Westmore · UDRP DecisionRandstadholdlng.com
The Panel ordered transfer of <randstadholdlng.com>. It found the Domain Name confusingly similar to the Complainant’s RANDSTAD mark, that the Respondent lacked rights or legitimate interests, and that the Domain Name had been registered and used in bad faith as a typosquatted version of the Complainant’s corporate and email domain. Evidence that it was used to seek information from the Complainant’s personnel supported the findings on the second and third elements.
The timeline behind randstadholdlng.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
Westmore reconstructs the full history behind randstadholdlng.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that UDRP bad-faith use is not limited to website content. A domain may be inactive as a website yet still support transfer where it is used for deceptive email communications. The close imitation of a corporate email domain, combined with evidence of attempts to obtain information from employees, was central to the Panel’s findings.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
WIPO Arbitration and Mediation Center ADMINISTRATIVE PANEL DECISION Randstad Holding N.V. v. Laura Henry Case No. D2016-1720 1. The Parties The Complainant is Randstad Holding N.V. of Diemen, Netherlands, represented by Chiever B.V., Netherlands. The Respondent is Laura Henry of Brookline, Massachusetts, United States of America. 2. The Domain Name and Registrar The disputed domain name <randstadholdlng.com> (the “Domain Name”) is registered with Wild West Domains, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 24, 2016. On August 24, 2016, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On August 24, 2016, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that the Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on September 1, 2016. In accordance with the Rules, paragraph 5, the due date for Response was September 21, 2016. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 22, 2016. The Center appointed Dawn Osborne as the sole panelist in this matter on October 6, 2016. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant owns the trade mark RANDSTAD for recruitment services in, inter alia , the United States of America (where the Respondent is based) with the Complainant’s first use there recorded as 1993. The Complainant uses <randstadholding.com> for the email addresses used by its employees. The Domain Name which appears to be a misspelling of <randstadholding.com> was registered in 2016 and it has been used to attempt to obtain sensitive information from the Complainant, but it does not resolve to a web site. 5. Parties’ Contentions A. Complainant The Complainant’s contentions can be summarized as follows: The Complainant was founded in the Netherlands in 1960 and is the world’s second largest recruitment and HR services company. It has used the mark RANDSTAD worldwide for many years and currently operates in 40 countries through 4,496 branches. It owns the trade mark RANDSTAD throughout the world for recruitment and employment agency services. It also owns <randstad.com> and has web sites in each of the territories in which it operates. The Domain Name incorporates the RANDSTAD mark. The addition of “holdlng” and “.com” does not alter its confusing similarity to the RANDSTAD mark which is the distinctive part of the Domain Name. The Respondent has no rights or legitimate interest in the Domain Name. The Complainant acquired its exclusive rights in the RANDSTAD mark for recruitment services well before the Respondent registered the Domain Name. The Respondent has no connection or affiliation with the Complainant and the Complainant has never granted the Respondent consent to use the RANDSTAD mark in any manner. The Respondent is not using the Domain Name in connection with a bona fide offering of services, nor is the Respondent known by the Domain Name. The Domain Name was registered and is being used in bad faith. The Respondent has misused the Domain Name to send phishing emails to the Complainant in order to obtain sensitive or financial information. The Respondent has not answered a warning letter. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical and/or Confusingly Similar The Domain Name consists of the Complainant’s RANDSTAD mark (which is registered in, inter alia the United States of America and the European Union for recruitment services with first use in the United States of America recorded as 1993), a misspelling of the dictionary word “holding” as “holdlng” and the generic Top-Level Domain (“gTLD”) “.com”. The Panel agrees that the addition of a misspelling of the word “holding” as “holdlng” to the Complainant’s mark does not prevent the Domain Name from being confusingly similar to the Complainant’s trade mark pursuant to the Policy. The fact that the Complainant’s name is Randstad Holding NV and it uses <randstadholding.com> for email addresses adds to any likely confusion. The gTLD “.com” does not serve to distinguish the Domain Name from the RANDSTAD mark which is the distinctive component of the Domain Name. Accordingly, the Panel holds that the Domain Name is confusingly similar to a mark in which the Complainant has rights. As such the Panel holds that the Complainant has satisfied the first limb of the Policy. B. Rights or Legitimate Interests The Respondent does not appear from the evidence to be commonly known by the Domain Name or making a legitimate noncommercial or fair use of the name. The Domain Name appears to be a typosquatted version of the Complainant’s domain name used for email addresses which reflects the Complainant’s corporate name chosen in the hope that someone might mistakenly see an email coming from the Domain Name as a genuine email from the Complainant. The Complainant has provided evidence of use of the Domain Name as a phishing device to get information from the Complainant’s personnel. As such the Domain Name was registered for deceptive purposes which cannot form the basis for a right or legitimate interest. As such the Panel finds that the Respondent does not have rights or legitimate interests in the Domain Name and the Complainant has satisfied the second limb of the Policy. C. Registered and Used in Bad Faith Typosquatting may be evidence of relevant bad faith registration and use. The mimicking of the Complainant’s corporate name and domain name used for the Complainant’s email addresses shows knowledge of the Complainant and its trade marks on the part of the Respondent. Given the similarity with the Complainant’s corporate name and email addresses and the typosquatting nature and non sensical spelling of the Domain Name is difficult to think of a reason why the Domain Name could have been registered except for deceptive purposes and the Respondent has not answered the Complainant or given any satisfactory explanation why it has registered the Domain Name. The Complainant has also provided evidence that the Domain Name has been used for the purposes of trying to obtain information from the Complainant’s employees. As such the Domain Name has clearly been registered and used in bad faith for the purposes of causing and taking advantage of confusion on the Internet and the Panel holds that the Complainant has satisfied the third limb of the Policy. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the Domain Name, <randstadholdlng.com> be transferred to the Complainant. Dawn Osborne Sole Panelist Date: October 18, 2016
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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