Westmore · UDRP DecisionApply-ibm.co + 11 more domains
The Panel consolidated the proceeding against the nominally different registrants after finding common-control indicators across the 12 disputed domain names. It found each domain confusingly similar to the Complainant’s IBM mark, found no rights or legitimate interests, and found registration and use in bad faith. The Panel ordered all 12 domain names transferred to the Complainant.
The timeline behind apply-ibm.co
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 apply-ibm.co — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates consolidation based on a combination of registration, hosting, naming, redirection, and MX-record similarities. It also treats direct redirection to a trademark owner’s official website as evidence of deliberate targeting rather than legitimate use, and combines that conduct with passive holding, questionable contact details, and a related UDRP decision to establish bad faith.
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 International Business Machines Corporation v. Aaron Stevens, IbmStudio, Chris Steven, EEbm, Maggie Wang, IBMie Case No. D2026-3300 1. The Parties The Complainant is International Business Machines Corporation, United States of America (“United States”), internally represented. The Respondents are Aaron Stevens, IbmStudio, United States; Chris Steven, EEbm, United States; and Maggie Wang, IBMie, United States. 2. The Domain Names and Registrar The disputed domain names <apply-ibm.co>, <careers-ibm.co>, <careers-ibm.tech>, <explore-ibm.co>, <find-ibm.co>, <hiring-ibm.co>, <info-ibm.co>, <jobs-ibm.co>, <join-ibm.co>, <reply-ibm.co>, <search-ibm.co>, and <talent-ibm.co> are registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 24, 2026. On July 27, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On July 28, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (John Doe) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 30, 2026 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amendment to the Complaint on July 31, 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondents of the Complaint, and the proceedings commenced on August 13, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 2, 2026. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on September 9, 2026. The Center appointed Gary Saposnik as the sole panelist in this matter on September 14, 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 was incorporated in 1911 and officially became International Business Machines in 1924. The Complainant has been offering products and services in the information technology space ever since, including computers, computer hardware, software, programs, and other computer products and services. The Complainant has a presence in over 175 countries through its wholly owned subsidiaries with over 288,300 employees worldwide. The Complainant was ranked the 16th Most Valuable Global Brand in 2026 by the Kantar Brandz index, and was ranked the 22nd best global brand in 2025 by Interbrand. The Complainant has expended more than USD 8.3 billion on advanced research in 2025, and more than USD 1 billion annually marketing its goods and services globally, using the IBM trademark. The Complainant owns and has owned trademark registrations for IBM in 131 countries around the world, for a broad range of goods and services, including but not limited to, information technology related goods and services. The Complainant’s trademark registration for IBM includes the following registrations in the United States: - IBM, United States Registration No. 4181289, registered July 31, 2012, in classes 9, 16, 18, 20, 21, 22, 25, 28, 35 and 41; - IBM, United States Registration No. 3002164, registered September 27, 2005, in classes 9; - IBM, United States Registration No. 1694814, registered June 16, 1992, in class 36; - IBM, United States Registration No. 1205090, registered August 17, 1982, in classes 1, 9, 16, 37, and 41. These registrations are referred to herein as the “IBM Trademark”. All of the disputed domain names were registered by the Respondents on May 17, 2026 The disputed domain names <apply-ibm.co>, <explore-ibm.co>, <careers-ibm.co>, <find-ibm.co>, <hiring-ibm.co>, <info-ibm.co>, <jobs-ibm.co>, <join-ibm.co>, <reply-ibm.co>, <search-ibm.co>, <talent-ibm.co> redirect to the Complainant’s official webpage at “www.ibm.com”, while the disputed domain name <careers-ibm.tech> previously redirected to the Complainant’s webpage, but is currently inactive. Upon becoming aware of the disputed domain names, the Complainant sent a cease-and-desist letter to the Respondents, through the Registrar, at the email addresses listed in the WhoIs records, which the Respondents did not reply to. 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 names. page 3 Notably, the Complainant contends that the disputed domain names are identical or confusingly similar to the IBM Trademark in which the Complainant has rights. The disputed domain names consist of descriptive words associated with career services, namely “apply”, “explore”, “find”, “search”, “join”, “careers”, “info”, “jobs”, “talent”, “reply” and “hiring”, followed by a hyphen, the letters “ibm”, and the country-code Top-Level Domain (“ccTLD”) “.co” or the generic Top-Level Domain (“gTLD”) “.tech”. The letters “ibm” contained in the disputed domain names is exactly the same as the Complainant’s IBM Trademark. The inclusion of the hyphen sets apart the Complainant’s IBM Trademark from the rest of the terms in the disputed domain names, which enhances the distinctiveness of the IBM Trademark in the disputed domain names. The Complainant contends that the Respondents have no rights or legitimate interests in respect of the disputed domain names. The Complainant has never