DECISION

 

Bristol West Holdings, Inc. v. Habib Saqib

Claim Number: FA2607002232500

 

PARTIES

Complainant is Bristol West Holdings, Inc. ("Complainant"), represented by Felicia J. Boyd of Norton Rose Fulbright US LLP, Minnesota, USA. Respondent is Habib Saqib ("Respondent"), Pakistan.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <bristol-west.online> (the "Disputed Domain Name"), registered with NameCheap, 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 July 14, 2026; Forum received payment on July 14, 2026.

 

Complainant submitted an Amended Complaint on July 16, 2026, following the Registrar's disclosure of the underlying registrant information.

 

On July 15, 2026, NameCheap, Inc. confirmed by e-mail to Forum that the <bristol-west.online> domain name is registered with NameCheap, Inc. and that Respondent is the current registrant of the name. NameCheap, Inc. has verified that Respondent is bound by the NameCheap, 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 July 17, 2026, Forum served the Amended Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 6, 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@bristol-west.online. Also on July 17, 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 August 7, 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

Complainant alleges:

 

That it began as a private passenger automobile insurance carrier for Florida residents in 1973 and has since expanded its reach to 43 states across the United States, and is today a member of the Farmers Insurance Group of Companies, one of the largest property and casualty insurer groups in the country. Complainant offers automobile insurance and related customer services under the BRISTOL WEST trademark and variations incorporating "BRISTOL WEST" (the "BRISTOL WEST Marks"), owns United States federal registrations for those marks, and has marketed its services through its website at the <bristolwest.com> domain name, which it registered in 1996, since at least as early as 1998.

 

That the Disputed Domain Name <bristol-west.online> is confusingly similar to the BRISTOL WEST Marks because it incorporates the BRISTOL WEST trademark in its entirety as the sole distinctive portion of the domain name, followed only by the generic top-level domain ".online."

 

That Respondent has no rights or legitimate interests in the Disputed Domain Name. Respondent has no relationship, affiliation, connection, endorsement, or association with Complainant, and has never requested or received any authorization, permission, or license to use the BRISTOL WEST Marks. There is no evidence that Respondent has been commonly known by the Disputed Domain Name, or that the Disputed Domain Name is Respondent's legal name. The website resolving from the Disputed Domain Name displays Complainant's word mark, invites Internet users to pay their Bristol West bill, and directs them to a telephone number not associated with Complainant's business, which is neither a bona fide offering of goods or services nor a legitimate noncommercial or fair use.

 

That Respondent registered and is using the Disputed Domain Name in bad faith. The BRISTOL WEST Marks were sufficiently distinctive at the time of registration that Respondent must have been aware of Complainant's rights, and Respondent selected a domain name containing Complainant's trademark in its entirety in order to promote services identical or related to Complainant's own. Respondent uses the Disputed Domain Name to impersonate Complainant and to create the false impression that the resolving website is affiliated with or operated by Complainant, in furtherance of a scheme to obtain the personal information of Complainant's customers.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

The Panel finds the following:

 

Complainant, a Delaware corporation with its principal place of business in Woodland Hills, California, underwrites and administers private passenger automobile insurance in the United States. USPTO records in evidence show four United States service mark registrations owned by Complainant, each registered on July 15, 2008, each since renewed and each live and active, covering insurance underwriting, administration, claims administration, and agency services in International Class 36: BRISTOL WEST, Reg. No. 3,466,477; BRISTOL WEST INSURANCE GROUP, Reg. No. 3,466,478; B BRISTOL WEST INSURANCE GROUP and design, Reg. No. 3,466,479; and a stylized "B" design, Reg. No. 3,466,480 (collectively, the "BRISTOL WEST Marks"). Those records state a first use of the mark in commerce of January 1, 1998. On the uncontested record, Complainant has traded under the Bristol West name in the automobile insurance business since 1973 and now writes business in 43 states as a member of the Farmers Insurance Group of Companies.

 

The WHOIS record in evidence for Complainant's own domain name <bristolwest.com> shows a registration dating from 1996, and screenshots in the record show Complainant's operational website at that address, through which it markets its insurance services and accepts customer payments.

 

On the uncontested record the Disputed Domain Name was registered on June 30, 2026, a date consistent with the expiration date of June 30, 2027, confirmed in the Registrar's verification. The Complaint as originally filed identified the registrant only as a privacy service in Reykjavik, Iceland; the Registrar's verification disclosed the underlying registrant as Habib Saqib, of Quetta, Balochistan, Pakistan, with a personal Gmail contact address, and confirmed that the language of the registration agreement is English.

 

A screen capture in the record, taken on or around July 12, 2026, shows that the Disputed Domain Name resolves to an active website (the "Respondent's Website") headed "Bristol West Billing Support Partner" above the strapline "Elegant, phone-first support page." The Respondent's Website invites Internet users, under the heading "Pay your Bristol West bill with confidence," to obtain billing support and payment guidance, and repeats throughout the page a series of call prompts, among them "Tap to Call" and "Call Billing Now," directed to a "Call Center Contact" number, +1 855-409-7255, which Complainant states is not a number associated with its business, and to a second telephone number at the foot of the page. The Respondent's Website carries no disclaimer of affiliation with Complainant and identifies no source other than Complainant's mark. Its remaining text is unedited template material addressed to whoever deploys the page, including "Conversion focus," "Google Ads Friendly," "Place your form embed or lead capture section here," and an instruction to use the page "only if your business is authorized to represent itself as a billing support partner." The Panel infers that the page was built from a commercial landing-page template intended to generate inbound telephone calls.

