2017 edition. ADR Trends. Afnic out-of-court dispute resolution procedures

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1 2017 edition ADR Trends

2 Foreword For this new edition of ADR Trends, Afnic invites you to learn more on page 5 about the views of a SYRELI Rapporteur about the defense of the rights of a Claimant ineligible under the naming policy of the.fr TLD when an.fr domain name is adversely affecting him. In parallel, you will learn more about the latest decisions on each of the items discussed in this review. Finally, to complete your SYRELI kit, Afnic invites you to visit its website to check out the latest Scope infography. We wish you to enjoy the reading! Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 2 2

3 Contents Facts and figures 4 News 5 Grounds for the claim 12 Completeness of the claim file 13 Admissibility of documents and evidence 14 Claimant s right to bring action 15 Eligibility of Claimant 16 Agreement of Holder 17 Refusal or failure to reply by Holder 18 Legitimate interest of the Holder 19 Holder s lack of good faith 20 Must-read sections 24 Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 3 3

4 Facts and figures Domain name transfer or deletion rate following a Syreli decision Since November 2011, the College has handed down 1054 decisions. In 54% of the cases, the College accepted the requested action: 87% of the motions to transfer the domain name 13% of the motions to delete the domain name For further statistics, check out our Scope reports by following this link Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 4 4

5 Defending the rights of a Claimant ineligible under the Naming Policy when an.fr domain name is adversely affecting them News First of all, it should be recalled that the registration or renewal of a domain name under the.fr is not open to everyone; both acts are governed by Article L45-3 of the French Electronic Communications and Telecommunications Act (CPCE), which states that "Application to register a domain name, in each of the top-level domains is possible for: - Individuals resident in the territory of the European Union; - Corporate entities having their registered or main office located in the territory of a Member of the European Union." In addition, when a domain name under the.fr has been registered by a third party which infringes your rights, apart from an amicable settlement 1, only judicial or extrajudicial means can be used to bring the infringement to an end. Various means can be used to bring the infringement to an end. In such a case, depending on the damage suffered, the claimant will opt for one solution rather than another. What are the possible solutions to bring the infringement to an end? First of all, there is the technical operation referred to as a "suspension" of the domain name, which consists in precluding any request for a future operation on the domain name (change of registrar, transfer of the domain name, etc.). This does not affect the operation of the domain name, however. In other words, the website to which the domain name refers will always be visible to the general public. There also exists the "blocking" of a domain name, which consists in rendering the domain name inoperative (the website and related addresses no longer work). The deletion of the domain name is also a technical solution to bring the infringement to an end since this causes the domain name to fall back into the public domain ( the web site and related (Cont'd on page 6) 1 For further information, please see our Practical Guide for rights-holders. Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 5 5

6 Defending the rights of a Claimant ineligible under the Naming Policy when an.fr domain name is adversely affecting them News addresses no longer work). It is important to note that deletion results in the immediate withdrawal of the domain name from the Whois database, making it registrable on a first-come, first-served basis, although sometimes the first-comer is not the claimant who obtained the deletion of the domain name. Finally, there is the compulsory transfer of the domain name, in other words the recovery of the domain name without obtaining the consent of its holder, which is only possible when a judicial or extrajudicial decision (SYRELI or Expert ADR) has ordered it. Care should be taken though: these solutions are not opened by simple request to Afnic. The latter does not suspend, block, delete or transfer a domain name on its own initiative. It may carry out such operations only in the context of procedures strictly defined in the Naming Policy or pursuant to a court decision. This raises the question of how rights-holders who are not eligible under the Naming Policy can defend their rights against a domain name under the.fr that is detrimental to them. Afnic's Alternative Dispute Resolution procedures (ADR): Article L45-6 of the French Electronic Communications and Telecommunications Act (CPCE) states that "Any individual that has a valid reason for doing so may petition the Registry [of the.fr] to delete or transfer a domain name for the individual's benefit when the domain name in question falls within the scope provided for in Article L The Registry shall give its decision within two months of its receipt, in accordance with an adversarial procedure...". The article refers here to the two Afnic ADRs, namely, SYRELI and Expert ADR, which are also the only two possible out-of-court procedures for dealing with disputes relating to domain names under the.fr. 2 A cursory review of articles L45-3 and L.45-6 of the CPCE suggests that only the deletion of a domain name, when it falls within the scope provided for in Article L45-2 of the CPCE, can be requested by a (Cont'd on page 7) 2 as well as those under the other TLD suffixes which Afnic manages, i.e.:.pm,.re,.tf,.wf and.yt. Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 6 6

