ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Hanson Bridgett LLP v. Name Redacted Case No. D2025-4046 1. The Parties The Complainant is Hanson Bridgett LLP, United States of America (“United States”), represented by Hanson Bridgett LLP, United States. The Respondent is Name Redacted1. 2. The Domain Name and Registrar The disputed domain name is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 3, 2025. On October 3, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 6, 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 (Domain Admin, Privacy Protect LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 6, 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 October 9, 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”). 1 The Respondent appears to have used the name of a third party when registering the disputed domain name. In light of the potential identity theft, the Panel has redacted the Respondent’s name from this decision. However, the Panel has attached as Annex 1 to this decision an instruction to the Registrar regarding transfer of the disputed domain name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in this proceeding and has indicated Annex 1 to this decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST 12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788.
page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on October 15, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 4, 2025. The Respondent sent emails to the Center on October 22, 23, 28, and November 4 and 5 in which it asked for an automatic four calendar day extension for response under paragraph 5(b) of the Rules. The response due date was therefore extended to November 8, 2025. The Respondent did not submit any formal response. The Center appointed Michelle Brownlee as the sole panelist in this matter on November 14, 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 is a limited liability partnership, formed under the laws of California, United States. The Complainant has provided legal services under the name HANSON BRIDGETT since 1958. The Complainant employs over 200 attorneys and has been recognized on the “AmLaw 200” list published by American Lawyer magazine of the 200 largest United States law firms by revenue. The Complainant has owned the domain name since 1997 and operates a web site at that domain name and uses it for the firm’s email addresses. The disputed domain name was registered on October 1, 2025. The disputed domain name resolves to a parked page hosted by the Registrar. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainant contends that the disputed domain name is confusingly similar to its unregistered trademark, HANSON BRIDGETT, that the Respondent has no rights to or legitimate interests in respect of the disputed domain name and that the Respondent registered and is using the disputed domain name in bad faith. The Complainant argues that the disputed domain name has changed only one letter from the Complainant’s trademark, which is evidence of “typosquatting,” a practice of diverting Internet users who make mistakes when typing into a web browser. The Complainant notes that the Respondent is not known by the name “Hanson Bridgatt” and is not licensed by the Complainant. The Complainant also suggests that the Respondent likely used false contact information in the registration of the disputed domain name because the address was associated with a residential address owned by an 80-year-old Tango dance instructor. Finally, the Complainant provided evidence that the Respondent has set up mail exchange (“MX”) records with the disputed domain name. The Complainant argues that this action suggests that the Respondent was planning to use the disputed domain name in connection with emails with the intention of misleading recipients into believing that the messages came from the Complainant. B. Respondent The Respondent stated that he has never owned the disputed domain name. The Respondent stated that he had an account with the Registrar to host a web site and he had recently learned that someone hacked his account, stole his credit card information and used such information to pay for domain name registrations with the Registrar. Except for these statements, the Respondent did not submit a formal response to the Complaint.
page 3 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 Panel finds the Complainant has established unregistered trademark or service mark rights for the purposes of the Policy. WIPO Overview 3.0, section 1.3. As discussed above, the Complainant has been doing business under the name HANSON BRIDGETT for more than 60 years and is one of the 200 largest law firms in the United States. The Panel finds the mark is recognizable within the disputed domain name. WIPO Overview 3.0, section 1.7. The disputed domain name appears to be an obvious misspelling of the Complainant’s HANSON BRIDGETT. A domain name which consists of a common, obvious, or intentional misspelling of a trademark is considered by panels to be confusingly similar to the relevant mark. WIPO Overview 3.0, section 1.9. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. 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 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. 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. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1.
page 4 In the present case, the Panel notes that the Respondent registered the disputed domain name that is nearly identical in appearance to the Complainant’s distinctive trademark and that MX records have been set up for the disputed domain name, which is strong evidence that the Respondent has used or is making preparations to use the disputed domain name in connection with fraudulent activity involving emails that are designed to appear that they originate from the Complainant. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. The Panel also notes that the Respondent appears to have provided false contact information, since the person on record stated that he did not register the disputed domain name and stated that his account with the Registrar was hacked and used to make multiple domain name registrations without his knowledge or consent. Providing false contact information is another factor that reinforces the conclusion that the disputed domain name was registered and used in bad faith. WIPO Overview 3.0, section 3.6. The Panel finds that the Complainant has established the third element 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. /Michelle Brownlee/ Michelle Brownlee Sole Panelist Date: November 28, 2025
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