WIPO D2000-0622 · decided 23 August 2000
K2r Produkte AG v. Jeremie Trigano
The parties
- Complainant
- K2r Produkte AG
- Respondent
- Jeremie Trigano
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel found k2r.com virtually identical, and so confusingly similar, to the K2r trademark, while noting that the parties' different fields of activity made actual confusion unlikely. |
| 4(a)(ii) No rights or legitimate interests | The complainant failed this element. The panel accepted that k2r.com was a reasonable derivative of Kirk & Rosie Rich, the Paris store of Jeremie Trigano's mother, registered before notice of the dispute. |
| 4(a)(iii) Registered and used in bad faith | The panel found no evidence of any paragraph 4(b) circumstance or any other bad faith, and rejected the alleged pattern of cybersquatting as unsupported by the evidence. |
Why does K2r Produkte matter for a complaint today?
In K2r Produkte AG v. Jeremie Trigano, WIPO Case No. D2000-0622, a three-member WIPO panel dismissed the complaint over k2r.com and, by a majority, found reverse domain name hijacking. K2r Produkte AG had lost k2r.com when its German subsidiary failed to pay the maintenance fee. Jeremie Trigano registered it on 7 March 2000 for his mother's Paris boutique, Kirk & Rosie Rich, after failing to register KRR.com. Before filing, K2r Produkte AG had his explanation in a letter from his lawyer and had obtained the store's business card. The majority held that the complainant had ascertained the facts showing a legitimate interest and still filed allegations of cybersquatting that the evidence did not support. One panelist dissented on this point. He thought the complainant genuinely, though wrongly, believed the explanation was false, given the unusual combination of letters and numeral. If you let a domain name lapse and someone else registers it for their own business, a UDRP complaint is the wrong tool. Section 4.16 of the WIPO Overview 3.1 lists clear knowledge of respondent rights as a reason for a hijacking finding, and section 2.10.2 asks for a credible explanation when a domain name is an acronym.
What does the WIPO Overview 3.1 say?
The WIPO Overview 3.1 summarises how WIPO panels decide each issue. These sections cover the same point of law.
- Section 4.16: In what circumstances will panels issue a finding of Reverse Domain Name Hijacking (RDNH)? The Overview cites this decision here.
- Section 2.2: What qualifies as prior use, or demonstrable preparations to use the domain name, in connection with a bona fide offering of goods or services? The Overview cites this decision here.
- Section 2.10: Does a respondent have rights or legitimate interests in a domain name comprised of a dictionary word/phrase or acronym? The Overview cites this decision here.
Who decided the case?
A three-member panel decided the case on 23 August 2000: Alan L Limbury (presiding), Diane Cabell, Tony Willoughby.
Read the decision
The full text is published by the WIPO Arbitration and Mediation Center. We summarise it here; the decision itself is the authority.
Summarised by Gergana Dimitrova, who worked at the WIPO Arbitration and Mediation Center from 2018 to 2021 and sits as a domain name panelist at the Czech Arbitration Court. Checked against the published decision on 23 October 2026. Full background.
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