DECISION

 

Robert Half Inc. v. Laney Raynor I / Mr. Korbin Olson

Claim Number: FA2607002233342

 

PARTIES

Complainant is Robert Half Inc. ("Complainant"), represented by Emily Ostreich of Foley & Lardner LLP, New York, USA. Respondent is Laney Raynor I / Mr. Korbin Olson ("Respondent"), Multiple Locations, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <networkroberthalf.com>, <globalroberthalf.com>, <onlineroberthalf.com>, <roberthalf-network.com>, <roberthalf-online.com>, <roberthalfteam.com> and <roberthalfjob.com>, registered with NameSilo, 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.

 

James Bridgeman SC as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on July 17, 2026; Forum received payment on July 17, 2026.

 

On July 20, 2026, NameSilo, LLC confirmed by e-mail to Forum that the <networkroberthalf.com>, <globalroberthalf.com>, <onlineroberthalf.com>, <roberthalf-network.com>, <roberthalf-online.com>, <roberthalfteam.com> and <roberthalfjob.com> domain names are registered with NameSilo, LLC and that Respondents are the current registrants of the names. NameSilo, LLC has verified that Respondents are bound by the NameSilo, LLC registration agreement and have 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 23, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 12, 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@networkroberthalf.com, postmaster@globalroberthalf.com, postmaster@onlineroberthalf.com, postmaster@roberthalf-network.com, postmaster@roberthalf-online.com, postmaster@roberthalfteam.com, postmaster@roberthalfjob.com. Also on July 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 August 13, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed James Bridgeman SC 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 disputed domain names be transferred from Respondent to Complainant.

 

PRELIMINARY ISSUE: MULTIPLE RESPONDENTS

Referring to Policy Rule 3(c). Complainant submits that the disputed domain names are owned by the same individual or entity, either outright or through multiple aliases. UDRP Rule 3(c).

 

This conclusion is supported by at least the following: (1) the disputed domain names share the same or similar format, namely, they incorporate Complainant's entire well-known ROBERT HALF house mark and add a generic/descriptive term and the generic top-level domain extension ".com"; (2) the disputed domain names were all registered on April 23, 2026 with NameSilo, LLC; (3) the registrant information is identical for <networkroberthalf.com>, <globalroberthalf.com>, and <onlineroberthalf.com>; (4) the registrant information is identical for <roberthalf-network.com>, <roberthalf-online.com>, <roberthalfteam.com>, and <roberthalfjob.com>; (5) the registrant email addresses for the each of the disputed domain names all use <@deltajohnsons.com>; and (6) the disputed domain names all resolve to websites that are inactive, inaccessible, and cannot be reached.

 

Complainant adds that the names provided by the registrant namely "Mr Olson Korbin" and "Raynor Laney I" are on the balance of probabilities aliases.

 

Furthermore it is argued that the disputed domain names are not meaningfully distinguishable from the ROBERT HALF mark and in each case are passively held and do not resolve to any active website.

 

When assessing whether to permit a consolidated complaint against multiple respondents the WIPO Overview of WIPO Panel Views on Select UDRP Questions ("WIPO Overview 3.1") observes that "panels look at whether (i) the domain names or corresponding websites are subject to common control, and (ii) the consolidation would be fair and equitable to all parties. Procedural efficiency would also underpin panel consideration of such a consolidation scenario."

 

WIPO Overview 3.1 adds that "[p]anels have considered a range of factors, typically present in some combination, as useful to determining whether such consolidation is appropriate, such as similarities in or relevant aspects of (i) the registrants' identity(ies) including pseudonyms, (ii) the registrants' contact information including email address(es), postal address(es), or phone number(s), including any pattern of irregularities, (iii) relevant IP addresses, name servers, or webhost(s), (iv) the content or layout of websites corresponding to the disputed domain names, (v) the nature of the marks at issue (e.g., where a registrant targets a specific sector), (vi) any naming patterns in the disputed domain names (e.g., <mark-country> or <mark-goods>), (vii) the relevant language/scripts of the disputed domain names particularly where they are the same as the mark(s) at issue, (viii) any changes by the respondent relating to any of the above items following communications regarding the disputed domain name(s), (ix) any evidence of respondent affiliation with respect to the ability to control the disputed domain name(s), (x) any (prior) pattern of similar respondent behavior, or (xi) other arguments made by the complainant and/or disclosures by the respondent(s)."