7 News Defending the rights of a Claimant ineligible under the Naming Policy when an.fr domain name is adversely affecting them Claimant not eligible under the Naming Policy. Since the Claimant is not eligible, they cannot register a domain name under the.fr and consequently cannot request the transfer of the domain name for their benefit in an ADR procedure. In its thirteenth decision, the SYRELI College was able to act on this principle. In decision ref. FR sonos.fr the College noted that "Despite the fact that SONOS Inc. has an interest in bringing proceedings, the company cannot benefit from the transfer operation requested since it is not eligible under Article L of the CPCE.". The SYRELI College also noted in its decision ref. FR lululemon.fr than "as long as the Claimant requests the deletion and not the transfer of the domain name concerned by their request, Article L.45-3 is respected; on the basis of their interest in bringing proceedings, the Claimant may request the deletion of the domain name". However, in the course of the decisions, the SYRELI College has given a broader interpretation to these two articles, since 17% of the requests for transfers filed by Claimants not eligible under the Naming Policy were granted by the College. How can an ineligible Claimant obtain the transfer of a domain name under the.fr? In decision ref. FR yahoomag.fr, the SYRELI College, after recalling that "the Claimant is a company located within the territory of the United States and as such is not eligible for the.fr Naming Policy and is therefore not entitled to request the transfer of the domain name <yahoomag.fr>", found that "the request for transfer is for the benefit of the French company YAHOO! France SAS" and that "the legal relationship between the Claimant and YAHOO! France SAS has been proven" and considered that "the request for transfer is admissible." Conversely, in decision ref. FR scubapro.fr, the SYRELI College noted that "although (Cont'd on page 8) Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 7 7

8 News Defending the rights of a Claimant ineligible under the Naming Policy when an.fr domain name is adversely affecting them referring to a French subsidiary, the Claimant has not requested the transfer of the domain name <scubapro.fr> for the latter's benefit; nor has any evidence been provided to establish the legal relationship between the subsidiary in question and the Claimant". On reading these two decisions, it appears that the College accepts requests to transfer disputed domain names for the benefit, not of a Claimant that is ineligible under the Naming Policy, but for one of its French subsidiaries with which the legal relationship has been proven. This principle was confirmed in particular in decision refs. FR and FR concerning the domain name broadsoftsas.fr; in the first decision the College indicated that "although the Claimant seeks the transfer of the domain name on behalf of its French subsidiary, BROADSOFT SAS, the College finds that the information provided by the Claimant does not establish the legal relationship between BROADSOFT Inc., and the BROADSOFT SAS company". In the second decision the College found that "the Claimant requests the transfer of the domain name on behalf of its French subsidiary, BROADSOFT SAS; [and that] the information provided by the Claimant is sufficient to establish the legal relationship between BROADSOFT Inc. and the French company BROADSOFT SAS. Accordingly, the College considered that the request for transfer was admissible." In 2014, in decision ref. FR adroll.fr the College extended the admissibility of a request for transfer to a subsidiary located in the territory of one of the Member States of the European Union after having obviously found that "the legal relationship between the Claimant and ADROLL AD- VERTISING LIMITED has been proven". The decision is coherent within the meaning of Article L.45-3 of the CPCE which authorizes the registration of a domain name by individuals residing within the territory of the European Union and by corporate entities having their registered office or place of business within the territory of one of the Member States of the European Union, and has been repeatedly confirmed in several decisions, in particular FR hikvision.fr, FR cloudb.fr (Cont'd on page 9) Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 8 8

