DECISION

 

Huron Consulting Group Inc. v. Yilun Pan

Claim Number: FA2604002215476

 

PARTIES

Complainant is Huron Consulting Group Inc. ("Complainant"), represented by Joshua S. Frick of Barnes & Thornburg LLP, Illinois, USA. Respondent is Yilun Pan ("Respondent"), Canada.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <huron.info> (the "Disputed Domain Name"), registered with One.com A/S.

 

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.

 

Ivett Paulovics as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on April 13, 2026; Forum received payment on April 13, 2026.

 

On April 14, 2026, One.com A/S confirmed by e-mail to Forum that the <huron.info> domain name is registered with One.com A/S and that Respondent is the current registrant of the Disputed Domain Name. One.com A/S has verified that Respondent is bound by the One.com A/S 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 April 14, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of May 4, 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@huron.info. Also on April 14, 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.

 

A timely Response was received and determined to be complete on April 14, 2026.

 

On April 15, 2026, pursuant to the Parties' requests to have the dispute decided by a single-member Panel, Forum appointed Ivett Paulovics as Panelist.

 

On April 15, 2026, Complainant's Additional Submission was received by Forum. On the same day, Respondent's Additional Submission was received by Forum.

 

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") "Panel 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.

 

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A. Complainant

Complainant asserts rights in the HURON trademark based on multiple trademark registrations in the United States and in other jurisdictions, as well as its use of the mark in connection with consulting services.

 

Complainant contends that the Disputed Domain Name <huron.info> is identical to its HURON mark, as it incorporates the mark in its entirety.

 

Complainant further submits that Respondent has no rights or legitimate interests in respect of the Disputed Domain Name. According to Complainant, Respondent is not affiliated with or authorized by Complainant, is not commonly known by the Disputed Domain Name, and has not made any bona fide or legitimate noncommercial use of it.

 

Complainant argues that the Disputed Domain Name was registered and is being used in bad faith. It submits that Respondent was aware of Complainant's mark at the time of registration and that the passive holding of the Disputed Domain Name, combined with the alleged risk of email-related fraud, supports a finding of bad faith.

 

B. Respondent

Respondent contends that the Disputed Domain Name consists of the term "Huron," which has an independent geographic and historical meaning and is not exclusively associated with Complainant.

 

Respondent submits that he resides in Ontario, Canada, where the term "Huron" is commonly used in geographic and cultural contexts, and that the Disputed Domain Name was registered for its descriptive or geographic value.

 

Respondent further argues that the Disputed Domain Name was registered recently and is in the process of being set up. Respondent denies any intent to target Complainant or its trademark and asserts that the Disputed Domain Name has not been used for any misleading, commercial, or abusive purpose.

 

Respondent also provides evidence of DNS-related configuration activity and denies that the Disputed Domain Name has been used for email or other deceptive conduct.

 

C. Additional Submissions

Complainant submitted an Additional Submission reiterating its prior arguments and maintaining that Respondent must have been aware of Complainant's HURON mark at the time of registration. Complainant further emphasized the alleged risk of misuse of the Disputed Domain Name and disputed Respondent's explanation for the registration.

 

Respondent submitted an Additional Submission reiterating that the term "Huron" has a geographic and historical meaning and denying any intent to target Complainant. Respondent further referred to evidence of technical configuration activity and maintained that the Disputed Domain Name was registered for its descriptive or geographic value.

 

FINDINGS

Complainant is a United States-based company providing consulting services and operates internationally under the name "Huron Consulting Group Inc."

 

Respondent is an individual residing in Ontario, Canada.

 

The Disputed Domain Name was registered on March 2, 2026.

 

The Disputed Domain Name does not resolve to an active website.

 

The term "Huron" has a recognized geographic and historical meaning, including as the name of a Great Lake in North America and in numerous geographic place names in Canada and the United States.

 

The record indicates that Respondent has a connection to Ontario, Canada, where the term "Huron" is commonly used.

 

There is no evidence on record that Respondent has used the Disputed Domain Name for any commercial, misleading, or otherwise abusive purposes.

 

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.

 

Only if all three elements are satisfied will the Panel order the transfer of the Disputed Domain Name to Complainant. If any of the elements is not satisfied, the Complaint must be denied and the Disputed Domain Name will remain with Respondent.

