Compagnie Générale des Etablissements Michelin v; Robert Chen, Michelinfood
WIPO Case No. D2025-3529
•21-10-2025
ARBITRATION
AND
| MEDIATION CENTER |
ADMINISTRATIVE PANEL DECISION
Compagnie Générale des Etablissements Michelin v.
Robert Chen, Michelinfood
Case No. D2025-3529
1. The Parties
The Complainant is Compagnie Générale des Etablissements Michelin, France, represented by
Tmark Conseils, France.
The Respondent is Robert Chen, Michelinfood, Cambodia.[1]
2. The Domain Names and Registrar
The disputed domain names <michelinfinefoods.com>, <michelingastronomyguide.com>,
<michelinguideglobal.com>, <michelinguidegourmet.com>, <michelinrestaurantawards.com>, and
<michelinstarreview.com> are registered with Gname.com Pte. Ltd. (the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) in respect of the
domain names <michelinfinefoods.com>, <michelingastronomyguide.com>, <michelinguideglobal.com>, connection with these disputed domain names. On September 3, 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.
<michelinguidegourmet.com>, and <michelinrestaurantawards.com> on August 26, 2025.
The Center verified that the 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”).
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In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on September 12, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 2, 2025. The Respondent did not submit any
response. Accordingly, the Center notified the Respondent’s default on October 3, 2025.
On October 6, 2025, the Complainant requested to add another domain name <michelinstarreview.com> to the proceedings, for which it filed an amended Complaint on October 6, 2025.
The Center appointed Nayiri Boghossian as the sole panelist in this matter on October 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.
On October 14, 2025, the Panel instructed the Center to send a request for registrar verification in connection with the disputed domain name <michelinstarreview.com>. On October 15, 2025, the Registrar transmitted by email to the Center its verification response, confirming that the disputed domain name <michelinstarreview.com> is registered by the Respondent. On October 15, 2025, the Panel issued
Procedural Order No. 1, inviting the Respondent to comment on the Complainant’s request for addition of the
domain name <michelinstarreview.com> to the Complaint. No response to the Procedural Order No. 1 has
been received.
4. Factual Background
The Complainant is a French company that sells tires and publishes the Michelin Guide that ranks fine dining establishments. The Complainant owns trademark registrations for MICHELIN in numerous jurisdictions such as the following:
1. International Trademark Registration No. 1254506, registered on December 10, 2014; and
2. United States of America Trademark Registration No. 5775734, registered on June 11, 2019.
The disputed domain names were registered on July 25, 2025, and resolve to websites which display the
Complainant’s trademark and logo, display “We offer a top-rated experience that helps retailers promote their
brands”, and invite users to log in or sign up.
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 trademark. The Complainant is the owner of the trademark MICHELIN. The Complainant’s
trademark is considered well known by prior UDRP panels. The disputed domain names incorporate the
Complainant’s trademark. The generic Top-Level Domain (“gTLD”) “.com” is a standard registration
requirement and is as such disregarded under the first element confusing similarity test. The terms
“gourmet”, “restaurant”, “awards”, “gastronomy”, “finefoods”, “star” and “guide” in combination with the well-
known trademark MICHELIN reinforce the risk of confusion as they relate to the Complainant’s Michelin
Guide activity.
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The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain names. The Complainant is the only owner of the trademark MICHELIN. The Complainant did not authorize the Respondent to use its trademark.
The Complainant contends that the disputed domain names were registered and are being used in bad faith.
The Respondent had knowledge of the Complainant’s trademark. A simple Google search would reveal the
Complainant’s website. The Complainant’s trademark is well known and the disputed domain names resolve
to websites which reproduce the Complainant’s trademark and a “Michelin Man” logo. The Respondent has
provided erroneous contact details, which is further evidence of bad faith. The disputed domain names
resolve to websites which reproduce the Complainant’s trademark and relate to culinary activities. The
Respondent is impersonating the Complainant in order to divert traffic towards its websites.
B. Respondent
The Respondent did not reply to the Complainant’s contentions.
6. Discussion and Findings
6.1. Preliminary Issue – Addition of a Domain Name
On October 6, 2025, the Complainant requested to add the domain name <michelinstarreview.com> to the current proceedings. Requests for addition of domain names to a complaint after it has been notified to the respondent and the proceedings have formally commenced would be addressed by the panel upon
appointment. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition
(“WIPO Overview 3.0”), section 4.12.2.
The Registrar confirmed in its verification response regarding the domain name <michelinstarreview.com> the Respondent is the registrant of this domain name. The Panel further invited the Respondent to provide
comments on the Complainant’s request for addition of the domain name <michelinstarreview.com> to the
proceedings. The Respondent has provided no comments and thus did not object to such addition.
The Panel further notes that, as per the evidence submitted by the Complainant, the domain name
<michelinstarreview.com> resolves to a website with the exact same layout as the other five disputed
domain names.
In view of the above, the Panel finds that the circumstances of this case and procedural efficiency favor
allowing the addition of this domain name to the Complaint and grants the Complainant’s request.
6.2. Substantive Issues
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.
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Although the addition of other terms here, “fine”, “foods”, “gastronomy”, “guide”, “global”, “gourmet”,
“restaurant”, “awards”, “star”, and “review” 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.
The Panel finds that the composition of the disputed domain names together with the use to which they have been put were deliberately intended to mislead Internet users into believing that the websites were connected to, or operated by, the Complainant.
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 the present case, the Panel notes that the Respondent must have been aware of the Complainant’s
trademark as the disputed domain names resolve to websites, which display the Complainant’s trademark and logo alongside the pictures of food. Also, the Complainant’s trademark was registered over a decade
before the registration of the disputed domain names.
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.
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.
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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 <michelinfinefoods.com>, <michelingastronomyguide.com>,
<michelinguideglobal.com>, <michelinguidegourmet.com>, <michelinrestaurantawards.com>, and
<michelinstarreview.com> be transferred to the Complainant.
/Nayiri Boghossian/
Nayiri Boghossian
Sole Panelist
Date: October 21, 2025
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