Westmore · UDRP decision
FORUM · Case No. FA2607002233682

Roberthalf-findjob.com + 3 more domains

TransferFORUM-indexed · informational, not legal advice

The Panel ordered transfer of all four disputed domain names. It found them confusingly similar to Complainant's ROBERT HALF mark, found no rights or legitimate interests based on phishing or non-use, and found bad-faith registration and use based on phishing, passive holding, concealment through a privacy service, and actual knowledge of Complainant's mark.

Outcome
Transfer
At a glance
Provider
FORUM
Outcome
Transfer
Decision date
2026-08-18
Panelist(s)
Richard Hill
Complainant
Robert Half Inc.
Respondent
Prof. Willard O'Kon / Odilon Fontaine
Counsel
Bianca Ascolese
Law firm
Foley & Lardner LLP
Disputed domain(s)
roberthalf-findjob.com, network-roberthalf.com, roberthalfsocial.com, roberthalfrecruit.com
Citation weightrelies on 22 authorities
Domain history UDRP Intelligence

The timeline behind roberthalf-findjob.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 roberthalf-findjob.com — 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
Outcome by domain

How each disputed name was decided in this proceeding.

roberthalf-findjob.comTransferred
network-roberthalf.comTransferred
roberthalfsocial.comTransferred
roberthalfrecruit.comTransferred
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of roberthalf-findjob.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The Panel found bad-faith registration and use because two domains were used for phishing and the other two constituted bad-faith passive holding in the circumstances. It also found that Respondent concealed its identity through a privacy service and registered the domains with actual knowledge of Complainant's rights.

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
2026-08-18
Panel
Richard Hill
Full decision
17 min read · hosted by Westmore

