DECISION
Travero, Inc. v. Josh Hart
Claim Number: FA2506002162168
PARTIES
Complainant is Travero, Inc. ("Complainant"), represented by Jennifer Budzien, Wisconsin, USA. Respondent is Josh Hart ("Respondent"), Iowa, USA.
REGISTRAR AND DISPUTED DOMAIN NAME
The domain name at issue is <travvero.com>, registered with GoDaddy.com, LLC.
PANEL
Alan L. Limbury, as Panelist.
PROCEDURAL HISTORY
Complainant submitted a Complaint to Forum electronically on June 23, 2025. Forum received payment on June 23, 2025.
On June 24, 2025, GoDaddy.com, LLC confirmed by e-mail to Forum that the <travvero.com> domain name is registered with GoDaddy.com, LLC and that Respondent is the current registrant of the name. GoDaddy.com, LLC has verified that Respondent is bound by the GoDaddy.com, LLC registration agreement 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 June 30, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of July 21, 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@travvero.com. Also on June 30, 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 response from Respondent, Forum transmitted to the parties a Notification of Respondent Default.
On July 22, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Alan L. Limbury 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 name be transferred from Respondent to Complainant.
PARTIES' CONTENTIONS
A. Complainant
Established in 1904, Complainant, Travero, Inc., is a wholly owned subsidiary of Alliant Energy Corporation. For nearly 5 years, Complainant has used the TRAVERO mark in interstate commerce in the United States in connection with the provision of various energy-related products and services. The mark is registered with the USPTO. Complainant owns, among others, the domain name <traverologistics.com>, registered on April 16, 2020.
The <travvero.com> domain name is confusingly similar to the TRAVERO mark.
Respondent has no rights or legitimate interests in the <travvero.com> domain name. Complainant has never licensed or otherwise authorized Respondent to use the mark or any confusingly similar mark nor to register a domain name incorporating the mark or any confusingly similar mark. On information and belief, Respondent does not own a trademark or service mark registration for any mark comprising, in whole or in part, the mark TRAVERO (or similar variations thereof). Respondent is using the domain name to commercially profit from advertisements for products/services that compete with or are at least highly related to Complainant. It is not making a legitimate non-commercial or fair use of the domain name, without intent for commercial gain.
Respondent registered and is using the <travvero.com> domain name in bad faith in connection with an email address to impersonate a member of Complainant's staff for purposes of submitting fraudulent purchase orders. This fraudulent and criminal activity is being perpetrated through the domain name to deceive third parties into believing that Respondent is affiliated with Complainant.
B. Respondent
Respondent failed to submit a Response in this proceeding.
FINDINGS
Complainant has established all the elements entitling it to relief.
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 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 shown that it has rights in the service mark TRAVERO, through USPTO Registration No. 6,412,397, registered on July 6, 2021 for services in International Classes 35 and 39.
The Panel finds Respondent's <travvero.com> domain name to be confusingly similar to Complainant's TRAVERO mark, only differing by an additional letter "v", which is insufficient to distinguish the domain name from the mark. The inconsequential ".com" generic top-level domain ("gTLD") may be ignored under this element. See, for example, Rollerblade, Inc. v. Chris McCrady, D2000-0429 (WIPO June 25, 2000).
Complainant has established this element.
Rights or Legitimate Interests
Paragraph 4(c) of the Policy provides that any of the following circumstances, in particular but without limitation, if found by the Panel to be proved based on its evaluation of all evidence presented, shall demonstrate Respondent's rights or legitimate interests to the domain name for purposes of Paragraph 4(a)(ii):
(i) before any notice to Respondent of the dispute, the use by Respondent of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or
(ii) Respondent (as an individual, business or other organization) has been commonly known by the domain name, even if Respondent has acquired no trademark or service mark rights; or
(iii) Respondent is making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert customers or to tarnish the trademark or service mark at issue.
The <travvero.com> domain name was registered on May 15, 2025, almost four years after the registration of Complainant's TRAVERO mark. On May 21, 2025, an email was sent from <freight@travvero.com>, purporting to be from the Logistics Manager of Complainant, to a customer of Complainant, infiltrating an email exchange between the customer and Complainant, saying:
"I am waiting on carrier compliance to get you approved, will send rate confirmation shortly. It normally takes 30-40 minutes for them to get you setup, so kindly be patient."
These circumstances, together with Complainant's assertions, are sufficient to constitute a prima facie showing of absence of rights or legitimate interests in respect of the domain name on the part of Respondent. The evidentiary burden therefore shifts to Respondent to show that it does have rights or legitimate interests in the <travvero.com> domain name. See JUUL Labs, Inc. v. Dryx Emerson / KMF Events LTD, FA 1849706 (Forum July 17, 2019). Respondent has made no attempt to do so.
The Panel finds that Respondent has no rights or legitimate interests in respect of the domain name.
Complainant has established this element.
Registration and Use in Bad Faith
The four illustrative circumstances set out in paragraph 4(b) of the Policy as evidence of the registration and use of a domain name in bad faith for purposes of paragraph 4(a)(iii) are not exclusive.
The circumstances set out above in relation to the second element satisfy the Panel that Respondent was fully aware of Complainant's TRAVERO mark when Respondent registered the <travvero.com> domain name and that Respondent registered and is using the domain name in bad faith to impersonate an employee of Complainant for the purpose of masquerading as Complainant.
Further, the Panel finds the <travvero.com> domain name to be a typosquatted version of Complainant's TRAVERO mark. Typosquatting is independent evidence of bad faith registration and use of a domain name per Policy ¶ 4(a)(iii). See Homer TLC, Inc. v. Artem Ponomarev, FA 1623825 (Forum July 20, 2015).
Complainant has established this element.
DECISION
Complainant having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <travvero.com> domain name be TRANSFERRED from Respondent to Complainant.
Alan L. Limbury Panelist
Dated: July 23, 2025
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