Kobalttoolsinc.com, Kobalttoolsco.com

The timeline behind kobalttoolsinc.com

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

How each disputed name was decided in this proceeding.

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

NATIONAL ARBITRATION FORUM DECISION LF, LLC v. Personal / Shan Arain / Zeeshan Arain Claim Number: FA2509002175702 PARTIES Complainant is LF, LLC ("Complainant"), represented by Jeanette Eriksson of FairWinds Partners LLC, District of Columbia, USA. Respondent is Personal / Shan Arain / Zeeshan Arain ("Respondent"), Pakistan. REGISTRAR AND DISPUTED DOMAIN NAMES The domain names at issue are <kobalttoolsinc.com> and <kobalttoolsco.com>, registered with Dynadot Inc and Name.com, 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. Richard Hill as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on September 8, 2025; Forum received payment on September 8, 2025. On September 10 and 12, 2025, Dynadot Inc and Name.com, Inc. confirmed by e-mail to Forum that the <kobalttoolsinc.com> and <kobalttoolsco.com> domain names are registered with Dynadot Inc and Name.com, Inc. and that Respondent is the current registrant of the names. Dynadot Inc and Name.com, Inc. have verified that Respondent is bound by the Dynadot Inc and Name.com, Inc. registration agreements 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 September 15, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of October 6, 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@kobalttoolsinc.com and postmaster@kobalttoolsco.com. Also on September 15, 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 October 7, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Richard Hill 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 names be transferred from Respondent to Complainant. PRELIMINARY ISSUE: MULTIPLE RESPONDENTS In the instant proceedings, Complainant has alleged that the entities which control the domain names at issue are effectively controlled by the same person and/or entity, which is operating under several aliases. Paragraph 3(c) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") provides that a "complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder." The Panel finds that the domain names are under common control as the resolving websites have very similar layouts and structure, the same logo, same icon and browser tabs claiming to be "Official"; each of them impersonates Complainant's KOBALT brand, harvesting personal information through leave-a-reply or subscription fields, using the trademarks to attract traffic that is (once sufficient traffic is achieved) monetized through various tactics such as monetized ads or affiliate links for competing or unrelated products. Further, the WHOIS information shows same last name, phone number, email and address for both of the disputed domain names. This is sufficient to find that the domain names were registered by the same domain name holder. See The Valspar Corporation v. Zhou Zhiliang / zhouzhiliang / Zhiliang Zhou / Eric Chow / Visspa Ltd., FA 133934 (Forum Sept. 28, 2010); see also BBY Solutions, Inc. v. White Apple / Dev Kumar, FA 1787251 (Forum June 20, 2018). Consequently, the Panel will rule on both contested domain names, and the registrants are collectively referred to as "Respondent". PARTIES' CONTENTIONS A. Complainant Complainant states that, in 1998, and long prior to the creation of the disputed domain name, Complainant and its outside manufacturing partner commenced use of the KOBALT Mark in connection with the advertising, marketing and sale of hand and power tools exclusively at Lowe's retail home improvement supply stores. Since the inception of the mark, Complainant has continually used it in interstate commerce. Complainant serves customers through more than 1,700 stores in the United States and Canada, had net sales of nearly USD 83 Billion for fiscal year 2024, serves over 16 million customer transactions per week in the United States, and employs approximately 300,000 associates. Complainant is a wholly-owned subsidiary of Lowe's Companies, Inc. which is traded on the New York Stock Exchange under the ticker symbol LOW. Complainant asserts rights in the KOBALT mark based upon its registration in the United States in 2003. Complainant alleges that the disputed domain names are confusingly similar to its KOBALT trademark because they incorporate the mark in its entirety and merely add the generic/descriptive terms "tools" and "inc" or " co", together with the generic top-level domain ("gTLD") ".com". Complainant cites UDRP precedents to support its position. According to Complainant, Respondent does not have rights or legitimate interests in the disputed domain names. Respondent is not licensed or authorized to use Complainant's KOBALT mark and is not commonly known by the disputed domain names. Respondent does not use the disputed domain names for a bona fide offering of goods