 

On the uncontested record, Complainant has not licensed, authorized, or otherwise permitted Respondent to use the BRISTOL WEST Marks, and Respondent has no affiliation with Complainant. No evidence in the record suggests that Respondent trades, or is known to anyone, as Bristol West.

 

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 Overview 3.1 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's registration of the BRISTOL WEST mark with the USPTO establishes its rights in the mark for purposes of the Policy. See WIPO Overview 3.1 at ¶ 1.2.1; see also Udemy, Inc. v. Maxclimb Maxclimb / Jumbo Ads, FA 2136358 (Forum Feb. 13, 2025) (registration of a mark with the USPTO is sufficient to establish rights in that mark).

 

The Disputed Domain Name reproduces the BRISTOL WEST mark in full, substituting a hyphen for the space between the two words, and appends the generic top-level domain ("gTLD") ".online." A space cannot form part of a domain name, and a hyphen standing in its place neither alters how the string reads nor how it sounds. The gTLD is disregarded under the first element as a standard technical requirement of registration. See WIPO Overview 3.1 at ¶ 1.11.1. Nothing in the Disputed Domain Name distinguishes it from the mark. The Panel reached a like conclusion on the same mark in Bristol West Holdings, Inc. v. bristol west, FA 2229682 (Forum July 23, 2026), concerning the domain name <bristolwest.org>.

 

The Panel finds that the Disputed Domain Name is confusingly similar to Complainant's BRISTOL WEST mark under Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in the Disputed Domain Name, at which point the burden of production shifts to Respondent to come forward with evidence that it does have rights or legitimate interests. See WIPO Overview 3.1 at ¶ 2.1.

 

The Registrar's verification identifies the registrant as "Habib Saqib," a name bearing no resemblance to the Disputed Domain Name, and nothing else in the record suggests that Respondent is commonly known by the Disputed Domain Name under Policy ¶ 4(c)(ii). See Bittrex, Inc. v. Operi Manaha, FA 1815225 (Forum Dec. 10, 2018) (respondent not commonly known by the disputed domain name where the WHOIS information gives a registrant name bearing no resemblance to the domain name and nothing else in the record indicates authorization to use the mark).

 

Nor does the Respondent's Website amount to a bona fide offering of goods or services under Policy ¶ 4(c)(i) or to a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii). The page is addressed to Complainant's own policyholders, offers to help them pay their Bristol West bills, takes Complainant's mark as its heading and as its only badge of origin, and carries no disclaimer of affiliation. A visitor arriving at a domain name consisting of Complainant's mark and finding that content would take the page for Complainant's, or for that of an authorized agent. Holding oneself out in that way is not a use that confers rights or legitimate interests. See Kylie Jenner, Inc. v. TrafficDomains INC / John Deecon, FA 2195489 (Forum Jan. 13, 2026) (no bona fide offering under Policy ¶ 4(c)(i) where the resolving website impersonates the complainant). Respondent, by defaulting, has offered nothing to the contrary.

 

The Panel finds that Respondent has no rights or legitimate interests in respect of the Disputed Domain Name under Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

Respondent registered the Disputed Domain Name on June 30, 2026, nearly eighteen years after Complainant's BRISTOL WEST registrations issued and decades after Complainant began trading under the name. Respondent then built a page whose subject matter is the payment of Complainant's own insurance bills. A registrant with no knowledge of Complainant would have had no reason to devote a page to Complainant's billing customers. The Panel finds that Respondent registered the Disputed Domain Name with actual knowledge of Complainant's rights in the BRISTOL WEST Marks and with Complainant in mind.

 

As to use, the Respondent's Website is designed to convert visitors into telephone calls: its several call prompts lead to a call-center number that, on the uncontested record, is not Complainant's, and its own template text describes the page as built for conversion and for use with paid search advertising. The natural effect, and on this record the evident object, is to intercept Internet users looking for Complainant's billing services and route them to a telephone operation that is not Complainant's, for Respondent's commercial gain. That is bad faith under Policy ¶ 4(b)(iv). See Cable News Network, Inc. v. GARCIA Antonio Manuel Moniz / Maka Mavulo Newsfreelance, FA 2144830 (Forum Apr. 10, 2025) (using a disputed domain name to attract Internet traffic to a site that passes off as the complainant's evinces bad faith).

 

A further feature of the record corroborates that conclusion. Respondent registered the Disputed Domain Name behind a privacy service and its identity emerged only on the Registrar's disclosure to Forum. See Microsoft Corporation v. Arif Khan, FA 1907105 (Forum Aug. 31, 2020) (use of a WHOIS privacy service supporting a finding of bad faith in the circumstances of that case).

 

Complainant further contends that the Respondent's Website exists to extract personal information from Complainant's customers who call the number displayed. The record contains no fraudulent e-mail, no targeted solicitation, no mail-exchange configuration, and no data-capture form, the page carrying only an unedited template placeholder where a form embed would go; the Panel makes no finding of phishing, and the bad-faith finding rests on the grounds set out above.

 

The Panel finds that Respondent registered and is using the Disputed Domain Name in bad faith under 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 <bristol-west.online> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

 

David L. Kreider, Panelist

Dated: August 7, 2026