NATIONAL ARBITRATION FORUM DECISION Robert Half Inc. v. Prof. Willard O'Kon / Odilon Fontaine Claim Number: FA2607002233682 PARTIES Complainant is Robert Half Inc. ("Complainant"), represented by Bianca Ascolese of Foley & Lardner LLP, New York, USA. Respondent is Prof. Willard O'Kon / Odilon Fontaine ("Respondent"), USA. REGISTRAR AND DISPUTED DOMAIN NAMES The domain names at issue are <roberthalf-findjob.com>, <network-roberthalf.com>, <roberthalfsocial.com> and <roberthalfrecruit.com>, registered with Spaceship, Inc. and 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. Richard Hill as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on July 20, 2026; Forum received payment on July 20, 2026. On July 20 and 21, 2026, Spaceship, Inc. and NameSilo, LLC confirmed by e-mail to Forum that the <roberthalf-findjob.com>, <network-roberthalf.com>, <roberthalfsocial.com> and <roberthalfrecruit.com> domain names are registered with Spaceship, Inc. and NameSilo, LLC and that Respondent is the current registrant of the names. Spaceship, Inc. and NameSilo, LLC have verified that Respondent is bound by the Spaceship, Inc. and NameSilo, LLC registration agreements 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 July 28, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 17, 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@roberthalf-findjob.com, postmaster@network-roberthalf.com, postmaster@roberthalfsocial.com, postmaster@roberthalfrecruit.com. Also on July 28, 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 August 18, 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 names be transferred from Respondent to Complainant. PRELIMINARY ISSUE: MULTIPLE RESPONDENTS In the instant proceedings, Complainant has alleged that the entities which control the domain names at issue are effectively controlled by the same person and/or entity, which is operating under several aliases. Paragraph 3(c) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") provides that a "complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder." Three of the disputed domain names have identical WHOIS entries. One of those domain names was used to send fraudulent phishing emails, which referred to a website created using the fourth disputed domain name, see below. The Panel finds that this is sufficient to find that the domain names were registered by the same domain name holder. See The Valspar Corporation v. Zhou Zhiliang / zhouzhiliang / Zhiliang Zhou / Eric Chow / Visspa Ltd., FA 133934 (Forum Sept. 28, 2010); see also BBY Solutions, Inc. v. White Apple / Dev Kumar, FA 1787251 (Forum June 20, 2018). Consequently, the Panel will rule on all four contested domain names, and the two registrants are collectively referred to as "Respondent". PARTIES' CONTENTIONS A. Complainant Complainant states that it is one of the world's largest specialized employment staffing agencies. Since its founding in 1948, Complainant has provided its clients with skilled professionals in the fields of accounting and finance, technology, legal, creative, marketing, and administration. Complainant has more than 300 consulting and staffing locations throughout the world and employs over 10,000 employees. Over the three (3) year period ending in 2025 alone, Complainant, through itself and its subsidiary, Protiviti Inc., has rendered services, many of which are ROBERT HALF-branded services, that exceeded 17.5 billion U.S. dollars in revenue. Complainant has rights in the ROBERT HALF mark through its registration in multiple jurisdictions, including in the United States in 1981. The mark is well known. Complainant alleges that the disputed domain names are confusingly similar to its ROBERT HALF mark because they incorporate the mark in its entirety, merely adding a hyphen and/or generic/descriptive terms, together with the ".com" generic top-level domain ("gTLD"). Complainant cites UDRP precedents to support its position. According to Complainant, Respondent has no rights or legitimate interests in the disputed domain names. Respondent is not commonly known by the disputed domain names and Complainant has not authorized or licensed to Respondent any rights in the ROBERT HALF mark. Respondent does not use the disputed domain names for a bona fide offering of goods or services or a legitimate noncommercial or fair use. Instead, the disputed domain names <roberthalf-findjob.com> and <roberthalfrecruit.com> are used in furtherance of a fraudulent email phishing scheme. Specifically the <roberthalf-findjob.com> domain name was used to send an email in which Respondent represents themselves as "Brenda Andrews," a Senior Recruiter for Complainant, and requests that the victim schedule a phone call through the link <booking.roberthalfrecruit.com>, which previously resolved to a website that featured Complainant's mark and ROBERT HALF logo. The disputed domain names <network-roberthalf.com> and <roberthalfsocial.com> are not being used. Complainant cites UDRP precedents to support its position. Further, says Complainant, Respondent registered and uses the disputed domain names in bad faith. Two of the disputed domain names are used in furtherance of a fraudulent email phishing scheme. Two of the disputed domain names are not being used. Respondent had actual or constructive knowledge of Complainant's mark. Complainant cites UDRP precedents to support its position. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant has rights in the mark ROBERT HALF dating back to at least 1981 and uses it to provide employment staffing services around the world. The mark is well known. The disputed domain names were registered in 2026. Complainant has not licensed or otherwise authorized Respondent to use its mark. The disputed domain names <roberthalf-findjob.com> and <roberthalfrecruit.com> are used in furtherance of a fraudulent email phishing scheme. The website at <booking.roberthalfrecruit.com> displayed Complainant's mark and logo. The disputed domain names <network-roberthalf.com> and <roberthalfsocial.com> are not being used. 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 disputed domain names incorporate Complainant's ROBERT HALF mark in its entirety, merely adding a hyphen and/or generic/descriptive terms, together with the ".com" generic top-level domain ("gTLD"). This is not sufficient to distinguish the domain names from the mark. 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 Vanguard Group Inc. v. Proven Fin. Solutions, FA 572937 (Forum Nov. 18, 2005) (holding that the addition of both the word "advisors" and the gTLD ".com" did not sufficiently alter the disputed domain name to negate a finding of confusing similarity under Policy ¶ 4(a)(i)); see also Mrs. World Pageants, Inc. v. Crown Promotions, FA 94321 (Forum Apr. 24, 2000) (finding that punctuation is not significant in determining the similarity of a domain name and mark). Therefore, the Panel finds that the disputed domain names are confusingly similar to Complainant's mark under Policy ¶ 4(a)(i). Rights or Legitimate Interests Complainant has not authorized Respondent to use its mark. Under Policy ¶ 4(c)(ii), the Panel may look to the WHOIS information to determine whether Respondent is commonly known by the disputed domain name. See Chevron Intellectual Property LLC v. Fred Wallace, FA 1626022 (Forum July 27, 2015) (finding that the respondent was not commonly known by the <chevron-europe.com> domain name under Policy ¶ 4(c)(ii), as the WHOIS information named "Fred Wallace" as registrant of the disputed domain name). The WHOIS information on record lists "Prof. Willard O'Kon / Odilon Fontaine" as the registrant name. Therefore, the Panel concludes that Respondent is not commonly known by the disputed domain names. The disputed domain names <roberthalf-findjob.com> and <roberthalfrecruit.com> are used in furtherance of a fraudulent email phishing scheme. Specifically the <roberthalf-findjob.com> domain name was used to send an email in which Respondent represents themselves as "Brenda Andrews," a Senior Recruiter for Complainant, and requests that the victim schedule a phone call through the link <booking.roberthalfrecruit.com>, which previously resolved to a website that featured Complainant's mark and ROBERT HALF logo. A respondent's use of an email address incorporating a disputed domain name to pass itself off as a complainant under false pretenses, or its use in a website used in support of phishing, may support a finding of failure to make a bona fide offering of goods or services or a legitimate noncommercial or fair use per Policy ¶¶ 4(c)(i) or (iii). See Microsoft Corporation v. Terrence Green / Whois Agent / Whois Privacy Protection Service, Inc., FA 1661030 (Forum Apr. 4, 2016) (finding the respondent's use of the disputed domain names to send fraudulent emails purportedly from agents of complainant to be neither a bona fide offering of goods or services under Policy ¶ 4(c)(i), nor a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii)); see also Enterprise Holdings, Inc. v. I S / Internet Consulting Services Inc., FA 1785242 (Forum June 5, 2018) ("On its face, the use of a domain name that is confusingly similar to the mark of another in order to facilitate a phishing scheme cannot be described as either 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)."); see also Allianz of Am. Corp. v. Bond, FA 690796 (Forum June 12, 2006) (respondent's use of disputed domain name for phishing was not bona fide offering of goods or services or legitimate noncommercial or fair use of disputed domain name pursuant to Policy). Thus the Panel finds that Respondent fails to use those disputed domain names to make a bona fide offering of goods or services or a legitimate noncommercial or fair use under Policy ¶¶ 4(c)(i) or (iii). The disputed domain names<network-roberthalf.com> and <roberthalfsocial.com> are not being used. Failure to make an active use of a domain name demonstrates that Respondent is not using the disputed domain name for a bona fide offering of goods or services or a legitimate noncommercial fair use. See Bloomberg L.P. v. SC Media Servs. & Info. SRL, FA 296583 (Forum Sept. 2, 2004) ("Respondent is wholly appropriating Complainant's mark and is not using the <bloomberg.ro> domain name in connection with an active website. The Panel finds that the [failure to make an active use] of a domain name that is identical to Complainant's mark is not a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use of the domain name pursuant to Policy ¶ 4(c)(iii)."). Therefore, the Panel finds that Respondent is not using those disputed domain name to make a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i), or a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii). For all the above reasons, 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 names. Indeed, as already noted, Respondent uses the <roberthalf-findjob.com> and <roberthalfrecruit.com> domain names in furtherance of a fraudulent email phishing scheme. Phishing may in and of itself be considered evidence of bad faith registration and use under Policy ¶ 4(a)(iii). See Zoetis Inc. and Zoetis Services LLC v. VistaPrint Technologies Ltd, FA 1623601 (Forum July 14, 2015) ("Respondent's attempt to use the <zoietis.com> domain name to phish for personal information in fraudulent emails also constitutes bad faith pursuant to Policy ¶ 4(a)(iii)."); see also Smiths Group plc v. Snooks, FA 1372112 (Forum Mar. 18, 2011) (finding that the respondent's attempt to impersonate an employee of the complainant was evidence of bad faith registration and use under Policy ¶ 4(a)(iii)); see also Wells Fargo & Co. v. Maniac State, FA 608239 (Forum Jan. 19, 2006) (finding bad faith registration and use where the respondent was using the <wellsbankupdate.com> domain name in order to fraudulently acquire the personal and financial information of the complainant's customers); see also Hess Corp. v. GR, FA 770909 (Forum Sept. 19, 2006) (finding that the respondent demonstrated bad faith registration and use because it was attempting to acquire the personal and financial information of Internet users through a confusingly similar domain name). Thus the Panel finds bad faith registration and use under Policy ¶ 4(a)(iii). Further, also as already noted, the disputed domain names <network-roberthalf.com> and <roberthalfsocial.com> are not being used. According to paragraph 3.3 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (WIPO Jurisprudential Overview 3.1): "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 by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panelists have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. 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 taking active steps to conceal its identity or (iv) the use of false or inaccurate contact details (noted to be in breach of the respondent's registration agreement). Taking the above factors into consideration, panels assess the overall plausibility of any (claimed) good faith use to which the domain name may be put in light of the composition of the domain name in relation to the relevant mark, such that, the more arbitrary or distinctive a mark the less plausible a claimed non-infringing good faith use is likely to be, and vice versa." In the present case, Complainant's trademark is well known. It is difficult to envisage any use of the disputed domain names that would not violate the Policy, see Morgan Stanley v. TONY / shentony, FA 1637186 (Forum Oct. 10, 2015) ("Respondent registered the disputed domain name [MORGANSTANLEY.ONLINE] in bad faith because . . . it is difficult to envisage any use of the disputed domain name that would not violate the Policy."); see also Singapore Airlines Ltd. v. European Travel Network, D2000-0641 (WIPO Aug. 29, 2000) (where selection of disputed domain name is so obviously connected to complainant's well-known trademark, use by someone with no connection with complainant suggests opportunistic bad faith); see also Starwood Hotels & Resorts Worldwide, Inc., Sheraton Int'l IP, LLC, Westin Hotel Mgmt., L.P. v. Jingjing Tang, D2014-1040 (WIPO Aug. 19, 2014) ("The Panel finds that the [WESTIN] Marks are not such that could legitimately be adopted by traders other than for the purpose of creating an impression of an association with Complainant. Thus, the Panel concludes that the disputed domain names were registered in bad faith."). There has been no response to the Complaint and Respondent used a privacy service, that is, it attempted to conceal its identity. Given these circumstances, the Panel finds that, in this particular case, a finding of bad faith use can be inferred even though the disputed domain names are not being actively used. See Telstra Corporation Limited v. Nuclear Marshmallows, D2000-0003 (WIPO Feb. 18, 2000). Finally, Respondent registered the disputed domain names with actual knowledge of Complainant's mark: The website at <booking.roberthalfrecruit.com> displayed Complainant's mark and logo. 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 marks prior to Respondent's registration of the disputed domain name and that this constitutes 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 <roberthalf-findjob.com>, <network-roberthalf.com>, <roberthalfsocial.com> and <roberthalfrecruit.com> domain names be TRANSFERRED from Respondent to Complainant. Richard Hill, Panelist Dated: August 18, 2026 Click Here to return to the main Domain Decisions Page. Click Here to return to our Home Page

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