 

Applying these principles to the arguments presented by Complainant, the Panel finds on the balance of probabilities the disputed domain names are under the control of a single entity.

 

The Panel consequently directs that the Complaint may proceed against Respondent notwithstanding that the names given on the WhoIs are different from each other.

 

PARTIES' CONTENTIONS

A. Complainant

Complainant claims rights in the ROBERT HALF trademark, alone and in combination with other word and design elements, based on its rights in the portfolio of service mark registrations described below.

 

Complainant adds that it has continuously and exclusively used the ROBERT HALF mark in its business providing specialized employment staffing agencies services. It carries on business at more than 300 consulting and staffing locations throughout the world and employs over 10,000 employees.

 

Complainant firstly alleges that the disputed domain names, and each of them, are identical or confusingly similar to the ROBERT HALF mark, as they each incorporate the mark in its entirety, adding only minor elements in combination with the respective generic Top-Level Domain ("gTLD") extension.

 

Complainant firstly argues that the additional minor elements in each case are descriptive and generic and, in certain instances, include a hyphen and in each case are insufficient to distinguish the respective domain name from Complainant's mark.

 

Complainant adds that the addition of a gTLD extension is generally insufficient to differentiate a disputed domain name from the mark that it incorporates. In this regard, complainant cites Amazon Technologies, Inc. v. James David, FA 2129158 (Forum Jan. 3, 2025) (finding adding the descriptive word "network" to the complainant's marks is not sufficient to differentiate the disputed domain name from the marks it incorporates).

 

Secondly, complainant alleges that Respondent has no rights or legitimate interests in the disputed domain names, arguing that

·       Respondent is not commonly known by the disputed domain names;

·       the WHOIS registration records for each of the disputed domain names identify the registrants as "Mr Olson Korbin" and "Raynor Laney I", neither of which indicate that respondent is known by the disputed domain names;

·       Respondent can show no bona fide use or legitimate non-commercial or fair use of the disputed domain names;

·       as shown in the screen captures exhibited in the annexes to the Complaint none of the disputed domain names resolves to an active web page and past panels established under the Policy have consistently found that using domain names to resolve to an inactive and inaccessible website or passively holding domain names at issue does not amount to a bona fide use or a legitimate non-commercial or fair use.

 

Thirdly, Complainant alleges that the disputed domain names were registered and are being used in bad faith.

 

Complainant argues that each of the disputed domain names is confusingly similar to complainant's ROBERT HALF mark, as it incorporates the mark in its entirety, and Complainant has continuously and exclusively used the ROBERT HALF mark, which had an established goodwill prior to the registration of the disputed domain names.

 

Furthermore, Complainant argues that panels established under the Policy have consistently held that "there is a legal presumption of bad faith, when Respondent reasonably should have been aware of Complainant's trademarks, actually or constructively". Digi International Inc. v. DDI Systems FA 0124506 (Forum Oct. 24, 2002).

 

Complainant argues that actual knowledge of Complainant's rights prior to registering a domain name is adequate evidence of bad faith under the Policy.

 

Complainant adds that actual knowledge may be proved through the totality of the circumstances surrounding the registration of the disputed domain names and argues that the totality of the circumstances surrounding the use and registration of the disputed domain names in this proceeding undoubtedly demonstrate that Respondent had actual knowledge of Complainant and its marks.

 

Furthermore, Complainant argues Respondent's use of the confusingly similar domain names is an attempt to pass the disputed domain names off as being those of Complainant.

 

Complainant concludes Respondents' use of the disputed domain names to resolve to webpages that are currently inactive, inaccessible, and cannot be reached establishes bad faith use and registration.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

Complainant is a specialized staffing agency and carries on business using the service mark ROBERT HALF, and holds a portfolio of registered trademarks, for, and incorporating, the ROBERT HALF mark, including

·       United States registered trademark Robert Half, registration number 1,156,612, registered on the Principal Register on June 2, 1981, for services in International Class 35;

·       United States registered trademark RH ROBERT HALF and Design, registration number 4,482,350, registered on the Principal Register on Feb 11, 2014, for services in International Class 35;

·       United States registered trademark RH Robert Half Management Resources and Design, registration number 4527041, registered on the Principal Register on May 06, 2014, for services in International Class 35.

 

Complainant has an established Internet presence and has maintained its website at <www.roberthalf.com> since as early as 1995.

