La Chaine Info v Nora Dean
WIPO Case No. D2025-2471
•13-08-2025
| ARBITRATION AND MEDIATION CENTER |
ADMINISTRATIVE PANEL DECISION
LA CHAINE INFO v. Nora Dean
Case No. D2025-2471
1. The Parties
Complainant is LA CHAINE INFO, France, represented by AARPI Scan Avocats, France.
Respondent is Nora Dean, United States of America.
2. The Domain Name and Registrar
The disputed domain name <lci-info.com> is registered with NameCheap, Inc. (the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 23, 2025.
On June 23, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the disputed domain name. On June 23, 2025, the Registrar transmitted by email to the
Center its verification response disclosing registrant and contact information for the disputed domain name
which differed from the named Respondent (Redacted for Privacy, Privacy service provided by Withheld for
Privacy ehf) and contact information in the Complaint. The Center sent an email communication to
Complainant on June 24, 2025, providing the registrant and contact information disclosed by the Registrar,
and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended
Complaint on June 25, 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 Respondent of the Complaint, and the proceedings commenced on July 1, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 21, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on July 23, 2025.
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The Center appointed Marina Perraki as the sole panelist in this matter on July 30, 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
Complainant is a leading company in the field of TV news channels in France. LCI channel was launched in 1994 by the TF1 group to which Complainant belongs and has been broadcasted since. TF1 group is a leading television company in France, created in 1975, operating, per Complaint, the first and oldest television channel in France.
LCI channel has been accessible free of charge since 2016. Complainant contends LCI is today the third followers on Facebook; and more than a billion views on YouTube. Under the LCI trademark, Complainant offers news editions, debates, talk shows, columns, and specialized magazines.
largest news channel in France, with audience that may exceed one million live viewers in some cases.
LCI is also available live on Complainant’s website which had a traffic of 14 million internet users in
Complainant owns a number of LCI trademarks including the French trademark registration No. 94523091, LCI (figurative), filed and registered on June 3, 1994, for goods and services in International Classes 9, 26, 35, 38 and 41.
The disputed domain name was registered on April 13, 2025. Initially it led to a pay-per-click (“PPC”) webpage including links to competing websites. Currently, it leads to an inactive website.
Complainant sent a cease-and-desist letter to Respondent, to which Respondent did not reply.
5. Parties’ Contentions
A. Complainant
Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name.
B. Respondent
Respondent did not reply to the Complainant’s contentions.
6. Discussion and Findings
Paragraph 4(a) of the Policy lists the three elements which Complainant must satisfy with respect to the
Domain Name:
(i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which
Complainant has rights; and
(ii) Respondent has no rights or legitimate interests in respect of the disputed domain name; and
(iii) the disputed domain name has been registered or is being used in bad faith.
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A. Identical or Confusingly Similar
It is well accepted that the first element functions primarily as a standing requirement. The standing
(o 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.
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 incorporated and recognizable within the disputed domain name. Accordingly,
the disputed domain name is confusingly similar to Complainant’s mark for the purposes of the Policy.
WIPO Overview 3.0, section 1.7.
Although the addition of other terms, here, “info” and a hyphen, 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 name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8.
The generic Top-Level Domain (“gTLD”) “.com” is disregarded, as gTLDs typically do not form part of the
comparison on the grounds that they are required for technical reasons (Rexel Developpements SAS v.
Zhan Yequn, WIPO Case No. D2017-0275; Hay & Robertson International Licensing AG v. C. J. Lovik,
WIPO Case No. D2002-0122).
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 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 Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent has not rebutted 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.
On the contrary, the disputed domain name was used to host a parked page with PPC links, including links to competing websites. The Panel finds that it is not unlikely that Respondent received PPC fees from the linked websites and used the disputed domain name for its own commercial gain. The use of a domain
name to host a parked page comprising PPC links does not represent a bona fide offering where such links
mislead Internet users and trade off the complainant’s trademark (Virgin Enterprises Limited v. LINYANXIAO
aka lin yanxiao, WIPO Case No. D2016-2302; WIPO Overview 3.0, section 2.9).
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Furthermore, there is no evidence on record giving rise to any rights or legitimate interests in the disputed domain name on the part of Respondent within the meaning of paragraphs 4(c)(ii) and 4(c)(iii) of the Policy.
In addition, the nature of the disputed domain name, entirely incorporating Complainant’s trademark plus the descriptive term “info” carries a risk of implied affiliation. WIPO Overview 3.0, section 2.5.1.
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.
Because the LCI mark had been used and registered before the disputed domain name registration, the Panel finds it more likely than not that Respondent had Complainant’s mark in mind when registering the disputed domain name.
Moreover, the similarity of the disputed domain name to Complainant’s mark, and the choice of the descriptive word “info” which coincides with Complainant’s activity, particularly in relation to the LCI channel content of Complainant, reinforces the notion that Respondent was aware of and intentionally targeted Complainant in an attempt to confuse Internet users who were expecting to find Complainant’s website.
As regards bad faith use, the disputed domain name directed Internet users to a website displaying links to
third-party sites, including websites competing to Complainant, which suggests that, presumably,
Respondent received PPC fees from the linked websites that were listed thereon. It has been recognized
that such use of another’s trademark to generate revenue from Internet advertising can constitute registration
and use in bad faith (McDonald’s Corporation v. ZusCom, WIPO Case No. D2007-1353; Volkswagen
Aktiengesellschaft v. Robert Brodi, WIPO Case No. D2015-0299; SAP SE v. Domains by Proxy, LLC /
Kamal Karmakar, WIPO Case No. D2016-2497; WIPO Overview 3.0, section 3.5).
| name, and in the circumstances of the case, affirms the bad faith (Aygaz Anonim Şirketi v. Arthur Cain, | This, in view of the finding that Respondent has no rights to or legitimate interests in the disputed domain the disputed domain name does not prevent a finding of bad faith. WIPO Overview 3.0, section 3.3. |
| Under these circumstances and on this record, the Panel finds that Respondent has registered and is using the disputed domain name in bad faith. | |
| The Panel finds that 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 name <lci-info.com> be transferred to Complainant. | |
| /Marina Perraki/ Marina Perraki Sole Panelist Date: August 13, 2025 |
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