DECISION

 

Target Brands, Inc. v. syed Naqvi / targetreddcard.com

Claim Number: FA2601002202570

 

PARTIES

Complainant is Target Brands, Inc. ("Complainant" or "Target"), represented by Jeanette Eriksson of FairWinds (USA) Inc., District of Columbia, USA. Respondent is syed Naqvi / targetreddcard.com ("Respondent"), India.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <targetreddcard.com> ("Disputed Domain Name"), registered with Squarespace Domains II LLC.

 

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 29, 2026. Forum received payment on January 29, 2026.

 

On January 30, 2026, Squarespace Domains II LLC confirmed by e-mail to Forum that the <targetreddcard.com> domain name is registered with Squarespace Domains II LLC and that Respondent is the current registrant of the name. Squarespace Domains II LLC has verified that Respondent is bound by the Squarespace Domains II 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 February 2, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 23, 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@targetreddcard.com. Also on February 2, 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, Forum transmitted to the parties a Notification of Respondent Default.

 

On February 24, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, 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

 

Established in Minneapolis, Minnesota in 1962 as a division of the former Dayton Hudson Corporation, Complainant is the owner of the distinctive and world-famous TARGET and REDCARD trademarks (the "Marks"), which Target uses in connection with the advertising, marketing and operation of retail department stores and the sale of products and services related thereto, including groceries, personal care products, baby products, apparel, toys, housewares as well as offer credit and debit cards.

 

Respondent is utilizing the Disputed Domain Name to engage in an impersonation and phishing scheme. The Respondent initially attracts searchers to its website ("Respondent's Website") by using an identical copy of Complainant's TARGET Mark, merely adding an intentional misspelling of its REDCARD Mark and the ".com" extension, thereby making those who see the domain think that it is related to Complainant, which it is not.

 

The Disputed Domain Name resolves to a fake TARGET-branded webpage for logging in to manage credit and debit cards offered by Complainant, namely the RedCard (which has recently been rebranded as Circle Card). Users are invited to click "login" on the homepage of Respondent's Website, and informed that by doing so, they will be able to, e.g., sign up for an account, pay off their card, see and manage users, and more. The site was clearly designed to pass itself off as a legitimate site of Complainant's. Evidence of such mimicking is seen by the use of Complainant's distinctive red color scheme, the Target Red Bullseye trademark and frequent mentioning of Complainant and its services. To further the deception, the site intentionally misleads users as to its source by displaying a footer stating "Copyright © 2024 Target Brands, Inc." It is thus clear that Respondent is seeking to deceive visitors of Respondent's Website at the Disputed Domain Name into clicking "login" and divulging personal information to obtain commercial gain from its use of the Disputed Domain Name through confusion with Complainant's Marks.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

1.       Complainant Target Brands Inc is the owner of the TARGET and REDCARD trademarks, including U.S. Registration Number 845193 registered on February 27, 1968 (for its TARGET Mark), and U.S. Registration Number 4382151 registered on August 13, 2013 (for its REDCARD Mark).

2.       Respondent registered the Disputed Domain Name on September 4, 2025.

3.       The Disputed Domain Name fully incorporates Complainant's TARGET and REDCARD Marks, merely adding the letter 'd' to the REDCARD mark and the generic top-level domain ".com".  

4.       The Registrar has disclosed that the owner of the Disputed Domain Name is syed Naqvi, who has no demonstrated connection to the Disputed Domain Name and is not commonly known by the Disputed Domain Name or any similar name, as required under Policy ¶ 4(c)(ii).

5.       Under the "TARGET RED CARD LOGIN" banner, Respondent's Website purports to guide visitors how to "handle all your card-related activities in one place", including making payments, accessing and managing Target Credit Card accounts.

6.       Respondent's unauthorized use of Complainant's TARGET and REDCARD Marks, combined with a 'typosquatting' strategy, clearly demonstrates an intent to confuse the public. This confusion extends to the source, sponsorship, affiliation, or endorsement of the website and its products, all for the purpose of attracting consumers and achieving commercial gain.

7.       The Panel finds from the evidence that Respondent uses the information submitted on Respondent's Website to defraud visitors by either directly exploiting such information for further phishing activities or by selling such information to third parties for fraudulent purposes, as evidenced by the site's collection of login credentials, account numbers, and personal identifying information.

