Hr-block.org

The timeline behind hr-block.org

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 HRB Innovations, Inc. v. Liam Enukoha Claim Number: FA2602002206000 PARTIES Complainant is HRB Innovations, Inc. ("Complainant"), represented by Timothy J. Feathers of Stinson LLP, Missouri, USA. Respondent is Liam Enukoha ("Respondent"), Delaware, USA. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <hr-block.org>, 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. Petter Rindforth as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on February 18, 2026; Forum received payment on February 18, 2026. On February 19, 2026, NameCheap, Inc. confirmed by e-mail to Forum that the <hr-block.org> 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 24, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of March 16, 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@hr-block.org. Also on February 24, 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 formal response from Respondent, Forum transmitted to the parties a Notification of Respondent Default. On March 17, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Petter Rindforth 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 The Complainant provides tax preparation services under the trademark H&R BLOCK since 1956. Complainant has rights in the H&R BLOCK trademark through its registration of the trademark with the United States Patent and Trademark Office ("USPTO") (e.g., Reg. No. 3,338,962 registered November 20, 2007). Respondent's <hr-block.org> domain name is nearly identical and confusingly similar to Complainant's H&R BLOCK trademark, as it consists of the H&R BLOCK designation with the ampersand deleted, a dash in between HR and BLOCK, and the addition of a top-level domain. Respondent has no legitimate interests in the <hr-block.org> domain name. Respondent is not commonly known by the disputed domain name and Complainant has not authorized or licensed Respondent any rights in the H&R BLOCK trademark. Additionally, Respondent does not use the disputed domain name for any bona fide offering of goods or services or legitimate noncommercial or fair use. Instead, the disputed domain name resolves to a web page that mimics Complainant by using Complainant's H&R BLOCK word mark in purported conjunction with Complainant's goods and services. Respondent registered and uses the <hr-block.org> domain name in bad faith. There is no other explanation for Respondent's actions other than that it aims to pass off as the Complainant to trade off of the considerable goodwill that Complainant has generated in its H&R BLOCK trademarks. Respondent registered the disputed domain name in order to disrupt Complainant's business and divert customers for commercial gain. Finally, Respondent registered the disputed domain name with constructive and/or actual knowledge of Complainant's rights in the H&R BLOCK trademark. B. Respondent Respondent failed to submit a formal Response in this proceeding. It is however noted that Respondent sent an informal note to Forum on March 17, 2026, stating that Respondent registered the disputed domain name on behalf of a client, and that Respondent did not independently originate or intend to infringe on any third-party rights. Respondent claims to be willing to cooperate in resolving the matter amicably and, if required, to facilitate the transfer of the domain name. Respondent also states that, "in the interest of fairness" the Respondent would appreciate consideration for reimbursement of the out-of-pocket registration costs incurred. FINDINGS The Complainant is the owner of the following U.S. trademark registrations: No. 3,338,962 H&R BLOCK (word), registered November 20, 2007 for services in Intl Classes 35, 36 and 41; No. 3,213,068 H&R BLOCK (fig), registered February 27, 2007 for services in Intl Class 35. The Complainant has also generally referred to 10 other U.S. trademark registrations that contain the H&R BLOCK trademark. The disputed domain name <hr-block.org> was registered on January 24, 2026. 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 Complainant asserts rights in the H&R BLOCK trademark based upon the registration with the USPTO (e.g., Reg. No. 3,338,962 registered November 20, 2007). Registration of a trademark with the USPTO is a valid showing of rights in a trademark. 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)."). Since Complainant provides evidence of registration of the H&R BLOCK mark with the USPTO, the Panel finds that the Complainant has rights in the trademark under Policy 4(a)(i). Complainant then argues that the disputed domain name is nearly identical and confusingly similar to Complainant's H&R BLOCK trademark. The Panel agrees with that conclusion. For pure technical reasons, the symbol "&" cannot be part of a domain name, and the addition of a generic symbol like a dash ("-") does nothing to distinguish the disputed domain name from the H&R BLOCK trademark. See Microsoft Corporation v. Thong Tran Thanh, FA 1653187 (Forum, Jan. 21, 2016) (determining that confusing similarity exists where a disputed domain name contains Complainant's entire mark and differs only by the addition of a generic or descriptive phrase and top-level domain). Therefore, the Panel finds that the disputed domain name is confusingly similar to Complainant's trademark per Policy ¶ 4(a)(i). Rights or Legitimate Interests Once the Complainant makes a prima facie case in support of its allegations in