DECISION
Robinhood Markets, Inc. Allen Lau / Sahad Mohammed Riviera / Sahari Muti Inc / Domino Gg / araki 9113 / asdfasdf / Ratata Bumbum / Kameron Scott / Host Master / Njalla Okta LLC / Dan Hall
Claim Number: FA2503002147159
PARTIES
Complainant is Robinhood Markets, Inc. ("Complainant"), represented by David K. Caplan of Kilpatrick Townsend & Stockton LLP, California, USA. Respondent is Allen Lau / Sahad Mohammed Riviera / Sahari Muti Inc / Domino Gg / araki 9113 / asdfasdf / Ratata Bumbum / Kameron Scott / Host Master / Njalla Okta LLC / Dan Hall ("Respondent"), Various Locations.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <robinhood-ai.store>, <robinhood.cheap>, <hoodxrp.fun>, <hoodsolana.com>, <hoodsolana.co>, <hoodsolana.net>, <hoodonbase.online>, <hoodbase.fun>, and <hoodoneth.site>, registered with NameCheap, Inc., GoDaddy.com, LLC, Tucows Domains Inc., OwnRegistrar, Inc., Porkbun LLC and HOSTINGER operations, UAB.
PANEL
The undersigned certifies that they have acted independently and impartially and to the best of their knowledge have no known conflict in serving as Panelist in this proceeding.
Héctor Ariel Manoff as Panelist.
PROCEDURAL HISTORY
Complainant submitted a Complaint to Forum electronically on March 26, 2025; Forum received payment on March 26, 2025.
On March 27 and 28, 2025, NameCheap, Inc., GoDaddy.com, LLC, Tucows Domains Inc., OwnRegistrar, Inc., Porkbun LLC and HOSTINGER operations, UAB confirmed by e-mail to Forum that the <robinhood-ai.store>, <robinhood.cheap>, <hoodxrp.fun>, <hoodsolana.com>, <hoodsolana.co>, <hoodsolana.net>, <hoodonbase.online>, <hoodbase.fun>, and <hoodoneth.site> domain names are registered with NameCheap, Inc., GoDaddy.com, LLC, Tucows Domains Inc., OwnRegistrar, Inc., Porkbun LLC and HOSTINGER operations, UAB and that Respondent is the current registrant of the names. NameCheap, Inc., GoDaddy.com, LLC, Tucows Domains Inc., OwnRegistrar, Inc., Porkbun LLC and HOSTINGER operations, UAB have verified that Respondent is bound by the NameCheap, Inc., GoDaddy.com, LLC, Tucows Domains Inc., OwnRegistrar, Inc., Porkbun LLC and HOSTINGER operations, UAB registration agreements and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy").
On April 2, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of April 22, 2025 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@robinhood-ai.store, postmaster@robinhood.cheap, postmaster@hoodxrp.fun, postmaster@hoodsolana.com, postmaster@hoodsolana.co, postmaster@hoodsolana.net, postmaster@hoodonbase.online, postmaster@hoodbase.fun, and postmaster@hoodoneth.site. Also on April 2, 2025, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts.
Having received no formal response from Respondent, Forum transmitted to the parties a Notification of Respondent Default.
On April 23, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Héctor Ariel Manoff as Panelist.
Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent.
RELIEF SOUGHT
Complainant requests that the domain names be transferred from Respondent to Complainant.
