DECISION

 

Carahsoft Technology Corp. v. Lauri Chan / carasoltt.com

Claim Number: FA2602002203656

 

PARTIES

Complainant is Carahsoft Technology Corp. ("Complainant"), represented by Adam D. Mandell of Millen, White, Zelano & Branigan, P.C., Virginia, USA. Respondent is Lauri Chan / carasoltt.com ("Respondent"), Trinidad and Tobago.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <carasoltt.com>, registered with Squarespace Domains II LLC.

 

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.

 

Nick J. Gardner as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on February 4, 2026; Forum received payment on February 4, 2026.

 

On February 5, 2026, Squarespace Domains II LLC confirmed by e-mail to Forum that the <carasoltt.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 6, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 26, 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@carasoltt.com. Also on February 6, 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 27, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Nick J. Gardner 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 argues that <carasoltt.com> is a typosquatted variation of its CARAHSOFT mark. Specifically, the Domain omits the silent "h" and substitutes "lt" for the "f," producing a string that is visually and phonetically similar — both share the prefix "cara" and end with a single syllable beginning with "so." Complainant relies on prior Forum decisions against itself involving similar typosquatted variations of the same mark (carhasoft.com, carahsofft.org) and standard authorities on minor misspellings not defeating confusing similarity. The gTLD ".com" is disregarded as usual.

 

Complainant contends that Respondent is not known by the name carasoltt, has no licence or authorisation from Complainant, and that the disputed domain name main resolves only to a generic "under construction" page. Complainant argues this constitutes passive holding, which does not amount to a bona fide offering or legitimate noncommercial/fair use. Complainant also flags that Respondent used a privacy shield to conceal its identity, which it argues supports an inference of bad intent.

 

Complainant advances several bad faith indicators: the disputed domain name was registered decades after the CARAHSOFT mark became well known and its USPTO registration (filed 2009) became incontestable; typosquatting itself evidences bad faith; the "under construction" passive holding further demonstrates it; the use of a privacy/identity shield is an additional indicator; and there is no plausible legitimate explanation for choosing this particular string. Complainant also notes a broader pattern of bad actors registering CARAHSOFT typosquats for phishing purposes targeting government contractors and technology vendors, framing this disputed domain name as part of that pattern.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

Based on the evidence submitted the Panel finds as follows.

 

Complainant is a leading value-added reseller and distributor of information technology products and services to federal, state, and local governments, educational institutions, and prime contractors. Complainant has operated under the CARAHSOFT mark in commerce since at least 1999 and employs a team of more than 2,000 sales, marketing, customer service, and contracting professionals. Annual sales of goods and services offered under the CARAHSOFT mark have exceeded several billion United States dollars, and Complainant spends in excess of ten million dollars per year on marketing and promotion.

 

Complainant holds multiple United States trademark registrations for the CARAHSOFT mark, including USPTO Registration No. 3,685,627 for the mark CARAHSOFT in International Class 35 (value-added reseller services featuring information technology products), filed February 26, 2009 and registered September 22, 2009. That registration has achieved incontestable status under 15 U.S.C. § 1065, constituting conclusive evidence of Complainant's exclusive right to use the mark in connection with the registered goods and services throughout the United States. Complainant additionally holds USPTO Registration No. 5,595,279 for the mark COUNT ON CARAHSOFT (registered October 30, 2018) and Registration No. 6,620,076 for the stylized CARAHSOFT mark (registered January 18, 2022), both in International Class 35. All filing and registration dates predate the Domain's registration by a substantial margin — in the case of the principal CARAHSOFT registration, by more than sixteen years.

 

The disputed domain name was registered on January 4, 2026 — well after Complainant's trademark rights were established and the mark had become well known in the information technology services sector. At the time of filing the Complaint, the disputed domain name resolved to a webpage displaying the message "carasoltt.com — We're under construction. Please check back for an update soon," with no indication of any particular business or enterprise associated with Respondent. Respondent has not responded to the Complaint and has offered no explanation for its choice of the Domain.

 

Complainant has represented that it is aware of a pattern of bad actors registering domain names confusingly similar to the CARAHSOFT mark in order to conduct phishing scams targeting technology vendors, prime contractors, systems integrators, and channel partners, in some cases tricking victims into providing personal information and payments. Complainant has actively enforced its rights against such registrations through cease-and-desist correspondence

 

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 established rights in the CARAHSOFT mark through its USPTO registrations, including the incontestable Registration No. 3,685,627. Ownership of a trademark registration is generally sufficient evidence that a complainant has the requisite rights in a mark for purposes of paragraph 4(a)(i) of the Policy. See Farmlane Brands, LLC v. Helene Isbell Biggane, FA 1996757 (Forum July 12, 2022).