respect of the second element of the Policy, the burden shifts to the Respondent to show that it does have rights or legitimate interests pursuant to Policy ¶ 4(a)(ii). See AOL LLC v. Gerberg, FA 780200 (Forum Sept. 25, 2006) ("Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light. If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names."); see also Hanna-Barbera Prods., Inc. v. Entm't Commentaries, FA 741828 (Forum Aug. 18, 2006) (holding that the complainant must first make a prima facie case that the respondent lacks rights and legitimate interests in the disputed domain name under UDRP ¶ 4(a)(ii) before the burden shifts to the respondent to show that it does have rights or legitimate interests in a domain name). Complainant contends that Respondent lacks rights or legitimate interests in the <hr-block.org> domain name since Respondent is not commonly known by the disputed domain name and Complainant has not authorized or licensed to Respondent any rights in the H&R BLOCK trademark. In the absence of any formal response from the Respondent, WHOIS information may be used to determine whether a respondent is commonly known by the disputed domain name under Policy ¶ 4(c)(ii). 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). Additionally, lack of authorization to use a complainant's trademark 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 [the] complainant's mark may support a finding that [the] respondent does not have rights or legitimate interests in the disputed domain name per Policy ¶ 4(c)(ii)"). Here, the WHOIS information for the disputed domain name lists the registrant as "Liam Enukoha", and there is no other evidence to suggest that Respondent was authorized to use the H&R BLOCK trademark. As noted above, Respondent did not formally respond in due time. In the informal, and late, response, Respondent claimed to have registered the disputed domain name on behalf of a third party, including – as the Panel understand the situation – linking the disputed domain name to the infringing web site. As Respondent is the identified and registered owner of <hr-block.org>, Respondent is also responsible for the registration and use of the disputed domain name. The Panel finds that Respondent is not commonly known by the disputed domain name per Policy ¶ 4(c)(ii). Additionally, Complainant argues that Respondent fails to use the disputed domain name in connection with a bona fide offering of goods or services or legitimate noncommercial or fair use as the disputed domain name instead resolves to a web page that mimics Complainant by using Complainant's H&R BLOCK word trademark in purported conjunction with Complainant's goods and services. Such use is indeed not noncommercial or fair use. See Clarisse, Inc. v. Jiarong Huo, FA 2068926 (Forum Nov. 28, 2023) ("Respondent uses the confusingly similar <gownsclarisse.com> domain name to address a website that mimics Complainant's genuine website… Respondent's use of <gownsclarisse.com> in this manner is neither indicative of a bona fide offering of goods or services under UDRP ¶ 4(c)(i) nor of a non-commercial or fair use under UDRP ¶4(c)(iii)"). Therefore, the Panel finds that Respondent fails to use the disputed domain name for a bona fide offering of goods or services or legitimate noncommercial or fair use under Policy ¶ 4(c)(i) or (iii). Registration and Use in Bad Faith Complainant argues that Respondent registered and uses the <hr-block.org> domain name in bad faith because Respondent disrupts Complainant's business and attempts to attract Internet users to its competing website for commercial gain. Previous panels have found such behavior as clear evidence of bad faith. See Hugh Jackman v. Peter Sun, FA 248716 (Forum May 10, 2004), "Registration of a domain name that is confusingly similar to a mark, despite knowledge of the mark holder's rights, is evidence of bad faith registration pursuant to UDRP ¶ 4(a)(iii)." See also Digi Int'l v. DDI Sys., FA 124506 (Forum Oct. 24, 2002) ("[T]here is a legal presumption of bad faith, when Respondent reasonably should have been aware of Complainant's trademarks, actually or constructively."). Respondents' argument that Respondent did not independently originate or intend to infringe on any third-party rights cannot be considered, as everyone that register and use a domain name has a duty to make a pre-search in order to avoid infringement. See Collegetown Relocation, L.L.C. v. John Mamminga, FA95003 (Forum July 20, 2000) ("When registering domain names, the Respondent has a duty to investigate and refrain from using a domain name that infringes on a third party's rights."). In the present case, Complainant's trademark rights indeed pre-date the registration of the disputed domain name, and the said domain is also used to be confusingly related to Complainant's services. Therefore, the Panel finds that Respondent registered and used the disputed domain name in bad faith per Policy ¶¶ 4(b)(iii) and/or (iv). Further, based on the domain name itself compared to Complainant's trademark, and the services connected to the disputed domain name, the Panel concludes that Respondent did have actual knowledge of Complainant's right in its trademark, which support a finding of bad faith 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 <hr-block.org> domain name be TRANSFERRED from Respondent to Complainant. Petter Rindforth, Panelist Dated: March 23, 2026 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.