Westmore · UDRP DecisionSoleohealth.org
The Panel ordered transfer of <soleohealth.org>. It found the Domain Name identical to Complainant’s SOLEO HEALTH marks, found no rights or legitimate interests because Respondent used the Domain Name for fake employment opportunities and impersonation, and found bad-faith registration and use based on Respondent’s awareness of Complainant’s prior rights and use of Domain Name email capabilities for employment-related impersonation, phishing, and collection of personal information.
The timeline behind soleohealth.org
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 soleohealth.org — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how an exact-match domain used primarily through email can satisfy the UDRP even where the published record contains little discussion of a public-facing website. The employment impersonation evidence simultaneously undermined any claim to legitimacy and demonstrated knowledge, targeting, and bad faith. It also shows that a registrant organization field mirroring the domain does not by itself prove that a respondent is commonly known by the domain when the surrounding use indicates impersonation.
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 Soleo Health Holdings, Inc. v. Steph Zach, Soleohealth Case No. D2026-2167 1. The Parties Complainant is Soleo Health Holdings, Inc., United States of America (“United States”), represented by Polsinelli PC, United States. Respondent is Steph Zach, Soleohealth, United States. 2. The Domain Name and Registrar The disputed domain name <soleohealth.org> (the “Domain Name”) is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 19, 2026. On May 20, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On May 21, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (Redacted) and contact information in the Complaint. The Center sent an email communication to Complainant on May 21, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on May 21, 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 Respondent of the Complaint, and the proceedings commenced on June 1, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 21, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on June 22, 2026. page 2 The Center appointed Kimberley Chen Nobles as the sole panelist in this matter on June 23, 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 Complainant provides specialty pharmacy services, delivering therapies for conditions requiring focused clinical monitoring and interventions. With an interdisciplinary team of clinical pharmacists, registered nurses, reimbursement specialists and patient care ambassadors, Complainant offers pharmacy licensure in 50 states, as well as national nursing coverage. Complainant owns numerous registered trademarks with the SOLEO HEALTH and/or SOLEO in combination with other terms, including: - United States registered trademark number 4,648,210 for the SOLEO HEALTH word mark, registered on December 2, 2014; - United States registered trademark number 4,645,289 for the SOLEO HEALTH word and design mark, registered on November 25, 2014; and - United States registered trademark number 7,320,177 for the SOLEO HEALTH word mark, registered on March 5, 2024. Complainant also owns and operates its website at “www.soleohealth.com”. The Domain Name was registered on May 20, 2025 and was configured with email capabilities to facilitate sending emails to Complainant’s customers, for use in social media and as part of fraudulent employment related activities. These include sending of emails to Complainant’s consumers or as part of fraudulent employment related activities, such as offering of fraudulent employment opportunities and conducting fraudulent employee interviews, as well as soliciting personal information of interviewees. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Name. Notably, Complainant contends that (i) the Domain Name is confusingly similar to Complainant’s trademarks; (ii) Respondent has no rights or legitimate interests in the Domain Name; and (iii) Respondent registered and is using the Domain Name in bad faith. In particular, Complainant contends that it has trademark registrations and rights for SOLEO HEALTH and that Respondent registered and is using the Domain Name with the intention to confuse Internet users looking for bona fide and well-known SOLEO HEALTH products and services. Complainant notes that it has no affiliation with Respondent, nor authorized Respondent to register or use a domain name, which includes Complainant’s trademarks, and that Respondent has no rights or legitimate interests in the registration and use of the Domain Name. Rather, Complainant contends that Respondent has acted in bad faith in acquiring and setting up the Domain Name, when Respondent clearly knew of Complainant’s rights. Specifically, Complainant argues that Respondent used the Domain Name to impersonate or pose as Complainant, so as to send fraudulent messages to page 3 Complainant’s consumers or as part of fraudulent employment related activities, such as offering of fraudulent employment opportunities and conducting fraudulent employee interviews, as well as soliciting personal information of interviewees. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”) states that failure to respond to the complainant’s contentions would not by itself mean that the complainant is deemed to have prevailed; a respondent’s default is not necessarily an admission that the complainant’s claims are true. Thus, although in this case Respondent has failed to respond to the Complaint, the burden remains with Complainant to establish the three elements of paragraph 4(a) of the Policy by a preponderance of the evidence. A. Identical or Confusingly Similar Complainant has provided evidence of its rights in the SOLEO HEALTH trademarks, as noted above. Complainant has therefore proven that it has the requisite rights in the SOLEO HEALTH trademarks. With Complainant’s rights in the SOLEO HEALTH trademarks established, the remaining question under the first element of the Policy is whether the Domain Name, typically disregarding the Top-Level Domain (“TLD”) in which it was registered (in this case, is “.org”) is identical or confusingly similar to Complainant’s trademarks. See, e.g., B & H Foto & Electronics Corp. v. Domains by Proxy, Inc. / Joseph Gross, WIPO Case No. D2010-0842. Here, the Domain Name is identical to Complainant’s SOLEO HEALTH trademarks. The absence of the space between SOLEO and HEALTH in the Domain Name does not prevent a finding of identity or confusing similarity between the Domain Name and the SOLEO HEALTH trademarks. See section 1.8 of the WIPO Overview 3.1. Thus, the Panel finds that Complainant has satisfied the first element of the Policy. B. Rights or Legitimate Interests Under paragraph 4(a)(ii) of the Policy, a complainant must make a prima facie showing that a respondent possesses no rights or legitimate interests in a disputed domain name. See, e.g., Malayan Banking Berhad v. Beauty, Success & Truth International, WIPO Case No. D2008-1393. Once