9 News Defending the rights of a Claimant ineligible under the Naming Policy when an.fr domain name is adversely affecting them and FR lockheed.fr. In decision ref. FR whitestripsenligne.fr, the College provides further clarification in noting that "the Claimant requests the transfer of the domain name <whitestripsenligne.fr> for the benefit of its indirect French subsidiary with which the legal relationship has been proven [...] wholly owned by PROCTER & GAMBLE HOLDING France, which is itself 15.95% owned by the Claimant and 84.05% by the GILLETTE LATIN AMERICA HOLDING BV, which is 100% owned by the Claimant.". From this observation, the College considered that "the request for the transfer of the domain name <whitestripsenligne.fr> for the benefit of an indirect subsidiary wholly owned by the Claimant was not admissible under Article I.iii of the SYRELI Regulations which provides that: "the measures that may be applied for and obtained by the Claimant in connection with the proceedings are limited exclusively to the transfer of the domain name to the Claimant [...]". This decision therefore clarifies the framework within which an ineligible Claimant may request the transfer of a.fr domain name to one of its subsidiaries. Since the Claimant cannot benefit from the domain name themselves, nor can they transfer it to one of their subsidiaries located within the territory of one of the Member States of the European Union, unless they own 100% of the subsidiary in question. As will be appreciated, a Claimant that is not eligible under the Naming Policy may therefore request either the deletion or the transfer of the domain name to a 100%-owned subsidiary located within the territory of one of the Member States of the European Union. However, the deletion of the domain name or its transfer to one of the Claimant's eligible subsidiaries will only be possible if and only if the Claimant first of all substantiates their interest in bringing proceedings, secondly substantiates their legal relationship with the subsidiary for which they have requested the transfer, and thirdly if they subsequently substantiate that the domain name falls within (Cont'd on page 10) Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 9 9

10 News Defending the rights of a Claimant ineligible under the Naming Policy when an.fr domain name is adversely affecting them the scope of one of the cases listed in article L.45-2 of the French Electronic Communications and Telecommunications Act (CPCE). In decision ref. FR snws.fr the College rejected the request for transfer of the domain name after considering that "the Claimant had not demonstrated their interest in bringing proceedings... ". In decision ref. FR magnapool.fr the College dismissed the Claimant's request for transfer for lack of "useable documents in the case file". In decision ref. FR missguided.fr, the College found that "in spite of the fact that Debbie Morgan Macao Commercial Offshore Ltd and MISSGUIDED LIMITED had an interest in bringing proceedings, they could not benefit from the transfer operation requested since no evidence had been brought forward to support their eligibility with regard to Article L.45-3 of the CPCE". Finally, in decision ref. FR renaissance-bienetre.fr the College considered that "by requesting the deletion and not the transfer of the domain name <renaissance-bienetre.fr>, the Claimant complies with Article L.45-3 of the CPCE [... and] can therefore request the deletion of the domain name.". At the end of its analysis of the case file, however, the College considered that "the documents provided by the Claimant are insufficient to provide proof of the lack of legitimate interest and of good faith on the holder's behalf [...] and decided to refuse the transfer of the domain name". Other procedures and services offered by Afnic: In addition to the alternative dispute resolution procedures (SYRELI and ADR EXPERT), it is possible for anyone, including persons not eligible under the.fr Naming Policy, to apply to Afnic for the opening of a eligibility verification procedure against a holder that is not eligible under the.fr Naming Policy. There is only one condition: proof must be provided, by any means, of the Holder's ineligibility. (Cont'd on page 11) Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 10 10

