Westmore · UDRP DecisionCaranhsoft.com
The Panel found that <caranhsoft.com> was confusingly similar to Complainant's registered CARAHSOFT mark, that Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith through passive holding, phishing-related emails, and deliberate typosquatting. The Panel ordered transfer of the domain to Complainant.
The timeline behind caranhsoft.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 caranhsoft.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
Considering Complainant's reputation, the use of the domain for emails that sometimes induced disclosure of personal information and payments, and the absence of any evidence of contemplated good-faith use, the Panel found that passive holding constituted bad-faith use. The deliberate addition of an extra "n" was also found to be typosquatting and further evidence of bad-faith registration and use.
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. Man Likeori Claim Number: FA2602002203657 PARTIES Complainant is Carahsoft Technology Corp. ("Complainant"), represented by Adam D. Mandell of Millen, White, Zelano & Branigan, P.C., Virginia, USA. Respondent is Man Likeori ("Respondent"), California, USA. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <caranhsoft.com>, registered with NameCheap, Inc. PANEL The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding. Ho-Hyun Nahm, Esq. as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on February 4, 2026; Forum received payment on February 4, 2026. On February 5, 2026, NameCheap, Inc. confirmed by e-mail to Forum that the <caranhsoft.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 February 9, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of March 2, 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@caranhsoft.com. Also on February 9, 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 March 3, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Ho-Hyun Nahm, Esq. 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 i) Complainant, Carahsoft Technology Corp., provides information regarding technology products, services, and training to federal, state, and local governments, educational institutions, and prime contractors. Complainant has established rights in the CARAHSOFT mark through its registration with the USPTO (e.g., Reg. No. 3,685,627, registered September 22, 2009). The disputed domain name is confusingly similar to Complainant's CARAHSOFT mark, as it incorporates the mark in its entirety, merely adding the letter "n" and the ".com" generic top-level domain ("gTLD"). ii) Respondent lacks rights or legitimate interests in the disputed domain name. Respondent is not commonly known by the disputed domain name, nor has Complainant authorized Respondent to use the CARAHSOFT mark. Additionally, Respondent is not using the disputed domain name for any bona fide offering of goods or services or a legitimate noncommercial or fair use, as the domain resolves to an error message. The disputed domain name is used to send emails to technology vendors, prime contractors, systems integrators, value-added resellers, and channel partners. In some cases, these emails induce victims into providing personal information and payments to fraudsters. iii) Respondent registered and is using the disputed domain name in bad faith. Respondent registered the disputed domain name many years after Complainant had commenced use of the CARAHSOFT mark and well after it had become well-known and incontestable in the United States. Respondent's passive holding of the disputed domain name further supports a finding of bad faith. Furthermore, Respondent's bad faith is evidenced by the use of a WHOIS privacy service to conceal its identity. Finally, the disputed domain name constitutes typosquatting. Respondent intended for the disputed domain name to be confusingly similar to the CARAHSOFT mark in an attempt to deprive Complainant of the use of the domain name. B. Respondent Respondent did not submit a Response in this proceeding. FINDINGS 1. The disputed domain name was registered on January 12, 2026. 2. Complainant has established rights in the CARAHSOFT mark through its registration with the USPTO (e.g., Reg. No. 3,685,627, registered September 22, 2009). 3. The disputed domain name resolves to an error message. 4. The disputed domain name is used to send emails to technology vendors, prime contractors, systems integrators, value-added resellers, and channel partners. In some cases, these emails induce victims into providing personal information and payments to fraudsters. 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 3.1 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 based on registration of the mark with the USPTO (e.g., Reg. No. 3,685,627, registered September 22, 2009). Registration of a mark with the USPTO is a valid showing of rights in a mark. Since Complainant provides evidence of registration of the CARAHSOFT mark with the USPTO, the Panel finds that Complainant has rights in the mark under Policy ¶ 4(a)(i). Complainant argues that the disputed domain name <caranhsoft.com> is confusingly similar to Complainant's CARAHSOFT mark as it incorporates the entire mark, merely adding the letter "n" as in CARANHSOFT and the ".com" generic top-level domain ("gTLD") to form the disputed domain name. Visually similar misspellings of a complainant's mark by replacing and/or adding a letter, plus the addition of a gTLD, are not sufficient to distinguish a disputed domain name from a mark under Policy ¶ 4(a)(i). See additionally PathAdvantage Associated v. VistaPrint Technologies Ltd, FA 1625731 (Forum July 23, 2015) (holding that the <pathadvantages.com> domain name was confusingly similar to the PATHADVANTAGE trademark because the domain name "merely adds the letter 's' to Complainant's mark"); see also Carahsoft Technology Corp. v. Fatkin Tdme, FA 1981718 (Forum Feb. 28, 2022) (holding that the domain name consists of a sign confusingly similar to the Complainant's CARAHSOFT mark merely transposing two letters, an 'a' and a 'h' and adding the gTLD ".com". The Panel agrees that misspellings such as the transposition of two letters does not distinguish the domain name from the Complainant's trade mark pursuant to the Policy.). As the disputed domain name incorporates Complainant's mark in its entirety, merely adding the letter "n" and the ".com" generic top-level domain ("gTLD"), the Panel finds that the disputed domain name is confusingly similar to Complainant's CARAHSOFT 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), then the burden shifts to Respondent to show it does have rights or legitimate interests. See Section 2.1, WIPO Jurisprudential Overview 3.1 ("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. If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element."). Complainant argues that Respondent has no rights or legitimate interest in the disputed domain name as Respondent is not commonly known by the disputed domain name, nor has