DECISION

 

Home Depot Product Authority, LLC v. Maymunah Maymunah

Claim Number: FA2601002199761

 

PARTIES

Complainant is Home Depot Product Authority, LLC ("Complainant"), represented by Laura Lamansky of Michael Best & Friedrich LLP, Illinois, USA.  Respondent is Maymunah Maymunah ("Respondent"), Ukraine.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <husky-tool-chest.com> ("Disputed Domain Name"), 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 L. Kreider, Chartered Arbitrator (UK), as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on January 15, 2026; Forum received payment on January 15, 2026.

 

On January 15, 2026, Dynadot Inc confirmed by e-mail to Forum that the <husky-tool-chest.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 January 20, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 9, 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@husky-tool-chest.com. Also on January 20, 2026, 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, the Forum transmitted to the parties a Notification of Respondent Default.

 

On February 10, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the Forum appointed David L. Kreider 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 the owner of the distinctive and well-known HUSKY trademark. Home Depot Product Authority, LLC, through its predecessors in interest and licensees ("Complainant" or "Home Depot"), commenced use of the mark HUSKY as well as its well-known HUSKY and Design mark featuring its distinctive husky dog head design (the "Marks") in connection with hand tools, tool boxes, tool chests, tool organizers, and other home improvement products since at least as early as 1924.

 

Respondent's website accessible at the Disputed Domain Name is designed to look like a website operated with the authority of the owner of the HUSKY Marks. The most prominent language on the site is "HUSKY TOOL CHEST" which uses Complainant's HUSKY mark and the descriptive term "tool chest" which describes Complainant's products. Respondent's website includes: (1) prominent use of Complainant's HUSKY Marks, and (2) products that have Complainant's identical logo on them. 

 

Respondent uses the Domain Name for commercial purposes because the website accessible at the Domain Name contains prolific use of Complainant's HUSKY mark alongside an image and YouTube video of a third-party drawer organizer product (the FoamFit organizer) which is a type of product offered by Complainant under its HUSKY Marks and covered by Complainant's trademark registration for HUSKY, Reg. No. 4994243. Accordingly, such website content indicates that Respondent may be benefitting from video advertising revenue from the website located at the Domain Name.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

1)       Complainant owns the registered trademark HUSKY, including U.S. trademark registration number 1881043, registered on February 28, 1995.

2)       Complainant's primary website for its HUSKY brand is at <huskytools.com>, which redirects to the HUSKY product page on the Home Depot website. Home Depot registered the <huskytools.com> domain name on March 25, 1999.

3)       Respondent registered the Disputed Domain Name on January 2, 2025, using a privacy or proxy registration service to conceal his true identity. Additionally, the Registrar has identified the Respondent as Maymunah Maymunah of Ukraine. Both the use of a privacy registration service and providing false contact information may be viewed as indications of bad faith. See WIPO Overview 3.0, par. 3.6.

4)       The Panel finds that Respondent registered and is using the Disputed Domain Name in bad faith to operate a misleading website that attempts to pass off as Complainant to promote competing products.

 

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.

 

Given 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

The Disputed Domain Name is confusingly similar to Complainant's registered HUSKY Marks and <huskytools.com> domain name. The Disputed Domain Name contains Complainant's full registered HUSKY Mark with descriptive terms "tool" and "chest" with interspersed hyphens between the terms, followed by ".com," which is a generic top-level domain. The addition of "tool," "chest," the hyphens, and the ".com" top-level domain to a registered trademark is not sufficient to distinguish it from Complainant's registered trademark.

 

