Car-ahsoft.com

The timeline behind car-ahsoft.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

NATIONAL ARBITRATION FORUM DECISION Carahsoft Technology Corp. v. James Koko Claim Number: FA2508002172091 PARTIES Complainant is Carahsoft Technology Corp. ("Complainant"), represented by Miki Motohashi Iino of Millen, White, Zelano & Branigan, P.C., Virginia, USA. Respondent is James Koko ("Respondent"), Virginia, USA. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <car-ahsoft.com>, registered with NameCheap, Inc. PANEL The undersigned certifies that they have acted independently and impartially and to the best of their knowledge have no known conflict in serving as Panelist in this proceeding. Steven M. Levy as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on August 18, 2025; Forum received payment on August 18, 2025. On August 19, 2025, NameCheap, Inc. confirmed by e-mail to Forum that the <car-ahsoft.com> domain name is registered with NameCheap, Inc. and that Respondent is the current registrant of the name. NameCheap, Inc. has verified that Respondent is bound by the NameCheap, Inc. registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy"). On August 19, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of September 8, 2025 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@car-ahsoft.com. Also on August 19, 2025, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts. Having received no response from Respondent, Forum transmitted to the parties a Notification of Respondent Default. On September 9, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Steven M. Levy as Panelist. Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent. RELIEF SOUGHT Complainant requests that the domain name be transferred from Respondent to Complainant. PARTIES' CONTENTIONS A. Complainant Since at least as early as 1999, Complainant has used the trademark CARAHSOFT in connection with value-added reseller services, namely, distributorship services featuring information technology ("IT") products. Complainant provides information regarding technology products, services and training to federal state, state and local governments, educational institutions and prime contractors. Complainant also provides under the CARAHSOFT mark IT services, a website featuring information in the IT field, technology consultation services and educational services. Complainant has registered the CARAHSOFT mark with the United States Patent and Trademark Office including Reg. No. 3685627 dated September 22, 2009; Reg. No. 5595279 dated October 30, 2018; and Reg. No. 6620076 dated January 18, 2022. Complainant uses the domain name <carahsoft.com> for its website and email addresses. The <car-ahsoft.com> domain name, registered on July 3, 2025, is confusingly similar to the CARAHSOFT mark as it consists of the entire mark and adds only a hyphen and the ".com" TLD. Respondent has no rights or legitimate interests in the disputed domain name where it is not commonly known by the domain name and the domain name does not resolve to any website content. The disputed domain name was registered and is used in bad faith as Respondent had prior knowledge of the CARAHSOFT mark based on the reputation of the mark, it has passively held the domain name, and it has engaged in typosquatting which is commonly used by bad actors who pursue phishing schemes. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS - Complainant owns trademark rights to the CARAHSOFT mark and the <car-ahsoft.com> domain name is confusingly similar to the mark; - Respondent does not have rights or legitimate interests in the disputed domain name where it is not commonly known by the domain name and the domain name does not resolve to any website content; and - The disputed domain name was registered and is used in bad faith based on the likelihood of Respondent's prior knowledge of Complainant's marks, its passive holding of the domain name, and its engaging in typosquatting. DISCUSSION Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable." Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred: (1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (2) Respondent has no rights or legitimate interests in respect of the domain name; and (3) the domain name has been registered and is being used in bad faith. In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) ("Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint"). Identical and/or Confusingly Similar Complainant asserts rights in the CARAHSOFT mark through its registrations with the USPTO. Registration of a mark with the USPTO is sufficient to demonstrate rights in the mark under Policy ¶ 4(a)(i). See DIRECTV, LLC v. The Pearline Group, FA 1818749 (Forum Dec. 30, 2018) ("Complainant's ownership of a USPTO registration for DIRECTV demonstrate its rights in such mark for the purposes of Policy ¶ 4(a)(i).") Here, Complainant provides copies of its USPTO registration certificates. Therefore, the Panel finds that Complainant has rights in the CARAHSOFT mark under Policy ¶ 4(a)(i). Complainant argues that Respondent's <car-ahsoft.com> domain name is confusingly similar to Complainant's mark because the disputed domain name incorporates the CARAHSOFT mark in its entirety and adds a hyphen and the ".com" TLD. The addition of a hyphen and a TLD to a trademark is typically not sufficient to distinguish a disputed domain name from that mark. See, e.g., Amazon Technologies, Inc. v. chacha nagar, FA 2169111 (Forum June Aug. 26, 2025) (confusing similarity found where "[t]he disputed domain name [<alexa-echo.store>] incorporates Complainant's