 

The burden of proof rests with Complainant. The applicable standard of proof in proceedings under the Policy is the balance of probabilities, meaning that a party must demonstrate that it is more likely than not that a claimed fact is true.

 

Identical and/or Confusingly Similar

The first element of the Policy functions primarily as a standing requirement. Where a complainant holds a nationally or regionally registered trademark, this is sufficient to establish rights in a mark for purposes of Policy 4(a)(i). See Quora, Inc. v. Jon Ban, FA 1997021 (Forum July 22, 2022).

 

Complainant has provided evidence of trademark registrations for the mark HURON. On this basis, the Panel finds that Complainant has established rights in the HURON mark for purposes of Policy 4(a)(i).

 

Respondent does not contest Complainant's trademark rights or the similarity between the mark and the Disputed Domain Name.

 

The Panel notes that Complainant has also referred to the status of its trademark, including its alleged incontestable status. However, such status is not determinative for purposes of the Policy, which requires an independent assessment based on the evidence submitted in this proceeding and does not depend on national law concepts beyond the existence of trademark rights.

 

The Panel further notes that Complainant has asserted that its mark is well known. However, the evidence submitted in support of this assertion consists primarily of printouts from Complainant's own website and does not, in itself, establish that the term "HURON" has acquired a level of distinctiveness or reputation beyond its registered status. In any event, such considerations are not determinative for the purposes of the first element.

 

Once trademark rights are established, the Panel assesses whether the Disputed Domain Name is identical or confusingly similar to the mark. This involves a straightforward comparison of the domain name and the textual elements of the mark to determine whether the mark is recognizable within the domain name. See Google LLC v. Domain Manager, FA 1755084 (Forum Jan. 18, 2018).

 

The Disputed Domain Name <huron.info> incorporates Complainant's HURON mark in its entirety. The addition of the ".info" generic top-level domain ("gTLD") is a technical requirement of registration and is disregarded in the confusing similarity analysis. See The Regents of The University of Michigan v. Jason Ferrantello, FA 2019913 (Forum Dec. 29, 2022).

 

Accordingly, the Panel finds that the Disputed Domain Name is identical to Complainant's HURON mark and that Policy 4(a)(i) is satisfied.

 

Rights or Legitimate Interests

Under Policy 4(a)(ii), the complainant must establish that the respondent has no rights or legitimate interests in respect of the domain name. Once the complainant makes a prima facie showing, the burden of production shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests. See Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011); see also Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014).

 

Paragraph 4(c) of the Policy sets out a non-exhaustive list of circumstances by which a respondent may demonstrate rights or legitimate interests, including:

 

(i) before any notice of the dispute, he used or made demonstrable preparations to use the domain name in connection with a bona fide offering of goods or services; or

(ii) he (as an individual, business, or other organization) has been commonly known by the domain name, even if he has not acquired trademark or service mark rights; or

(iii) he is making a legitimate noncommercial or fair use of the domain name without intent for commercial gain to misleadingly divert consumers or to tarnish the complainant's mark.

 

The Panel finds that Complainant has made out a prima facie case. The Disputed Domain Name is identical to Complainant's mark, Respondent is not affiliated with Complainant, and there is no evidence that Respondent has been authorized to use the HURON mark.

 

The Panel therefore turns to Respondent's arguments and the evidence on record.

 

The Disputed Domain Name consists of the term "Huron," which has an established geographic and historical meaning, referring, inter alia, to Lake Huron in North America and to the Huron-Wendat people historically associated with that region. The term is also widely used in geographic place names in both Canada and the United States and is not exclusively associated with Complainant.

 

Respondent has provided a plausible explanation for the registration of the Disputed Domain Name based on its geographic significance. In this respect, Respondent has submitted a copy of an official identification document indicating residence in Ontario, Canada. There is nothing on record that calls into question the authenticity of this document. The Panel therefore accepts that Respondent has a connection to a region where the term "Huron" is commonly used.

 

The Panel further notes that the Disputed Domain Name was registered recently and that the record reflects technical configuration activity, which is consistent with a domain name in the process of being set up.