11 News Defending the rights of a Claimant ineligible under the Naming Policy when an.fr domain name is adversely affecting them As part of this eligibility verification procedure, the holder must provide evidence of their eligibility within a maximum period of two months, or risk having their entire domain name portfolio deleted. This eligibility verification procedure therefore constitutes an alternative to the ADR procedures since any applicant for such a procedure has no need to have an interest in bringing proceedings or even to have rights protected in French territory. Please also note that Afnic provides rights-holders with a set of tools that can be used to reach an amicable solution with holders. To find out more, we invite you to read our Practical Guide which is also available on our website. Lastly, Afnic recently set up a new service called "Fr Watch", enabling anyone (regardless of their geographical location) to check whether a.fr domain name infringes their rights or not (trademarks, company names, domain names, etc.). The service allows you to identify domain names that include your brand, domain name or company name in their terminology, and also to evaluate the share of traffic being lost as a result. To set up this service, please contact your registrar. Please note that all.fr-accredited registrars can provide the service. For further information, please visit our website section entitled "Products and services". Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 11 11

12 Grounds for a claim Article L.45-2 of the French Electronic Communications and Telecommunications Act (CPCE) Article L.45-2 paragraph 1 The domain name is liable to disrupt public order or morality, or the rights guaranteed by the French Constitution or French law; Article L.45-2 paragraph 2 The domain name is liable to infringe intellectual property rights or personal rights, unless the Claimant provides proof of a legitimate interest and is acting in good faith; Article L.45-2 paragraph 3 The domain name is identical or related to that of the French Republic, of a local authority or group of local authorities, of an institution or a local or national public service, unless the Claimant provides proof of a legitimate interest and is acting in good faith. Any claim filed on grounds other than those set out in Article L.45-2 will be declared inadmissible by the College. Benchmark decisions 1 st Paragraph : FR agence-bolero.fr FR muscadet.fr FR mamzellesswing.fr FR drumedis.fr 2 nd Paragraph : FR credit-mutuel.yt FR pharmaprix.fr FR cic-france.fr FR pataugas-soldes.fr 3 rd Paragraph : FR base-loisirs-creteil.fr FR chambord.fr FR rambolitrain.fr... Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 12 12

13 Completeness of the claim file The Rapporteur ensures that 1. The application form is complete; 2. The costs of the proceedings have been paid; 3. The domain name has been registered; 4. The domain name is not subject to any judicial or out-ofcourt proceedings. If the claim does not comply with any one of these items, it is rejected by the Rapporteur. [if a complaint has been filed, it ensures that the latter explicitly addresses the domain name in question] The Rapporteur does not verify the consistency of the documents filed by the Parties or their relevance to the arguments presented. Benchmark decisions Judicial or out-of-court proceedings in progress concerning the domain name in dispute: FR parkingmazarine.fr FR ambassadebenin.fr FR atosho.fr FR steico.fr FR le-boncoup.fr Judicial or out-of-court proceedings in progress not concerning the domain name in dispute: syndicat-portage- FR salarial.fr Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 13 13

14 Admissibility of documents The College 1. Reserves the right not to accept documents provided in a foreign language; 2. Not to take into account documents submitted by hyperlink; 3. Not to take into account documents that are not usable; 4. Not to take into consideration arguments with no documents in proof. There may be little evidence but it must be the RIGHT evidence! Benchmark decisions On the lack of documents in proof: FR canordest.fr FR mavenhosting.fr On documents submitted by hyperlink: FR pneu.fr FR gamblingaffiliation.fr FR davidyurman.fr FR institut-montparnasse.fr On documents provided in a foreign language: FR gamblingaffiliation.fr FR besports.fr FR monorauto.fr FR madurasoldes.fr FR credit-mutuel.yt Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 14 14