 

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

The Panel finds that the Disputed Domain Name, which combines Complainant's TARGET and REDCARD Marks and differs from the Complainant's Mark only in that the Respondent added the letter "d", is confusingly similar to Complainant's registered Marks. This minor change makes those who see the Disputed Domain Name think that it is related to Complainant and its product offerings. WIPO Overview 3.0, section 1.7, further states that "the overall facts and circumstances of a case (including relevant website content) may support a finding of confusing similarity, particularly where it appears that the respondent registered the domain name precisely because it believed that the domain name was confusingly similar to a mark held by the complainant". Such is the case here. For these reasons, the Panel finds that this element of the Policy has been met.

 

Rights or Legitimate Interests

Respondent's actions are not a bona fide offering of goods or services under Policy ¶ 4(c)(i). Complainant has not licensed, authorized, or permitted Respondent to register the Disputed Domain Name incorporating Complainant's TARGET and REDCARD trademarks, or to use the Marks in general. See Guerlain S.A. v. Peikang D2000-0055 (WIPO Mar. 21, 2000) ("Therefore, in the absence of any license or permission from the Complainant to use any of its trademarks or to apply for or use any domain name incorporating those trademarks, it is clear that no actual or contemplated bona fide or legitimate use of the domain name could be claimed by Respondent").

 

The Disputed Domain Name resolves to Respondent's Website, claiming to be the official "TARGET RED CARD LOGIN" website, and Respondent is attempting to pass itself off as Complainant and mislead Internet users for the purpose of phishing for their sensitive personal information, which is not, in any way, associated with, licensed, or approved by Complainant. None of this activity can possibly be considered to be bona fide. Prior UDRP panels have held that the use of a domain name for illegal activity (e.g., phishing, impersonation/passing off, or other types of fraud) and misleading consumers who are searching for a particular business, to a site that is impersonating the trademark owner can never confer rights or legitimate interests on a respondent and is not a bona fide use; see WIPO Overview 3.0, section 2.13. See e.g.  Brumate, Inc. v. Ndt Ndt / BruMate, FA 2000840 (Forum July 14, 2022) in which the Panel stated that "Complainant argues that Respondent does not use the disputed domain name for any bona fide offering of goods or services, nor for any legitimate non-commercial or fair use, because Respondent attempts to pass off as Complainant. Impersonation of a Complainant in a disputed domain name's associated webpage may not qualify as either a bona fide offer of goods and services, nor is it a legitimate noncommercial or fair use, under Policy ¶ 4(c)(i) or (iii). Accordingly, the Panel finds that Complainant has satisfied this element of the Policy.

 

Registration and Use in Bad Faith

Respondent has inserted specific content on its site designed to pass itself off as Complainant and confuse users into believing that the site originates with or is affiliated with Complainant or in any way authorized by Complainant, when this is not the case. The site makes extensive use of Complainant's distinctive red color, Red Bullseye trademark, references Complainant's credit and debit card offering, names Complainant's full company name in the copyright section of the footer and cetera, all of which clearly shows Respondent's bad faith intention to mimic a legitimate website of Complainant's and fool users into eventually giving up their personal information.

 

As established in Findings ¶ 3, the Disputed Domain Name incorporates Complainant's Marks with only the addition of the letter 'd', constituting typosquatting. The Panel finds that the Respondent registered and used the Disputed Domain Name in bad faith to free ride on Complainant's business goodwill and reputation for Respondent's own commercial gain and fool public Internet users into giving up their personal information. This conduct satisfies Policy ¶ 4(b)(iv) as the Disputed Domain Name "attempts to attract, for commercial gain, Internet users to [Respondent's] web site or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of [Respondent's] web site or location or of a product or service on [Respondent's] web site or location". The Panel therefore finds that this final element of the Policy has been satisfied.

 

DECISION

Having established that the Disputed Domain Name is confusingly similar to a trademark in which Complainant has rights, that Respondent has no rights or legitimate interests in the domain name, and that the domain name was registered and is being used in bad faith, the Panel concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <targetreddcard.com> domain name

be TRANSFERRED from Respondent to Complainant.

 

 

David L. Kreider, Panelist

Dated: February 25, 2026