Westmore · UDRP decision
FORUM · Case No. FA2601002200209

Himss2026.org

TransferFORUM-indexed · informational, not legal advice

The Panel ordered transfer of <himss2026.org>, finding it confusingly similar to Complainant's HIMSS mark, that Respondent lacked rights or legitimate interests because the website impersonated Complainant, and that the impersonation and Respondent's actual knowledge established bad-faith registration and use.

Outcome
Transfer
At a glance
Provider
FORUM
Outcome
Transfer
Decision date
2026-02-11
Panelist(s)
Richard Hill
Complainant
Healthcare Information and Management Systems Society
Respondent
Sobey Panore
Counsel
Caitlin R. Byczko
Law firm
Barnes & Thornburg LLP
Disputed domain(s)
himss2026.org
Citation weightCited by 1 later decision · relies on 11 authorities
Domain history UDRP Intelligence

The timeline behind himss2026.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 himss2026.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 himss2026.org.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The Panel found bad-faith registration and use because the website was likely to confuse consumers about affiliation, endorsement, authorization, or sponsorship. Display of Complainant's mark and business name also showed Respondent's actual knowledge of Complainant's rights when registering the domain.

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
2026-02-11
Panel
Richard Hill
Full decision
12 min read · hosted by Westmore

NATIONAL ARBITRATION FORUM DECISION Healthcare Information and Management Systems Society v. Sobey Panore Claim Number: FA2601002200209 PARTIES Complainant is Healthcare Information and Management Systems Society ("Complainant"), represented by Caitlin R. Byczko of Barnes & Thornburg LLP, Indiana, USA. Respondent is Sobey Panore ("Respondent"), India. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <himss2026.org>, registered with GoDaddy.com, LLC. 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 January 16, 2026; Forum received payment on January 16, 2026. On January 20, 2026, GoDaddy.com, LLC confirmed by e-mail to Forum that the <himss2026.org> domain name is registered with GoDaddy.com, LLC and that Respondent is the current registrant of the name. GoDaddy.com, LLC has verified that Respondent is bound by the GoDaddy.com, LLC 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@himss2026.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, 2026, 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 name be transferred from Respondent to Complainant. PARTIES' CONTENTIONS A. Complainant Complainant states that it is a membership-based not-for-profit organization whose mission is to "reform the global health ecosystem through the power of information and technology". In furtherance of its mission, Complainant has established itself as the leading provider of global health technology and information tools, subject-matter expertise, professional development, and communication services for its members of the healthcare industry at large. Complainant has used the trademarks HEALTHCARE INFORMATION AND MANAGEMENT SYSTEMS SOCIETY and HIMSS since at least as early as 1986 to deliver scientific and technological services, educational services, professional development, policy advocacy, and development of industry best practices. One of the most meaningful and prominent ways in which Complainant serves its members and its mission is by hosting its Annual Global Conference – typically referred to in the healthcare industry as "the HIMSS Conference" or sometimes just "HIMSS" (as in, "are you going to HIMSS this year?"), underscoring the strength of the connection between the organization and the Annual Conference. Complainant and its partners operate multiple websites to promote the HIMSS Annual Conference and to facilitate scheduling, planning and registration for Complainant's events. These websites include <www.himssconference.com> and <www.himss.org>. Complainant hosts its events and offers its services throughout the United States and also in jurisdictions around the world including the UK, EU, Canada, Mexico, the Middle East and Asia-Pacific. Complainant has more than 125,000 global members, and it brings insights from the health systems around the world, including 400 provider organizations, 500 non-profit partners, and 550 health services organizations. Complainant asserts rights in the mark HIMSS through its registration in the United States in 2000. The mark is registered elsewhere around the world. Complainant alleges that the disputed domain name is confusingly similar to its HIMSS mark as it incorporates the mark in its entirety, merely adding the term "2026" (which is the year of Complainant's next conference) and the ".org" generic top-level domain ("gTLD"). Complainant cited UDRP precedents to support its position. According to Complainant, Respondent lacks rights or legitimate interests in the disputed domain name as Respondent is not commonly known by the disputed domain name, nor did Complainant authorize it to use its mark in any way. Respondent fails to make a bona fide offering of goods or services or legitimate noncommercial or fair use in connection with the disputed domain name. Instead, the resolving website impersonates Complainant: it displays Complainant's mark and business name, and purports to provide information on Complainant's next conference. Complainant cited UDRP precedents to support its position. Further, says Complainant, Respondent registered and uses the disputed domain name in bad faith as Respondent attempts to impersonate Complainant. Respondent had actual knowledge of Complainant's rights in its mark. Complainant cited UDRP precedents to support its position. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant owns the mark HIMSS and uses it to deliver scientific and technological services, educational services, professional development, policy advocacy, and development of industry best practices, including through an annual conference. Complainant's rights in its mark date back to at least 2000. The disputed domain name was registered in 2025. Complainant has not licensed or otherwise authorized Respondent to use its mark. The resolving website impersonates Complainant, displaying Complainant's mark and business name. 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 name incorporates Complainant's HIMSS mark in its entirety, merely adding the term "2026" (which is the year in which Complainant's next conference will be held"), together with the ".org" generic top-level domain ("gTLD"). Under Policy ¶ 4(a)(i), adding a gTLD and/or relevant or meaningless numbers is generally insufficient in differentiating a disputed domain name from the mark it incorporates. 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 Wiluna Holdings, LLC v. Edna Sherman, FA 1652781 (Forum Jan. 22, 2016) (finding the addition of a generic term and gTLD is insufficient in distinguishing a disputed domain name from a mark under 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 name is 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 name: under Policy ¶ 4(c)(ii), WHOIS information may be used to determine whether a respondent is commonly known by the disputed domain name. See Amazon Technologies, Inc. v. LY Ta, FA 1789106 (Forum June 21, 2018) (concluding a respondent has no rights or legitimate interests in a disputed domain name where the complainant asserted it did not authorize the respondent to use the mark, and the relevant WHOIS information indicated the respondent is not commonly known by the domain name). Here, the WHOIS information for the disputed domain names lists the registrant as "Sobey Panore". Therefore, the Panel finds that Respondent is not commonly known by the disputed domain name per Policy ¶ 4(c)(ii). The resolving website impersonates Complainant: it displays Complainant's mark and business name. Use of a disputed domain name to create a false impression that a respondent is associated or affiliated with a complainant is not a bona fide offering of goods or services or legitimate noncommercial or fair use per Policy ¶ 4(c)(i) or (iii). Indeed, according to paragraph 2.5 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (WIPO Jurisprudential Overview 3.0): "Fundamentally, a respondent's use of a domain name will not be considered 'fair' if it falsely suggests affiliation with the trademark owner …". See 201 Folsom Option JV, L.P. and 201 Folsom Acquisition, L.P. v. John Kirkpatrick, D2014-1359 (WIPO, Oct. 28, 2014); see also Ripple Labs Inc. v. Jessie McKoy / Ripple Reserve Fund, FA 1790949 (Forum July 9, 2018) (finding the respondent did not use the domain name to make a bona fide offering of goods or services per Policy ¶ 4(c)(i) or for a legitimate noncommercial or fair use per Policy ¶ 4(c)(iii) where the website resolving from the disputed domain name featured the complainant's mark and various photographs related to the complainant's business). Therefore, the Panel finds that Respondent has failed to use the disputed domain name to make a bona fide offering of goods or services or 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 name. 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 name. Indeed, as already noted, consumers visiting the resolving website are likely to be confused as to whether Respondent and/or its website are affiliated in some way with Complainant; and/or the disputed domain name or the associated website is endorsed, authorized, or sponsored by Complainant, none of which are true. This is a form of bad faith use of the disputed domain name. See Bank of America Corp. v. Out Island Props., Inc., FA 154531 (Forum June 3, 2003) (bad faith established "[s]ince the disputed domain names contain entire versions of Complainant's marks and are used for something completely unrelated to their descriptive quality, a consumer searching for Complainant would become confused as to Complainant's affiliation with the resulting search engine website."). Thus the Panel finds bad faith registration and use under Policy ¶ 4(a)(iii). Further, Respondent registered the disputed domain name with actual knowledge of Complainant's mark: the resolving website displays Complainant's mark and business name. 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 name and that this constitutes 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 <himss2026.org> domain name be TRANSFERRED from Respondent to Complainant. Richard Hill, Panelist Dated: February 11, 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.

