Westmore · UDRP decision
WIPO · Case No. D2024-2255

Ihghelp.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <ihghelp.com> to Six Continents Limited. It found the domain confusingly similar to the Complainants’ IHG mark because it incorporated IHG with the additional term “help.” The Complainants made a prima facie showing that the Respondent lacked rights or legitimate interests, which the defaulting Respondent did not rebut. Bad faith was established because the case record indicated that the domain had been used for email impersonation, notwithstanding that it resolved to an inactive website.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2024-07-23
Panelist(s)
Lee, Ilhyung
Complainant
Six Continents Hotels, Inc. Six Continents Limited
Respondent
Chase Logan
Counsel
Douglas M. Isenberg
Disputed domain(s)
ihghelp.com
Domain history UDRP Intelligence

The timeline behind ihghelp.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 ihghelp.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of ihghelp.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates that an inactive website does not prevent a bad-faith finding when the domain is used for deceptive email. It also shows the risk created by combining a well-established mark with a support-oriented term such as “help,” particularly where the resulting domain is used to impersonate the trademark owner.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used in Bad FaithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2024-07-23
Panel
Lee, Ilhyung
Full decision
7 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Six Continents Hotels, Inc., Six Continents Limited v. Chase Logan Case No. D2024-2255 1. The Parties The Complainants are Six Continents Hotels, Inc., United States of America (“United States”) and Six Continents Limited, United Kingdom, represented by The GigaLaw Firm, Douglas M. Isenberg, Attorney at Law, LLC, United States. The Respondent is Chase Logan, United States. 2. The Domain Name and Registrar The disputed domain name <ihghelp.com> is registered with IONOS SE (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 1, 2024. On June 3, 2024, the Center transmitted to the Registrar a request for registrar verification in connection with the disputed domain name. On June 4, 2024, the Registrar transmitted to the Center its verification response disclosing registrant and contact information for the disputed domain name, which differs from the named Respondent (“REDACTED FOR PRIVACY / 1&1 Internet Inc.”) and contact information that appears in the Complaint. On June 7, 2024, the Center provided the Complainants with the registrant and contact information disclosed by the Registrar, and invited the Complainants to amend the Complaint. On June 7, 2024, the Complainants responded, stating that they do “not wish to make substantive amendments to the Complaint but ... wish to add the newly identified registrant as respondent to the Complaint.” The Center verified that the Complaint, together with the amendment to 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 proceeding commenced on June 12, 2024. In accordance with the Rules, paragraph 5, the due date for the Response was July 2, 2024. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 3, 2024. page 2 The Center appointed Professor Ilhyung Lee as the sole panelist in this matter on July 15, 2024. 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 Six Continents Hotels, Inc. is incorporated in Delaware, United States, with its principal place of business in Atlanta, Georgia. Its affiliate, Six Continents Limited, is a public limited company in the United Kingdom. The Complainants are two of a number of companies collectively known as IHG Hotels & Resorts, which manages, leases, or franchises thousands of hotels in dozens of countries throughout the world, including Crowne Plaza Hotels & Resorts, Holiday Inn Hotels, and InterContinental Hotels & Resorts, among others. The Complainants and their affiliates have registered or own hundreds of marks containing “IHG”, in several countries. In the United States, their registrations include: IHG service mark, registration number 3544074, registered on December 9, 2008, for “business management; business advisory and business consultancy services relating to hotel management and to hotel franchising”; and IHG trademark and service mark, registration number 4921698, March 22, 2016, for “downloadable mobile applications for accommodation reservations and bookings and for providing information on travel, local events, dining, ground transportation, and accommodations”. The Complainants have also registered several domain names that contain the IHG mark, including <ihg.com> (registered on May 4, 1998), <ihghotels.com> (May 15, 2004), <ihghiring.com> (April 17, 2023), and <ihgmember.com> (October 17, 2022). The disputed domain name <ihghelp.com> was registered on April 26, 2024. The disputed domain name resolves to an inactive website. 5. Parties’ Contentions A. Complainants The Complainants contend principally that: (i) the disputed domain name is identical or confusingly similar to a mark in which the Complainants have rights; (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. In addition, the Complaint states, inter alia: “Respondent has used the Disputed Domain Name in connection with an email address impersonating Complainant to send an email to one of Complainant’s hotels (a Holiday Inn Express & Suites hotel in Houston, Texas) as part of a fraudulent attempt to obtain credit card refunds in the amount of $19,000.” “Respondent us[ed] the email address [...]@ihghelp.com, to Complainant’s Holiday Inn Express & Suites hotel in Houston, Texas, discussing a fake ‘system update/compatibility test’ regarding ‘transactions to our test simulator Visa/master cards.’” “Complainant has never assigned, granted, licensed, sold, transferred or in any way authorized the Respondent to register or use the IHG Trademark in any manner.” B. Respondent The Respondent did not reply to the Complainant’s contentions. Under paragraphs 5(f) and 14(a) of the Rules, the Panel may decide the dispute based on the Complaint. Paragraph 14(b) allows the Panel to draw appropriate inferences from the Respondent’s default. page 3 6. Discussion and Findings In order to prevail, the Complainants must satisfy each of the three elements of paragraph 4(a) of the Policy. A. Identical or Confusingly Similar The Panel concludes that the disputed domain name <ihghelp.com> is identical or confusingly similar to a mark in which the Complainants have rights (IHG), under paragraph 4(a)(i) of the Policy. The Complainants’ mark appears prominently in the disputed domain name. The addition of the term “help” does not prevent a finding of confusing similarity. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0 ”), section 1.8. The Top Level Domain “.com”, a technical registration requirement, is disregarded in the consideration of this element. WIPO Overview 3.0, section 1.11.1. The first element has been established. B. Rights or Legitimate Interests The Complainants state that they have not authorized the Respondent to use the IHG mark, and have met their initial burden of making a prima facie showing that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The burden shifts to the Respondent to demonstrate any such rights or legitimate interests. Paragraph 4(c) of the Policy provides a non-exhaustive list of circumstances that may demonstrate the Respondent’s rights or legitimate interests in the disputed domain name. The Respondent has defaulted. The Panel is unable to ascertain any evidence that would demonstrate the Respondent’s rights or legitimate interests in the disputed domain name, as described in the Policy, or otherwise. The second element has also been established. C. Registered and Used in Bad Faith Under paragraph 4(a)(iii) of the Policy, the Complainants must show that the disputed domain name “has been registered and is being used in bad faith”. Paragraph 4(b) provides a non-exhaustive list of circumstances that can satisfy this element. Other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0 , section 3.2.1. The disputed domain name <ihghelp.com> resolves to an inactive site. The case record indicates that the Respondent has used the disputed domain name to impersonate the Complainants in email correspondence. “Panels have held that the use of a domain name for purposes other than to host a website may constitute bad faith. Such purposes include sending email, phishing, identity theft, or malware distribution.... Many such cases involve the respondent’s use of the domain name to send deceptive emails ....” WIPO Overview 3.0 section 3.4. This case appears to be one such example of bad faith. The third element is satisfied. page 4 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 <ihghelp.com> be transferred to the Complainant Six Continents Limited. /Ilhyung Lee/ Ilhyung Lee Sole Panelist Date: July 23, 2024

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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