Westmore · UDRP DecisionHmrctaxreturnform.com
The Panel ordered transfer of <hmrctaxreturnform.com>. It found the domain confusingly similar to the Complainant’s HMRC trademark because the mark remained recognizable and the added words “tax return form” described a document closely associated with the Complainant. The Respondent lacked rights or legitimate interests, and the Panel found bad-faith registration and use based on the distinctive HMRC mark, the domain’s tax-related wording, the Respondent’s inferred knowledge of the Complainant, its apparent attempt to attract users seeking the Complainant, and third-party warnings concerning harmful or illegal use.
The timeline behind hmrctaxreturnform.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
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The decision illustrates a strong targeting pattern where a distinctive government acronym is combined with words describing the agency’s core public function. The descriptive additions did not dilute similarity; instead, they helped demonstrate knowledge of and targeting of the trademark owner. Third-party security warnings supplied additional support for bad faith, while the Respondent’s default left the lack-of-rights case unrebutted.
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 The Commissioners for HM Revenue and Customs v. Withheld for Privacy Purposes, Privacy service provided by Withheld for Privacy ehf / Rolce Rolley Case No. D2021-1245 1. The Parties The Complainant is The Commissioners for HM Revenue and Customs, United Kingdom (“UK”), represented by Demys Limited, UK. The Respondent is Withheld for Privacy Purposes, Privacy service provided by Withheld for Privacy ehf, Iceland / Rolce Rolley, UK. 2. The Domain Name and Registrar The disputed domain name <hmrctaxreturnform.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 22, 2021. On April 22, 2021, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 22, 2021, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name, which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to the Complainant on April 26, 2021 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 April 26, 2021. 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 April 28, 2021. In accordance with the Rules, paragraph 5, the due date for Response was May 18, 2021. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 25, 2021. The Center appointed Adam Samuel as the sole panelist in this matter on June 4, 2021. 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 non-ministerial department of the UK Government, responsible for the collection of taxes. It provides information about its activities through a website contained within the UK Government’s official portal which can also be accessed through the domain name <hmrc.gov.uk> The Complainant owns a UK trademark number 2471470, with a filing date of November 5, 2007 and registered on March 28, 2008, for the name HMRC by which it is commonly known. The disputed domain name was registered on April 6, 2021. The Google Safe Browsing service currently reports that the disputed domain name is unsafe in that it contains harmful content including pages trying to trick visitors into sharing personal information or downloading software. McAfee Web Advisor gives a similar warning to Internet users seeking to view the Respondent’s website. 5. Parties’ Contentions A. Complainant The disputed domain name only differs from the Complainant’s trademark by the addition of the dictionary words “tax” “return” and “form”. These words are inherently associated with the Complainant and its activities. The Complainant’s mark is the most prominent, dominant and distinctive element of the disputed domain name. When combined with the Complainant’s well-known mark, the adornment “tax return form” does not dispel any possibility of confusion but increases the potential for confusion among Internet users. The generic Top-Level Domain (“gTLD”) “.com” is required only for technical reasons and can be ignored for the purposes of comparison of the disputed domain name to the Complaint’s marks. Equally, the hyphens featured in the disputed domain name do not further distinguish it from the Complainant’s marks. The Respondent has not been commonly known by the names “hmrc” or “hmrc tax return form” prior to or after the disputed domain name’s registration. The Respondent has not received any permission, consent or acquiescence from the Complainant to use its marks or name in association with the registration of any domain name. The Respondent does not own any trademarks that incorporate or are similar or identical to the terms “hmrc” or “hmrc tax return form”. The disputed domain name has been flagged as being used for phishing or other criminality by a reputable third party, Google’s Safe Browsing Service. In any event, this is a case of passive holding. The Complainant’s trademark is very distinctive and there is a high degree of implausibility of any good faith use to which the disputed domain name could be put. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings To succeed, the Complainant must demonstrate that all of the elements listed 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 the Complainant has rights; and (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. A. Identical or Confusingly Similar The disputed domain name consists of the Complainant’s distinctive trademark HMRC, which is also the commonly-used UK acronym for the Complainant, followed by “tax return form”, a frequently-used description of the document that UK taxpayers file with the Complainant as a way of reporting to the Complainant their liability to tax and the generic gTLD “.com”. The gTLD is irrelevant here because it does not affect the meaning of the disputed domain name and is a standard registration requirement. See section 1.11 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”). The Complainant’s trademark is an acronym with no ordinary meaning other than to describe the Complainant. The words “tax” “return” and “form” describe what most UK taxpayers regard as the key document that they send the Complainant to report their tax liability. The addition of dictionary words like “tax”, “return”, and “form” to a trademark does not prevent the confusing similarity that exists between the disputed domain name and the Complainant’s trademark. Section 1.8 of the WIPO Overview 3.0 says: “Where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element.” For all these reasons, the Panel concludes that the disputed domain name is confusingly similar to the Complainant’s trademark. B. Rights or Legitimate Interests The Respondent is not called “hmrc”, “tax”, “return”, or “form” or anything similar. There is no evidence that the Complainant has ever authorized the Respondent to use its trademarks. The Respondent does not appear to have used the disputed domain name for any legitimate purpose that can be identified. Based on the available record, and in the absence of any response on this point, the Panel concludes that the Respondent has no rights or legitimate interests in respect of the disputed domain name. C. Registered and Used in Bad Faith The Complainant’s trademark HMRC is a word without any ordinary meaning except as the common acronym of the Complainant. By virtue of the Complainant’s function, the HMRC trademark is in extremely common usage in the UK to describe the Complainant. As such, it is highly distinctive. In the disputed domain name, the Respondent has combined the Complainant’s trademark with a reference that is widely used by UK citizens to report their tax liability to the Complainant. From this, the Panel concludes that the Respondent knew of the Complainant’s activities when it registered the disputed domain name. The Respondent appears to have done this to disrupt the Complainant’s activities by attracting to its own website Internet users seeking the Complainant’s website. See also section 3.3 of the WIPO Overview 3.0 . For these reasons, the Panel concludes that the Respondent registered and is using the disputed domain name in bad faith: UDRP, paragraph 4(b)(iv). This conclusion is reinforced by the warnings of reputable third-party entities about the illegal use, which the Respondent has made of the disputed domain name. 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 <hmrctaxreturnform.com> be transferred to the Complainant. Adam Samuel Sole Panelist Date: June 4, 2021
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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