Westmore · UDRP decision
WIPO · Case No. D2026-3331

Sso-barracuda.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <sso-barracuda.com> to Barracuda Networks, Inc. The domain reproduced the BARRACUDA mark with the term “sso” and substituted a hyphen for the dot in the Complainant’s <sso.barracuda.com> authentication subdomain. The associated website mimicked the Complainant’s single sign-on site, displayed its logo, and requested email addresses and passwords. The Panel found all three UDRP elements established and held that the website and configured MX records evidenced deceptive use and likely phishing activity. Although the Respondent offered to transfer the domain, the Panel exercised its discretion to decide the case on the merits because of the nature of the Respondent’s actions.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-10-08
Panelist(s)
Michelle Brownlee
Complainant
Barracuda Networks, Inc.
Respondent
James Gallagher
Disputed domain(s)
sso-barracuda.com
Domain history UDRP Intelligence

The timeline behind sso-barracuda.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 sso-barracuda.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 sso-barracuda.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates a high-risk impersonation pattern in which a respondent converts a legitimate authentication subdomain into a lookalike second-level domain by replacing a dot with a hyphen. The combination of a visually similar domain, copied branding, credential-entry fields, and MX records supported findings on both lack of legitimate interests and bad faith, even without stated proof that credentials were captured or deceptive emails were sent.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-10-08
Panel
Michelle Brownlee
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Barracuda Networks, Inc. v. James Gallagher Case No. D2026-3331 1. The Parties The Complainant is Barracuda Networks, Inc., United States of America (“United States”), represented by KXT LAW, LLP, United States. The Respondent is James Gallagher, United States. 2. The Domain Name and Registrar The disputed domain name <sso-barracuda.com> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 28, 2026. On July 28, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 25, 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on the same date, 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 August 26, 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 the Respondent of the Complaint, and the proceedings commenced on August 31, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 20, 2026. The Respondent sent email communications to the Center on August 25 and 26, and September 16 and 17, 2026, expressing his willingness to settle the dispute. On September 17, 2026, the Center informed the Parties that, should they wish to explore settlement options, the Complainant would need to submit a request to suspend the proceeding. The page 2 Complainant did not request the suspension of the proceeding. The Center notified the Parties of the Commencement of Panel Appointment Process on September 21, 2026. The Center appointed Michelle Brownlee as the sole panelist in this matter on September 24, 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 in the business of information technology security, networking and storage appliances, and was incorporated in Delaware, United States, in 2003. The Complainant is the owner of United States Registration Number 4,715,332 for the mark BARRACUDA, registered on April 7, 2015, in connection with goods and services in International Classes 9, 41, and 42, which claims use in commerce of the mark since at least as early as December 2002 in relation to services in International Classes 41, and 42 and at least as early as October 2003 in relation to the goods in International Class 9. The Complainant owns the domain name <barracuda.com> and uses the subdomain name <sso.barracuda.com> in connection with cloud control authentication. The disputed domain name was registered on June 12, 2026 and is being used in connection with a web site that uses the Complainant’s logo and is very similar in appearance to the web site that the Complainant hosts at the subdomain name <sso.barracuda.com>. The web site at the disputed domain name incorporates blank fields for visitors to the site to enter their email address and password to sign in the 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 BARRACUDA trademark, the Respondent has no rights to or legitimate interests in respect of the disputed domain name and the Respondent registered and is using the disputed domain name in bad faith in furtherance of a potential phishing scheme by displaying a site that closely resembles the site that the Complainant uses for single sign-on authentication to prompt visitors to enter their email address and password. The Complainant argues that the substitution of a hyphen for the dot used in the Complainant’s <sso.barracuda.com> subdomain name is designed to deceive site visitors into believing that they are visiting the Complainant’s web site. The Complainant also presented evidence that the Respondent set up the disputed domain name with mail exchange (“MX”) records, which the Complainant contends that the Respondent may use the disputed domain name to send emails that appear to originate from the Complainant. B. Respondent The Respondent did not formally reply to the Complainant’s contentions. The Respondent sent several communications to the Center indicating that he did not need the disputed domain name, and offering to transfer the disputed domain name to the Complainant. page 3 6. Discussion and Findings As an initial matter, the Panel addresses the fact that the Respondent has offered to transfer the disputed domain name to the Complainant. In some cases, panels will accept the offer and order the requested remedy without proceeding to a decision on the merits. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.10. In other cases, however, panels will exercise discretion to proceed to a case on the merits. The Panel finds that there is an interest to be served by proceeding to a decision on the merits in this case because of the nature of the Respondent’s actions. See WIPO Overview 3.1, section 4.10. 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. WIPO Overview 3.1, section 1.7. 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 entirety of the mark is reproduced 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 other terms, here, “sso”, 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 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 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. Panels have held that the use of a domain name for illegal activity, here, claimed passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel finds the second element of the Policy has been established. page 4 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 is using the disputed domain name in connection with a web site that mimics the Complainant’s single sign-on authentication web site, including the use of the Complainant’s logo and trademark. The composition of the disputed domain name, which substitutes a hyphen for the dot that the Complainant uses in its <sso.barracuda.com> subdomain name evidences an intent to deceive site visitors into believing that they are visiting the Complainant’s web site. The Respondent’s setting up the disputed domain name with MX records is further evidence of the likely use of the disputed domain name in connection with a phishing scheme. The Panel finds that the Respondent’s actions constitute bad faith under paragraph 4(b)(iv) of the Policy in that the Respondent intentionally attempted to attract, for potential commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark. Panels have held that the use of a domain name for illegal activity, here, claimed passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes 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 <sso-barracuda.com> be transferred to the Complainant. /Michelle Brownlee/ Michelle Brownlee Sole Panelist Date: October 8, 2026

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

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