Westmore · UDRP decision
FORUM · Case No. FA2601002200000

Hackensackmeridiianhealth.org

TransferFORUM-indexed · informational, not legal advice

The Panel ordered transfer of the domain after finding it confusingly similar to Complainant’s HACKENSACK MERIDIAN HEALTH mark, that Respondent lacked rights or legitimate interests, and that registration and passive holding constituted bad faith under the circumstances.

Outcome
Transfer
At a glance
Provider
FORUM
Outcome
Transfer
Decision date
2026-02-23
Panelist(s)
Nick J. Gardner
Complainant
Hackensack Meridian Health, Inc.
Respondent
Hall Caleb / hackensackmeridiianhealth
Counsel
Sarah E. Bro
Law firm
McDermott Will & Schulte LLP
Disputed domain(s)
hackensackmeridiianhealth.org
Citation weightrelies on 8 authorities
Domain history UDRP Intelligence

The timeline behind hackensackmeridiianhealth.org

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 hackensackmeridiianhealth.org — 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 hackensackmeridiianhealth.org.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

Although the Panel could not determine whether a specific Policy paragraph 4(b) circumstance applied, it found bad faith because the mark was obviously connected with Complainant, no good-faith use of the confusingly similar domain was conceivable without consent, and passive holding supported bad faith based on the mark’s reputation, Respondent’s default, and the implausibility of good-faith use.

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.

Related decisions
Case details
Provider
FORUM
Outcome
Transfer
Decision date
2026-02-23
Panel
Nick J. Gardner
Full decision
12 min read · hosted by Westmore