15 Claimant s right to bring action Article L.45 of the French Electronic Communications and Telecommunications Act (CPCE): "Any individual that has a valid reason for doing so may petition the competent registrar to delete or transfer a domain name for the individual's benefit when the domain name in question falls within the scope provided for in Article L. L.45-2 [ ]. The Claimant has a right to bring action if 1. It has an identical, virtually identical or similar domain name 1 under another TLD for the disputed domain name; 2. If it has a virtually identical or similar domain name 1 under the same TLD for the disputed domain name; 3. It holds a trademark 1, business name 1, surname or pseudonym, title of ownership 1 (work, patent, design and model etc.) that is similar, identical or virtually identical to the disputed domain name. In accordance with Article II.vi.b of the Regulations, the College does not carry out any further research. Any claim submitted by a Claimant who does not substantiate his/her/its right to bring action, will be declared inadmissible by the College. 1 No matter what the date of creation or registration. Benchmark decisions Absence of right to bring action: FR sdbpro.fr FR maisons.fr FR schottfrance.fr FR baume-du-tigre.fr Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 15 15

16 Eligibility of Claimant The Claimant is deemed to be non-eligible when The latter is located outside the territory of a Member State of the European Union. A domain name cannot be transferred to a Claimant that is ineligible under the naming policy of the.fr TLD, even though it may have a right to bring action. The claim by a Claimant who is ineligible under the naming policy of the.fr TLD is admissible if 1. The Claimant requests the transfer of the domain name to one of its subsidiaries which is located in the territory of a Member State of the European Union, subject to the condition that it furnishes proof of a legal relationship with the Claimant; 2. The Claimant requests the deletion of the domain name. Benchmark decisions Ineligible Claimants: FR dpstream.yt FR wellsfargo.fr FR whitestripsenligne.fr FR electrabike.fr FR baume-du-tigre.fr Claimants ineligible but claim admissible: FR vonage.fr FR mywhitestrips.fr FR lockheed.fr FR crossfit.fr Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 16 16

17 Agreement of Holder The College takes note of the agreement of the Holder if and only if 1. The Claimant has a right to bring action; 2. The agreement of the Holder is explicit; 3. The agreement to transfer the domain name is to the benefit of the Claimant and not to that of a third party. In the absence of any one of these provisions, the College continues to study the case considering that the Holder does not agree to transfer or delete the domain name. Benchmark decisions Agreement of Holder: FR kelassur.fr FR tntplay.fr FR noreply-boursorama.fr FR cpam-78.fr Agreement of Holder with no right of Claimant to bring action: FR tandm.fr Non-explicit agreement of Holder: FR concours-sesame.fr Agreement of Holder to transfer the domain name to a third party: FR sportintown.fr Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 17 17

18 Refusal or lack of reply from Holder The College examines 1. The grounds on which the Claimant bases its claim: The domain name is liable to disrupt public order or morality, or the rights guaranteed by the French Constitution or French law (L ); The domain name is liable to infringe intellectual property rights or personal rights, unless the Claimant furnishes proof of a legitimate interest and is acting in good faith (L ); The domain name is identical or related to that of the French Republic, of a local authority or group of local authorities, of an institution or a local or national public service, unless the Claimant furnishes proof of a legitimate interest and is acting in good faith (L ). 2. The lack of any legitimate interest on behalf of the Holder, except in the cases provided for in Article L of the French Electronic Communications and Telecommunications Act (CPCE); 3. The bad faith of the Holder, except in the cases provided for in Article L of the French Electronic Communications and Telecommunications Act (CPCE). Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 18 18

19 Legitimate interest of the Holder Article R of the Decree of 1 august 2011 The Holder has a legitimate interest if 1. It uses the domain name (or demonstrates that it is prepared to do so) in connection with the offering of goods or services; 2. It is known by an identical name or one related to the domain name EVEN if it has NO right to do so; 3. It has used the domain name for non-commercial purposes: or without any intention to deceive the consumer, without damaging the reputation of the other name. Non-exhaustive list! The College then assesses the Holder s lack of good faith. Whatever the circumstances, in the absence of legitimate interest, the College will grant the redress sought by the Claimant. Benchmark decisions Legitimate interest: Use of the domain name in connection with the offering of goods or services FR eurobiol.fr FR rambolitrain.fr FR palaiseau.fr Legitimate interest: Is known by an identical name or one related to the domain name FR m3.fr FR palomas.fr Absence of any legitimate interest on behalf of the Holder: FR michelpiron.fr FR foehnxrh.fr FR vm.fr FR ltb-france.fr Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 19 19