or services, or a legitimate noncommercial or fair use. Instead, the disputed domain names resolve to webpages claiming to be the official KOBALT website, but are actually merely a vehicle for financial gain through numerous monetized ads, sponsored links, and affiliate links to unauthorized or competing products – i.e. what has commonly come to be known as a spam blog or a "splog"; this is described in the Wikipedia entry on the topic as "a blog which the author uses to promote affiliated websites, to increase the search engine rankings of associated sites or to simply sell links/ads." The resolving websites also display "leave a reply" fields, presumably with the sole purpose to harvest personal information as part of a phishing attempt or perhaps for the sale of such personal information to a third party. Complainant cites UDRP precedents to support its position. Further, says Complainant, Respondent registered and uses the disputed domain names in bad faith. Respondent disrupts Complainant's business and profits from consumer confusion: the resolving websites display Complainant's mark, claiming to be the official KOBALT website, display advertising links for competing products, and may be used in furtherance of phishing. Respondent has engaged in a pattern of bad faith registration and use of domain names. Complainant cites UDRP precedents to support its position. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant has registered trademarks for the mark KOBALT and uses it to market tools. The mark was registered in 2003. Complainant has not licensed or otherwise authorized Respondent to use its mark. The disputed domain names were registered in 2025. The resolving websites display Complainant's mark and purport to be Complainant's website. Respondent has engaged in a pattern of bad faith registration and use of domain names. 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 The disputed domain names incorporate Complainant's KOBALT mark in its entirety and merely add the generic/descriptive term "tools", together with the letters "inc" or " co" and the generic top-level domain ("gTLD") ".com". Adding generic/descriptive terms, and a gTLD is insufficient to differentiate a disputed domain name from a complainant's mark under Policy ¶ 4(a)(i). . See Bloomberg Finance L.P. v. Nexperian Holding Limited, FA 1782013 (Forum June 4, 2018) ("Where a relevant trademark is recognisable within a disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) does not prevent a finding of confusing similarity under the first element."); see also The Toronto-Dominion Bank v. George Whitehead, FA 1784412 (Forum June 11, 2018) ("[S]light differences between domain names and registered marks, such as the addition of words that describe the goods or services in connection with the mark and gTLDs, do not distinguish the domain name from the mark incorporated therein per Policy ¶ 4(a)(i)."); see also Home Depot Product Authority, LLC v. Angelo Kioussis, FA 1784554 (Forum June 4, 2018) ("The domain name contains the mark in its entirety, with only the addition of the generic letters 'sb' and the digits '2018,' plus the generic Top Level Domain ("gTLD") '.com.' These alterations of the mark, made in forming the domain name, do not save it from the realm of confusing similarity under the standards of the Policy."). Therefore the Panel finds that the disputed domain names are confusingly similar to Complainant's mark under Policy ¶ 4(a)(i). Rights or Legitimate Interests Complainant has not licensed or otherwise authorized Respondent to use its mark. Respondent is not commonly known by the disputed domain names: under Policy ¶ 4(c)(ii), WHOIS information may be used to determine whether a respondent is commonly known by the disputed domain name. See State Farm Mutual Automobile Insurance Company v. Dale Anderson, FA 1613011 (Forum May 21, 2015) (concluding that because the WHOIS record lists "Dale Anderson" as the registrant of the disputed domain name, the respondent was not commonly known by the <statefarmforum.com> domain name pursuant to Policy ¶ 4(c)(ii)). Here, the WHOIS information for the disputed domain names lists the registrants as "Personal / Shan Arain / Zeeshan Arain". Therefore the Panel finds that Respondent is not commonly known by the disputed domain names per Policy ¶ 4(c)(ii). The resolving websites display Complainant's mark and purport to be Complainant's website. This indicates an attempt to impersonate Complainant, which is not a bona fide offering of goods or services under Policy ¶4(c)(i) or a legitimate noncommercial or fair use under Policy ¶4(c)(iii). See Edible Communities v. Thoreau, FA 1158554 (Forum Apr. 16, 2008) ("[R]espondent's use of the disputed domain name [<theedibleaustin.com>] to pass itself off as [c]omplainant shows that [r]espondent lacks rights and legitimate interests in the disputed domain name under Policy ¶4(c)(i) as well as Policy ¶4(c)(iii)."); see