 

The Domain <carasoltt.com> is a confusingly similar typosquatted variation of the CARAHSOFT mark. The second-level domain "carasoltt" reproduces the first four letters of the CARAHSOFT mark ("cara") and approximates the remainder by omitting the silent letter "h" and substituting "lt" for the letter "f," resulting in a string that closely resembles the mark both visually and phonetically. Both the mark and the Domain share the prefix "cara" and conclude with a single syllable beginning with "so." The domain name thus represents a deliberate typographical distortion of the CARAHSOFT mark of the kind routinely identified as typosquatting. See Victoria's Secret v. Zuccarini, FA 95762 (Forum Nov. 18, 2000).

 

Prior panels have addressed the CARAHSOFT mark in comparable typosquatting scenarios. See Carahsoft Technology Corp. v. Fatkin Tdme, FA 1981718 (Forum Feb. 22, 2022) (carhasoft.com) (transposition of two letters of the CARAHSOFT mark found confusingly similar). See also Carahsoft Technology Corp. v. Zoe Davis, FA 1981717 (Forum Feb. 28, 2022) (carahsofft.org) (addition of an extra letter to the CARAHSOFT mark found confusingly similar).

 

The addition of the generic top-level domain ".com" is a standard technical requirement of domain name registration and does not affect the confusing similarity analysis. See Rollerblade, Inc. v. McCrady, WIPO Case No. D2000-0429.

 

The Panel finds that Complainant has satisfied Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Under Policy ¶ 4(a)(ii), it is now well established that the Complainant must first make a prima facie case that the Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii) and that, if the prima facie case is made out, the burden then shifts to the Respondent to show that it does have such rights or legitimate interests. See Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011) (finding that a complainant must offer some evidence to make its prima facie case and satisfy Policy ¶ 4(a)(ii)).

 

Complainant has demonstrated that Respondent is not authorized to use the CARAHSOFT trademark and has no relationship with Complainant. The Registrar disclosure identifies Respondent as " Lauri Chan " which bears no resemblance to the disputed domain name. There is no evidence that Respondent has been commonly known by the disputed domain name or has acquired any trademark rights in CARAHSOFT or any similar term. Accordingly, Complainant has established a prima facie case under Policy ¶ 4(a)(ii), and the burden shifts to Respondent to demonstrate rights or legitimate interests. Respondent has failed to respond and therefore has failed to demonstrate any rights or legitimate interests.

 

The Panel finds that Respondent is not making a bona fide offering of goods or services under Policy ¶ 4(c)(i). The disputed domain name does not resolve to any active website.

 

The Panel finds that Respondent is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii). Respondent's unauthorized use of Complainant's mark supports a lack of rights or legitimate interests. See Solstice Marketing Corp. v. Marc Salkovitz d/b/a Image Media, LLC, FA 040087 (Forum Aug. 31, 2007) (respondent not commonly known by disputed domain name because respondent lacked authorization to use complainant's registered service mark).

 

The Panel finds that Respondent is not making a legitimate noncommercial or fair use of the disputed domain name under Policy ¶ 4(c)(iii). The passive holding of a domain name does not constitute legitimate noncommercial or fair use.

 

Respondent has failed to rebut Complainant's prima facie case or to demonstrate any rights or legitimate interests in the disputed domain name.

 

The Panel finds that Complainant has established Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

Policy ¶ 4(b) sets forth four non-exclusive circumstances that constitute evidence of registration and use in bad faith. It is not possible to determine whether any of these are applicable to the facts of the present case. However the list is non exhaustive. The CARAHSOFT trademark is so obviously connected with Complainant that Respondent's registration and use of the confusingly similar disputed domain name strongly supports a finding of bad faith.  It is not possible to conceive of a good faith use of the domain name (absent consent from the Complainant). The fact that the domain name has not been used and is passively held does not alter this analysis – see Bridgewater Associates, LP v. hamza hamed, FA 1894223 (Forum June 9, 2020) ("The fame of Complainant's mark and the lack of evidence of legitimate use and bona fide offering of goods and services by Respondent are the factors that, inter alia, support finding of passive holding as constituting bad faith registration and use". See also Coachella Music Festival, LLC v. Mike Gau, FA 1878581 (Forum Jan. 16, 2020) ("The overriding objective of the Policy is to curb the abusive registration of domain names in circumstances where the registrant seeks to profit from or exploit the trade mark of another. Passive holding of a domain name containing a mark with a reputation can be bad faith registration and use"). See also WIPO Overview 3.1 at ¶ 3.3. "From the inception of the UDRP, panelists have found that the non-use of a domain name (including a blank or "coming soon" page) would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panelists have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy.

 

Factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant's mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent's taking active steps to conceal its identity or (iv) the use of false or inaccurate contact details (noted to be in breach of the respondent's registration agreement).

 

Taking the above factors into consideration, panels assess the overall plausibility of any (claimed) good faith use to which the domain name may be put in light of the composition of the domain name in relation to the relevant mark, such that, the more arbitrary or distinctive a mark the less plausible a claimed non-infringing good faith use is likely to be, and vice versa.".  At least factors (i), (ii) and (iv) apply in the present case.

 

The Panel finds that Complainant has established 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 <carasoltt.com> domain name be TRANSFERRED from Respondent to Complainant

 

 

 

Nick J. Gardner Panelist

Dated: March 3, 2026