ALEX and ECHO marks in their entirety, merely adding a hyphen and the ".store" generic top-level domain.") See also MTD Products Inc v. Mike Kernea / Skyline, FA 1775278 (Forum Apr. 19, 2018) ("The mere addition of a gTLD is inconsequential and does not avoid a finding of identity.") For the above-stated reasons, the Panel finds that the <car-ahsoft.com> domain name is confusingly similar to Complainant's mark under Policy ¶ 4(a)(i). Rights or Legitimate Interests Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii). Should it succeed in this effort, the burden then shifts to Respondent to show that it does have rights or legitimate interests. See Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011) (finding that a complainant must offer some evidence to make its prima facie case and satisfy Policy ¶ 4(a)(ii)); see also Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014) ("Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests"). Complainant first contends that Respondent lacks rights or legitimate interests in the disputed domain name as Respondent is not commonly known by the domain name. It is widely accepted that WHOIS information can be used to help determine whether a respondent is commonly known by a disputed domain name under Policy ¶ 4(c)(ii). See Amazon Technologies, Inc. v. Timothy Mays aka Linda Haley aka Edith Barberdi, FA 1617061 (Forum June 9, 2015) (concluding that the respondent was not commonly known by the <amazondevice.org>, <amazondevices.org>, and <buyamazondevices.com> domain names under Policy ¶ 4(c)(ii), as the pertinent WHOIS information identified "Timothy Mays", "Linda Haley", and "Edith Barberdi" as the respective registrants). Here, the WHOIS information for the disputed domain name, as verified to Forum by the concerned Registrar, identifies the Registrant Name as "James Koko". As Respondent has filed no Response or made any other submission in this case, there is no evidence to suggest that it is known otherwise. Further, lack of authorization to use a complainant's mark may indicate that the respondent is not commonly known by the disputed domain name. See Emerson Electric Co. v. golden humble / golden globals, FA 1787128 (Forum June 11, 2018) ("lack of evidence in the record to indicate a respondent is authorized to use complainant's mark may support a finding that respondent does not have rights or legitimate interests in the disputed domain name per Policy ¶ 4(c)(ii)"). Here, Complainant states that "Respondent … is not an agent or licensee of any of the Complainant." Thus, the Panel finds no ground upon which to conclude that Respondent is commonly known by the disputed domain name per Policy ¶ 4(c)(ii). Next, Complainant notes that the disputed domain name does not resolve to any website content. A Respondent failing to make use of a confusingly similar domain name in relation to a website typically indicates a lack of a bona fide offering of goods or services or a legitimate noncommercial or fair use per Policy ¶¶ 4(c)(i) or (iii). See Kohler Co. v xi long chen, FA 1737910 (Forum Aug. 4, 2017) ("Respondent has not made a bona fide offering of goods or services, or a legitimate non-commercial or fair use of the domain. Respondent's <kohler-corporation.com> resolves to an inactive webpage displaying the message 'website coming soon!'"). See also Activision Blizzard, Inc. / Activision Publishing, Inc. / Blizzard Entertainment, Inc. v. Cimpress Schweiz GmbH, FA 1737429 (Forum Aug. 3, 2017) ("Complainant insists that Respondent has made no demonstrable preparations to use the disputed domain name. When Respondent is not using the disputed domain name in connection with an active website, the Panel may find that Respondent is not using the disputed domain name for a bona fide offering of goods or services… As Respondent has not provided a response to this action, Respondent has failed to meet its burden regarding proof of any rights or legitimate interest in the disputed domain.") Here, Complainant submits a screenshot showing that the disputed domain resolves to a page displaying the message "This site can't be reached" and so this provides no indication that Respondent is making a bona fide offering of goods or services, nor that it has made any demonstrable preparations for the same. As Complainant has made out a prima facie case that has not been rebutted by Respondent, upon a preponderance of the available evidence the Panel finds that Respondent fails to make a bona fide offering of goods or services or a legitimate noncommercial or fair use of the disputed domain name per Policy ¶¶ 4(c)(i) or (iii). Registration and Use in Bad Faith Complainant argues that Respondent had prior knowledge of its rights in the CARAHSOFT mark at the time of registering the <car-ahsoft.com> domain name. A respondent's actual knowledge of a complainant's rights in an asserted mark prior to registering a disputed domain name can form a foundation upon which to base an argument for bad faith. See AutoZone Parts, Inc. v. Ken Belden, FA 1815011 (Forum Dec. 24, 2018) ("Complainant contends that Respondent's knowledge can be presumed in light of the substantial fame and notoriety of the AUTOZONE mark, as well as the fact that Complainant is the largest retailer in the field. The Panel here finds that Respondent did have actual knowledge of Complainant's mark, demonstrating bad faith registration and use under Policy ¶ 4(a)(iii).") see also iFinex Inc. v. xu shuaiwei, FA 1760249 (Forum Jan. 1, 2018) ("Respondent's prior knowledge is evident from the notoriety of Complainant's BITFINEX trademark as well as