 

The disputed domain names were registered on April 23, 2026, none of which resolves to any active website.

 

There is no information available about Respondent except for that provided in the complaint as amended, the registrar's WHOIS, and the information provided by the registrar in response to the request by Forum for details of the registration of the disputed domain names for the purposes of this proceeding.

 

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 3.1 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 has provided convincing, uncontested evidence that it has rights in the ROBERT HALF mark, established by its ownership of the service mark registrations described above and extensive use of the mark in its business as a specialized staffing agency at more than 300 consulting and staffing locations throughout the world and employs over 10,000 employees.

 

The disputed domain names <networkroberthalf.com>, <globalroberthalf.com>, <onlineroberthalf.com>, <roberthalf-network.com>, <roberthalf-online.com>, <roberthalfteam.com> and <roberthalfjob.com>, each consists of Complainant's trademark in its entirety in combination with other descriptive or generic elements and hyphens, together with the generic Top-Level Domain ("gTLD") extension <.com>

 

It is well accepted that a complainant may succeed in the first element of the test in Policy ¶ 4(a)(i) where, as in this proceeding, the domain name at issue contains the mark relied upon by the complainant in its entirety.

 

The additional descriptive and generic elements and the hyphens do not contribute any distinguishing character to any of the disputed domain names.

 

Furthermore, it is well accepted that that gTLD extension <.com> may be ignored for the purposes of comparison because it would be considered to be a necessary technical requirement for a domain name registration.

 

Applying these principles this Panel finds that the disputed domain names, and each of them, are confusingly similar to the ROBERT HALF mark in which Complainant has rights and Complainant has therefore succeeded in the first element of the test in Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Complainant has made out a prima facie case that Respondent has no rights legitimate interests in the disputed domain names as set out in Complainant's detailed submissions above.

 

In particular, none of the disputed domain names resolves to any active website and the Panel has found that the circumstances of their registration indicate that they were all registered adopting Complainant's ROBERT HALF mark as their dominant characteristic and are in the control of a single entity.

 

It is well established that once a complainant makes out a prima facie case that a respondent has no rights or legitimate interests in the domain name at issue, the burden of production shifts to the respondent to prove its rights or legitimate interests.

 

Respondent has failed to discharge that burden and therefore this Panel must find that Respondent has no rights or legitimate interests in the disputed domain name.

 

Complainant has therefore succeeded in the second element of the test in Policy paragraph 4(a)(ii).

 

Registration and Use in Bad Faith

Complainant has adduced uncontested evidence that it owns and has used the ROBERT HALF mark continuously in its business as a specialized staffing agency since 1981 when its service mark was registered.

 

The disputed domain names were registered on April 23, 2026, long after Complainant began use of the mark and long after Complainant launched its website at <www.roberthalf.com> in 1995.

 

Each of the disputed domain names contains the ROBERT HALF mark as its dominant and only distinguishing character.

 

The evidence shows that each of the disputed domain names were registered on the same day in two batches using a different name for the registrant in each batch.

 

It must be more than coincidence that the pattern of registration of the disputed domain names all contained a reference to Complainant and its ROBERT HALF mark.

 

The Panel finds therefore that on the balance of probabilities the disputed domain names were chosen and registered to target and take predatory advantage of the Complainant's mark and its goodwill in the mark.

 

This Panel finds therefore the disputed domain names were registered in bad faith.

 

The uncontested evidence adduced by the Complainant further shows that none of the disputed domain names resolves to any active website, and there is no indication that they have been put to any active use.

 

The WIPO Overview 3.1 addresses passive holding of domain names at section 3.3 as follows:

"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."

 

In the present proceeding: (i) ROBERT HALF is a distinctive mark and Complainant has built its reputation since at least on June 2, 1981, when its service mark was first registered, (ii) the failure of Respondent has failed to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) by using two different names as the registrant of the disputed domain names Respondent took active steps to conceal its identity.

 

As this Panel has found that the disputed domain names were registered and are being used in bad faith, Complainant has therefore succeeded in the third element of the test in 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 <networkroberthalf.com>, <globalroberthalf.com>, <onlineroberthalf.com>, <roberthalf-network.com>, <roberthalf-online.com>, <roberthalfteam.com> and <roberthalfjob.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

 

James Bridgeman SC

Panelist

Dated: August 14, 2026