licensed, contracted, or otherwise permitted anyone to apply to register the disputed domain names. There is no evidence that the disputed domain names are similar to the name of the Respondents or their respective business entities. Nor is there evidence that the Respondents are using the disputed domain names incorporating the Complainant’s IBM Trademark for a bona fide offering of goods or services or noncommercial fair use. Such unauthorized use of the Complainant’s trademark is likely to trick consumers into erroneously believing that the Complainant is somehow affiliated with the Respondents or endorsing the Respondents’ commercial activities, when no such relationship exists. Lastly, the Complainant avers that the disputed domain names were registered and are being used in bad faith. Previous WIPO panels have found that “the registration of a domain name that is confusingly similar to a trademark by an entity that has no relationship to that mark may be sufficient evidence of opportunistic bad faith.” International Business Machines v. John Doe/Anonymize, Inc., WIPO Case No. D2019-2754. The disputed domain names are confusingly similar to the Complainant’s mark, and the Respondents have no relationship to the Complainant nor the IBM Trademark. The Respondents were well aware of the Complainant’s IBM Trademark at the time the Respondents registered the disputed domain names, with the Complainant’s trademarks being well-known around the world. The Respondents registered the disputed domain names at least 69 years after the Complainant established registered trademark rights in the IBM mark. Internet search engines yield results for the Complainant and its products/services when using “apply ibm”, “explore ibm”, “find ibm”, “hiring ibm”, “join ibm”, “search ibm”, “ careers ibm”, “info ibm”, “jobs ibm”, “reply ibm”, “talent ibm”, and “ibm” as search terms. As such, the Respondents either knew or should have known of the Complainant’s IBM mark when registering the disputed domain names. The Complainant argues that there may be a presumption of bad faith solely through redirecting the domain name to the complainant’s or a competitor’s website. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 3.1.4. At some point during the registration period, all of the disputed domain names redirected to the Complainant’s main IBM webpage. While the <careers-ibm.tech> disputed domain name is currently inactive, this creates a real or implied ongoing threat to the Complainant, and such behavior demonstrates bad faith use of the disputed domain names. Additionally, the Complainant contends that the disputed domain names <careers-ibm.co>, <apply-ibm.co>, <find-ibm.co>, <search-ibm.co>, <explore-ibm.co>, <careers-ibm.tech>, <info-ibm.co>, <jobs-ibm.co>, <join-ibm.co>, and <reply-ibm.co> are cybersecurity threats linked to malicious activity or malware. Furthermore, the Respondents connected the disputed domain names to a mail server responsible for sending and accepting email messages on behalf of the disputed domain names. This suggests that the Respondents may have intended to use the disputed domain names for phishing or other fraudulent purposes, such as an employment scam. The Complainant sent a cease-and-desist letter to the Respondents through the Registrar, asking the Respondents to disable and transfer the disputed domain names to the Complainant. The Respondents’ failure to reply to the Complainant’s letter is a further showing of bad faith on the Respondents’ part. page 4 Upon receipt of the disclosure of the registrants of the disputed domain names by the Registrar, the Complainant contends that the Respondents are, in fact, the same entity and that all of the disputed domain names are under common control. The Complainant alleges that the provided postal addresses provided by the Respondents are not legitimate addresses as they only include numbers without a street, and that the registrations are under fictitious company and personal names. Additionally, the registrants use email addresses that differ from their listed names. Lastly, all of the registrants use the area code +376, which is an international country code for Andorra. B. Respondents The Respondents did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1. Consolidation: Multiple Respondents The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the domain name registrants are the same entity or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. The disputed domain name registrants did not comment on the Complainant’s request.. Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. In addressing the Complainant’s request, the Panel will consider whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview 3.1, section 4.11.2. As regards common control, the Panel notes that: 1) all of the disputed domain names are registered with the same registrar, 2) all of the disputed domain names use the same hosting provider, and 3) all of the disputed domain names were registered on the same day, namely May 17, 2026. Additionally, all of the disputed domain names have Mail Exchange (“MX”) records with shared IP addresses. Namely, the disputed domain names <apply-ibm.co>, <find-ibm.co>, <hiring-ibm.co>, and <search-ibm.co> have MX records association with the same address, while <explore-ibm.co>, <careers-ibm.co>, <careers-ibm.tech>, <info-ibm.co>, <jobs-ibm.co>, <join-ibm.co>, <reply-ibm.co>, and <talent-ibm.co> have MX records associated with the same IP address. Moreover, the dispute domain names follow similar naming patterns, comprised of descriptive words associated with career services, followed by a hyphen, the letters “ibm”, and the ccTLD “co” or the gTLD “.tech”. The only difference between the disputed domain names are the descriptive terms, and all but one disputed domain name have the ccTLD “.co”. Additionally, all of the disputed domain names are in Latin script. Lastly, all of the disputed domain names either redirect or had redirected to the Complainant’s official webpage. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party. Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding. page 5 6.2. Substantive Issues 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 names. WIPO Overview 3.1, section 1.7. The Complainant has shown rights in respect of its IBM trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds the IBM mark is recognizable within each of the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms here, “careers-”, “apply-”, “explore-”, “find-”, “hiring-”, “info-”, “jobs-”, “join-”, “reply-”, “search-”, and “talent-”, may bear on assessment of the second and third elements, the Panel finds the addition of such terms 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 that 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 names. 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 names such as those enumerated in the Policy or otherwise. The composition of the disputed domain names naturally creates a likelihood of confusion and association with the Complainant for consumers seeking out information about or employment with the Complainant, which is furthered by the use of the disputed domain names to previously all redirect to the Complainant’s website. The Panel also notes that although the Respondent registered the disputed domain names under the company names “IbmStudio”, “EEbm”, and “IBMie”, the Complainant has asserted that the Respondent is not associated with the Complainant, which the Respondent has not disputed. Further, there is no evidence demonstrating that the Respondent is commonly known by those names or disputed domain names. The Panel finds the second element of the Policy has been established. page 6 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 all of the disputed domain names on the same day, many decades after the Complainant acquired trademark rights in its well-known IBM Trademark. The Respondent redirected the disputed domain names <apply-ibm.co>, <explore-ibm.co>, <careers-ibm.co>, <explore-ibm.co>, <find-ibm.co>, <hiring-ibm.co>, <info-ibm.co>, <jobs-ibm.co>, <join-ibm.co>, <reply-ibm.co>, <search-ibm.co>, and <talent-ibm.co> to the Complainant’s official webpage, with such redirections still continuing. The disputed domain name <careers-ibm.tech> was previously redirected to the Complainant’s official webpage but is currently inactive. However, the Complainant has provided evidence that this inactive disputed domain name is still associated with MX records and likely being used to distribute malware, phishing and/or spam. 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. These circumstances include registrations that incorporate the complainant’s mark plus an additional term such as a descriptive term, or one that corresponds to the complainant’s area of activity or natural zone of expansion. All of the disputed domain names incorporate the Complainant’s well-known IBM Trademark and a descriptive term that would naturally create a likelihood of confusion and association with the Complainant for consumers seeking out information about or employment with the Complainant. Panels have consistently found that the mere registration of a domain name that is confusingly similar (particularly domain names incorporating a descriptive the mark plus a descriptive term) to a well-known trademark can by itself create a presumption of bad faith. The redirection of the disputed domain names to the Complainant’s website is an obvious indicia of the Respondent targeting the Complainant, as well as evidence supporting that the Respondent registered the disputed domain names to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s mark. WIPO Overview 3.1, section 3.1.4. The Respondent’s contact information is obviously incomplete and likely false, with an email address not matching the Respondent’s names, fake phone numbers, and addresses without a street name listed. These likely false and incomplete contact details are further indicia of bad faith by the Respondent. Regarding the inactive disputed domain name, the Panel notes that: the well-known reputation of the Complainant’s mark; the prior redirecting use; the composition of this disputed domain name; and the Respondent’s failure to provide a response, support a finding that in the circumstances of this case the passive holding of this disputed domain name does not prevent a finding of bad faith under the Policy. WIPO Overview 3.1, section 3.3. The Panel also notes that the Respondent, Aaron Stevens, IbmStudio, was found by this Panel to have registered and used six IBM-related domain names in bad faith in International Business Machines Corporation v. Aaron Stevens, IbmStudio, WIPO Case No. D2026-3303. Those domain names were registered on the same date as the disputed domain names, and under similar circumstances. Combined with the current case, the Panel finds that the Respondent has engaged in a pattern of trademark abusive conduct in registering the IBM-related domain names. WIPO Overview 3.1, section 3.1.2. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names constitutes bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. page 7 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 names <apply-ibm.co>, <careers-ibm.co>, <careers-ibm.tech>, <explore-ibm.co>, <find-ibm.co>, <hiring-ibm.co>, <info-ibm.co>, <jobs-ibm.co>, <join-ibm.co>, <reply-ibm.co>, <search-ibm.co>, and <talent-ibm.co> be transferred to the Complainant. /Gary Saposnik/ Gary Saposnik Sole Panelist Date: September 28, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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