PRELIMINARY ISSUE: CONSENT TO TRANSFER
Respondent consents to transfer the disputed domain names <hoodsolana.com> and <hoodxrp.fun> to Complainant. Since Respondent has not contested the transfer of the disputed domain names but instead agrees to transfer the domain names in question to Complainant, the Panel decides to forego the traditional UDRP analysis and orders an immediate transfer of the <hoodsolana.com> and <hoodxrp.fun> domain names. See Boehringer Ingelheim Int'l GmbH v. Modern Ltd. – Cayman Web Dev., FA 133625 (Forum Jan. 9, 2003) (transferring the domain name registration where the respondent stipulated to the transfer); see also Malev Hungarian Airlines, Ltd. v. Vertical Axis Inc., FA 212653 (Forum Jan. 13, 2004) ("In this case, the parties have both asked for the domain name to be transferred to the Complainant… Since the requests of the parties in this case are identical, the Panel has no scope to do anything other than to recognize the common request, and it has no mandate to make findings of fact or of compliance (or not) with the Policy."); see also Disney Enters., Inc. v. Morales, FA 475191 (Forum June 24, 2005) ("[U]nder such circumstances, where Respondent has agreed to comply with Complainant's request, the Panel felt it to be expedient and judicial to forego the traditional UDRP analysis and order the transfer of the domain names.").
ORDER as to domain nameS <hoodxrp.fun> and <hoodxrp.fun>
It is therefore Ordered, pursuant to the authority granted to the Panel by Rules 10, 14 and 17, that the domain names <hoodsolana.com> and <hoodxrp.fun> be forthwith TRANSFERRED from Respondent to Complainant. This Order terminates the proceeding as to Dan Hall and Ratata Bumbum.
PRELIMINARY ISSUE: MULTIPLE RESPONDENTS
Complainant has alleged that the entities which control the domain names at issue are effectively controlled by the same person and/or entity, which is operating under several aliases.
Complainant asserts that the disputed domain names share substantial characteristics and content.
The Panel finds that all disputed domain names fully incorporate Complainant's trademark and terms associated with sales or blockchains that host cryptocurrencies.
The websites for <robinhood-ai.store>, <robinhood.cheap>, <hoodsolana.net>, <hoodonbase.online>, <hoodbase.fun> and <hoodoneth.site> either share, or once shared, nearly identical content.
Moreover, <robinhood.cheap> and <hoodoneth.site> use the same domain name servers and registrars as well as <hoodbase.fun> and <hoodonbase.online>.
Additionally, many of the domain names were all registered within the same 12-day span between January 30 and February 10, 2025 and several of the domain names were registered within the 11-day span between February 26 and March 3, 2025.
Finally, all of the Disputed Domain Names fully incorporate the Robinhood marks, demonstrating an intentional pattern of using a Robinhood mark as a prefix and the name of a blockchain (e.g., Solana, Base, ETH [Ethereum]) or cryptocurrency (e.g., XRP, ETH) as a suffix.
Taking the aforesaid into account the Panel finds support for accepting the Complaint filed in respect of all the domain names in dispute.
PARTIES' CONTENTIONS
A. Complainant
1- Complainant owns ROBINHOOD and HOOD marks and the Feather Design Logo as well as a website (robinhood.com) and mobile application with those terms.
2- Complainant owns the popular Robinhood online financial services investing company and mobile application available for both iOS and Android operating systems
3- Complainant started its activities in 2013 and the Robinhood App was launched in 2015.
4- Complainant owns and produces the UNDER THE HOOD podcast and website <underthehood.robinhood.com>.
5- Complainant owns numerous trademark registrations and applications for the Robinhood marks in the United States, United Kingdom, and European Union, among many other countries.
6- The sites related to the disputed domain names promote or once promoted a cryptocurrency referred to as "HOOD," "$HOOD," "HOOD Token," "$HOOD Coin," and "ROBINHOOD".
7- Respondent appears to be using the Crypto Websites to encourage users to download third-party cryptocurrency software and purchase the Respondent's Cryptocurrency.
8- The disputed domain names incorporate the entirety of the ROBINHOOD and HOOD Marks, creating a strong likelihood of consumer confusion regarding Respondent's affiliation with Complainant.
9- The addition of the terms "xrp," "base," "eth," and "solana," names referring to blockchains that host cryptocurrencies, and the inclusion of the gTLDs ".store," ".cheap," ".fun," ".online," ".site," and ".net" and the ccTLD ".co," to Complainant's Robinhood marks do not prevent a finding of confusing similarity.
