Westmore · UDRP DecisionCarucontainers-hk.com
The Panel ordered transfer of <carucontainers-hk.com>. It found the domain confusingly similar to the Complainant’s CARU and CARU CONTAINERS marks, that the Respondent lacked rights or legitimate interests, and that the combination of the mark with the geographic abbreviation “hk,” together with passive holding and the absence of a rebuttal or explanation, established registration and use in bad faith.
The timeline behind carucontainers-hk.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 carucontainers-hk.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how a domain combining an entire trademark with a geographic abbreviation can imply an official regional presence, particularly where the complainant actually operates in that location. It also shows that inactivity does not prevent transfer when the domain’s composition indicates targeting and the respondent supplies no credible explanation or evidence of legitimate 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 Caru Containers B.V. v. David Larson Case No. D2026-0728 1. The Parties The Complainant is Caru Containers B.V., Netherlands (Kingdom of the), represented by Merkenbureau Knijff & Partners, Netherlands (Kingdom of the). The Respondent is David Larson, United States of America. 2. The Domain Name and Registrar The disputed domain name <carucontainers-hk.com> is registered with Realtime Register B.V. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 20, 2026. On February 20, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 23, 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 (Unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 23, 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 amended Complaint on February 27, 2026. The Center verified that the Complaint together with the amended 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 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 19, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 21, 2026. page 2 The Center appointed Daniel Peña as the sole panelist in this matter on March 27, 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, founded in 2000, operates globally in the sale, rental, and storage of shipping containers, as well as logistics services. It trades new and used containers worldwide from 10 offices across more than 70 countries. The Complainant also maintains a presence in Hong Kong, China through its local entity CARU CONTAINERS CO., LIMITED. The Complaint is based on the Complainant’s ownership and use of the trademarks CARU and CARU CONTAINERS. The CARU trademark is protected through multiple registrations, including: - Benelux Registration No. 983592, registered on December 29, 2015; - International Registration No. 1442793, registered on October 22, 2018, designating China, the European Union, Switzerland, the United Kingdom, and the United States of America; and - United Kingdom Registration No. UK00801442793, registered on June 5, 2019. The CARU CONTAINERS trademark is protected, among others, through International Registration No. 1734562, registered on April 12, 2023. The Complainant operates its official website at the domain name <carucontainers.com>. These registrations cover services in classes 35 (sales management, retail, business administration relating to containers), 36 (leasing of containers), and 39 (rental and storage of containers). The disputed domain name was registered on January 8, 2026. The disputed domain name resolves to an inactive site. 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 trademark CARU and CARU CONTAINERS, with the only difference being the addition of “-hk,” which refers to Hong Kong, China, where the Complainant operates. The Respondent has no rights or legitimate interests in the disputed domain name, as it is not affiliated with the Complainant, has not been authorized to use the trademark, is not commonly known by the disputed domain name, and has not made any bona fide or fair use of it. Addition of the geographical abbreviation “hk” reinforces the false impression of association with the Complainant’s Hong Kong, China operations. The Complainant further contends that the disputed domain name was registered and is being used in bad faith. The Respondent knew or should have known of the Complainant’s trademark rights, and the deliberate incorporation of the mark with “hk” shows targeting of the Complainant’s business. Even without an active website, passive holding under these circumstances constitutes bad faith, especially given the risk of fraudulent use such as phishing or impersonation. page 3 The disputed domain name is particularly suited for deceptive practices, and its registration demonstrates an intent to exploit the Complainant’s trademark, disrupt its business, and benefit from user confusion. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar In assessing the first element under paragraph 4(a)(i) of the UDRP, the Panel considers whether the disputed domain name is identical or confusingly similar to a trademark in which the Complainant has rights. According to section 1.7 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), the test for confusing similarity involves a straightforward comparison between the trademark and the domain name, disregarding the generic Top-Level Domain (“gTLD”). Where the trademark is recognizable within the domain name, panels generally find confusing similarity. Here, the Complainant’s trademarks CARU and CARU CONTAINERS are clearly recognizable in the disputed domain name. The addition of a hyphen and the letters “hk” to the CARU CONTAINERS mark does not prevent a finding of confusing similarity. As noted in section 1.8 of the WIPO Overview 3.1, the addition of geographical or oter descriptive terms to a trademark in a domain name typically does not prevent a finding of confusing similarity. Accordingly, the Panel finds that the disputed domain name is confusingly similar to the Complainant’s trademarks, satisfying the first element of paragraph 4(a)(i) of the UDRP. B. Rights or Legitimate Interests According to paragraph 4(a)(ii) of the Policy, the Complainant must demonstrate that the Respondent has no rights or legitimate interests in the disputed domain name. As outlined in section 2.1 of the WIPO Overview 3.1, the Complainant is required to make a prima facie showing, after which the burden of production shifts to the Respondent to rebut (although the burden of proof always remains on the complainant). In this case, the Complainant has established such a prima facie case, and the Respondent has not provided any evidence in rebuttal. The Respondent is not affiliated with the Complainant, nor has it been licensed or authorized to use the Complainant’s trademark. There is no indication that the Respondent has been commonly known by the disputed domain name or holds any trademark rights in it. The disputed domain name does not resolve to an active website and has not been used for any bona fide offering of goods or services or for legitimate noncommercial purposes. Furthermore, the composition of the disputed domain name – incorporating the Complainant’s trademark in its entirety together with the geographic abbreviation “hk” (and, as such, highly similar to the Complainant’s official domain name <carucontainers.com>) – suggests the false impression of an official connection with the Complainant’s business in Hong Kong, China. On this basis, the Panel concludes that the Respondent has most likely registered the disputed domain name with the intention to target the Complainant and as such has no rights or legitimate interests in the disputed domain name within the meaning of paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith The Panel must determine under paragraph 4(a)(iii) of the Policy whether the disputed domain name was registered and is being used in bad faith. As noted in section 3.1 of the WIPO Overview 3.1, this assessment requires consideration of the totality of the circumstances, including whether the Respondent page 4 knew or should have known of the Complainant’s trademark rights and whether the domain name was registered to exploit those rights. The Complainant’s trademark is distinctive and well established, including in Hong Kong, China. The deliberate incorporation of the trademark together with the geographic identifier “hk” demonstrates that the Respondent most likely specifically targeted the Complainant and its business. Although the disputed domain name does not resolve to an active website, section 3.3 of the WIPO Overview 3.1 confirms that passive holding does not by itself prevent a finding of bad faith. To the contrary, in looking at the totality of the circumstances, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. In this case, such circumstances include the confusing similarity to the Complainant’s trademark, the absence of any rights or legitimate interests, and the lack of any explanation by the Respondent for its choice of the domain name. Taken together, these factors demonstrate that the Respondent more likely than not registered and is holding the disputed domain name with an intent to exploit the Complainant’s trademark. The Panel therefore concludes that the disputed domain name was registered and is being used in bad faith within the meaning of paragraph 4(a)(iii) 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 <carucontainers-hk.com> be transferred to the Complainant. /Daniel Peña/ Daniel Peña Sole Panelist Date: April 10, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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