The Complainant is G4S Plc of London, United Kingdom of Great Britain and Northern Ireland (“United Kingdom”), represented by SafeNames Ltd., United Kingdom.
The Respondent is Domain Administrator, SeePrivacyG of Phoenix, Arizona, United States of America (“United States”) / Zhichao Yang of Hefei, Anhui, China. 2. The Domain Name and Registrar
The disputed domain name is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 19, 2017. On July 20, 2017, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 20, 2017, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name that differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to the Complainant on July 25, 2017 providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on July 25, 2017.
The Center verified that the Complaint together with the amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”).
In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on July 28, 2017. In accordance with the Rules, paragraph 5, the due date for Response was August 17, 2017. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 18, 2017.
The Center appointed William F. Hamilton as the sole panelist in this matter on August 23, 2017. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background
The Complainant is a multinational provider of security services across six continents in 100 countries. The Complainant employs over 500,000 people worldwide. The Complainant’s stock is listed on the Financial Times Stock Exchange Index and the Copenhagen Stock Exchange. The Complainant has used the mark G4S (the “Mark”) since 2004 and has obtained numerous international registrations of the Mark including in the United States of America, where it owns trademark registration no. 3,378,800 for G4S, registered on February 5, 2008. The Complainant has operated the website “” since 1999. The Complainant is also operates various social media platforms including Facebook, Twitter, and LinkedIn.
The disputed domain name was registered on November 1, 2016, and resolves to a website with pay-per-click links. 5. Parties’ Contentions A. Complainant
The Complainant asserts the disputed domain name is confusingly similar to the G4S Mark. Additionally, the Complainant asserts that the Respondent has not conducted bona fide business under the disputed domain name or the Mark and therefore has no rights or legitimate interests in the Mark or the disputed domain name. The Complainant further asserts the disputed domain name was registered and is being used in bad faith by the Respondent to attract unsuspecting Internet users to the Respondent’s website that features numerous commercial click-through links. B. Respondent
The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar
The Panel finds that the Complainant has rights in the Mark and that the disputed domain name is confusingly similar to the Mark. The disputed domain name is merely composed of the Mark and a series of dictionary terms, “secure”, “payment”, and “services”. The composition of the disputed domain name is thus insufficient to adequately distinguish it from the Complainant’s Mark. Comerica Bank v. Will Rote,WIPO Case No. D2016-0419 (transferring ); Mastercard International Incorporated v. Dolancer Outsourcing, Inc.,WIPO Case No. D2012-0619 (transferring ); Societé Française du Radiotelephone – SFR v. Tobadoros Musicania,WIPO Case No. D2011-0815 (transferring ).
The Complainant has met its burden of proof under paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests
The Panel finds the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant has specifically denied that any license or authorization was provided to the Respondent to use the Mark or the disputed domain name. There is no evidence that the Respondent had any legitimate business before its utilization of the disputed domain name. The Respondent has failed to respond to the Complaint or to provide any evidence of rights or legitimate interests in the Mark or the disputed domain name.
The Complainant has met its burden of proof under paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith
The Panel finds the disputed domain name was registered and is being used in bad faith by the Respondent to attract Internet users to the Respondent’s website that features numerous commercial click-through links.
Other WIPO UDRP panels have recognized the distinctiveness of the Mark. G4S Plc. v. Noman Burki,WIPO Case No. D2016-1383; G4S Plc. v. Sikko van der Donk,WIPO Case No. D2016-0650. It is inconceivable that when composing the disputed domain name the Respondent could have whimsically and unknowingly seized upon the peculiar alphanumeric combination of “G”, “4”, and “S”, while attaching the dictionary terms “security”, “payment”, and “services” as a domain name suffix. Moreover, the disputed domain name resolves to a page featuring click-through websites selling commercial security-related services competing with the Complainant’s services as described under paragraph 4(b)(iv). It strains credulity to believe that the Respondent was not aware of the Mark and the Complainant’s services when registering the disputed domain name. Myer Stores Limited v. Mr. David John Singh,WIPO Case No. D2001-0763. The Panel finds that the Respondent registered and is using the disputed domain name in bad faith.
The Complainant has met its burden of proof under paragraph 4(a)(iii) of the Policy. 7. Decision
For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name be transferred to the Complainant.
William F. Hamilton
Sole Panelist
Date: September 4, 2017
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