10- There is no relationship between Complainant and Respondent. Respondent has no right to own or use any domain name incorporating the Robinhood marks, and nothing in Respondent's WHOIS information for any of the disputed domain names suggests Respondent is commonly known by any of the disputed domain names.
11- Respondent does not use the disputed domain names in any way for the bona fide offerings of goods or services or for making a legitimate noncommercial or fair use of them.
12- Respondent is not making a legitimate non-commercial or fair use of the disputed domain names.
13- They resolve to the Crypto Websites with content that leads the consumers into confusion.
14- Respondent registered the disputed domain names in bad faith with actual knowledge of Complainant's rights in the Robinhood marks.
15- Respondent uses the domain names in bad faith.
B. Respondent
Respondent failed to submit a formal Response in this proceeding.
FINDINGS
Complainant, Robinhood Markets, Inc., owns trademark registrations for ROBINHOOD and HOOD marks and the Feather Design Logo as well as a website (robinhood.com) and mobile application with those terms.
Trademark rights and use of the marks are prior to the date of registration of the disputed domain names. Respondent registered and is using the domain names in bad faith.
DISCUSSION
Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable."
Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:
(1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and
(2) Respondent has no rights or legitimate interests in respect of the domain name; and
(3) the domain name has been registered and is being used in bad faith.
In view of Respondent's failure to submit a formal response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) ("Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint").
Identical and/or Confusingly Similar
Complainant has rights in the ROBINHOOD and HOOD marks and the Feather Design Logo as well as website (robinhood.com) and mobile application with those terms. (Annexes D, H, I).
Since Complainant provides evidence of registration of the ROBINHOOD and the Feather Design Logo with the USPTO and also use of HOOD mark, the Panel finds Complainant has demonstrated rights in those marks per Policy ¶ 4(a)(i). Bittrex, Inc. v. Domain Privacy Services, FA 1786849 (Forum June 15, 2018) (finding Complainant has trademark rights in the BITTREX mark through registration of the mark with the EUIPO and the USPTO).
The Panel finds that the disputed domain names are confusingly similar to Complainant's ROBINHOOD and HOODS marks.
The disputed domain names incorporate Complainants' trademarks ROBINHOOD and HOODS marks along with generic terms and gTLDs and ccTLDs.
The addition of generic terms and/or gTLDs and ccTLDs is not sufficient to diminish the similarity between the domain names and Complainant's marks and prior Panels have stated that. See Trip Network Inc. d/b/a Cheap Tickets, Inc. v. Sigfredo Alviera, FA0702000914943 (Forum March 27, 2007) ("The Panel finds that the mere addition of the geographic term "cancun" does not overcome a finding of confusing similarity under Policy ¶ 4(a)(i) and that the affixation of a gTLD to each domain name is irrelevant to a Policy ¶ 4(a)(i) analysis").
See also, e.g., American Eagle Outfitters, Inc. & Retail Royalty Co. v. Web Commerce Communications Ltd. / Client Care / Dina Bishop, FA 2053578 (Forum Aug. 29, 2023) (finding <americaneaglecanada.com> confusingly similar to AMERICAN EAGLE: "Here, the disputed domain names prominently start with and feature the identical AMERICAN EAGLE trademark and merely, and constantly, add a geographical indication related to countries all over the world, as well as the ".com" gTLD, and the ".co" ccTLD. Therefore, the Panel find that the disputed domain names are all confusingly similar to Complainant's trademark per Policy ¶ 4(a)(i)"); Lady of Leisure Holdings Ltd. v. Client Care / Web Commerce Communications Ltd., FA 1992406 (Forum May 18, 2022) (finding <sweatybettycanada.com> confusingly similar to SWEATY BETTY); Chan Luu Inc. v. Byron Gossett, FA 1500891 (Forum June 25, 2013) (finding <chanluucanada.com> confusingly similar to CHAN LUU).
