to a fraudulent email scheme impersonating an employee of the Complainant. Such use can never confer rights or legitimate interests on a respondent. See WIPO Overview 3.0, section 2.13.

The Panel finds the second element of the Policy has been established.

C. Registered or Used in Bad Faith

The Panel notes that, for the purposes of paragraph 3(a)(iii) of the Policy, paragraph 3(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 the present case, the Panel finds that the Respondent knew that the disputed domain name comprised the Complainant’s trademark at the time of registration. This is evident from the fact that the disputed domain name is identical to the Complainant’s mark, which is registered in both Azerbaijan – where the Respondent appears to be located – and Qatar, whose country-code Top-Level domain (“ccTLD”) has been selected by the Respondent, as well as the use of the disputed domain name.

Panels have held that the use of a domain name for illegal activity (e.g. phishing, impersonation, or other types of fraud) constitutes bad faith. WIPO Overview 3.0, section 3.4.

In this case, the illegal activity consists of using the disputed domain name to send fraudulent emails impersonating an employee of the Complainant in an attempt to solicit money from its client. The Panel is of the opinion that recipients of such emails are likely to be confused, particularly because the emails include a signature reproducing the name “Bureau Veritas International Qatar” along with the local address of the Complainant’s subsidiary, thereby misleading the Complainant’s clients.

Accordingly, the Panel concludes that the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy.

The Panel finds that the Complainant has established the third element of the Policy.

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7. Decision

For the foregoing reasons, in accordance with paragraph 3(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <bureauveritas.qa> be transferred to the Complainant.

/Anita Gerewal/
Anita Gerewal
Sole Panelist
Date: August 14, 2025

Policy (“UDRP”), the Panel has cited decisions under the UDRP and WIPO Overview 3.0, where appropriate.

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