ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Pryor Cashman LLP v. kir.kpoqo3 pryorcashman.com, pryorcashrnan Case No. D2025-4257 1. The Parties Complainant is Pryor Cashman LLP, United States of America (“United States” or “U.S”), represented by Pryor Cashman, LLP, United States. Respondent is kir.kpoqo3 pryorcashman.com, pryorcashrnan, United States. 2. The Domain Name and Registrar The disputed domain name
(the “Disputed Domain Name”) is registered with Tucows Domains Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 16, 2025. On October 17, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On October 17, 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 (REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email communication to Complainant on October 20, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on October 20, 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 Respondent of the Complaint, and the proceedings commenced on October 21, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 10, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on November 11, 2025.
page 2 The Center appointed Colin T. O'Brien as the sole panelist in this matter on November 17, 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 Complainant is a midsize law firm founded in 1963 and headquartered in New York City. With over 200 attorneys, Complainant spans across three offices, including locations in both Miami and Los Angeles, and serves a diverse client base that spans around the globe. Complainant’s official website can be accessed at the domain name . Complainant is the owner of U.S. Trademark Registration No. 3,834,912 for the PRYOR CASHMAN LLP mark for use in connection with Class 45 “legal services,” which registered on August 17, 2010. Respondent registered the Disputed Domain Name without Complainant’s authorization on October 13, 2025. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Disputed Domain Name. Notably, Complainant contends that Respondent’s Disputed Domain Name (i) is typographical error or confused spelling of Complainant’s PRYOR CASHMAN LLP mark; (ii) is nearly identical and confusingly similar to Complainant’s official domain name because the Disputed Domain Name merely changed the letter “m” in Complainant’s official domain name to the letters “rn” to look similar in appearance to the letter “m” (i.e., Respondent engages in typosquatting); and (iii) is likely to cause confusion, mistake and/or deception among the consuming public. Respondent has no rights or legitimate interests in the Disputed Domain Name. Respondent has never been an authorized representative, agent, or licensee of Complainant. Respondent has not demonstrated any attempt to make legitimate use of the Disputed Domain Name. Complainant does not have any type of business relationship with Respondent. Complainant has never consented to Respondent’s registration or use of the Disputed Domain Name. Respondent’s use of the Disputed Domain Name cannot be considered a bona fide offering of goods or services nor a legitimate noncommercial or fair use of the Disputed Domain Name. The Disputed Domain Name has been registered (i) with the intent that confused Internet users searching for Complainant will be misdirected to Respondent’s webpage and/or (ii) to transmit emails for the purpose of furtherance of a fraudulent scheme through the impersonation of an employee of Complainant. Respondent is using an email address incorporating the Disputed Domain Name to impersonate an employee at Complainant via an email address which is virtually identical to Complainant’s employee’s actual email address in order to perpetrate a fraudulent scheme against an innocent third party. Respondent intended to cause the recipient of Respondent’s communications sent using the fraudulent email address to mistakenly believe that Complainant’s employee sent such communications, when it did not, and ultimately steal money from the recipient. These actions can never confer rights or legitimate interests.
page 3 B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar Complainant has demonstrated it owns registered trademark rights in the PRYOR CASHMAN LLP mark. The Disputed Domain Name differs from Complainant’s PRYOR CASHMAN LLP mark by replacing the letter “m” with “rn” does not prevent a finding of confusing similarity between the mark and the Disputed Domain Name. See section 1.9 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”). Accordingly, the Disputed Domain Name is confusingly similar to the mark in which Complainant has rights. B. Rights or Legitimate Interests Complainant has presented a prima facie case that Respondent has no rights or legitimate interests in respect of the Disputed Domain Name and has not been commonly known by the Disputed Domain Name. The fact that Respondent obtained the Disputed Domain Name which is a typo of Complainant’s primary domain name indicates that Respondent likely sought to piggyback on Complainant’s mark for illegitimate reasons. After a complainant has made a prima facie case, the burden of production shifts to a respondent to present evidence demonstrating rights or legitimate interests in the domain name. See, e.g., Croatia Airlines d.d. v. Modern Empire Internet Ltd., WIPO Case No. D2003-0455. Here, Respondent has provided no evidence of any rights or legitimate interests in the Disputed Domain Name. In the absence of any evidence rebutting Complainant’s prima facie case indicating Respondent’s lack of rights or legitimate interests in respect of the Disputed Domain Name, the Panel finds that Complainant has satisfied paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith The Disputed Domain Name was registered years after Complainant first used and registered its PRYOR CASHMAN LLP mark. The evidence provided by Complainant makes it clear that Respondent undoubtedly knew of Complainant’s PRYOR CASHMAN LLP mark and knew that it had no rights or legitimate interests in the Disputed Domain Name when it was registered. There is no apparent benign reason for Respondent to have registered the Disputed Domain Name that is a typo variant of Complainant’s mark. Further, the use of the Disputed Domain Name by Respondent is in bad faith. Paragraph 4(b)(iv) states that evidence of bad faith may include a respondent’s use of a domain name to intentionally attempt to attract Internet users for commercial gain. Complainant has alleged that Respondent used the Disputed Domain Name to send fraudulent emails to its client impersonating an employee of Complainant in an attempt to phish funds from Complainant’s client. The fact that the Disputed Domain Name does not resolve to an active website is immaterial as the Disputed Domain Name was used for email purposes and as ammunition to attack Complaint and its clients, is clearly indicative of bad faith use on the part of Respondent. Accordingly, the Panel finds that the Disputed Domain Name has been registered and is being used in bad faith.
page 4 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. /Colin T. O'Brien/ Colin T. O'Brien Sole Panelist Date: December 1, 2025
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