Self-represented complainant could not keep his story straight
A panelist at the Canadian International Internet Dispute Resolution Centre (CIIDRC) has determined that Jeremy Labreche, operating as Addison Electronique Entreprise Inc., attempted reverse domain name hijacking in a dispute over the domain addison-electronique.com.
The dispute between the parties has been ongoing for some time. The respondent filed a lawsuit against the complainant immediately before the complainant submitted a UDRP complaint. Because a legal action was pending, the panel had grounds to dismiss the UDRP complaint outright. Instead, the panelist, Nathalie Dreyfus, issued a detailed decision and expressly found that the complainant’s conduct amounted to reverse domain name hijacking.
The matter is complicated by family relationships and a long-running commercial history. The complainant represented himself and presented a case that the panel found inconsistent in multiple material respects. The panel’s analysis highlighted several contradictions and verifiable facts that undermined the complainant’s assertions and supported a finding of bad faith attempt to use the UDRP to obtain the domain.
Key issues identified by the panel included the following:
First, the complainant’s own descriptions of family history and business connections were inconsistent. At various points he claimed that his grandfather owned the original Addison stores until 2002, that his father founded Maddison Électronique in 1994, and that he was the respondent’s “direct cousin” with family ties to the ADDISON name that date to the late 1930s. Those assertions suggest that the complainant had personal, firsthand knowledge of the respondent’s and its predecessors’ use of the Addison name long before the complaint was filed.
Second, the domain’s creation date—May 4, 2001—was a matter of public record and easily verifiable through WhoIs data prior to filing. That timeline is incompatible with the complainant’s claim that the respondent registered the domain in bad faith more recently.
Third, the complainant’s claimed trademark rights did not support a finding of prior rights that would justify the complaint. The record showed at best a pending trademark application filed on October 6, 2025 and a minority, non-controlling shareholding in a company that owns a 2011 trademark registration. Those limited interests could not plausibly establish that the respondent registered the domain in bad faith in 2001.
Fourth, the complainant described his own domain addisonelectronique.com as having been active “for many years” and referred to a broader portfolio of similar names as evidence of a longstanding interest in the Addison brand. The panel verified that addisonelectronique.com was actually registered only on November 29, 2024, shortly before the dispute escalated, and no reliable evidence supported earlier registration dates for the other domains. Misrepresenting the age and continuity of an online presence to bolster claimed rights was a factor weighing in favor of reverse domain name hijacking.
Fifth, the complainant’s filings contained additional internal contradictions that went to the heart of the UDRP elements he was required to prove. He described the entity identified by NEQ 2281364051 inconsistently—on the one hand as a federally incorporated company, and on the other as an unincorporated Entreprise Individuelle. He also contradicted himself about the nature of his business, alternately claiming it operated in “the exact same sector” as the respondent and in “a fundamentally different sector.” Those inconsistencies undermined the credibility of the complaint and further supported the panel’s conclusion that the complaint was not a bona fide invocation of the UDRP.
After reviewing the evidence and the parties’ submissions, the panel concluded that the complaint lacked the factual foundation required to prove the elements of a successful UDRP claim and that the complainant pursued the proceeding in bad faith. The finding of reverse domain name hijacking reflects the panel’s view that the complainant sought to use the UDRP process improperly to try to take control of a domain that the respondent had lawfully held since 2001.
The decision serves as a reminder that panels will assess not only the legal merits of a complaint but also the complainant’s conduct, credibility, and the verifiable historical record. Misstatements about registration dates, inconsistent descriptions of corporate status or business activity, and attempts to proceed while parallel litigation is pending can all weigh heavily against a complainant and lead to a finding of reverse domain name hijacking.
Case details and the panel decision were publicly available through the CIIDRC docket and related summaries reported by industry observers.