L’utilisation d’un nom de domaine ainsi que celle des balises méta dans les métadonnées d’un site Internet constituent-ils de la publicité susceptible d’être considérée comme trompeuse au sens de l’article 2 de la directive 84/450/CEE du Conseil, du 10 septembre 1984, en matière de publicité trompeuse et de publicité comparative (JO L 250, p.17) et de l’article 2 de la directive 2006/114/CE du 12 décembre 2006, en matière de publicité trompeuse et de publicité comparative.
Une première société avait fait enregistrer en 2007 le nom de domaine «www.bestlasersorter.com». Une seconde société concurrente avait déposé en 2008 une marque figurative « Benelux BEST » puis avait fait constater par voie d’huissier que la première avait intégré dans ses méta les mots suivants : «Helius sorter, LS9000, Genius sorter, Best+Helius, Best+Genius, […] Best nv ». Elle considérait que ces mots portaient atteinte à sa marque et à son nom commercial et constituaient des infractions à la réglementation en matière de publicité trompeuse et comparative ainsi qu’à celle relative à l’enregistrement illicite des noms de domaine. Elle a assigné en conséquence sa concurrente pour obtenir le retrait de ces mots.
La CJUE a finalement été saisie d’une question préjudicielle visant à déterminer si l’article 2, point 1, de la directive 84/450 et l’article 2, sous a), de la directive 2006/114 doivent être interprétés en ce sens que la notion de «publicité», telle que définie par ces dispositions, couvre, dans une situation telle que celle en cause dans l’affaire au principal, premièrement, l’enregistrement d’un nom de domaine, deuxièmement, l’utilisation d’un tel nom et, troisièmement, l’utilisation de balises méta dans les métadonnées d’un site Internet.
La Cour considère tout d’abord que « La notion de «publicité», au sens des directives 84/450 et 2006/114, ne saurait être interprétée et appliquée de façon à ce que des démarches entreprises par un professionnel en vue de promouvoir la vente de ses produits ou de ses services, qui sont susceptibles d’influencer le comportement économique des consommateurs et, partant, d’affecter les concurrents de ce professionnel, échappent aux règles de concurrence loyale imposées par ces directives. »
La Cour décide ensuite que l’enregistrement d’un nom de domaine ne peut être qualifié de publicité. Il en va en revanche différemment de l’utilisation de ce nom de domaine qui « a manifestement pour but de promouvoir la fourniture des produits ou des services du titulaire du nom de domaine ».
Enfin, en ce qui concerne les balises méta, elle juge que « Dans la mesure où l’utilisation de balises méta correspondant aux dénominations des produits d’un concurrent et au nom commercial de celui-ci dans le code de programmation d’un site Internet a donc pour conséquence qu’il est suggéré à l’internaute, qui introduit l’une de ces dénominations ou ce nom comme mot de recherche, que ce site a un rapport avec sa recherche, une telle utilisation doit être considérée comme une forme de communication, au sens de l’article 2, point 1, de la directive 84/450 et de l’article 2, sous a), de la directive 2006/114. » (CJUE, 11 juill.2013, C-657/11, Belgian Electronic Sorting Technology NV contre Bert Peelaers, Visys NV).
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