Westmore · UDRP DecisionRemoteihg.com
The Panel ordered transfer of <remoteihg.com> to Six Continents Limited. It found the domain confusingly similar to the IHG mark because it incorporated IHG in full with the term “remote,” which also corresponded to the Complainant’s remote-support portal at <remote.ihg.com>. The Respondent lacked rights or legitimate interests because its prior use impersonated the Complainant and directed users to deceptive security alerts associated with an apparent tech-support scam. The composition of the domain, the reputation of the IHG mark, and the deceptive use established registration and use in bad faith. The domain’s later resolution to a page stating “The connection is not confidential” did not prevent a bad-faith finding.
The timeline behind remoteihg.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
This decision illustrates how a domain that removes the dot from a trademark owner’s existing subdomain can present especially strong targeting evidence. The case also shows that deceptive security-alert or tech-support content may be relevant to both the absence of legitimate interests and bad faith, and that changing the site to an inactive or browser-warning page during the proceeding does not erase documented prior 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. Domain Admin, TotalDomain Privacy Ltd Case No. D2026-0591 1. The Parties The Complainants are Six Continents Hotels, Inc., United States of America (the “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 Domain Admin, TotalDomain Privacy Ltd, Panama. 2. The Domain Name and Registrar The disputed domain name <remoteihg.com> is registered with PDR Ltd. d/b/a PublicDomainRegistry.com (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 13, 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 (Domain Admin / Privacy Protect, LLC (PrivacyProtect.org)) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 16, 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 23, 2026. In accordance with the Rules, page 2 paragraph 5, the due date for Response was March 15, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 16, 2026. The Center appointed Ganna Prokhorova 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 (1) Six Continents Hotels, Inc., a Delaware corporation, Unites States of America, and its affiliate (2) Six Continents Limited, a public limited company in the United Kingdom (collectively the “Complainant”). The Complainant is collectively known as InterContinental Hotels Group (“IHG”), one of the world’s largest hotel groups. Companies within IHG own, manage, lease or franchise, through various subsidiaries, 6,845 hotels and 1,010,756 guest rooms in about 100 countries and territories around the world. The Complainant is the owner of numerous trademark registrations incorporating the mark IHG, including, inter alia: - United States Trademark Registration IHG (word), No. 3544074, registered on December 9, 2008 in International class 35; - European Union Trademark Registration IHG (word), No. 915655, registered on December 21, 2006, in International classes 35 and 43; and - United Kingdom Trademark Registration IHG (word), UK00002436937, registered on April 27, 2007, in International classes 35 and 43. The Complainant has been using the domain names <ih g.com> since 1998, and <ihgplc.com> since 2003. The Complainant also operates a website at <remote.ihg.com> to conduct remote support sessions and manage machines for troubleshooting. The disputed domain name was registered on January 6, 2010. At the time of filing the Complaint, the disputed domain name redirected to a website that displayed such statements: “Safety warning!”, “you have recently browsed compromised websites that are most likely infected with viruses”, and “run an antivirus scan immediately” by clicking a button labeled “Run Quick Scan”. At the time of this Decision, the disputed domain name resolves to the website, which includes statement “The connection is not confidential”. 5. Parties’ Contentions 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: (1) the disputed domain name is confusingly similar to the Complainant’s trademark, since it incorporates the IHG mark and the addition of the term “remote” and the generic Top-Level Domain (“gTLD”) “.com” does not prevent confusion. The term “remote” is used by the Complainant on the website “www.remote.ihg.com”, therefore the Respondent’s inclusion of the word “remote” increases confusing similarity; page 3 (2) the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent registered the disputed domain name years after the Complainant established and widely used the IHG trademark. The Respondent is not affiliated with the Complainant, has no license or authorization to use the IHG mark, and is not commonly known by the disputed domain name. The disputed domain name displays deceptive security alerts, falsely claiming the visitor's device is infected to induce the download of unauthorized software. This creates a misleading impression of affiliation with the Complainant’s IHL brand, which is not a bona fide offering of goods or services. The Respondent owns no trademark corresponding to the disputed domain name. Such conduct negates any claim of legitimate interests. (3) The disputed domain name was registered and is being used in bad faith. Registering the disputed domain name connected to a well-known mark without authorization is itself evidence of bad faith. The Respondent used the disputed domain name creating a misleading association with the Complainant and suggesting deceptive security alerts and fraudulent virus warnings, intended to induce users into performing unauthorized scans. Such conduct aims to attract Internet users by creating a likelihood of confusion as to source, sponsorship, or affiliation. Moreover, the earliest of the Complainant’s IHG trademarks was registered years prior to the Respondent’s registration of the disputed domain name. Given the longstanding and well-known nature of the Complainant’s IHG mark, the Respondent cannot credibly assert that it was unaware of it . The Respondent’s registration and use of the disputed domain name, despite knowledge of the Complainant’s rights, prevents the rightful trademark owner from using its mark and constitutes bad faith under the Policy. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1 Procedural matter – consolidation of Complainants The Complaint was filed by two Complainants against a single Respondent. Neither the Policy nor the Rules expressly provides for or prohibits the consolidation of multiple complainants. In this regard, section 4.11.1 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”) states that panels look at whether (i) the complainants have a specific common grievance against the respondent, or the respondent has engaged in common conduct that has affected the complainants in a similar fashion, and (ii) it would be equitable and procedurally efficient to permit the consolidation. Both Complainants form part of the same corporate group. As such, the two entities have a sufficient common legal interest in the trademarks reflected in the disputed domain name to file a joint Complaint. 