 

While Respondent has not provided evidence of a fully developed project or demonstrable preparations for use in the sense of Policy 4(c)(i), the Policy does not require such evidence where the domain name consists of a term with an independent meaning and there is no indication that it was registered to target the complainant.

 

On the record before it, the Panel finds that Complainant has not demonstrated that Respondent lacks rights or legitimate interests in the Disputed Domain Name. Accordingly, Policy 4(a)(ii) is not satisfied.

 

Registration and Use in Bad Faith

Under Policy 4(a)(iii), Complainant must prove that the Disputed Domain Name was registered and is being used in bad faith.

 

Policy 4(b) sets out a non-exhaustive list of circumstances which, if found to be present, shall be evidence of registration and use in bad faith. The Panel has considered all circumstances of the case in light of the evidence on record.

 

The Panel finds that Complainant has not established that Respondent registered the Disputed Domain Name with Complainant or its HURON mark in mind. In particular, the Panel finds no evidence of targeting of Complainant by Respondent.

 

The Disputed Domain Name consists solely of the term "Huron," which, as discussed above, has an independent geographic and historical meaning and is widely used in geographic place names in both Canada and the United States. The record further indicates that Respondent resides in Ontario, Canada, a region where the term "Huron" is commonly used. In these circumstances, the mere registration of a domain name corresponding to such a term does not, in itself, support an inference that Respondent intended to target Complainant. 

 

Panels have declined to find bad faith where a domain name corresponds to a term with a geographic or descriptive meaning and the evidence does not establish targeting of the complainant, particularly where the respondent's location supports a plausible alternative meaning. See Zetland Capital v. Steve King, D2024-0264 (WIPO Mar. 26, 2024).

 

The record also shows that Respondent registered the Disputed Domain Name through the Registrar at a standard registration fee. There is no indication that the Disputed Domain Name was acquired through an aftermarket transaction or at a price suggesting targeting of Complainant.

 

Complainant relies on prior UDRP decisions involving domain names incorporating expressions such as "huronconsulting," "huronconsultinggroup," or similar terms. Those cases are distinguishable, as the domain names at issue combined the term "Huron" with elements directly referring to Complainant's business or services, thereby supporting a finding of targeting. By contrast, the Disputed Domain Name consists solely of the term "Huron."

 

The Disputed Domain Name does not resolve to an active website. However, passive holding does not automatically amount to bad faith. The Panel has considered the principles set out in Telstra Corp. v. Nuclear Marshmallows, D2000-0003 (WIPO Feb. 18, 2000), but finds that they do not apply in the present case. Unlike in Telstra, the mark at issue is not a coined or inherently distinctive term uniquely associated with Complainant, and the record does not exclude plausible good faith uses of the Disputed Domain Name, particularly in connection with its geographic meaning.

 

The Panel further finds that the Disputed Domain Name was registered recently and that the record reflects technical configuration activity, including DNS-related changes consistent with a domain name in the process of being set up rather than being passively held for abusive purposes.

 

There is no evidence that Respondent offered the Disputed Domain Name for sale, engaged in a pattern of abusive domain name registrations, registered the Disputed Domain Name to disrupt Complainant's business, or used it to attract Internet users for commercial gain by creating a likelihood of confusion with Complainant's mark. There is also no evidence of phishing, impersonation, pay-per-click links, or other misleading use. Complainant's assertion that the Disputed Domain Name could be used for email-related fraud is speculative and unsupported by evidence of actual misuse.

 

Even if Respondent may have been aware of Complainant's mark, such awareness alone is not sufficient to establish bad faith in the absence of evidence that the Disputed Domain Name was registered to target Complainant.

 

Having considered all the circumstances of the case, the Panel finds that there are no additional factors on the record that would support a finding of bad faith.

 

On the totality of the circumstances, and on the balance of probabilities, the Panel finds that Complainant has failed to establish that the Disputed Domain Name was registered and is being used in bad faith.

 

Accordingly, Policy 4(a)(iii) is not satisfied.

 

DECISION

Having not established all three elements required under the ICANN Policy, the Panel concludes that relief shall be DENIED.

 

Accordingly, it is Ordered that the <huron.info> domain name REMAIN WITH Respondent.

 

 

 

Ivett Paulovics, Panelist

Dated: April 27, 2026