Westmore · UDRP decision
WIPO · Case No. D2026-0643

Halliburton-inc.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <halliburton-inc.com>. It found the domain confusingly similar to the Complainant’s registered HALLIBURTON mark because the mark remained recognizable despite the addition of a hyphen and “inc.” The Respondent lacked rights or legitimate interests, and the domain’s composition carried a risk of implied affiliation. Bad faith was established based on the well-known mark, registration approximately 23 years after the cited trademark registrations, passive holding, the absence of a Response or evidence of contemplated good-faith use, concealment of identity, and the use of false or inaccurate contact details appropriating the name of a genuine member of the Complainant’s leadership team.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-16
Panelist(s)
Weston, Nicholas
Complainant
Halliburton Energy Services, Inc.
Respondent
Eric Carre, halliburton-inc
Counsel
Polsinelli PC
Disputed domain(s)
halliburton-inc.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind halliburton-inc.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 halliburton-inc.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 halliburton-inc.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining a well-known mark with the corporate abbreviation “inc” may heighten rather than reduce affiliation concerns. It also shows that inactivity does not prevent transfer where passive holding is accompanied by a reputed mark, an affiliation-signaling domain composition, no respondent explanation, concealment, and false identity details.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-16
Panel
Weston, Nicholas
Full decision
12 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Halliburton Energy Services, Inc. v. Name Redacted, halliburton-inc Case No. D2026-0643 1. The Parties The Complainant is Halliburton Energy Services, Inc., United States of America (“United States”), represented by Polsinelli PC, United States of America. The Respondent is Name Redacted, 1 halliburton-inc, Nigeria. 2. The Domain Name and Registrar The disputed domain name <halliburton-inc.com> (the “Disputed Domain Name”) 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 13, 2026. On February 15, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On February 17, 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 (REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 18, 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 1 The Respondent appears to have used the name of a third party when registering the disputed domain name. In light of the potential identity theft, the Panel has redacted the Respondent’s name from this decision. However, the Panel has attached as Annex 1 to this decision an instruction to the Registrar regarding transfer of the disputed domain name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in this proceeding and has indicated Annex 1 to this decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST- 12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. page 2 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, 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 20, 2026. The Center appointed Nicholas Weston as the sole panelist in this matter on April 2, 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 Complainant is a wholly owned subsidiary of the Halliburton Company founded in 1919 which, in turn, operates an energy business with 40,000 employees in 70 countries and revenue of USD 22.9 billion in 2024. The Complainant owns numerous registrations for the HALLIBURTON trademark in more than 60 countries, including United States Trademark Registration Number 2575819, registered on June 4, 2002, for the mark HALLIBURTON for services in classes 37, 40, and 42 and United States Trademark Registration Number 2575840, registered on June 4, 2002, for the mark HALLIBURTON for goods in classes 1, 6, 7, 9, and 16. The Complainant is also the owner of, inter alia, the domain name <halliburton.com> which resolves to the company’s main website. The Disputed Domain Name was registered on October 29, 2025 and is inactive. 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 cites numerous trademark registrations for the mark HALLIBURTON, and variations of it, in numerous jurisdictions as prima facie evidence of ownership. The Complainant submits that its rights in the mark HALLIBURTON predate the Respondent’s registration of the Disputed Domain Name and submits that the Disputed Domain Name is confusingly similar to its trademark, for the reason that its well-known trademark is recognizable in the Disputed Domain Name “having merely added a hyphen and a term (inc) to the end of distinctive HALLIBURTON mark”. The Complainant contends that the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name because “[t]he Respondent is not affiliated with Halliburton, licensed to use the Complainant’s HALLIBURTON mark, or licensed to register or use domain names, or associated email accounts, incorporating the HALLIBURTON mark” and infers that none of the circumstances set out in paragraph 4(c) of the Policy apply. Finally, the Complainant alleges that the registration and use of the Disputed Domain Name was, and currently is, in bad faith, contrary to the Policy and the Rules having regard to the prior use and submits that “the Respondent was well aware of the Complainant and had the Complainant’s HALLIBURTON mark firmly in mind when registering the Disputed Domain Name”, and advances the argument that “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 also indicative of bad faith. page 3 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant has the burden of proving the following: (i) that the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name; and (iii) that the Disputed Domain Name has been registered and is being used in bad faith. 