DECISION

 

Workday, Inc. v. Uzair Lakho

Claim Number: FA2512002193589

 

PARTIES

Complainant is Workday, Inc. ("Complainant"), represented by Caitlin R. Byczko of Barnes & Thornburg LLP, Indiana, USA. Respondent is Uzair Lakho ("Respondent"), Pakistan.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <workdaytenants.com>, registered with NameCheap, Inc.

 

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.

 

Dr. Beatrice Onica Jarka as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on December 9, 2025; Forum received payment on December 9, 2025.

 

On December 10, 2025, NameCheap, Inc. confirmed by e-mail to Forum that the <workdaytenants.com> domain name is registered with NameCheap, Inc. and that Respondent is the current registrant of the name. NameCheap, Inc. has verified that Respondent is bound by the NameCheap, Inc. 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 December 15, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of January 5, 2026 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@workdaytenants.com. Also on December 15, 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.

 

A timely Response was received and determined to be complete on December 16, 2025.

 

On December 16, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Dr. Beatrice Onica Jarka 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.

 

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A.       Complainant 

Complainant contends as follows:

 

Complainant, Workday, Inc. is a leading provider of enterprise cloud applications for human resources and finance. In connection with this business, Complainant uses the WORKDAY mark and legitimate <workday.com> domain name to provide information about its services and resources for its consumers.

 

Complainant has rights in the WORKDAY mark based upon multiple registrations in United States of America (under registration numbers: 3280638, 3326815, 5048288, 5131360) since as early as 2007, Australia (under registration numbers: 1664325, 1664326, 1829554, 2054780, 2054781), China, Hong Kong, India, Japan, Korea, UK and EU.

 

Respondent registered the disputed domain name, on October 4, 2025.

- Forum has acknowledged Complainant's strong trademark rights in and to the Workday Marks in previous decisions

 

Respondent's <workdaytenants.com> is confusingly similar to Complainants WORKDAY mark, as the disputed domain name consists to the mark in its entirety, and merely adds the generic term "tenants" and  top-level domain name ("gTLD") ".com."

 

Respondent has no rights or legitimate interests in the <workdaytenants.com> disputed domain name. Respondent is not commonly known by the disputed domain name, nor has Complainant authorized or licensed Respondent to use the WORKDAY mark for any reason. Respondent's use of the disputed domain name does not amount to a bona fide offering of goods or services or a legitimate noncommercial or fair use. The disputed domain name appears to resolve to a  number of links to login to each of the WORKDAY Tenant portals or accounts for each of the listed customers. When following these links, the websites again prominently display the WORKDAY Marks, along with various third-party trademarks, and purport to offer links for customers to login to the WORKDAY portal for each of said customers. The disputed domain name is being used to impersonate Complainant and Complainant's customers to illicitly gain the public's trust in order to deceive Complainant's customers, divert web traffic intended for Complainant, or some other nefarious purpose, such as a phishing scheme.

 

Respondent is using the disputed domain name in furtherance of a phishing scheme in an attempt to impersonate complainant and deceive third parties into believing the disputed domain name offers Complainant's legitimate services, use which is in an attempt to divert web traffic away from Complainant's legitimate website or in attempt to phish login information or other personal information from innocent third parties and Complainant's customers.

 

Upon information and belief, Respondent registered the disputed domain name with actual knowledge of Complainant's mark as Respondent intentionally copied the WORKDAY Marks and the third party trademarks of Complainant's customers, as the time Respondent registered the disputed domain name, the WORKDAY Marks were distinctive and registered throughout numerous jurisdictions in the world, so as to give constructive, if not actual notice, to Respondent that the registration of the disputed domain name at issue would violate Complainant's rights.

 

B. Respondent

In its timely Response, the Respondent contends as follows:

The Respondent does not dispute the first element of the Policy, but submits that, the term "Workday" was referenced solely for descriptive and nominative purposes in connection with an informational directory relating to Workday tenant login portals.

The Respondent submits that the domain name was used in connection with a legitimate informational purpose, as a directory listing publicly available tenant login URLs, without offering competing products or services or claiming to be "official" or affiliated with Complainant. Additionally, no Workday logos, branding, or proprietary user interface elements were used.

The Complaint fails on the third and decisive element of the Policy. Complainant has not demonstrated that the disputed domain name was registered or used in bad faith.

The Respondent submits that there is no phishing or credential harvesting occurred in connection with the disputed domain name, as the website:

-       Did not contain any username or password fields;

-       Did not host any login pages;

-       Did not collect or intercept credentials;

-       Did not contain malware or scripts designed to capture user data; and

-       Did not proxy, redirect, or alter login flows.

