DECISION

 

Guidehouse LLP v. Linda James / guidehouseglobal

Claim Number: FA2602002206451

 

PARTIES

Complainant is Guidehouse LLP ("Complainant"), represented by Bruce A. McDonald of SMITH, GAMBRELL & RUSSELL LLP, District of Columbia, USA. Respondent is Linda James / guidehouseglobal ("Respondent"), Nigeria.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <guidehouseglobal.com>, registered with Tucows Domains 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.

 

Nick J. Gardner as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on February 20, 2026; Forum received payment on February 20, 2026.

 

On February 21, 2026, Tucows Domains Inc. confirmed by e-mail to Forum that the <guidehouseglobal.com> domain name is registered with Tucows Domains Inc. and that Respondent is the current registrant of the name. Tucows Domains Inc. has verified that Respondent is bound by the Tucows Domains 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 February 23, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of March 16, 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@guidehouseglobal.com. Also on February 23, 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 March 17, 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 says it is a leading global management consultancy, the successor to PricewaterhouseCoopers' public sector business acquired in 2018. It has over 16,500 professionals in 55+ locations globally, annual revenues exceeding USD3 billion, and was acquired by Bain Capital in December 2023 at a reported valuation of approximately USD7 billion. It operates under the GUIDEHOUSE mark exclusively since 2018.

 

Complainant says it holds multiple registrations for GUIDEHOUSE (standard characters) in the US (USPTO Reg. Nos. 5,723,735 and 7,049,296, registered 2019 and 2023), Australia, Canada, New Zealand, Singapore, Great Britain, and via WIPO International Registrations covering the EU, Japan, India, Mexico, Korea, and others. The mark is asserted to be arbitrary and distinctive, with no dictionary meaning and no known third-party registrations or uses. Complainant cites a substantial prior UDRP track record — more than a dozen prior Forum decisions transferring domains incorporating GUIDEHOUSE.

 

Complainant asserts as follows.

 

Element 1 — Confusing Similarity

The domain incorporates GUIDEHOUSE in full and appends the geographically descriptive term "global." Complainant argues that adding a geographic descriptor to a famous mark cannot dispel confusion — and in this case actually compounds it, since it mimics the kind of global-brand styling Complainant itself might use. Complainant cites Guidehouse LLP v. Stacy Paul/GuidehouseUSA, FA 2133304 (Forum Jan. 29, 2025) as directly on point for "GUIDEHOUSEUSA.COM." Complainant further argues that Respondent's active use of the domain to impersonate Complainant is itself conclusive evidence of likely confusion.

 

Element 2 — No Rights or Legitimate Interests

Complainant contends there is plainly no legitimate interest in a criminal impersonation scheme. Respondent is not known by the domain, is not authorised to use the GUIDEHOUSE mark, and is making no bona fide offering of goods or services. Complainant characterises the conduct as "combo-squatting," citing several Forum decisions holding that registration and use of a combination domain (mark + descriptor) rules out any legitimate interest. Complainant further alleges that Respondent is committing identity theft, wire fraud, and violations of the federal fictitious name statute.

 

Element 3 — Bad Faith

Complainant advances several grounds:

·       Combo-squatting on a famous mark is itself evidence of bad faith and of knowledge of the mark at registration.

·       Active phishing/employment fraud operation: The domain is used by the registrant (or those acting in concert) to send fraudulent emails impersonating Complainant's recruiters. Complainant provides three specific examples of phishing attempts with supporting documentary evidence. Complainant argues that criminal impersonation, identity theft, and wire fraud are "manifestly" bad faith under UDRP precedent, citing Solva SA v. Palm Wino, D2023-0414 (WIPO Mar. 24, 2023).

·       Concealed identity — Respondent is operating from a concealed location (Nigeria-based registrant details), asserted to be for the purpose of evading accountability.

·       Parallel proceeding: Complainant believes Respondent is acting in concert with, or is the alter ego of, the registrant of <guidehouselnc.com>, Guidehouse LLP v. michelle taylor, FA 2205911 (Forum Mar. 19, 2026), though the two proceedings have been kept separate to avoid consolidation risk.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

Based on the record before the Panel it finds as follows.

 

Complainant is a leading global provider of consulting services to business and government clients. It is the successor to PricewaterhouseCoopers LLP's public sector business, which was acquired in 2018 by Veritas Capital, and was subsequently acquired by Bain Capital in December 2023 at an estimated valuation of approximately USD 7 billion.

 

Complainant employs more than 16,500 professionals across over 55 locations globally and reports annual revenues exceeding billion. Its clients include numerous U.S. federal agencies, including the Departments of Defense, Homeland Security, Veterans Affairs, Health and Human Services, and State.

 

Complainant has used the GUIDEHOUSE mark continuously in commerce since 2018 in connection with consulting, management, technology, risk assessment, and related professional services.

 

Complainant holds multiple trademark registrations for GUIDEHOUSE in standard characters, including USPTO Registration No. 5,723,735 (registered April 9, 2019, International Classes 35 and 42) and Registration No. 7,049,296 (registered May 9, 2023, International Classes 36, 42, and 45). Complainant further holds registrations in Australia, Canada, New Zealand, Singapore, and the United Kingdom, as well as WIPO International Registrations with protection extended to the European Union, India, Japan, Mexico, South Korea, and Great Britain, among others.

