Westmore · UDRP decision
WIPO · Case No. D2025-4005

Halliburtongroups.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <halliburtongroups.com>. It found the domain confusingly similar to the Complainant’s HALLIBURTON mark because it incorporated the mark in full with the additional term “groups.” The Respondent lacked rights or legitimate interests, and its use of the domain for emails falsely impersonating the Complainant’s Chief Recruitment Manager could not confer such rights. Bad faith was established by the Respondent’s evident awareness of the distinctive HALLIBURTON mark and its use of the domain in a fraudulent email scheme targeting job applicants.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-11-27
Panelist(s)
Azevedo, Rodrigo
Complainant
Halliburton Energy Services, Inc.
Respondent
Great Avano, Multi Services
Counsel
Polsinelli PC
Disputed domain(s)
halliburtongroups.com
Domain history UDRP Intelligence

The timeline behind halliburtongroups.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Reconstructing the record for halliburtongroups.com…
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of halliburtongroups.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates that a domain need not resolve to an active website to support transfer where it is used as an email instrument for impersonation. The combination of an entire distinctive mark, a corporate-sounding term, and recruitment-related emails gave the Panel direct grounds for finding both an absence of legitimate interests and bad-faith registration and use.

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
2025-11-27
Panel
Azevedo, Rodrigo
Full decision
10 min read · hosted by Westmore

ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Halliburton Energy Services, Inc. v. Great Avano, Multi Services Case No. D2025-4005 1. The Parties The Complainant is Halliburton Energy Services, Inc., United States of America (“United States”), represented by Polsinelli PC, United States. The Respondent is Great Avano, Multi Services, Nigeria. 2. The Domain Name and Registrar The disputed domain name <halliburtongroups.com> is registered with GMO Internet, Inc. d/b/a Discount- Domain.com and Onamae.com (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 30, 2025. On October 1, 2025, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On October 2, 2025, the Registrar transmitted by email to the Center its verification response, disclosing registrant and contact inf ormation f or the disputed domain name which dif f ered f rom the named Respondent (Whois Privacy Protection Service by onamae.com) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 2, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amendment to the Complaint on October 7, 2025. The Center verif ied that the Complaint together with the amendment to the Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on October 8, 2025. In accordance with the Rules, paragraph 5, the due date f or Response was October 28, 2025. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on October 31, 2025. page 2 The Center appointed Rodrigo Azevedo as the sole panelist in this matter on November 11, 2025. The Panel f inds 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 Founded in 1919, the Complainant is a United States based company that operates globally in the oil and gas industry. The Complainant owns numerous trademark registrations f or the mark HALLIBURTON in various jurisdictions. These include, among others, United States Trademark Registration No. 2,575,819, registered on June 4, 2002. The Complainant also owns and operates the domain name <halliburton.com>, which was registered on October 17, 1995, and is used in connection with its of f icial business activities. The disputed domain name was registered on August 17, 2025. The disputed domain name is not currently linked to an active website. The Complainant filed evidence that the disputed domain name was recently used by the Respondent to send e-mail messages pretending to be the Chief Recruitment Manager of the Complainant. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy f or a transf er of the disputed domain name. Notably, the Complainant contends that: (i) The disputed domain name is identical or conf usingly similar to the Complainant’s trademark. The Complainant asserts that the disputed domain name is confusingly similar to its well-kno wn HALLIBURTON trademark. The disputed domain name incorporates the entirety of the Complainant’s mark, with only the addition of the term “groups”, which does not prevent a finding of confusing similarity. The inclusion of such a generic term enhances rather than diminishes the risk of conf usion, as it may misleadingly suggest a connection with the Complainant's corporate structure or af f iliated entities. Furthermore, the generic Top- Level Domain “.com” is irrelevant f or the purpose of the comparison under the Policy. (ii) The Respondent has no rights or legitimate interests in the disputed domain name. The Complainant asserts that the Respondent is not affiliated with or authorized by the Complainant in any way and has never been licensed to use the HALLIBURTON trademark. The Respondent is not commonly known by the disputed domain name and has not acquired any trademark or service mark rights in the name. There is no evidence of the Respondent using the domain name in connection with a bona f ide of f ering of goods or services. On the contrary, the Complainant has provided evidence that the disputed domain name has been used as part of a fraudulent scheme to impersonate the Complainant and deceive job applicants, which cannot constitute a legitimate or f air use. (iii) The disputed domain name was registered and is being used in bad f aith. The Complainant contends that the Respondent registered the disputed domain name with f ull knowledge of the Complainant’s trademark rights, given the well-known and distinctive nature of the HALLIBURTON mark. The Complainant provided evidence that the disputed domain name was used in an attempt to impersonate the Complainant page 3 and mislead job seekers. Additionally, the use of a privacy or proxy service which is known to block or intentionally delay disclosure of the identity of the actual underlying registrant is another indication of bad f aith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 4(a) of the Policy provides that in order to be entitled to a transfer of the disputed domain name, a complainant shall prove the f ollowing three elements: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the complainant has 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 f aith. A. Identical or Confusingly Similar It is well accepted that the f irst element f unctions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. Annex 4 to the Complaint shows numerous registrations f or HALLIBURTON trademark obtained by the Complainant. Based on the available record, the Panel finds the Complainant has shown rights in respect of a trademark or service mark f or the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The trademark HALLIBURTON is wholly encompassed within the disputed domain name, with the addition of the term “groups”, as well as with the gTLD “.com”. Although the addition of other terms (here, “groups”), may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a f inding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. It is also well established that the addition of a gTLD, such as “.com”, is typically disregarded when determining whether a domain name is confusingly similar to a complainant’s trademark as such is viewed as a standard registration requirement. WIPO Overview 3.0, section 1.11.1. Based on the available record, the Panel f inds the f irst element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is of ten primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come f orward with page 4 relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent f ails to come f orward with such relevant evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come f orward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The Complainant has not licensed nor authorized the use of its trademark to the Respondent, and the Panel f inds no indication that the Respondent is commonly known by the disputed domain name. Furthermore, the Complainant has shown that the disputed domain name was used by the Respondent to f alsely impersonate the Complainant, sending email messages pretending to be the Complainant’s Chief Recruitment Manager, which certainly cannot co nf er rig hts o r legitimate interests. Based on the available record, the Panel f inds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, f or the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad f aith. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad f aith. WIPO Overview 3.0, section 3.2.1. The Panel concludes that it is inconceivable that the Respondent was not aware of the Complainant’s trademark and that the registration of the disputed domain name was a mere coincidence. When the disputed domain name was registered (in 2025) the HALLIBURTON trademark was already directly connected with the Complainant’s activities in the oil and gas industry. The disputed domain name includes the distinctive trademark HALLIBURTON in its entirety. According to the WIPO Overview 3.0, section 3.1.4, UDRP panels have consistently found that the mere registration of a domain name that is identical or confusingly similar to a famous or widely known trademark by an unaffiliated entity can by itself create a presumption of bad f aith. The addition of the term “g ro up s” may f alsely suggest to Internet users the mistaken belief that it is the of f icial domain name of the Complainant corporate group. Finally, panels have held that the use of a domain name f or illegitimate activity – such as the use of the disputed domain name as part of a fraudulent email scheme to impersonate the Complainant and deceive job applicants (phishing and impersonation/passing off) – constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad f aith under the Policy. page 5 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <halliburtongroups.com> be transf erred to the Complainant. /Rodrigo Azevedo/ Rodrigo Azevedo Sole Panelist Date: November 27, 2025

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

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