20 Holder s lack of good faith Article R of the Decree of 1 August 2011 The College has considered that the Holder is in bad faith if 1. It has obtained or requested the domain name primarily in order to sell, lease or transfer it and not to actually use it (see following pages); 2. It has obtained or requested the domain name in order to damage the reputation (see following pages) of the Claimant or of a product or service assimilated with that name; 3. It has obtained or requested the domain name primarily for the purpose of take advantage of the Claimant s reputation by creating confusion in the mind of the consumer (see following pages). Non-exhaustive list! W h a t e v e r t h e c i r - cumstances, if the Holder s lack of good faith is established, the College will grant the redress. Other indications of evidence of a lack of good faith are taken into consideration by the College (see below). Benchmark decisions Domain name registered in order to disrupt business activities: FR reminiscence-paris.fr Domain name registered to prevent its registration by a rights holder: FR leclerc-pharmacie-discount.fr FR cecileduflot.fr Bad faith established on the basis of a body of evidence: FR lab-merieux.fr FR calonneduteilleul-avocat.fr Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 20 20

21 Bad faith Interpretation of Article R paragraph 1 of Decree of 1 août 2011 The College must 1. Determine if the Holder can furnish proof of operation of the domain name prior to its proposed sale If so, the criterion of a lack of good faith cannot be retained. 2. Consider whether the proposal to sell, lease or transfer the domain name is the main goal of the Holder If so, the criterion of a lack of good faith may be retained. Benchmark decisions Domain name registered primarily for the purpose of selling it: FR louis-dreyfus.fr FR lacentraleduparticulier.fr FR vonage.fr FR stada.fr FR pharmaprix.fr Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 21 21

22 Bad faith Interpretation of Article R paragraph 2 of Decree of 1 août 2011 The College must 1. Consider whether the domain name affects the goodwill of the Claimant OR that of an equivalent product or a service 2. Determine whether a prejudice may be caused in the minds of consumers (affecting product awareness, brand awareness, reputation of the Claimant, etc.). If so, the criterion of a lack of good faith may be retained. Benchmark decisions Domain name registered in order to damage the reputation of the Claimant or that of a product or service assimilated with that name: FR base-loisirs-creteil.fr FR lalaitiere.fr FR adopteunmecgratuit.fr FR alexisdurand.fr FR etreenceinte.fr Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 22 22

23 Bad faith Interpretation of Article R paragraph 3 of Decree of 1 août 2011 The College must 1. Determine whether the domain name benefits from the reputation of the Claimant or that of a product or service assimilated with its name 2. Consider, on the basis of the documents in proof, whether the domain name creates a likelihood of confusion in the minds of consumers (product awareness, brand awareness, reputation of the Applicant, etc.) If so, the criterion of a lack of good faith may be retained. A French Holder cannot ignore the reputation of large companies located on French territory. Benchmark decisions Domain name registered primarily for the purpose of benefitting from the reputation of the Complainant by creating confusion in the minds of consumers: FR societeairfrance.fr FR cic-france.fr FR carrefour-france.fr FR pataugas-soldes.fr FR ria-france.fr... Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 23 23

24 Must-read sections SYRELI platform: SYRELI decisions: SYRELI statistics: Parl Expert platform: Parl Expert decisions: Parl Expert statistics: parl-alternative-dispute-resolution-procedures/scope-infography.html Legal booklets : Guide for rights holders Guide for domain name holders Booklet «Dispute resolutions made easy» The previous editions of ADR Trends 2015 : 1st quarter 2nd quarter 3rd & 4th quarters 2017 : 1st semester Association Française de Nommage Internet en Coopération contact@afnic.fr Twitter Facebook : afnic.fr 24 24