Respondent been authorized by Complainant to use Complainant's mark, and Respondent is not affiliated with Complainant. Relevant information, such as WHOIS information, can be used as evidence to show a respondent is or is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii). The Panel notes that the unmasked WHOIS data lists "Man Likeori" as the registrant, and there is no evidence in the record to suggest Respondent was authorized to use the mark. Therefore, the Panel finds that Respondent is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii). Additionally, Complainant argues that Respondent is not using the disputed domain name for any bona fide offering of goods or services or a legitimate noncommercial or fair use, as the domain resolves to an error message. Failure to make active use of a disputed domain name indicates that a respondent is not using the domain for a bona fide offering of goods or services or a legitimate noncommercial or fair use under Policy ¶¶ 4(c)(i) or (iii). See Morgan Stanley v. Francis Mccarthy / Baltec Marine Llc, FA 1785347 (Forum June 8, 2018) ("both Domain Names resolve to a web site that shows the words, 'Not Found, The requested URL / was not found on this server.' Inactive holding of a domain name does not qualify as a bona fide offering of goods or services within the meaning of Policy ¶ 4(c)(i), or a legitimate non-commercial or fair use within the meaning of Policy ¶ 4(c)(iii)."). Complainant has provided a screenshot showing that the disputed domain name resolves to an error message, "Whois verification is pending." Furthermore, the Panel notes that the disputed domain name is used to send emails to technology vendors, prime contractors, systems integrators, value-added resellers, and channel partners. In some cases, these emails induce victims into providing personal information and payments to fraudsters. The Panel considers that the use of the disputed domain name for phishing purposes, while simply resolving to an error page, does 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). The Panel finds that Complainant has established a prima facie case arising from the considerations above. All of these matters serve to establish the prima facie case against Respondent. As Respondent has not filed a response or attempted by any other means to rebut the prima facie case against it, the Panel finds that Respondent has no rights or legitimate interests in the disputed domain name. Registration and Use in Bad Faith Complainant argues Respondent registered and is using the disputed domain name in bad faith since Respondent inactively holds it. The Panel recalls that Complainant has provided a screenshot showing that the disputed domain name resolves to a webpage with an error message. The Panel agrees that the passive holding of a domain name does not necessarily circumvent a finding that the domain name is being used in bad faith within the requirements of Policy ¶ 4(a)(iii). See Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003 (finding that in considering whether the passive holding of a domain name, following a bad faith registration of it, satisfies the requirements of paragraph 4(a)(iii), the panel must give close attention to all the circumstances of the respondent's behavior, and a remedy can be obtained under the Policy only if those circumstances show that the respondent's passive holding amounts to acting in bad faith.) The particular circumstances of this case that the Panel has considered are: i) Complainant is a leading provider of software and IT services to public sector customers. Since at least as early as 1999, Complainant has used the CARAHSOFT mark in connection with value-added reseller services, namely, distributorship services featuring information technology ("IT") products. For years, sales of goods and services offered under Complainant's mark have exceeded billions of dollars on an annual basis. Complainant spends in excess of 8 billion US dollars ($8,000,000,000) per year on marketing and promoting the goods and services rendered under Complainant's mark. Over the years, Complainant has received more than 100 awards from its partners in recognition of outstanding performance. The company has also been recognized by numerous industry publications and media outlets as a fast-growth, top revenue-producing company. As a result of its enormous commercial success, the investment of considerable funds and significant efforts in advertising, the various awards and other achievements, and its enforcement efforts, Complainant has established an enviable reputation, acquired substantial goodwill, and attained distinctiveness in the CARAHSOFT mark throughout the entire United States; ii) The disputed domain name is used to send emails to technology vendors, prime contractors, systems integrators, value-added resellers, and channel partners. In some cases, these emails induce victims into providing personal information and payments to fraudsters; and iii) Respondent has provided no evidence whatsoever of any actual or contemplated good faith use by it of the disputed domain name. Taking into account all of the above, the Panel concludes that Respondent's passive holding of the disputed domain name constitutes bad faith under Policy ¶ 4(a)(iii) and that Respondent is using the disputed domain name in bad faith. Complainant further argues the disputed domain name constitutes typosquatting. Typosquatting is the purposeful misspelling of a complainant's mark and is itself evidence of bad faith. See Homer TLC, Inc. v. Artem Ponomarev, FA 1623825 (Forum July 20, 2015) ("Finally, under this head of the Policy, it is evident that the <homededpot.com> domain name is an instance of typosquatting, which is the deliberate misspelling of the mark of another in a domain name, done to take advantage of common typing errors made by Internet users in entering into a web browser the name of an enterprise with which they would like to do business online. Typosquatting is independent evidence of bad faith in the registration and use of a domain name."); see also Carahsoft Technology Corp. v. Zoe Davis, FA 1981717 (Forum Feb. 28, 2022) ("[t]he Domain Name seeks to take advantage of the situation where Internet users may make a typographical error. Typosquatting itself is evidence of relevant bad faith registration and use.). The Panel agrees and finds that Respondent's addition of an extra "n" in the disputed domain name is the deliberate misspelling of Complainant's mark in the disputed domain name, done to take advantage of common typing errors made by Internet users, and constitutes further evidence of bad faith registration and use. 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 <caranhsoft.com> domain name be TRANSFERRED from Respondent to Complainant. Ho-Hyun Nahm, Esq., Panelist Dated: March 4, 2026 Click Here to return to the main Domain Decisions Page. Click Here to return to our Home Page
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