NATIONAL ARBITRATION FORUM DECISION Hackensack Meridian Health, Inc. v. Hall Caleb / hackensackmeridiianhealth Claim Number: FA2601002200000 PARTIES Complainant is Hackensack Meridian Health, Inc. ("Complainant"), represented by Sarah E. Bro of McDermott Will & Schulte LLP, California, USA. Respondent is Hall Caleb / hackensackmeridiianhealth ("Respondent"), Georgia, USA. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <hackensackmeridiianhealth.org>, registered with Tucows Domains 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. Nick J. Gardner as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on January 15, 2026; Forum received payment on January 15, 2026. On January 16, 2026, Tucows Domains Inc. confirmed by e-mail to Forum that the <hackensackmeridiianhealth.org> domain name is registered with Tucows Domains Inc. and that Respondent is the current registrant of the name. Tucows Domains Inc. has verified that Respondent is bound by the Tucows Domains 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 January 21, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 10, 2026 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@hackensackmeridiianhealth.org. Also on January 21, 2026, 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 February 11, 2026pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Nick J. Gardner 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 Complainant is an integrated network of healthcare providers and the largest healthcare provider in New Jersey. Complainant holds multiple United States trademark registrations for the marks MERIDIAN HEALTH, HACKENSACK MERIDIAN HEALTH, and marks containing HACKENSACK MERIDIAN in various forms. Complainant has used the HACKENSACK MERIDIAN HEALTH mark since at least 2016. Complainant also owns the domain name <hackensackmeridianhealth.org> which resolves to its official website. Complainant contends that the <hackensackmeridiianhealth.org> domain name is confusingly similar to its HACKENSACK MERIDIAN HEALTH mark, as the disputed domain name is a typosquatted version of Complainant's mark and official domain name, differing only by the addition of an extra letter "i" in the word "meridian." Complainant contends that Respondent has no rights or legitimate interests in respect of the disputed domain name. Complainant asserts that Respondent is not affiliated with, licensed by, or otherwise authorized by Complainant to use its marks; that Respondent is not commonly known by the disputed domain name; and that Respondent is not making any bona fide offering of goods or services or legitimate noncommercial or fair use of the disputed domain name, as the domain name resolves to a "516 Upstream Certificate CN Mismatch" error page. Complainant contends that the disputed domain name was registered and is being used in bad faith. Complainant argues that the passive holding of a domain name incorporating its registered trademark indicates bad faith; that the error message associated with the domain name may indicate malware or malicious security attacks; that Respondent had actual knowledge of Complainant's marks at the time of registration given their widespread recognition and Respondent's use of a typosquatted version thereof; and that typosquatting is itself evidence of bad faith registration and use. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant is a New Jersey corporation and the largest healthcare provider in New Jersey. Complainant holds multiple United States trademark registrations for marks including HACKENSACK MERIDIAN HEALTH and MERIDIAN HEALTH, with rights in the HACKENSACK MERIDIAN HEALTH mark dating to at least 2016. See for example US registration No. 5,441,320 registered on April 10, 2018 for HACKENSACK MERIDIAN HEALTH. Complainant owns the domain name <hackensackmeridianhealth.org> which resolves to its official website. The disputed domain name <hackensackmeridiianhealth.org> was registered on January 1, 2026. The registrant is identified as Hall Caleb / hackensackmeridiianhealth. The disputed domain name resolves to a "516 Upstream Certificate CN Mismatch" error page. Respondent failed to submit a Response in this proceeding. 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 has established rights in the HACKENSACK MERIDIAN HEALTH mark through its United States trademark registrations and through continuous use of the mark since at least 2016 in connection with healthcare services. The Panel finds that Complainant has satisfied the threshold requirement of demonstrating rights in the HACKENSACK MERIDIAN HEALTH mark for the purposes of paragraph 4(a)(i) of the Policy – see Farmlane Brands, LLC v. Helene Isbell Biggane, FA 1996757 (Forum July 12, 2022) "Ownership of a trademark registration is generally sufficient evidence that a complainant has the requisite rights in a mark for purposes of paragraph 4(a)(i) of the Policy." The disputed domain name <hackensackmeridiianhealth.org> is confusingly similar to Complainant's HACKENSACK MERIDIAN HEALTH mark. The disputed domain name incorporates Complainant's mark in its entirety, with the sole modification being the addition of an extra letter "i" in the word "meridian" (rendering it "meridiian"). This constitutes typosquatting, which does not sufficiently distinguish the disputed domain name from Complainant's mark. This is a classic typosquatting scenario. Further the addition of a single letter does not distinguish the disputed domain name from Complainant's mark. See Victoria's Secret v. Zuccarini, FA 95762 (Forum Nov. 18, 2000) (finding that by misspelling words and adding letters to words, respondent does not create a distinct mark but nevertheless renders the domain name confusingly similar to complainant's marks); Intelius, Inc. v. Hyn, FA 703175 (Forum July 5, 2006) (finding <intellus.com> confusingly similar to complainant's INTELIUS mark because the domain name differed by one letter and was visually similar). The addition of the ".org" generic top-level domain is irrelevant to the analysis under Policy ¶ 4(a)(i). See Trip Network Inc. v. Alviera, FA 914943 (Forum Mar. 27, 2007). The Panel finds that Complainant has established Policy ¶ 4(a)(i). Rights or Legitimate Interests Under Policy ¶ 4(a)(ii), it is now well established that the Complainant must first make a prima facie case that the Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii) and that, if the prima facie case is made out, the burden then shifts to the Respondent to show that it does have such 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)). Under Policy ¶ 4(c) Respondent may demonstrate rights or a legitimate to the domain name for purposes of Policy ¶ 4(a)(ii) if without limitation any of the following apply: (i) before any notice to you of the dispute, your use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or (ii) you (as an individual, business, or other organization) have been commonly known by the domain name, even if you have acquired no trademark or service mark rights; or (iii) you are making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. Complainant has demonstrated that Respondent is not authorized to use the HACKENSACK MERIDIAN HEALTH mark and has no relationship with Complainant. There is no evidence Respondent is using the disputed domain name in connection with a bona fide offering of goods or services. The WHOIS information identifies Respondent as "Hall Caleb" which bears no resemblance to the disputed domain name. The WHOIS information identifying Respondent organization as hackensackmeridiianhealth is simply self-serving information provide by Respondent when effecting registration of the disputed domain name – there is no evidence that name has ever been used in any other way by Respondent. There is no evidence that Respondent has been commonly known by the disputed domain name or has acquired any trademark rights in "HACKENSACK MERIDIAN HEALTH" or any similar term. There is no evidence Respondent is making legitimate noncommercial or fair use of the disputed domain name. Accordingly, Complainant has established a prima facie case under Policy ¶ 4(a)(ii), and the burden shifts to Respondent to demonstrate rights or legitimate interests. Respondent has failed to rebut Complainant's prima facie case or to demonstrate any rights or legitimate interests in the disputed domain name. The Panel finds that Complainant has established Policy ¶ 4(a)(ii). Registration and Use in Bad Faith Policy ¶ 4(b) sets forth four non-exclusive circumstances that constitute evidence of registration and use in bad faith. It is not possible to determine whether any of these are applicable to the facts of the present case. However the list is non exhaustive. The HACKENSACK MERIDIAN HEALTH mark is so obviously connected with Complainant that Respondent's registration and use of the confusingly similar disputed domain name strongly supports a finding of bad faith. It is not possible to conceive of a good faith use of the domain name (absent consent from the Complainant). The fact that the domain name has not been used and is passively held does not alter this analysis – see Bridgewater Associates, LP v. hamza hamed, FA 1894223 (Forum June 9, 2020) ("The fame of Complainant's mark and the lack of evidence of legitimate use and bona fide offering of goods and services by Respondent are the factors that, inter alia, support finding of passive holding as constituting bad faith registration and use". See also Coachella Music Festival, LLC v. Mike Gau, FA 1878581 (Forum Jan. 16, 2020) ("The overriding objective of the Policy is to curb the abusive registration of domain names in circumstances where the registrant seeks to profit from or exploit the trade mark of another. Passive holding of a domain name containing a mark with a reputation can be bad faith registration and use"). See also WIPO Overview 3.0 at ¶ 3.3. "Can the "passive holding" or non-use of a domain name support a finding of bad faith? From the inception of the UDRP, panelists have found that the non-use of a domain name (including a blank or "coming soon" page) would not prevent a finding of bad faith under the doctrine of passive holding. While panelists will look at the totality of the circumstances in each case, factors that have been considered relevant in applying the passive holding doctrine include: (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". At least factors (i), (ii) and (iv) apply in the present case. The Panel finds that Complainant has established 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 <hackensackmeridiianhealth.org> domain name be TRANSFERRED from Respondent to Complainant. Nick J. Gardner Panelist Dated: February 23, 2026 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.

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