Skip to content
Home » What the BVLGARI Case Teaches About Domain Extension Strategy

What the BVLGARI Case Teaches About Domain Extension Strategy

Not all domain extensions carry the same level of risk. Since the launch of the new gTLD program in 2012, we have consistently argued that not all top-level domains deserve the same level of attention. Given the sheer number of TLDs already available, and the many more likely to appear in the future, it is neither realistic nor desirable to register a trademark under every possible extension. Instead, an effective protection strategy requires careful prioritisation based on the company’s business sector, the budget allocated to brand protection, the tools available, and the level of risk involved. Some extensions are unlikely ever to be used convincingly, while others can significantly increase the credibility of a fraudulent scheme.

A legally straightforward decision. A recent UDRP decision (Bulgari S.p.A. c. xiaoye wang, WIPO Case D2026-2222) provides an excellent illustration of this principle. From a legal standpoint, the case raised no particular difficulty. The disputed domain names, <bvlgari.bar> and <bvlgari.baby>, incorporated the BVLGARI trademark in its entirety and were not actively used, remaining subject to the well-established doctrine of passive holding. Their transfer was therefore unsurprising.

Extensions that tell a story. The real interest of the decision lies not in its legal reasoning but in the domain name strategy it highlights. Today, the choice of a top-level domain is no longer merely technical. An extension can reinforce the impression that a website is official, suggest a specific activity, or make a fraudulent domain name considerably more convincing. In this case, the .BAR extension clearly relates to BVLGARI’s hospitality business. The company operates several luxury hotels around the world, where bars and restaurants form an integral part of the customer experience. Consequently, the domain name <bvlgari.bar> appears immediately plausible. From the perspective of an Internet user, it could easily be perceived as the official website of Bulgari’s hospitality activities.

A more nuanced connection. The .BABY extension presents a less obvious case. Nevertheless, Bulgari is not entirely disconnected from this field. On the one hand, the company has long marketed its Petits et Mamans fragrance. On the other, it has partnered with Save the Children for many years and supports children’s programmes through a dedicated jewellery collection. Although .BABY does not display the same degree of sectoral consistency as .BAR, it cannot be regarded as entirely unrelated to the brand’s ecosystem.

The impossibility of comprehensive protection. For many years, companies attempted to maximise defensive registrations. This approach made sense when the domain name space was relatively limited. It has become far more difficult in an environment where hundreds of extensions are available and new ones continue to emerge. Inevitably, choices must now be made.

First criterion: business sector. The first consideration is the nature of the business itself. A bank will naturally pay particular attention to extensions such as .BANK, .LOAN or .FINANCE. An airline may prioritise .TRAVEL or .FLIGHTS. The examples are virtually endless. The most sensitive extensions are those that make a fraudulent use of a domain name appear legitimate because they correspond directly to the goods or services offered by the trademark owner.

Second criterion: geography. Prioritisation also depends on the geographical footprint of the business. Country-code top-level domains (ccTLDs) remain essential in the jurisdictions where a company operates or plans to expand. The same applies to geographic extensions such as .PARIS, .LONDON or .TOKYO, where the city itself reinforces the credibility of a website targeting local customers. Sector-specific and geographic considerations therefore complement each other in building a more refined assessment of risk.

Third criterion: available protection tools. Prioritisation should also take into account the protection mechanisms currently available. For example, the .BAR extension is now included in GlobalBlock, a blocking service that prevents the registration of a protected label across a large portfolio of participating domain extensions (currently 841), whereas .BABY is not. The decision also highlights another important point: a protection strategy should consider not only which extensions deserve protection, but also the different forms under which a brand is used. In Bulgari’s case, both BULGARI and BVLGARI coexist and should therefore be taken into account. More broadly, the case demonstrates that domain name protection strategies should be reviewed regularly as businesses evolve, new extensions are introduced and additional protection mechanisms become available.

A strategy in constant evolution. Ultimately, domain name protection can no longer be regarded as a simple registration policy. It has become a genuine risk management exercise based on prioritisation, continuous monitoring and the ongoing adaptation of protection strategies. A domain extension is valuable not merely because of its popularity, but because of the credibility it lends to a fraudulent use. Defensive registrations, blocking mechanisms, monitoring services and UDRP proceedings are no longer alternative solutions; together, they form the different layers of a comprehensive brand protection strategy.

About IP Twins

IP Twins assists trademark owners in protecting their digital identity through a comprehensive approach combining domain name portfolio management, domain monitoring, blocking services, the fight against cybersquatting, phishing and other forms of online abuse, as well as UDRP proceedings and numerous other domain name dispute resolution mechanisms. The objective is not merely to recover abusive domain names, but to implement a protection strategy tailored to each client’s business activities, markets and specific risk profile.