a complainant makes such a prima facie showing, the burden of production shifts to the respondent, though the burden of proof always remains on the complainant. If the respondent fails to come forward with relevant evidence showing rights or legitimate interests, the complainant will have sustained its burden under the second element of the UDRP. From the record in this case, it is evident that Respondent was, and is, aware of Complainant and its SOLEO HEALTH trademarks and does not have any rights or legitimate interests in the Domain Name. Complainant has confirmed that Respondent is not affiliated with Complainant, or otherwise authorized or licensed to use the SOLEO HEALTH trademarks or to seek registration of any domain name incorporating these trademarks. Respondent is also not known to be associated with the SOLEO HEALTH trademarks and there is no evidence showing that Respondent has been commonly known by the Domain Name. The Panel notes that the Registrar-confirmed registrant organization is listed as page 4 “Soleohealth”. However, there is no evidence that Respondent is commonly known by the Domain Name for the purposes of the Policy, and rather it appears this name was chosen in furtherance of its fraudulent employment activities impersonating Complainant. In addition, Respondent has not used the Domain Name in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use. Rather, at the time of filing of the Complaint, Respondent used the Domain Name to offer fake employment opportunities, essentially impersonating Complainant. UDRP panels have consistently held that use of a domain name for illegal activity — such as impersonation or passing off — can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. Complainant further alleges that Respondent’s use of its emails with the Domain Name also result in Respondent’s collection of personal information from individuals seeking employment opportunities with Complainant. Such use of the Domain Name is misleading and such potential attempts to reach individuals seeking employment with Complainant may result in giving the false impression to Internet users that the Domain Name is owned by Complainant. The resulting confusion would cause damage to Complainant’s reputation and goodwill, and interfere with Complainant’s business activities. The use of a domain name for email phishing and impersonation/passing off can never confer rights or legitimate interests on a respondent. Accordingly, Complainant has provided evidence supporting its prima facie showing that Respondent lacks any rights or legitimate interests in the Domain Name. Respondent has failed to produce countervailing evidence of any rights or legitimate interests in the Domain Name. Thus, the Panel concludes that Respondent does not have any rights or legitimate interests in the Domain Name and Complainant has met its burden under paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith The Panel finds that Respondent’s actions indicate that Respondent registered and is using the Domain Names in bad faith. Paragraph 4(b) of the Policy provides a non-exhaustive list of circumstances indicating bad faith registration and use on the part of a respondent, namely: “(i) circumstances indicating that you have registered or you have acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the domain name; or (ii) you have registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or (iii) you have registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of your website or location or of a product or service on your website or location.” The Panel finds that Complainant has provided ample evidence to show that registration and use of the SOLEO HEALTH trademarks long predate the registration of the Domain Name. Complainant is also well established and known. Indeed, the record shows that Complainant’s SOLEO HEALTH trademarks page 5 and related products and services are widely known and recognized. Therefore, and also noting the below use analysis, Respondent was clearly aware of the SOLEO HEALTH trademarks when it registered the Domain Name. The Panel therefore finds that Respondent’s awareness of Complainant’s trademark rights at the time of registration suggests bad faith. See Red Bull GmbH v. Credit du Léman SA, Jean-Denis Deletraz, WIPO Case No. D2011-2209; Nintendo of America Inc v. Marco Beijen, Beijen Consulting, Pokemon Fan Clubs Org., and Pokemon Fans Unite, WIPO Case No. D2001-1070; and BellSouth Intellectual Property Corporation v. Serena, Axel, WIPO Case No. D2006-0007. Moreover, the Domain Name’s inclusion of Complainant’s trademark in its entirety in the Domain Name, further reflects the awareness that Respondent had of Complainant and its trademarks at the time of registration. Such adoption of Complainant’s trademarks at the time of registration of the Domain Name illustrates Respondent’s effort to mislead Internet users as to the Domain Name’s association with Complainant. Moreover, Respondent registered and is using the Domain Name to confuse and mislead consumers looking for the bona fide and well-known SOLEO HEALTH products and services of Complainant, to its website likely for its own commercial benefit. In particular, at the time of filing of the Complaint, Respondent used the Domain Name in an attempt to solicit and direct Internet users looking for Complainant’s products and services through the use of emails to communicate with individuals seeking employment with Complainant. In particular, Respondent’s use of its emails associated with the Domain Name also result in Respondent’s collection of personal information from individuals seeking employment opportunities with Complainant. The resulting confusion from such impersonation and/or phishing communications would cause damage to Complainant’s reputation and goodwill, and interfere with Complainant’s business activities. The use of a domain name for email phishing and impersonation/passing off shows Respondent’s acts of bad faith, and is not rebutted by Respondent. UDRP panels have consistently held that Respondent’s use of the Domain Name to trade off goodwill in Complainant’s well-known trademark and impersonate Complainant constitutes bad faith. See Philip Morris Products S.A. v. homn mohmoodi, WIPO Case No. D2022-4158. Moreover, such use of the Domain Name may potentially result in tarnishing Complainant’s reputation and goodwill. Further, the Panel also notes the failure of Respondent to submit a response. In the present circumstances, considering the reputation of the SOLEO HEALTH trademarks and the fraudulent use of the Domain Name, the Panel finds that Respondent registered and is using the Domain Name in bad faith. Therefore, the Panel finds that Complainant succeeds under the third element of paragraph 4(a) 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 Domain Name <soleohealth.org> be transferred to Complainant. /Kimberley Chen Nobles/ Kimberley Chen Nobles Sole Panelist Date: June 25, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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