from Respondent's use of its trademark laden domain name to direct internet traffic to a website which is a direct competitor of Complainant"). Complainant submits the signed Declaration of its Chief Information Security Officer who states that Complainant's "team includes more than 2,000 sales, marketing, customer service and contracting professionals"; "For years, sales of goods and services offered under the Carahsoft Mark have exceeded billions of dollars on an annual basis" and "in 2020, sales of IT hardware, software and consulting services under the Carahsoft Mark were in excess of eight billion United States dollars ($8,000,000,000.00) (USD)", and that Complainant "advertises in a number of different ways, including on its website, blog, social media platforms, traditional advertising such as digital and print publications, email campaigns, podcasts, signage, promotional products and logo wear and at events." It goes on to declare that Complainant "spends in excess of ten million United States dollars ($10,000,000.00) per year on marketing and promoting the goods and services rendered under the Carahsoft Mark" and that "Carahsoft Technology has been recognized by numerous industry publications and media outlets as a fast growth, top revenue producing company." Screenshots from its <carahsoft.com> website are also provided. While further documentary evidence would have helped support its claims (e.g., copies of some of the items mentioned in the Declaration), the Panel does find that the Declaration does support the claim that the CARAHSOFT mark has developed at least some measure of reputation. Of further persuasive weight is the fact that the mark appears to be rather unique and the <car-ahsoft.com> domain name appears designed to be mistaken for Complainant's own <carahsoft.com> address. Based on the available evidence, the Panel finds it more likely than not that Respondent had actual knowledge of Complainant's marks at the time that it registered the disputed domain name and that it did so in bad faith. Complainant further notes that the disputed domain name does not resolve to any website. It has been held in many prior UDRP decisions that non-use of a domain name for website content, will not prevent a finding of bad faith under the doctrine of passive holding. Rather "panelists will look at the totality of the circumstances in each case, including: (i) the degree of distinctiveness or reputation of the complainant's mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent's concealing its identity or use of false contact details (noted to be in breach of its registration agreement), and (iv) the implausibility of any good faith use to which the domain name may be put." Telstra Corporation Limited v. Nuclear Marshmallows, D2000-0003 (WIPO Feb. 18, 2000). As noted above, the Complainant has referenced and submitted some evidence of the reputation of its mark and the mark is rather unique and distinctive; the Respondent has failed to submit a response or submit any evidence of good faith use; and while the WHOIS record does not, on its face, provide information that appears to be false, the Panel finds no plausible good faith use to which the disputed domain name may be put given that it is clearly intended to give the impression that it Complainant's own <carahsoft.com> address. In this case, Respondent's failure to resolve the disputed domain name to any substantive web page, along with the totality of the circumstances, supports the Complainant's assertion that the domain name is used in bad faith. In addition, Complainant argues that Respondent registered and uses the <car-ahsoft.com> domain name in bad faith because Respondent seeks to pass itself off as Complainant by engaging in typosquatting and confusing and deceiving the public. Such conduct is indicative of bad faith under Policy ¶¶ 4(b)(iii) and (iv). Webster Financial Corporation and Webster Bank, National Association v. IS / ICS INC, FA 16833 (Forum Aug. 11, 2016) ("Typosquatting is a practice whereby a domain name registrant, such as Respondent, deliberately introduces typographical errors or misspellings into a trademark and then uses the string in a domain name. The conniving registrant wishes and hopes that Internet users will inadvertently type the malformed trademark or read the domain name and believe it is legitimately associated with the target trademark. In doing so, wayward Internet users are fraudulently directed to a web presence controlled by the confusingly similar domain name's registrant.") Complainant notes that it "is aware that bad actors have registered domain names confusingly similar to Complainant's Carahsoft Mark in order to engage in phishing scams. * * * These domains are used to send emails to technology vendors, prime contractors, systems integrators, value-added resellers and channel partners. * * * In some cases, these emails trick victims into providing to the fraudsters personal information and payments." Respondent's copying of Complainant's mark and its <carahsoft.com> domain name by adding a hyphen to form the disputed domain name adds further support to the Panel's conclusion that it has engaged in bad faith registration and use under Policy ¶ 4(a)(iii). DECISION Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED. Accordingly, it is Ordered that the <car-ahsoft.com> domain name be TRANSFERRED from Respondent to Complainant. Steven M. Levy, Panelist Dated: September 12, 2025 Click Here to return to the main Domain Decisions Page. Click Here to return to our Home Page

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