Westmore · UDRP DecisionShrm-conference.org
The Panel ordered transfer of <shrm-conference.org>. It found the domain confusingly similar to the Complainant's SHRM trademark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith through a website that impersonated the Complainant and misleadingly presented information concerning its 2020 annual conference for commercial gain.
The timeline behind shrm-conference.org
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 shrm-conference.org — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates a straightforward conference-impersonation pattern: an established mark was combined with a term closely describing the trademark owner's event, and the resulting domain was used for event registration and housing content that suggested an official relationship. The website's targeted content was important not only to bad faith but also to the rejection of any bona fide or legitimate use.
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 Society for Human Resource Management v. Domains By Proxy, LLC / Admin Conferences Case No. D2020-0443 1. The Parties The Complainant is Society for Human Resource Management, United States of America, represented by Gavin Law Offices, PLC, United States of America (“United States”). The Respondent is Domains By Proxy, LLC, United States / Admin Conferences, India. 2. The Domain Name and Registrar The disputed domain name <shrm-conference.org> (the “Domain Name”) is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 25, 2020. On February 25, 2020, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On February 25, 2020, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to the Complainant on February 26, 2020, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on February 28, 2020. The Center verified that the Complaint together with the amended 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 March 20, 2020. In accordance with the Rules, paragraph 5, the due date for Response was April 9, 2020. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 14, 2020. The Center appointed Mathias Lilleengen as the sole panelist in this matter on April 17, 2020. 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 is a large human resources professional society, representing more than 300.000 members in over 165 countries. The Complainant has 575 affiliated chapters within the United States, and subsidiary offices in China, India, and United Arab Emirates. It offers human resources management products and services, including association services, training courses and materials, certification programs, conferences and meetings, and numerous resources for professionals in the field of human resources management. The Complainant’s largest conference is its Annual Conference & Exposition. The SHRM Annual Conference & Exposition has been held annually for decades. The upcoming annual conference is from June 28 to July 1, 2020 in San Diego, California, the United States. The Complainant has United States federal trademark registrations in SHRM, such as United States registration No. 1668891 registered on December 17, 1991, and No. 2154782 registered on May 5, 1998. The Complainant has also registered its mark in over thirty other countries than the United States. The Complainant has also registered dozens of domain names that incorporate the Complainant’s trademarks, including: <shrm.org> and <shrm.com>, the former registered as long back as May 9, 1995. According to the Registrar, the Domain Name was registered on January 29, 2019. At the time of the Complaint and at the time of drafting the Decision, the Domain Name redirected to a webpage that misleads visitors to believe it stems from the Complainant or that there is a relationship between the Respondent and the Complainant. 5. Parties’ Contentions A. Complainant The Complainant has registered trademark rights in SHRM. The Complainant submits that the Complainant’s trademark is distinctive and renowned in the human resources industry. The Domain Name adopts the Complainant’s trademark with the addition of “-conference”. The addition is insufficient to avoid a finding of confusing similarity under the first element of the UDRP. The Complainant submits that the Respondent has no rights or legitimate interests in the Domain Name. The Respondent has not been allowed by the Complainant to make any use of its trademark. The Domain Name redirected to a website that does not meet the requirements for a bona fide offering of goods. The Respondent is using the Domain Name in order to impersonate the Complainant and/or mislead visitors that a relationship exists between the Respondent and the Complainant. Internet users that visit the website will see information regarding registration and housing for the Complainant’s “SHRM 2020 Annual Conference & Exposition”. The Respondent attempts to pass itself off as the Complainant by referring to the Complainant in the “About Us” section and by using the Complainant’s trademark. The Respondent is not an approved housing provider for the “2020 SHRM Annual Conference & Exposition”, nor does any affiliation or relationship exist between the Complainant and the Respondent. The Complainant argues that the Respondent is seeking commercial gain by establishing a website imitating the Complainant’s webpage with information about the Complainant’s “2020 Annual Conference & Exposition”. The Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of the Domain Name. The Complainant underlines that there is no relationship between the Complainant and the Respondent, and the Complainant has not given the Respondent permission to use the Complainant’s trademark. Moreover, the Respondent has concealed its identity. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar The Complainant has established rights in the trademark SHRM. The test for confusing similarity involves the comparison between the trademark and the Domain Name. In this case, the Domain Name incorporates the Complainant’s trademark with the addition of “-conference”. The addition does not prevent a finding of confusing similarity. For assessing confusing similarity, it is permissible for the Panel to ignore the generic Top-Level Domain “.com”, see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.11 . The Panel finds that the Domain Name is confusingly similar to a trademark in which the Complainant has rights in accordance with paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests The Complainant has made unrebutted assertions that is has not granted any authorization to the Respondent to use the Complainant’s trademark. Based on the evidence, the Respondent is not affiliated or related to the Complainant in any way. There is no evidence that the Respondent has registered the Domain Name as a trademark or acquired unregistered rights. The way the Respondent has used the Domain Name to impersonate the Complainant and/or mislead visitors that a relationship exists between the Respondent and the Complainant, is not bona fide . The Panel finds the Respondent has no rights or legitimate interests in respect of the Domain Name in accordance with paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith Taking into account the Respondent’s use of the Domain Name, the Panel concludes that the Respondent knew of the Complainant and its business when the Respondent registered the Domain Name. The Respondent has attempted to attract Internet users to the Respondent’s website for commercial gain by creating a likelihood of confusion with the Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s website. The Complainant has not given the Respondent permission to use the Complainant’s trademark. The Respondent’s use misleads Internet users. The use of privacy protection service and the fact that the Respondent has not replied to the Complaint, further point to bad faith. The Panel concludes that the Domain Name was registered and is being used in bad faith, within the meaning of paragraph 4(a)(iii) 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, <shrm-conference.org> be transferred to the Complainant. Mathias Lilleengen Sole Panelist Date: April 20, 2020
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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