Westmore · UDRP DecisionZiprecrulter.net
The Panel ordered transfer of <ziprecrulter.net> to Ziprecruiter Inc. It found the domain confusingly similar to the ZIPRECRUITER trademark because it replaced the letter “i” with “l,” a classic form of typosquatting. The Respondent lacked rights or legitimate interests, and the domain’s prior imitation of an official ZIPRECRUITER website and apparent phishing use supported findings of bad-faith registration and use.
The timeline behind ziprecrulter.net
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The case illustrates how a visually subtle, one-letter substitution can satisfy confusing similarity and also contribute to a finding of deliberate targeting. The combination of typo-based imitation, copied website presentation, an identical logo, apparent phishing, and the absence of any legitimate explanation supported transfer even though the domain was inactive by the time described in the decision.
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. Grace Phillips Case No. D2018-0945 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 Grace Phillips of Charleston, South Carolina, United States. 2. The Domain Name and Registrar The disputed domain name <ziprecrulter.net> 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 it has used since 2010 and which is the subject of numerous trademark registrations, including the following: ZIPRECRUITER 3934310 Registered March 22, 2011 United States ZIPRECRUITER 015070873 Registered June 13, 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 February 23, 2018 and resolves to an inactive website. 5. Parties’ Contentions A. Complainant Complainant contends that the disputed domain name is confusingly similar to the 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 The Respondent did not reply to the 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 strong 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. 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 in 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.net> be transferred to the Complainant. Lynda J. Zadra-Symes Sole Panelist Date: June 21, 2018
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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