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. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“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 Complainant has produced sufficient evidence to demonstrate that it has registered trademark rights in the mark HALLIBURTON in numerous countries. Turning to whether the Disputed Domain Name is identical or confusingly similar to the HALLIBURTON trademark, the Panel observes that the Disputed Domain Name is comprised of: (a) the Complainant’s trademark HALLIBURTON; (b) followed by a hyphen and the term “inc”; (c) followed by the generic Top- Level Domain (“gTLD”) “.com”. It is well established that the gTLD used as part of a domain name is generally disregarded under the first element confusing similarity test. WIPO Overview 3.1, section 1.11.1. The relevant comparison to be made is with the second-level portion of the Disputed Domain Name, specifically: “halliburton-inc”. 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 the term “inc” 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. 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 disputed domain name may result in the page 4 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 disputed 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. The Panel finds that there is no indication that the Respondent was commonly known by the term “halliburton” prior to registration of the Disputed Domain Name. The Complainant has not licensed, permitted, or authorized the Respondent to use the trademark HALLIBURTON. The Panel also notes that the addition of the hyphen and the term “inc”, commonly understood as referring to an incorporated entity, fails to create any legitimate interest in the resulting composite term as it is a generic or descriptive term, and the composition of the Disputed Domain Name carries a risk of implied affiliation (see WIPO Overview 3.1, section 2.5.1). 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 Panel notes the evidence that the Disputed Domain Name resolves to an inactive webpage, which supports the Complainant’s evidence, and finds that this does not represent a bona fide offering of goods or services, or a legitimate noncommercial or fair use, given the substantial reputation and goodwill of the Complainant’s mark or capacity, to otherwise mislead Internet users. 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. In the present case, the Panel finds that the evidence in the case shows the Respondent registered and has used the Disputed Domain Name in bad faith. On the issue of registration, this Panel finds that there is no reason for the Respondent to have registered the Disputed Domain Name other than to trade off the reputation and goodwill of the Complainant’s well- known trademark. WIPO Overview 3.1, section 3.1.4. Further, a gap of several years between registration of a complainant’s trademark and respondent’s registration of a disputed domain name (containing the trademark) may indicate bad faith registration. In this case, the Respondent registered the Disputed Domain Name some 23 years after the Complainant established registered trademark rights in the HALLIBURTON mark. The Respondent has not come forward to rebut the Complainant’s allegations or to offer an alternative explanation. On the issue of use, the Disputed Domain Name does not currently resolve to an active website. page 5 Panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. Although panelists will look at the totality of the circumstances in each case, factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent’s taking active steps to conceal its identity or (iv) the use of false or inaccurate contact details (noted to be in breach of the respondent’s registration agreement). WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the Complainant’s well-known trademark, the composition of the Disputed Domain Name, and the Respondent’s failure to provide any evidence of actual or contemplated good-faith use , the Respondent’s taking active steps to conceal its identity, the use of false or inaccurate contact details by falsely appropriating the name of a genuine member of the Complainant’s leadership team 2 to register the Disputed Domain Name (noted to be in breach of the respondent’s registration agreement) and finds that in the circumstances of this case the passive holding of the Disputed Domain Name does not prevent a finding of bad faith under the Policy. 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 <halliburton-inc.com> be transferred to the Complainant. /Nicholas Weston/ Nicholas Weston Sole Panelist Date: April 16, 2026 2 See: https://www.halliburton.com/en/about-us/halliburton-leadership Under the general powers of a panel articulated inter alia in paragraphs 10 and 12 of the UDRP Rules, it has been accepted that a panel may undertake limited factual research into matters of public record if it would consider such information useful to assessing the case merits and reaching a decision, in particular to affirm or corroborate a party’s contention. WIPO Overview 3.1, section 4.8

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

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