Further, the Respondent contends that there is no email misuse or Impersonation Infrastructure in connection with the disputed domain name, as the disputed domain name was never configured for email use. No MX records were enabled, and no emails were sent or received using the domain.

According to the Respondent, the contact form was non-deceptive, as it was generic contact form for general inquiries relating to the directory itself. The form did not request Workday credentials, employee IDs, passwords, or employer-specific login information. It did not claim to be Workday support, customer service, or an official communication channel.

Moreover, the Respondent contends that the browser or security warnings do not establish bad faith and there is no commercial exploitation or confusion 

Additionally, the Respondent asserts that he did not register the domain name to sell it to Complainant, to block Complainant, or as part of any pattern of abusive registrations, as he has  no history of adverse UDRP decisions and bad faith cannot be presumed solely from the inclusion of a trademark in a domain name.

 

FINDINGS

The Panel finds that the disputed domain name is confusingly similar with the Complainant's trademark and notes that the first element of the Policy is not disputed by the Respondent. In respect of the second and third element of the Policy, this Panel finds that the Respondent cannot justify right or legitimate interests in the disputed domain name as all the pages of the website resolving under the disputed domain name display not only the Complainant's trademark but also information about the main services and resources referring to integrated Workday platform, related to workforce management, payroll, and data operations, ensuring smooth coordination across its network, for the Complainant's consumers and this documents further the constructive knowledge of thr Complainant and the clear intent to impersonate the Complainant.

 

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.

 

Identical and/or Confusingly Similar

Noting that the first element of the Policy goes undisputed by the Respondent and considering the prominence of the Complainant's trademark WORKDAY and its global recognition and protection, the Panel finds that the disputed domain name is confusingly similar with the Complainant's trademark and the first element of the Policy ¶4(a)(i).has been established.

 

Rights or Legitimate Interests

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.  See Hanna-Barbera Prods., Inc. v. Entm't Commentaries, FA 741828 (Forum Aug. 18, 2006).

 

Absent contrary evidence of Policy ¶4(c) circumstances, or other evidence supporting a finding of Respondent's having rights or legitimate interests in the domain name, Complainant's prima facie showing acts conclusively.

 

This Panel is persuaded that the Respondent has no rights or legitimate interests in the <workdaytenants.com> disputed domain name and he is not commonly known by the disputed domain name, nor has Complainant authorized or licensed Respondent to use the WORKDAY mark for any reason.

 

In respect of the Respondent's use of the disputed domain name as claimed in the Response, the Panel notes that  disputed domain name appears to resolve to a  number of links to login to each of the WORKDAY Tenant portals or accounts for each of the listed customers of WORKDAY, which further prominently display the WORKDAY Marks, along with various third-party trademarks, and purport to offer links for customers to login to the WORKDAY portal for each of said customers.

Contrary to the Respondent claiming that the disputed domain name was used in connection with a legitimate informational purpose, as a directory listing publicly available tenant login URLs, without offering competing products or services or claiming to be "official" or affiliated with Complainant, the Panel finds that all the pages of the website to which the disputed domain name resolves to contains the Complainant's trademark and specific reference to the Complainant's services, the enterprise platform for managing HR. The Workday branding is used on all pages. Although the Workday logo is not used accordingly, the trademark is displayed everywhere on the website pages resolving under the disputed domain name.

Accordingly, the Panel finds that the second element of the Policy ¶4(a)(ii)  has been established.

Registration and Use in Bad Faith

In respect of the third element of the Policy, the Panel notes that circumstances are present in this case sufficiently to conclude that Respondent acted in bad faith in registering and using the disputed domain name pursuant to paragraph 4(a)(iii) of the Policy.

The Respondent submits that there was no impersonation of the Complainant took place in connection with the disputed domain name.

As detailed above, the website to which the disputed domain name appears to resolve contains the Complainant's trademark and specific reference to the Complainant's services, the enterprise platform for managing HR. The Workday branding is used on all and each pages of the website. Although the Workday logo is not used, the trademark is displayed everywhere on the website resolving under the disputed domain name.

 

Corroborating these circumstances with the Respondent non-disputing position on the first element of the Policy which further documents the constructive knowledge of the Respondent in respect of the Complainant's trademark, this Panel finds that the disputed domain name is being used to impersonate Complainant and Complainant's customers to illicitly gain the public's trust in order to deceive Complainant's customers, divert web traffic intended for Complainant, or some other nefarious purpose.

 

Such registration and use represent accordingly the establishment of the 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 <workdaytenants.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Dr. Beatrice Onica Jarka, Panelist

Dated: December 22, 2025