Westmore · UDRP DecisionForbesstaff.com
The Panel ordered transfer of <forbesstaff.com>. It found the domain confusingly similar to Complainant’s FORBES mark because it incorporated the mark in full and the addition of “staff” did not prevent confusing similarity. Complainant established an unrebutted prima facie case that Respondent lacked rights or legitimate interests. The redirect to Complainant’s official website demonstrated actual knowledge of the mark, while the domain’s alleged use for impersonation, fraud, and phishing supported the finding of registration and use in bad faith.
The timeline behind forbesstaff.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The decision illustrates how a trademark-plus-“staff” domain, a redirect to the trademark owner’s genuine website, and alleged domain-based solicitation emails can operate together as evidence of targeted impersonation. The redirect was particularly important because the Panel treated it as proof that Respondent actually knew of Complainant and its FORBES mark at registration.
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 FORBES LLC v. Ronald Robinson Case No. D2026-2318 1. The Parties Complainant is FORBES LLC, United States of America, represented by Riker Danzig LLP, United States of America (“United States”). Respondent is Ronald Robinson, United States. 2. The Domain Name and Registrar The Disputed Domain Name <forbesstaff.com> 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 28, 2026. On May 29, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On May 29, 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 Complainant on June 2, 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 June 2, 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 3, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 23, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on June 24, 2026. page 2 The Center appointed Richard W. Page as the sole panelist in this matter on June 26, 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 is a limited liability company organized under the laws of the State of Delaware, United States, is the successor-in -interest to Forbes Inc., a corporation organized under the laws of the State of New York, United States. Complainant and its affiliates are internationally known companies that participate in a broad range of businesses in the publishing, investment, financial, and business fields, among others, using a family of registered and common law trademarks and services marks (collectively the “FORBES Mark”). Since 1917, Complainant has published FORBES Magazine, a bi-monthly business magazine that has an extensive Untied States and worldwide circulation. Since long prior to 2002, Complainant has also published and continues to publish a number of other print magazines containing the “Forbes” name, including Forbes Mexico and other titles. In 1997, Complainant expanded into electronic commerce and information delivery services by introducing the flagship Internet website at the domain name <forbes.com> which provides online publications, webcasts, market updates, newsletters, virtual events, an e-commerce platform, videos, and information about a wide variety of subject matters, including breaking news, e-commerce, business, finance, investing, economics, politics, entertainment, and travel and leisure, among others. Through this website, Complainant also makes available to the public online versions of its famous print publications such as Forbes Magazine, Forbeslife, and Forbes Mexico. Complainant is the owner, without limitation, of the following trademark registrations: United States Registration No. 1,141,299 for FORBES registered November 11, 1980 in International Class 16; United States Registration No.1,919,483 for FORBES registered September 19,1995 in International Class 9 and 35; and United Kingdom Registration No. 1,385,361 for FORBES registered September 18, 1992 in International Class 16. The Disputed Domain Name was registered on March 13, 2025 and redirects to Complainant’s official website at the domain name <forbes.com>. The Disputed Domain Name is also enrolled in a mail exchange (MX) which allows for the sending of emails, which are being sent in English and being used to solicit money from Complainant’s contributors under the guise that it is Complainant. 5. Parties’ Contentions A. Complainant Complainant contends that over the past 100 years, Complaint has expended an immense amount of time, effort, and money to advertise and promote its various services and publications under the “Forbes” name and under the FORBES Mark, and has built up its name and reputation to worldwide renown in connection with its publishing and information services operations. Complainant further contends that, by reason of its extensive use of the FORBES Mark, it has acquired common law rights in these marks in addition to trademark registrations in the United States and in numerous other countries around the world. page 3 Complainant further contends that the Disputed Domain Name is confusingly similar to the FORBES Mark because the entirety of the FORBES Mark is contained in the Disputed Domain Name. Complainant further contends that the addition of the phrase “staff” does not prevent confusing similarity. Complainant submits that the fraudulent emails being sent by Respondent seek monetary contributions in order for the opportunity to publish with Complainant, a service Complainant does not offer and which offends the journalistic integrity of Complainant’s publications. Accordingly, this use is an infringement of the FORBES Mark. Complainant further submits that Respondent is using the Disputed Domain Name to deceive Internet users into believing that it is Complainant and offering a legitimate service on behalf of Complainant. This use, and the Disputed Domain Name’s inclusion of the famous FORBES Mark, is an infringement of the FORBES Mark, constitutes unfair competition, serves to tarnish the reputation of Complainant, and is a fraud on the public. Complainant further submits that Respondent is not sponsored by or affiliated with Complainant in any way. Complainant has not given Respondent permission to use the FORBES Mark in any manner, including in domain names. Complainant further submits that Respondent is not commonly known by the Disputed Domain Name. Complainant further submits that Respondent’s fraudulent email scheme is neither a bona fide offering of goods and services, nor a legitimate non-commercial use of the Disputed Domain Name. Complainant alleges that it has been in business for over 100 years and is an American business magazine that is published six times a year. It has an international edition in Mexico as well as forty-eight (48) editions distributed in eighty-one (81) countries and regions worldwide in thirty-one (31) languages. Forbes Magazine is well known for its lists and rankings. Complainant further alleges that the website “www.forbes.com” reaches millions of unique visitors each month. In 2006, “www.forbes.com” claimed to be the world’s most widely visited business website. In 2020, Complainant won the Webby People’s Voice Award for a Business Blog/Website. In 2023, Complainant won a second Webby People’s Voice Award for its World Billionaires List. Complainant further alleges that in March 2026, the “www.forbes.com” website had a global rank of 804 with total foot traffic of 78,85 million visits. Complainant further alleges that redirecting the Disputed Domain Name to Complainant’s official website shows actual knowledge of Complainant’s rights in the FORBES Mark at the time of registration of the Disputed Domain Name, which is an indication of bad faith. Complainant further alleges that Respondent’s use of email associated with the Disputed Domain Name, plus having the Disputed Domain Name redirect to Complainant’s official website is a targeted form of phishing known as “spear phishing” and constitutes classic bad faith. Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Disputed Domain Name. B. Respondent Respondent did not reply to Complainant’s contentions. page 4 6. Discussion and Findings Paragraph 15(a) of the Rules instructs the Panel as to the principles the Panel is to use in determining the dispute: “A Panel shall decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules, and any rules and principles of law that it deems applicable.” Even though Respondent has failed to file a Response or to contest Complainant’s assertions, the Panel will review the evidence proffered by Complainant to verify that the three essential elements of the claims are met. WIPO Overview of WIPO Panel Views on UDRP Questions (“WIPO Overview 3.1”), section 4.3. Paragraph 4(a) of the Policy directs that Complainant must prove each of the following three elements: i) that the Disputed Domain Name registered by Respondent is identical or confusingly similar to the FORBES Mark in which Complainant has rights; and, ii) that 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 WIPO Overview 3.1, section 1.2.1 states that registration of a trademark, here the FORBES Mark, prima facie satisfies the threshold requirement of Complainant having trademark rights for purposes of standing to file a UDRP case. Complainant has shown rights in respect of the FORBES Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. 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 FORBES Mark and the Disputed Domain Name. WIPO Overview 3.1, section 1.7. The entirety of the FORBES Mark is reproduced within the Disputed Domain Name. Accordingly, the Disputed Domain Name is confusingly similar to the FORBES Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms, here the word “staff,” may bear on assessment of the second and third elements, t he Panel finds the addition of such term does not prevent a finding of confusing similarity between the Disputed Domain Name and the FORBES 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 the Disputed Domain Name. Paragraph 4(c) of the Policy allows three nonexclusive methods for the Panel to conclude that Respondent has rights or a legitimate interest in the Disputed Domain Name: (i) before any notice to you [Respondent] of the dispute, your use of, or demonstrable preparations to use, the Disputed Domain Name or a name corresponding to the Disputed Domain Name in connection with a bona fide offering of goods or services; or page 5 (ii) you [Respondent] (as an individual, business, or other organization) have been commonly known by the Disputed Domain Name, even if you have acquired no trademark or service mark rights; or (iii) you [Respondent] are making a legitimate noncommercial or fair use of the Disputed Domain Name, without intent for commercial gain to misleadingly divert consumers or to tarnish the FORBES Mark. Although the overall burden of proof in UDRP proceedings is on Complainant, panels have recognized that proving that Respondent lacks rights or legitimate interests in the Disputed Domain Name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of Respondent. As such, where Complainant makes out a prima facie case that Respondent lacks rights or legitimate interests, the burden of production on this element shifts to 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 Complainant). If Respondent fails to come forward with such relevant evidence, Complainant is deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the Disputed Domain Name. Respondent has not rebutted 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. Panels have held that the use of a domain name for illegitimate activity, here claimed as impersonation, fraud, and phishing, can never confer rights or legitimate interests on Respondent. WIPO Overview 3.1, section 2.13.1. 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 forth four nonexclusive criteria for Complainant to show bad faith registration and use of the Disputed Domain Name: (i) circumstances indicating that you [Respondent] have registered or you have acquired the Disputed Domain Name primarily for the purpose of selling, renting, or otherwise transferring the Disputed Domain Name registration to Complainant who is the owner of the FORBES Mark or to a competitor of Complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the Disputed Domain Name; or (ii) you [Respondent] have registered the Disputed Domain Name in order to prevent the owner of the FORBES Mark from reflecting the FORBES Mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or (iii) you [Respondent] have registered the Disputed Domain Name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the Disputed Domain Name, you [Respondent] 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 FORBES Mark as to the source, sponsorship, affiliation, or endorsement of your website or location or of a product on your website or location. page 6 Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that the Disputed 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 the Disputed Domain Name is in bad faith. WIPO Overview 3.1, section 3.2.1. One additional factor to be considered is whether Respondent knew or should have known of Complainant’s rights in the FORBES Mark at the time the Disputed Domain Name was registered. Having registered the Disputed Domain Name, Respondent redirected it to the official website of Complainant. This shows that Respondent had actual knowledge of the FORBES Mark when the Disputed Domain Name was registered. WIPO Overview 3.1, section 3.2.2. Panels have held that the use of the Disputed Domain Name illegitimate activity, here claimed as impersonation, fraud, and phishing, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds Respondent’s registration and use of the Disputed Domain Name constitutes bad faith under the Policy. The Panel finds that 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 <forbesstaff.com> be transferred to Complainant. /Richard W. Page/ Richard W. Page Sole Panelist Date: June 28, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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