Beyond the decision

What Westmore sees around himss2026.org

The decision is only the record. Westmore connects it to the cases, authorities, panelists, parties and domain evidence surrounding it.

Connected to Westmore UDRP Intelligence
115,979 decisions · citations · panelists · parties · domain history
Eleanor · UDRP intelligence
Ask Eleanor about this decision
Ask Eleanor about this decision

A short, grounded explanation drawn only from this decision's record — not legal advice or a prediction.

Unlocking Eleanor for this case uses 1 of your complimentary Intelligence unlocks· 3 remaining

Grounded in the Westmore record for this decision. Research/informational only — not legal advice or a prediction of any outcome.

Westmore Professional · Unlock the intelligence

The decision is only the beginning.

You've seen what happened. Now discover the deeper intelligence behind the case, the panelist, the parties and the authorities that matter.

Citation Intelligence
How this decision is cited and treated across the corpus.
Panelist Intelligence
The panel's tendencies, outcomes and reasoning patterns.
Domain History
Ownership chronology — creation vs. respondent acquisition.
Opposing-Party Research
Complainant, counsel and portfolio context.
Independent Case Review
Eleanor challenges your filing before the other side does.
Professional Matters
Open, research and manage matters end to end.
$395/month
Unlock Westmore Professional Annual & firm seats available · cancel anytime
Take the next step
Westmore UDRP · find the right service

Westmore UDRP records draw on FORUM-indexed decisions and are provided for research and informational purposes only. Not legal advice, a clearance opinion, or a prediction of any outcome.

Essential cookies only. Nothing is sold or shared.