ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Constellation Energy Corporation v. leblanc mcdonnell Case No. D2025-4225 1. The Parties Complainant is Halliburton Energy Services, Inc., United States of America (“United States”), represented by Polsinelli PC, United States. Respondent is Williams Tony, United States. 2. The Domain Name and Registrar The disputed domain name is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 14, 2025. On October 15, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 16, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information (Redacted for Privacy, Privacy Service Provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to Complainant on October 16, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. The Complainant submitted an amendment to the Complaint on October 16, 2025. The Center verified that the Complaint, together with the amendment to the 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 October 24, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 13, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on November 14, 2025. The Center appointed Lorelei Ritchie as the sole panelist in this matter on November 20, 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.
page 2 4. Factual Background Complainant is a multinational company based in the United States. For decades prior to the registration of the disputed domain name, Complainant has offered various energy services under the mark HALLIBURTON. Complainant is the owner of numerous registrations for the HALLIBURTON mark in various global jurisdictions. These include, among others, United States Registration Nos. 2,575,819 and 2,575,840 (both registered on June 4, 2002). The disputed domain name was registered on September 11, 2025. Although the disputed domain name does not appear to resolve to an active website, Respondent has used it to set up an email address to impersonate Complainant, targeting potential job recruits. Respondent has no affiliation with Complainant, nor any license to use its marks. 5. Parties’ Contentions A. Complainant Complainant contends that (i) the disputed domain name is identical or confusingly similar to Complainants’ trademarks, (ii) Respondent has no rights or legitimate interests in the disputed domain name; and (iii) Respondent registered and is using the disputed domain name in bad faith. Specifically, Complainant contends that it owns rights to the “distinctive and well-known” HALLIBURTON mark, which Complainant has used since it was “founded in 1919” with what is now “one of the world’s largest providers of products and services to the energy industry,” accruing over 22 billion USD in revenue in FY2024. Complainant contends that Respondent has incorporated Complainant’s HALLIBURTON mark into the disputed domain name, with a slight misspelling and the addition of a non-source-identifying hyphen along with the geographically descriptive term “UK.” Complainant further contends that Respondent lacks rights or legitimate interest in the disputed domain name and rather has registered and is using it in bad faith, having simply acquired the disputed domain name “in an attempt to profit” for Respondent’s own commercial gain. In particular, Complainant asserts that Respondent has set up an email address associated with the disputed domain name, which Respondent has used in a fraudulent attempt to impersonate Complainant, sending phishing emails to potential recruits of Complainant, and seeking sensitive personal and financial information. B. Respondent Respondent did not reply to 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. Complainant has shown rights in respect of a trademark or service mark, HALLIBURTON, for the purposes of the Policy, which is incorporated with a slight misspelling. WIPO Overview 3.0, section 1.2.1. Although the addition of other terms (here, a hyphen and the term “UK”) may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and Complainant’s mark for purposes of the Policy. WIPO Overview 3.0, section 1.8.
page 3 The Panel therefore finds that the disputed domain name is confusingly similar to a trademark in which Complainant has rights in accordance with paragraph 4(a)(i) of the Policy. 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 Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent has not rebutted 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, including phishing activity as here, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Panel finds that Complainant has provided sufficient evidence of Respondent’s lack of “rights or legitimate interests” in accordance with paragraph 4(a)(ii) of the Policy which Respondent has not rebutted. C. Registered and Used in Bad Faith There are several ways that a complainant can demonstrate that a domain name was registered and used in bad faith. Although the disputed domain name does not appear to resolve to an active website as of the filing of the Complainant, the Panel notes that the disputed domain name was used to set up an email address to impersonate Complainant, targeting potential job recruits. Respondent provided false contact information to the Registrar, with a contact address found to be undeliverable by the courier provider. Panels have held that the use of a domain name for illegal activity constitutes bad faith. WIPO Overview 3.0, section 3.4. As noted in Section 4, above, Respondent has set up an email address associated with the disputed domain name, which Respondent has used in a phishing attempt to impersonate Complainant with potential job recruits. Therefore, the Panel finds sufficient evidence that Respondent registered and used the disputed domain name in bad faith for purposes of 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 Complainant. /Lorelei Ritchie/ Lorelei Ritchie Sole Panelist Date: December 3, 2025
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