DECISION

 

King & Spalding LLP v. k kk

Claim Number: FA2512002196255

 

PARTIES

Complainant is King & Spalding LLP ("Complainant"), United States, represented by Kathleen E. McCarthy of King & Spalding LLP, United States. Respondent is k kk ("Respondent"), China.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <kingspaldingllp.com>, registered with Dynadot Inc.

 

PANEL

The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.

 

David E. Sorkin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on December 23, 2025; Forum received payment on December 23, 2025.

 

On December 23, 2025, Dynadot Inc confirmed by email to Forum that the <kingspaldingllp.com> domain name is registered with Dynadot Inc and that Respondent is the current registrant of the name. Dynadot Inc has verified that Respondent is bound by the Dynadot 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 29, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of January 20, 2026 by which Respondent could file a Response to the Complaint, via email to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@kingspaldingllp.com. Also on December 29, 2025, the Written Notice of the Complaint, notifying Respondent of the email 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 January 21, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed David E. Sorkin 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

Complainant is an international law firm founded in 1885. Complainant has more than 1,300 lawyers in 23 offices globally. Complainant has offered legal services under the KING & SPALDING mark since at least as early as 1962. Complainant owns longstanding trademark registrations for KING & SPALDING in the United States and other jurisdictions, and also asserts common law rights arising from extensive use and promotion.

 

The disputed domain name <kingspaldingllp.com> was registered in December 2025. The name is registered in the name of a privacy registration service on behalf of Respondent. The domain name is being used for a website that purports to offer legal services. It prominently displays Complainant's KING & SPALDING mark, photos and names of attorneys who are employed by Complainant, and a physical address corresponding to that of Complainant's New York office. Complainant states that Respondent is not commonly known by the domain name, has no relationship with Complainant, and is not authorized to use Complainant's mark.

 

Complainant contends on the above grounds that the disputed domain name <kingspaldingllp.com> is confusingly similar to its KING & SPALDING mark; that Respondent lacks rights or legitimate interests in the disputed domain name; and that the disputed domain name was registered and is being used in bad faith.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

The Panel finds that the disputed domain name is confusingly similar to a mark in which Complainant has rights; that Respondent lacks rights or legitimate interests in respect of the disputed domain name; and that the disputed domain name was registered and is being used 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 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 Overview of WIPO Panel Views on Selected UDRP Questions, § 4.3 (3d ed. 2017), available at http://www.wipo.int/amc/en/domains/search/overview3.0/; UDRP Perspectives on Recent Jurisprudence, §§ 0.2, 0.8 (updated June 2, 2025), available at https://udrpperspectives.org/; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) (dismissing complaint where complainant failed to "produce clear evidence to support its subjective allegations").

 

Identical and/or Confusingly Similar

The disputed domain name <kingspaldingllp.com> incorporates Complainant's registered KING & SPALDING trademark, omitting the ampersand symbol and spaces and adding the generic term "LLP" and the ".com" top-level domain. These alterations do not substantially diminish the similarity between the domain name and Complainant's mark. See, e.g., King & Spalding LLP v. Samantha Rhodei, FA 2153497 (Forum June 3, 2025) (finding <kingspaldinglaw.com> confusingly similar to KING & SPALDING); Haynes & Boone, LLP v. Robert Chuks, FA 1840446 (Forum May 23, 2019) (finding <haynesboonellp.com> confusingly similar to HAYNESBOONE). The Panel considers the disputed domain name to be confusingly similar to a mark in which Complainant has rights.

 

Rights or Legitimate Interests

Under the Policy, the Complainant must first make a prima facie case that the Respondent lacks rights and legitimate interests in the disputed domain name, and then the burden shifts to the Respondent to come forward with concrete evidence of such rights or legitimate interests. See Hanna-Barbera Productions, Inc. v. Entertainment Commentaries, FA 741828 (Forum Aug. 18, 2006).

 

The disputed domain name incorporates Complainant's registered mark without authorization. Its sole apparent use has been for a fraudulent website that attempts to pass off as Complainant. Such use does not give rise to rights or legitimate interests under the Policy. See, e.g., King & Spalding LLP v. Yin Feng E, FA 2130312 (Forum Jan. 9, 2025) (finding lack of rights or interests in similar circumstances).

 

Complainant has made a prima facie case that Respondent lacks rights and legitimate interests in the domain name, and Respondent has failed to come forward with any evidence of such rights or interests. Accordingly, the Panel finds that Complainant has sustained its burden of proving that Respondent lacks rights or legitimate interests in respect of the disputed domain name.

 

Registration and Use in Bad Faith

Respondent used a privacy registration service to register a domain name incorporating Complainant's mark without authorization, and is using it for a fraudulent website that attempts to pass off as Complainant. Such circumstances are indicative of bad faith registration and use under the Policy. See, e.g., King & Spalding LLP v. Yin Feng E, supra (finding bad faith registration and use in similar circumstances). The Panel so finds.

 

DECISION

Having considered the three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <kingspaldingllp.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

David E. Sorkin, Panelist

Dated: January 21, 2026