Westmore · UDRP DecisionZiprecrulter.com
The Panel ordered transfer of <ziprecrulter.com>. It found the domain confusingly similar to the ZIPRECRUITER mark because replacing the letter “i” with “l” was classic typosquatting. The Panel also found no rights or legitimate interests and concluded that the domain had been registered and used in bad faith, relying particularly on the Respondent’s likely awareness of the earlier mark and the domain’s previous use for a website resembling an official Ziprecruiter website and displaying an identical logo.
The timeline behind ziprecrulter.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
This decision illustrates a straightforward typosquatting case strengthened by evidence of website imitation. The bad-faith conclusion did not rest on inactivity alone: the Panel considered the earlier trademark rights, the near-identical domain, the Respondent’s likely awareness, the prior use of an official-looking website and identical logo, and the apparent effort to exploit confusion for commercial gain.
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 Ziprecruiter, Inc. v. Harold Wright Case No. D2018-0944 1. The Parties The Complainant is Ziprecruiter, Inc. of Santa Monica, California, United States of America (“United States”), represented by SafeNames Ltd., United Kingdom of Great Britain and Northern Ireland (“United Kingdom”). The Respondent is Harold Wright of Wayne, New Jersey, United States. 2. The Domain Name and Registrar The disputed domain name <ziprecrulter.com> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 27, 2018. On April 27, 2018, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 27, 2018, 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 May 3, 2018. In accordance with the Rules, paragraph 5, the due date for Response was May 23, 2018. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 24, 2018. The Center appointed Lynda J. Zadra-Symes as the sole panelist in this matter on June 8, 2018. 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 Complainant is an American online recruitment company with marketing operations in the United States, Canada and the United Kingdom. Complainant is the owner of the mark ZIPRECRUITER which is the subject of numerous trademark registrations, including the following: ZIPRECRUITER 3934310 Registered March 22, 2011 United States ZIPRECRUITER 015070873 Registered June13 2016 European Union ZIPRECRUITER TMA979480 Registered August, 28, 2017 Canada Complainant also owns the domain names <ziprecruiter.com>, <ziprecruiter.co.nz>, <ziprecruiter.com.au>, <ziprecruiter.fr>, <ziprecruiter.co>, and <ziprecruiter.co.uk>. In addition, Complainant uses the mark ZIPRECRUITER in connection with its Facebook, Twitter and LinkedIn pages. The disputed domain name was registered on January 16, 2018 and resolves to a website with no content. 5. Parties’ Contentions A. Complainant Complainant contends that the disputed domain name is confusingly similar to Complainant’s mark, that Respondent has no rights or legitimate interests in respect of the disputed domain name and that the disputed domain name was registered and is being used in bad faith. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings In order to succeed in its claim, Complainant must demonstrate that all of the elements enumerated in paragraph 4(a) of the Policy have been satisfied: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (ii) Respondent has no rights or legitimate interests with respect to the disputed domain name; and (iii) the disputed domain name has been registered and used in bad faith. Paragraph 15(a) of the Rules instructs this Panel to decide a complaint “on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. A. Identical or Confusingly Similar Complainant has demonstrated that it owns rights in the trademark ZIPRECRUITER. The disputed domain name incorporates the words “zip” and “recrulter”. The latter term is a slight variation of the word “recruiter”, with the “i” replaced by an “l”. This is a classic example of “typosquatting” whereby the disputed domain name takes advantage of innocent mistakes likely to occur when Internet users mistype Complainant’s mark and are redirected to an alternative website. The substitution of the letter “i” with the letter “l” constitutes typosquatting and adds no distinctiveness. Accordingly, the Panel finds that the disputed domain name is confusingly similar to Complainant’s trademark. B. Rights or Legitimate Interests Complainant contends that Respondent is not a licensee or authorized user of Complainant’s mark and has never had a business relationship with Complainant. Complainant further contends that it has not authorized Respondent to register the disputed domain name. Respondent’s website at the disputed domain name is currently inactive but in the past, has been known to resolve to a website which had the same look and feel as an official website owned by the Complainant. Such activity is often used for “phishing” purposes and thus, cannot constitute a bona fide offering of goods and/or services. Complainant has found no evidence that Respondent is using the disputed domain name as a company name or has any other legal rights in the name. Respondent is not using the domain name in connection with a bona fide offering of goods or services. Respondent’s website at the disputed domain name does not include any substantive content. There appears to be no other reason for the registration and use of the disputed domain name than deception of Complainant’s customers. Respondent also failed to respond to Complainant’s cease-and-desist letters sent on March 8, 2018 and March 15, 2018. Accordingly, the Panel finds that Complainant has satisfied the requirement of paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy states circumstances which, if found, shall be evidence of the registration and use of the disputed domain name in bad faith: (i) circumstances indicating that the respondent has registered or acquired the domain name primarily for the purpose of selling, renting or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of the complainant, for valuable consideration in excess of the documented out of pocket costs directly related to the domain name; or (ii) the respondent has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that the respondent has engaged in a pattern of such conduct; or (iii) the respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the domain name, the respondent has intentionally attempted to attract, for commercial gain, Internet users to the respondent’s website or other on line location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location of a product or service on the respondent’s website or location. The disputed domain name was registered over six years after Complainant’s ZIPRECRUITER trademark was registered. A simple Google search retrieves Complainant’s mark as the first hit. Respondent resides in the United States, where Complainant is based and promotes its services. In addition, the content previously shown on Respondent’s website at the disputed domain name had the same overall look as an official ZIPRECUIRTER website and included an identical logo. Therefore, the record indicates that Respondent was most likely aware of Complainant’s trademark rights at the time of registering the disputed domain name and that consumer recognition in Complainant’s mark motivated Respondent to register the disputed domain name, which is virtually identical to Complainant’s mark, except for a typo. Respondent’s website at the disputed domain name fails to evidence any bona fide use and is not supported by any valid trademark to which Respondent has rights. Indeed, it appears the disputed domain name has been used for the purposes of “phishing” to deceive Complainant’s potential customers and attract Internet users for commercial gain. These facts are indicative of bad faith in the sense of paragraph 4(b) of the Policy. The Panel finds that Respondent has registered and used the disputed domain name in bad faith. 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 disputed domain name <ziprecrulter.com> be transferred to the Complainant. Lynda Zadra-Symes Sole Panelist Date: June 21, 2018
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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