The Panel finds that the disputed domain names are confusingly similar to ROBINHOOD and HOOD marks, in which Complainant has rights, under Policy ¶ 4(a)(i).
Rights or Legitimate Interests
Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii), then the burden shifts to Respondent to show it does have rights or legitimate interests. See Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011) (finding that a complainant must offer some evidence to make its prima facie case and satisfy Policy ¶ 4(a)(ii)); see also Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014) ("Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests").
The Panel finds that Respondent has no rights or legitimate interests in the disputed domain names. Complainant has not authorized Respondent to use the ROBINHOOD and HOOD mark. See Emerson Electric Co. v. golden humble / golden globals, FA 1787128 (Forum June 11, 2018) ("lack of evidence in the record to indicate a respondent is authorized to use [the] complainant's mark may support a finding that [the] respondent does not have rights or legitimate interests in the disputed domain name per Policy ¶ 4(c)(ii)").
Respondent does not have any trademark rights in the domain names and is not named or commonly known by the business name ROBINHOOD or HOOD.
Thus, this Panel concludes that Respondent does not appear to be commonly known by the <robinhood-ai.store>, <robinhood.cheap>, <hoodsolana.co>, <hoodsolana.net>, <hoodonbase.online>, <hoodbase.fun>, and <hoodoneth.site> domain names. (Forum July 27, 2015) (finding that the respondent was not commonly known by the <chevron-europe.com> domain name under Policy ¶ 4(c)(ii), as the WHOIS information named "Fred Wallace" as registrant of the disputed domain name).
Therefore, the Panel agrees that Respondent is not commonly known by the disputed domain names do not have legitimate interest under Policy ¶ 4(a)(ii).
Registration and Use in Bad Faith
Respondent registered the disputed domain names several years after Complainant's first use and registration of the trademarks ROBINHOOD and HOOD (Annexes H and I).
It is proved that Respondent knew Complainant's trademarks when registered the domain names since the resolving websites includes the Complainant's trademarks and design and refers to the same services provided by Complainant (Annexes H, J and K).
This Panel finds that registration of an identical domain name by only adding a generic term is a bad faith registration.
Respondent registered a domain name incorporating Complainant's registered marks without authorization and is using them for a commercial website that attempts to pass off as Complainant, and possibly for other fraudulent purposes. Such circumstances are indicative of bad faith registration and use under the Policy. See Societe des Produits Nestle S.A. v. shoaib Nawaz / Study FA2406002102206 (Forum, July 17, 2024).
The Panel finds that the registration of the domain names was done with Complainant's mark in mind. In addition, the disputed domain names resolve to websites which include the Complainant's marks and design.
In the Panel's point of view, the cited facts are sufficient evidence to support that the domain names were registered in bad faith.
In addition, this Panel finds that the use of the domain names was done in bad faith too. Complainant has submitted evidence (Annex K) to prove that the domain names were used to impersonate Complainant.
This Panel concludes that Respondent has registered the domain names with the intent to attract and divert Internet users to the corresponding websites for its own benefit.
The Panel determines that Respondent registered and used the disputed domain names in bad faith under Policy ¶ 4(a)(iii).
DECISION
Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <robinhood-ai.store>, <robinhood.cheap>, <hoodsolana.co>, <hoodsolana.net>, <hoodonbase.online>, <hoodbase.fun>, and <hoodoneth.site> domain names be TRANSFERRED from Respondent to Complainant.
As regards to the domain names <hoodsolana.com> and <hoodxrp.fun>, as mentioned above, the Panel decides to forego the traditional UDRP analysis and orders that <hoodsolana.com> and <hoodxrp.fun> domain names be TRANSFERRED from Respondent to Complainant.
Héctor Ariel Manoff, Panelist
Dated: May 6, 2025
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