6.2 Substantive matter In accordance with paragraph 4(a) of the Policy, the Complainant must prove that each of the three following elements is satisfied: (i) the disputed domain name is identical or confusingly similar to the trademarks or service marks 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. page 4 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 mark and the disputed domain name. WIPO Overview 3.1, section 1.7. Based on the evidence submitted by the Complainant, the Panel finds that the Complainant has shown rights in respect of its IHG mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds that the Complainant’s mark is recognizable within the disputed domain name. The disputed domain name incorporates the Complainant’s IHG mark in its entirety, with the only differences being the addition of the term “remote”. In accordance with WIPO Overview 3.1, section 1.8, addition of other terms, whether descriptive, geographical, pejorative, meaningless, or otherwise, would not prevent a finding of confusing similarity under the first element, as the Complainant’s mark remains clearly recognizable within the disputed domain name. Furthermore, because the word “remote” is also used by Complainant in connection with the IHG Trademark in a remote support portal for employees at “www.remote.ihg.com”, the Respondent’s inclusion of the word “remote” in the disputed domain name does not prevent a finding of confusing similarity under the first element. The Panel further notes that the gTLD “.com” is required only for technical reasons and is generally ignored for the purposes of comparison of the Complainant’s mark to the disputed domain name. WIPO Overview 3.1, section 1.11.1. Accordingly, the Panel concludes that the disputed domain name is confusingly similar to the Complainant’s IHG mark and that the first element of paragraph 4(a) of the Policy is satisfied. 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. 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. The evidence before the Panel shows that the Respondent used the disputed domain name to impersonate the Complainant and its IHG brand. At the time of filing of the Complaint, the disputed domain name redirected to a website displaying alarming statements, which appears designed to induce users to engage with purported security scans for potentially fraudulent purposes. Although the website has changed since the filing of the Complaint, the Panel considers that the Respondent’s prior conduct did not demonstrate rights or legitimate interests in the disputed domain name. The use of the disputed domain name to page 5 impersonate the Complainant and mislead Internet users for tech support scam cannot constitute a bona fide offering of goods or services under paragraph 4(c)(i) of the Policy, nor a legitimate noncommercial or fair use under paragraph 4(c)(iii). Panels have categorically held that the use of a domain name for illegal activity (e.g. phishing/identity theft, distributing malware, unauthorized account access/hacking, or other types of fraud) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1; See LinkedIn Corporation v. Nanci Nette, WIPO Case No. D2023-2290. Furthermore, there is nothing in the record to suggest that the Respondent is commonly known by the disputed domain name within the meaning of paragraph 4(c)(ii) of the Policy. The fact that the disputed domain name now resolves to an inactive webpage containing the statement “The connection is not confidential” reinforces that it is not being used as an identifier for any legitimate enterprise. The Panel further notes that the Complainant has established trademark rights in IHG and has confirmed that it has no relationship with the Respondent. The Respondent has not been authorized, licensed, or otherwise permitted to use the Complainant’s trademark. In light of the absence of any credible evidence of rights or legitimate interests, and the clear impersonation of the Complainant, the Panel concludes that the Respondent has no rights or legitimate interests in the disputed domain name. Accordingly, the Complainant has satisfied the requirement of paragraph 4(a)(ii) of the Policy. 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. In the present case, the Panel notes that the Respondent registered and is using the disputed domain name in bad faith under paragraph 4(b) of the Policy. The Complainant is globally recognized as one of the world’s largest hotel groups under the InterContinental Hotels Group (IHG) name. The Complainant is best known for owning, managing, leasing or franchising hotels in about 100 countries and territories around the world. Overall, the Complainant has confirmed the renown of the IH G worldwide. The Complainant has also operated the domain name <remote.ihg.com>. Given the Complainant’s reputation around the world, internationally and the distinctive nature of its IH G mark, the Panel finds it implausible that the Respondent was unaware of the Complainant’s rights. The registration of the disputed domain name, reproducing the Complainant’s trademark in its entirety and merely adding the term “remote” referring to the Complainant’s website, demonstrates clear targeting of the Complainant’s well-known brand. Therefore, the Panel concludes that, under WIPO Overview 3.1, section 3.2.1, this composition strongly suggests deliberate targeting of the Complainant. The disputed domain name previously resolved to a fraudulent website displaying deceptive security alerts, falsely claiming the visitor's device is infected to induce the download of unauthorized software. This conduct falls squarely within paragraph 4(b)(iv) of the Policy, as the Respondent intentionally attempted to attract Internet users, for presumed commercial gain, by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the website. By using the disputed domain name for a tech support scam, the Respondent created a false impression of legitimacy and attempted to exploit users’ trust associated with the Complainant’s well-known IHG trademark. Panels have held that the use of a disputed domain name in connection with fraudulent or misleading “tech support” schemes constitutes bad faith under the Policy. See Arnold Clark Automobiles Limited v. Whois Agent, Whois Privacy Protection Service, Inc. / George Washere, WIPO Case No. D2018-0558. page 6 At the time of this Decision, the disputed domain name resolves to a webpage stating “The connection is not confidential”, which further demonstrates that the Respondent’s use of the disputed domain name does not correspond to any legitimate purpose and reinforces the conclusion that the Respondent registered and used the disputed domain name in bad faith pursuant to the Policy. Having reviewed the available record, the Panel notes the well-known nature of the Complainant’s trademark, the lack of response and the composition of the disputed domain name, and finds that in the circumstances of this case the current non-use of the disputed domain name does not prevent a finding of bad faith under the Policy. Considering the totality of circumstances, the Panel concludes that the disputed domain name was registered and is being used in bad faith under paragraph 4(a)(iii) of the Policy. Accordingly, the third element of paragraph 4(a) of the Policy has been established. 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 <remoteihg.com> be transferred to the Complainant Six Continents Limited. /Ganna Prokhorova/ Ganna Prokhorova Sole Panelist Date: March 27, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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