Westmore · UDRP DecisionChase-corporation.com
The Panel ordered transfer of <chase-corporation.com>, finding it confusingly similar to Complainant’s CHASE CORPORATION mark, that Respondent lacked rights or legitimate interests, and that passive holding and use involving impersonation of Complainant’s CEO established bad-faith registration and use.
The timeline behind chase-corporation.com
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The Panel found bad faith from Respondent’s failure to make active use of the domain and from Respondent’s knowledge of Complainant’s rights, evidenced by use of Complainant’s mark and logo and impersonation of Complainant’s CEO in an email.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
NATIONAL ARBITRATION FORUM DECISION Chase Corporation v. Joo Doo Claim Number: FA2606002229017 PARTIES Complainant is Chase Corporation ("Complainant"), represented by Ryan Thomas of Fish & Richardson P.C., Minnesota, USA. Respondent is Joo Doo ("Respondent"), New York, USA. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <chase-corporation.com>, registered with NameSilo, 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. Sandra J. Franklin as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on June 24, 2026; Forum received payment on June 24, 2026. On June 24, 2026, NameSilo, LLC confirmed by e-mail to Forum that the <chase-corporation.com> domain name is registered with NameSilo, LLC and that Respondent is the current registrant of the name. NameSilo, LLC has verified that Respondent is bound by the NameSilo, 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 June 26, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of July 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@chase-corporation.com. Also on June 26, 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 July 17, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Sandra J. Franklin 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 1. Respondent's <chase-corporation.com> domain name is confusingly similar to Complainant's CHASE CORPORATION mark. 2. Respondent does not have any rights or legitimate interests in the <chase-corporation.com> domain name. 3. Respondent registered and uses the <chase-corporation.com> domain name in bad faith. B. Respondent did not file a Response. FINDINGS Complainant offers industrial products and holds a registration for the CHASE CORPORATION logo mark with the United States Patent and Trademark Office ("USPTO") (Reg. No. 3,608,923, registered April 21, 2009). Complainant began using the CHASE CORPORATION name in 1980 and began conducting business at <chasecorp.com> in 1996. Respondent registered the <chase-corporation.com> domain name on June 17, 2026, and it resolves to an error message. 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 The Panel finds that Complainant has rights in the CHASE CORPORATION logo mark based on registration with the USPTO. See Brooks Sports, Inc. v. Joyce Cheadle, FA 1819065 (Forum Dec. 28, 2018) (finding that Complainant's registration of the BROOKS mark with the USPTO sufficiently conferred its rights in the mark under Policy ¶ 4(a)(i)). Complainant also has common law rights in the CHASE CORPORATION word mark due to continuous commercial use since 1980. Respondent's <chase-corporation.com> domain name uses the CHASE CORPORATION mark and simply adds a hyphen and the ".com" gTLD. These changes do not sufficiently distinguish a disputed domain name from a mark for the purposes of Policy ¶ 4(a)(i). See Ant Small and Micro Financial Services Group Co., Ltd. v. Ant Fin, FA 1759326 (Forum Jan. 2, 2018) ("Respondent's <antfinancial-investorrelations.com> Domain Name is confusingly similar to Complainant's ANT FINANCIAL mark. It incorporates the mark entirely. It adds a hyphen, the descriptive terms "investor relations," and the ".com" gTLD, but these additions are insufficient to distinguish the Domain name from complainant's mark for the purposes of Policy ¶ 4(a)(i).") The Panel therefore finds that Respondent's <chase-corporation.com> domain name confusingly similar to Complainant's CHASE CORPORATION mark. The Panel finds that Complainant has satisfied Policy ¶ 4(a)(i). Rights or Legitimate Interests Once Complainant makes a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii), the burden shifts to Respondent to show it does have 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)); see also Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327, (Forum Apr. 12, 2014) ("Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests."). Complainant contends that Respondent lacks rights and legitimate interests in the <chase-corporation.com> domain name as Respondent is not commonly known by the domain name and Complainant has not authorized or licensed to Respondent any rights in the CHASE CORPORATION mark. The WHOIS information for the disputed domain name lists the registrant as "Joo Doo". Therefore, the Panel finds that Respondent is not commonly known by the disputed domain name, and thus has no rights under Policy ¶ 4(c)(ii). 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)"). Complainant argues that Respondent fails to use the <chase-corporation.com> domain name for a bona fide offering of goods or services or legitimate noncommercial or fair use as the domain name does not resolve to any active content. Complainant provides a screenshot showing that the disputed domain name resolves to an error message that reads "Hmmm…can't reach this page". The Panel therefore finds that Respondent has no rights under Policy ¶¶ 4(c)(i) or (iii). See Teachers Ins. and Annuity Ass'n of Am. V. Wreaks Commc'ns Group (WIPO June 15, 2006) ("passive holding does not constitute 'legitimate non-commercial or fair use'"). The Panel finds that Complainant has satisfied Policy ¶ 4(a)(ii). Registration and Use in Bad Faith Complainant argues that Respondent's failure to make an active use of the CHASE CORPORATION domain name constitutes bad faith. The Panel agrees and finds bad faith under Policy ¶ 4(a)(iii). See Kohl's Illinois, Inc. v. c/o kohlsdepartmentstore.com; c/o khols.com, FA 1442950 (Forum June 7, 2012) ("Respondent's failure to make an active use of the disputed domain name s demonstrates bad faith registration and use under Policy ¶ 4(a)(iii)). Complainant also argues that Respondent registered the <chase-corporation.com> domain name with knowledge of Complainant's rights in the CHASE CORPORATION mark. The Panel notes that Respondent uses Complainant's mark and logo, and poses as Complainant's CEO in an email. The Panel therefore finds that Respondent registered the disputed domain name with knowledge of Complainant's rights in the CHASE CORPORATION mark, demonstrating further bad faith under Policy ¶ 4(a)(iii). See Chevron Intellectual Property, LLC v. Jack Brooks, FA 1635967 (Forum Oct. 6, 2015) (finding that respondent's use of <chevron-corps.com> to impersonate an executive of complainant in emails is bad faith under Policy ¶ 4(a)(iii).); see also Minicards Vennootschap Onder FIrma Amsterdam v. Moscow Studios, FA 1031703 (Forum Sept. 5, 2007) (holding that respondent registered a domain name in bad faith under Policy ¶ 4(a)(iii) after concluding that respondent "actual knowledge of Complainant's mark when registering the disputed domain name"). The Panel finds that Complainant has satisfied 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 <chase-corporation.com> domain name be TRANSFERRED from Respondent to Complainant. Sandra J. Franklin, Panelist Dated: July 18, 2026 Click Here to return to the main Domain Decisions Page. Click Here to return to our Home Page
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