Westmore · UDRP DecisionIhgproperty.com
The Panel ordered transfer of <ihgproperty.com>. It found the domain confusingly similar to the Complainant’s IHG mark because the mark remained recognizable despite the addition of “property.” The Respondent lacked rights or legitimate interests, and the domain’s use through email addresses to impersonate the Complainant and conduct phishing established bad-faith registration and use.
The timeline behind ihgproperty.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 ihgproperty.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that a domain need not host an active website to support transfer. Configured MX servers and deceptive email use can establish active targeting, defeat any claim to rights or legitimate interests, and demonstrate bad-faith registration and use.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Six Continents Hotels, Inc., and Six Continents Limited v. Kaden Young Case No. D2026-0590 1. The Parties The Complainants are Six Continents Hotels, Inc., United States of America (the “United States”) and Six Continents Limited, United Kingdom, (collectively the “Complainant”), represented by The GigaLaw Firm, Douglas M. Isenberg, Attorney at Law, LLC, United States. The Respondent is Kaden Young, United States. 2. The Domain Name and Registrar The disputed domain name <ihgproperty.com> is registered with Tucows Domains Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 12, 2026. On February 12, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 12, 2026, 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 (Contact Privacy Inc. Customer 0177045769) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 17, 2026, 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 amendment to the Complaint on February 18, 2026. 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 proceedings commenced on February 20, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 12, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 13, 2026. page 2 The Center appointed William Lobelson as the sole panelist in this matter on March 19, 2026. 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 Complainants are Six Continents Hotels, Inc. and Six Continents Limited, collectively known as InterContinental Hotels Group (“IHG”), a world hotels group that manages around 6,800 hotels around the world, and owns many trademark registrations for IHG, inter alia: - United States Trademark Registration No. 3544074 for IHG (registered on December 9, 2008); - United Kingdom Trademark Registration No. UK00002436937 for IHG (registered on April 27, 2007); and - International Trademark Registration No. 915655 for IHG (registered on December 21, 2006). The disputed domain name was registered on January 1, 2026. It does not resolve to any active web page. But the Respondent set up Mail Exchange (“MX”) servers and has used email addresses using the disputed domain name to contact some affiliates of the Complainant and impersonate the same for phishing purposes. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainant contends that the disputed domain name is confusingly similar to its earlier trademark, that the Respondent has no rights or legitimate interests in the disputed domain name, and that the disputed domain name has been registered and used in bad faith. In particular, the Complainant has substantiated that the disputed domain name was used for phishing purposes, as MX servers have been set up by the Respondent who uses email addresses formed with the disputed domain name to impersonate the Complainant. The Complainant requests the transfer of the disputed domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Notwithstanding the default of the Respondent, it remains incumbent on the Complainant to make out its case in all respects under the Rules set out in paragraph 4(a) of the Policy. Namely, the Complainant must prove that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights (paragraph 4(a)(i)); page 3 (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name (paragraph 4(a)(ii)); and (iii) the disputed domain name has been registered and is being used in bad faith (paragraph 4(a)(iii)). A. Identical or Confusingly Similar It is well accepted that the first element functions 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 Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. Based on the available record, the Panel finds the Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds the mark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms (here “property”) may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. Based on the available record, the Panel finds the first 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 often 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 forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name particularly by asserting that the Respondent is not affiliated with it in any way and that it never authorized the Respondent to use its trademark as part of the disputed domain name. The Complainant contends that the Respondent does not make any bona fide or legitimate noncommercial fair use of the disputed domain name. In addition, the disputed domain name was used to impersonate the Complainant, for phishing purposes. Panels have held that the use of a domain name for illegitimate activity, here impersonation/passing off, likely for phishing purposes, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. page 4 The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. Based on the available record, the Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, for 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 faith. 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 faith. WIPO Overview 3.1, section 3.2.1. Panels have held that the use of a domain name for purposes other than to host a website may constitute bad faith. Such active (“behind the scenes”) uses are considered distinct from the passive holding doctrine, and can include a range of bad faith activity or scams such as sending email, phishing, identity theft, or malware distribution. Many such cases involve the respondent’s use of the domain name to send deceptive emails, e.g., to obtain sensitive or confidential personal information from prospective job applicants, or to solicit payment of fraudulent invoices by the complainant’s actual or prospective customers. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. In the present case, the Panel notes that the Respondent has used the disputed domain name to impersonate the Complainant, which is a clear indication that the Respondent knew about the Complainant and had its trademark in mind when it registered the disputed domain name. Evidence filed in support of the Complaint reflect that the disputed domain name was used to impersonate the Complainant, for phishing purposes: the Respondent has used email addresses using the disputed domain name to Complainant’s affiliates, in an attempt to collect names, email addresses or credentials to various accounts. This clearly demonstrates a use in bad faith of the disputed domain name. The Panel finds that the Complainant has established the third element 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 disputed domain name <ihgproperty.com> be transferred to the Complainant. /William Lobelson/ William Lobelson Sole Panelist Date: March 20, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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