The terms "tool" and "chest" in the Disputed Domain Name exacerbate confusion with the HUSKY Marks because it misleads consumers into believing the website at the Disputed Domain Name is for tool chests sold by Complainant under the HUSKY Marks. Moreover, Forum has ruled that the addition of "tool chest" to a domain name with Complainant's HUSKY Mark is not sufficient to distinguish the domain name from Complainant's trademark. See Home Depot Product Authority, LLC v. 李策平, FA 2125832 (Forum December 18, 2024) (transferring <huskytoolchest.com> to Complainant). Further, Forum has concluded that domain names that include HUSKY with "tool" or "tools" are confusingly similar to Complainant's HUSKY Marks and that such additional descriptive terms in fact further perpetuates the confusion. See Home Depot Product Authority, LLC v. Donna Logan, FA 2146462 (Forum April 21, 2025) ("Notably, the inclusion of the term 'tools' in the domain name is suggestive of Respondent's tool related trademark and therefore adds to any confusion between the domain name and Complainant's mark"); Home Depot Product Authority, LLC v. Nikita Postnov, FA 2134885 (Forum February 10, 2025); Home Depot Product Authority, LLC v. Personal / Shan Arain, FA 2155985 (Forum June 10, 2025) (transferring <huskytoolsofficial.com> because "adding the generic terms 'tools' … do[es] not substantially diminish the similarity between the domain name and Complainant's mark"); Home Depot Product Authority, LLC v. Zeeshan Arain, FA 2175864 (Forum October 3, 2025) (transferring <huskytoolsinc.com> noting "the inclusion of the term 'tools' in the domain name is suggestive of Respondent's tool related trademark and therefore adds to any confusion between the domain name and Complainant's mark"). Further, the addition of hyphens in a domain name does not obviate the likelihood of confusion with a trademark. See Home Depot Product Authority, LLC v. Serhii Turkot, FA 2199989 (Forum, February 10, 2026) (The panel ordered the transfer of the disputed domain name <husky-toolchest.com> which incorporated that Complainant's HUSKY mark in its entirety, merely adding a hyphen and the generic/descriptive terms "tool chest", together with the ".com" gTLD, noting: "the addition of a gTLD and a descriptive term and a hyphen fails sufficiently to distinguish a disputed domain name from a mark per Policy ¶4(a)(i)).

 

Because the Disputed Domain Name consists of Complainant's HUSKY Marks with the generic terms "tool" and "chest," hyphens, and a generic top-level domain, the Panel finds that the Disputed Domain Name is confusingly similar to Complainant's well-known HUSKY Marks. Internet users will mistakenly expect that the Disputed Domain Name is associated with, sponsored by, or otherwise approved by Complainant.

 

Accordingly, the Panel finds that the first element at Policy Paragraph 4(a)(i) is satisfied.

 

Rights or Legitimate Interests

Respondent is not commonly known by, nor does it operate a business or other organization under, the Disputed Domain Name, which supports that Respondent has no right or legitimate interest in the Disputed Domain Name. Experian Limited, Experian Information Solutions Inc. v. Brenda Needham, D2011-1162 (WIPO Aug. 18, 2011) (concluding that Respondent had "no rights or legitimate interests in the disputed domain name" because no evidence showed that Respondent was commonly known as, identified by, or operated a business or other organization under the disputed domain name).

 

The website at the Disputed Domain Name describes competitive products and includes a YouTube video advertising a third party's competitive product, presumably so that the Respondent may make advertising revenue or sell the product depicted in the video. If a user clicks on the video on the website at the Disputed Domain Name, the user is brought to the You Tube video, where the link for the third party's

competitive product is accessible. Panels have determined that such advertising is not in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use. Home Depot Product Authority, LLC v. Guo Xing, FA 2175678 (Forum October 6, 2025) ("…Respondent is using the domain name to confuse and deceive consumers into believing that Respondent is an official site sponsored or

endorsed by Complainant. Once lured into Respondent's website under the cloak of apparent legitimacy, website visitors are served with ads for products that compete with products offered by Complainant and Respondent presumably receives a commission."). 

 

Moreover, the Panel accepts the Complainant's allegation that the Respondent registered and uses the Disputed Domain Name without the knowledge, consent, or authorization of Complainant. See Topco Holdings, Inc. (Cooperative) v. Patricia Doolittle / Diversified Exchange LLC, FA 2091468 (Forum April 26, 2024). The Respondent has defaulted and has not sought to refute or deny the Complainant's claims.

 

For these reasons, the Panel finds that the second element at Policy Paragraph 4(a)(ii) is satisfied.

 

Registration and Use in Bad Faith

The facts in this matter are substantially similar to another recent case involving Complainant's HUSKY Marks: "Respondent used a privacy registration service to register a domain name incorporating and obviously intended to create confusion with Complainant's registered mark. The domain name is being used for a misleading website that attempts to pass off as Complainant to promote competing products. Such circumstances are indicative of bad faith registration and use under the Policy." Home Depot Product Authority, LLC v. Personal / Shan Arain, FA 2155985 (Forum June 10, 2025) (finding bad faith and transferring the disputed domain name). The Panel finds that Respondent registered and is using the Disputed Domain Name in bad faith for a misleading website that attempts to pass off as Complainant to promote competing products and that the third element at Policy Paragraph 4(a)(iii) is satisfied.

 

DECISION

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

 

Therefore, it is Ordered that the <husky-tool-chest.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

David L. Kreider, Panelist

Dated: February 11, 2026