also Digg v. Digg, FA 1220833 (Forum Oct. 9, 2008) (finding no legitimate interest in respondent's use of the domain name <digg-inc.com> because "[r]espondent is attempting to pass itself off as [c]omplainant" and such "actions do not constitute a bona fide offering of goods or services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use under Policy ¶4(c)(iii)."). Thus the Panel finds that Respondent fails to use the disputed domain names to make a bona fide offering of goods or services, or a legitimate noncommercial or fair use per Policy ¶¶ 4(c)(i) or (iii). And the Panel finds that Respondent does not have rights or legitimate interests in the disputed domain names. Registration and Use in Bad Faith Respondent (who did not reply to Complainant's contentions) has not presented any plausible explanation for its use of Complainant's mark. In accordance with paragraph 14(b) of the Rules, the Panel shall draw such inferences from Respondent's failure to reply as it considers appropriate. Accordingly, the Panel finds that Respondent did not have a legitimate use in mind when registering the disputed domain names. Indeed, as already noted, the resolving websites attempt to impersonate Complainant. This can evince bad faith registration and use under Policy ¶ 4(a)(iii). See American International Group, Inc. v. Walter Busby d/b/a AIG Mergers and Acquisitions, FA 156251 (Forum May 30, 2003) (the resolving website gave every appearance of being associated or affiliated with Complainant's business); see also Mortgage Research Center LLC v. Russell Miranda, FA 993017 (Forum July 9, 2007) (Respondent is implying an affiliation with Complainant, and consumers seeking Complainant's products and services may become confused when encountering Respondent's website). Thus the Panel finds bad faith registration and use under Policy ¶ 4(a)(iii). Further, Respondent registered the disputed domain names with actual knowledge of Complainant's mark: the resolving websites display Complainant's mark and logo, and refer to Complainant's products. While constructive notice is insufficient to demonstrate bad faith, actual knowledge of a complainant's rights in a mark prior to registration may be evidence of bad faith per Policy ¶ 4(a)(iii). See Custom Modular Direct LLC v. Custom Modular Homes Inc., FA 1140580 (Forum Apr. 8, 2008) ("There is no place for constructive notice under the Policy."); see also Orbitz Worldwide, LLC v. Domain Librarian, FA 1535826 (Forum Feb. 6, 2014) ("The Panel notes that although the UDRP does not recognize 'constructive notice' as sufficient grounds for finding Policy ¶ 4(a)(iii) bad faith, the Panel here finds actual knowledge through the name used for the domain and the use made of it."); see also Univision Comm'cns Inc. v. Norte, FA 1000079 (Forum Aug. 16, 2007) (rejecting the respondent's contention that it did not register the disputed domain name in bad faith since the panel found that the respondent had knowledge of the complainant's rights in the UNIVISION mark when registering the disputed domain name). The Panel finds that Respondent had actual knowledge of Complainant's rights in the mark prior to Respondent's registration of the disputed domain names and that this constitutes bad faith under Policy ¶ 4(a)(iii). Finally, Complainant provides evidence showing that Respondent has been found to have registered and used domain names in bad faith in previous UDRP proceedings. Further, in the instant proceeding, Respondent has been found to have registered and used two domain names in bad faith. This is evidence that Respondent has engaged in a pattern of bad faith registration and use of domain names per Policy ¶ 4(b)(ii). See NIKE, Inc., and Nike Innovate, C.V. v. Emile Boulanger, FA 1732458 (Forum July 3, 2017) (finding that registration of several infringing domain names in a case satisfies the burden imposed by the Policy ¶ 4(b)(ii)); see also Philip Morris USA Inc. v. RapidClic / VAUCLIN Olivier, FA 1520008 (Forum Nov. 7, 2013) (respondent's registration of multiple infringing domain names established a pattern of bad faith registration and use under Policy ¶ 4(b)(ii)); see also DIRECTV, LLC v. michal restl c/o Dynadot, FA 1788826 (Forum July 5, 2018) ("The record contains evidence of Respondent's previous eleven UDRP actions, all of which resulted in the transfer of the domain names, thus establishing bad faith per Policy ¶ 4(b)(ii)."). Thus the Panel finds that Respondent registered and uses the disputed domain names in bad faith per Policy ¶ 4(b)(ii). 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 <kobalttoolsinc.com> and <kobalttoolsco.com> domain names be TRANSFERRED from Respondent to Complainant. Richard Hill, Panelist Dated: October 7, 2025 Click Here to return to the main Domain Decisions Page. 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Source of record: FORUM . Reproduced for research; FORUM is the authoritative source.