 

The GUIDEHOUSE mark is arbitrary and distinctive, possessing no dictionary definition, and Complainant has confirmed through searches that there are no third-party trademark registrations for the mark in any jurisdiction.

 

The Domain was registered on January 31, 2026 - well after Complainant's earliest USPTO registration in April 2019 and more than seven years after Complainant began using the GUIDEHOUSE mark in commerce.

 

Respondent has used the disputed domain name as a vehicle for a fraudulent phishing and employment-impersonation scheme. Named individuals operating through email addresses hosted under the disputed domain name, have contacted members of the public impersonating Complainant's employees and representatives, soliciting personal and professional information under the guise of fictitious employment or executive recruitment opportunities. Evidence submitted with the Complaint includes contemporaneous email exchanges demonstrating that multiple members of the public were deceived into believing they were corresponding with legitimate Guidehouse talent acquisition personnel.

 

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 GUIDEHOUSE mark through its USPTO registrations, the earliest of which predates the Domain's registration by approximately seven years, as well as through its extensive international registrations and continuous commercial use since 2018. Ownership of a trademark registration is generally sufficient to establish the requisite rights for the 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 name at issue incorporates Complainant's GUIDEHOUSE mark in its entirety and appends the geographically descriptive term "global." The addition of a generic or descriptive term to a complainant's mark does not negate a finding of confusing similarity. See Bloomberg Finance L.P. v. Nexperian Holding Limited, FA 1782013 (Forum June 4, 2018) ("Where a relevant trademark is recognisable within a disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) does not prevent a finding of confusing similarity under the first element."). In the present case, the appended word "global" - consistent with the international scope of Complainant's operations - serves to reinforce rather than dispel the association with Complainant. Prior panels have reached the same conclusion with respect to comparable combinations of the GUIDEHOUSE mark with geographically descriptive terms. See, for example, Guidehouse LLP v. Stacy Paul/GuidehouseUSA, FA 2133304 (Forum Jan. 29, 2025) (transferring GUIDEHOUSEUSA.COM; geographic addition to GUIDEHOUSE mark increases rather than reduces confusion). The generic top-level domain ".com" is disregarded in the analysis as a standard technical requirement of registration. See Rollerblade, Inc. v. McCrady, D2000-0429 (WIPO June 25, 2000).

 

The Panel therefore 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 GUIDEHOUSE trademark and has no relationship with Complainant. The WHOIS information identifies Respondent as "Linda James" 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 "GUIDEHOUSE" 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 has been used in fraudulent emails. The use of a domain name confusingly similar to a trademark for fraudulent email purposes cannot constitute a bona fide offering of goods or services. See Home Depot Product Authority, LLC v. Domain Owner / Knowbe4, FA 1990823 (Forum May 25, 2022) ("Using a domain name to gain commercially through a fraudulent email scam is neither a bona fide offering of goods or services as contemplated by Policy ¶ 4(c)(i) nor a legitimate noncommercial or fair use as contemplated by Policy ¶ 4(c)(iii)."). See also  Agilent Technologies, Inc. v. li wei wei et al., FA 1990953 (Forum May 23, 2022) (using disputed domain name to send fraudulent emails while inactively holding resolving website is not legitimate noncommercial or fair use).

  

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

 

Registration and Use in Bad Faith

Under Policy ¶ 4(a)(iii), Complainant must prove that Respondent registered and is using the disputed domain name in bad faith. Policy ¶ 4(b) provides non-exclusive examples of bad faith registration and use:

 

(i) circumstances indicating that the respondent has registered or acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of the respondent's documented out-of-pocket costs directly related to the domain name; or

 

(ii) the respondent has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that the respondent has engaged in a pattern of such conduct; or

 

(iii) the respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or

 

(iv) by using the domain name, the respondent has intentionally attempted to attract, for commercial gain, Internet users to the respondent's website 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 the respondent's website or location or of a product or service on the respondent's website or location.

   

The registration of a domain name obviously connected with a well-known trademark by someone with no connection to the trademark owner suggests bad faith. See Household Int'l, Inc. v. Cyntom Enters., FA 096784 (Forum Nov. 7, 2000) (inferring that respondent registered a well-known business name with hopes of attracting complainant's customers). The GUIDEHOUSE 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.

 

Use of the disputed domain name in connection with fraudulent e mails amounts to conduct within Policy ¶ 4(b)(iii) and/or (iv)" – see Swinerton Incorporated v. [NAME REDACTED], FA 1896039 (Forum June 8, 2020) ("Respondent subsequently used the disputed domain name to send and receive fraudulent emails in furtherance of a fraudulent phishing scheme. Such use constitutes bad faith pursuant to Policy ¶ 4(b)(iii) and/or (iv)."). See also Huntsman International, LLC v. Tony Carmean, FA 1920665 (Forum Nov. 23, 2020) ("[T]he domain name was registered and used to perpetrate a phishing scheme designed to bilk third parties. Such use of the domain name surely disrupts Complainant's business and was initiated for financial gain. Using the domain name in this manner demonstrates bad faith registration and use of the domain name pursuant to Policy ¶ 4(b)(iii) and (iv).").

 

The totality of the circumstances‚ including in particular the use of the disputed domain name for clearly fraudulent emails and lack of any conceivable legitimate use‚ compels the conclusion that Respondent registered and is using the disputed domain name in bad faith.

 

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 <guidehouseglobal.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Nick J. Gardner Panelist

Dated: March 24, 2026