ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION BLACKROCK FINANCE, INC. v. Bob Osullivan Case No. D2025-2940 1. The Parties The Complainant is BLACKROCK FINANCE, INC., United States of America, represented by Day Pitney LLP, United States of America. The Respondent is Bob Osullivan, United States of America. 2. The Domain Name and Registrar The disputed domain name is registered with Wild West Domains, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 23, 2025. On July 24, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 25, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (REGISTRATION PRIVATE, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 28, 2025, 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 August 1, 2025. 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 August 6, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 26, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 28, 2025.
page 2 The Center appointed Elizabeth Ann Morgan as the sole panelist in this matter on September 4, 2025. 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 and its affiliates (collectively, “BlackRock”) comprise one of the world’s preeminent asset management firms and are a premier provider of global investment management, risk management, and advisory services to institutional, intermediary, and individual investors around the world. With assets at USD12.5 trillion under management, BlackRock manages a broad range of investment portfolios on behalf of governments, corporations and individuals worldwide. In addition, BlackRock provides risk management, strategic advisory and enterprise investment system services to a broad base of clients. The BlackRock name, as well as its affiliated brands, are globally recognized as synonymous with the highest quality of financial and investment services. The Complainant has numerous registrations of the BLACKROCK trademark, which is a major asset of the Complainant, and an important symbol of its reputation and goodwill. BlackRock has widely used and promoted the BLACKROCK trademark throughout the United States and internationally and has established a worldwide reputation for the quality and success of its BLACKROCK funds and indexes. The Complainant owns trademark registrations for BLACKROCK in many jurisdictions worldwide, among them is Registration No. 006277818, registered on August 29, 2008, under class 35 and 36. The domain name was registered on June 25, 2025. The disputed domain name directs to an inactive webpage; however, the Complainant submits that it has been used in connection with a phishing scam. 5. Parties’ Contentions A. Complainant Founded in 1988, BlackRock’s global reputation is a result of the high quality of financial and investment services offered through its experienced professionals using BlackRock’s disciplined investment process and sophisticated analytical tools, which consistently add value to its client portfolios. BlackRock’s investment capabilities are complemented by a senior-level commitment to client service. The Complainant has numerous registrations of the BLACKROCK trademark, which is a major asset of the Complainant, and an important symbol of its reputation and goodwill. BlackRock has widely used and promoted the BLACKROCK trademark throughout the United States and internationally and has established a worldwide reputation for the quality and success of its BLACKROCK funds and indexes. The Complainant’s Marks afford the Complainant the exclusive right to use the BLACKROCK name and mark in association with financial and investment goods and services throughout the United States and other parts of the globe, as well as the right to prevent others from using the same or similar mark in a way that is likely to cause confusion among consumers. Further, the Complainant’s Marks have been continuously and extensively used in connection with promotion of the Complainant’s financial and investment funds since at least as early as 1988. The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name.
page 3 Notably, the Complainant contends that the disputed domain name, , is confusingly similar to the Complainant’s Marks. The disputed domain name is comprised of an intentional misspelling of the Complainant’s BLACKROCK trademark, adding only a second “O” in the “ROCK” portion of the mark. The Complainant submits that the Respondent does not have any rights or legitimate interests in the disputed domain name. The Respondent does not have a license, permission, or authorization from the Complainant to use the Complainant’s Marks. The disputed domain name is comprised of an intentional misspelling of the Complainant’s BLACKROCK trademark, adding only a second “O” in the “ROCK” portion of the mark. The Complainant further submits that the disputed domain name was registered and used in bad faith. The Complainant submits it became aware of the disputed domain name upon receipt of a report from one of the Complainant’s clients regarding a phishing scheme being perpetrated by the Respondent. On June 25, 2025, an individual impersonating a current BlackRock employee sent an email to the Complainant’s client from the following email address: [NAME REDACTED]@blackroock.com. The email at issue included new billing instructions intended to re-route the client’s payments to a different account presumably controlled by the individual associated with the [NAME REDACTED]@blackroock.com email address. The recipient of the email at issue complied with the instructions, leading to a loss of over USD 1,000,000 for the Complainant’s client. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The Panel finds the mark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The misspelling of the mark does not prevent the finding of confusing similarity. WIPO Overview 3.0, section 1.9. The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative,” requiring information that is often primarily within the knowledge or control of the respondent. As such, 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
page 4 relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. Panels have held that the use of a domain name for illegal activity, here claimed impersonation/passing off as part of a scheme to defraud, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. Panels have held that the use of a domain name for illegal activity, here claimed impersonation/ passing off as part of a fraudulent scheme, constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under 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. /Elizabeth Ann Morgan/ Elizabeth Ann Morgan Sole Panelist Date: September 16, 2025
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