DECISION

 

Robert Half Inc. v. Victor Kellear / John Dow

Claim Number: FA2608002237005

 

PARTIES

Complainant is Robert Half Inc. ("Complainant"), represented by Emily Ostreich of Foley & Lardner LLP, New York, USA. Respondent is Victor Kellear / John Dow ("Respondent"), Serbia.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <roberthalfemployment.com>, <roberthalf-sourcing.com>, <roberthalfsourcing.com>, <roberthalfskillsearch.com>, <roberthalf-employment.com>, <roberthalfexperts.com>, <roberthalftalentmatch.com> and <roberthalfpros.com> (collectively, the "Disputed Domain Names"), registered with Ultahost, 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 on August 3, 2026; Forum received payment on August 3, 2026.

 

On August 4, 2026, Ultahost, Inc. confirmed by e-mail to Forum that the Disputed Domain Names are registered with Ultahost, Inc. and disclosed the underlying registrant of each name. The Registrar has verified that each registrant is bound by the Ultahost, 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"), that each of the Disputed Domain Names is on registrar lock for the pendency of this proceeding, that the language of the registration agreement is English, and that each of the eight registrations expires on July 1, 2027.

 

Following Forum's deficiency notification of August 6, 2026, Complainant submitted an Amended Complaint, dated August 7, 2026, naming as Respondent the two registrants the Registrar had disclosed and putting its case that the two are in fact a single domain-name holder. The Amended Complaint is the operative pleading in this proceeding.

 

On August 10, 2026, Forum served the Amended Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 31, 2026 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registrations as technical, administrative, and billing contacts, and to postmaster@roberthalfemployment.com, postmaster@roberthalf-sourcing.com, postmaster@roberthalfsourcing.com, postmaster@roberthalfskillsearch.com, postmaster@roberthalf-employment.com, postmaster@roberthalfexperts.com, postmaster@roberthalftalentmatch.com, and postmaster@roberthalfpros.com. Also on August 10, 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 registrations as technical, administrative and billing contacts.

 

Respondent did not submit a Response by the August 31, 2026 deadline. Having received no response from Respondent, Forum transmitted to the parties a Notification of Respondent Default.

 

On September 1, 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.

 

Preliminary Issue: Multiple Respondents

The Amended Complaint names as Respondent the two registrants the Registrar disclosed on August 4, 2026: Victor Kellear, of Jagodina, Serbia, the registrant of the <roberthalfemployment.com>, <roberthalf-sourcing.com>, <roberthalfsourcing.com> and <roberthalf-employment.com> domain names, and John Dow, also of Jagodina, Serbia, the registrant of the <roberthalfskillsearch.com>, <roberthalfexperts.com>, <roberthalftalentmatch.com> and <roberthalfpros.com> domain names. Complainant asks that the two be treated as a single Respondent, the additional payment prescribed by Forum Supplemental Rule 4(c) having been paid.

 

Paragraph 3(c) of the Rules provides that a "complaint may relate to more than one domain name, provided that the domain names are registered by the same domain-name holder," and Forum Supplemental Rule 4(c) permits a complainant to argue, on the basis of the registrant information disclosed by the registrar, that nominally separate registrants are in fact a single domain-name holder. Rule 10(e) leaves the consolidation of multiple domain name disputes to the Panel, in accordance with the Policy and the Rules.

 

The record supports the request. The WHOIS records in evidence show that all eight Disputed Domain Names were registered on one day, July 1, 2026, through one Registrar, and the Registrar's verification confirms that each of the eight registrations runs to the same date, July 1, 2027. All eight stood in the public records behind the same privacy service until the Registrar disclosed the registrants, and all eight are served by the same pair of name servers. The eight names follow a single formula: Complainant's ROBERT HALF mark, without the space between its words, followed by one term drawn from the vocabulary of Complainant's staffing business, "employment," "sourcing," "skillsearch," "experts," "talentmatch" or "pros," in two instances with a hyphen before it, under the ".com" gTLD. None of the eight resolves to an active website.

 

The registrant records themselves point the same way. Both give the same city, region and country, Jagodina, Pomoravski okrug, Serbia. Neither set of contact data is a reliable indication that two unconnected persons stand behind the registrations: the first gives a postal code of "00000" and pairs a Serbian address with a telephone number carrying the Swiss country code, and the second gives as the registrant's name "John Dow," the common English placeholder name "John Doe" with a single letter changed.

 

The Panel finds it more likely than not that the Disputed Domain Names are held by a single domain-name holder, or by persons acting in concert under common control. Consolidation is also fair and equitable: it avoids duplicative proceedings on identical facts and the risk of inconsistent outcomes, and takes from the named registrants, neither of whom has answered, nothing that either has claimed. The Panel accordingly proceeds against the domain-name holder as a single Respondent, referred to in this decision in the singular. See ELANCO ANIMAL HEALTH GMBH v. lu jian feng / ASHLEE BRYANN-MORGAN EVANS / ASHLEE EVANS AEA LLC, FA 2226855 (Forum July 15, 2026); see also Lucy in the Sky, Inc. v. LiuYueQiang / chen zi yang, FA 2230021 (Forum July 28, 2026).

 

RELIEF SOUGHT

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

 

PARTIES' CONTENTIONS

A. Complainant

Complainant alleges:

 

That it is one of the world's largest specialized employment staffing firms, founded in 1948, which provides skilled professionals in the fields of accounting and finance, technology, legal, creative, marketing and administration, has more than 300 consulting and staffing locations throughout the world, and employs over 10,000 people.

 

That it has used ROBERT HALF as a trademark continuously and exclusively since 1948, and RH and RHI since at least as early as 1994, and owns registrations for marks incorporating those terms around the world, among them U.S. Reg. No. 1,156,612 for ROBERT HALF, first used in 1948 and now incontestable, together with U.S. Reg. Nos. 2,147,434, 4,482,350, 4,508,151, 4,527,041 and 4,527,042 (collectively, the "ROBERT HALF Marks"), a number of which predate the Disputed Domain Names by more than a decade; and that it has owned and operated the domain name <roberthalf.com> since at least as early as 1995.

 

That the Disputed Domain Names, all registered on or about July 1, 2026, are under the common ownership or control of a single person or entity operating under the aliases "Victor Kellear" and "John Dow," the latter a misspelling of the placeholder name "John Doe," and that the mailing addresses given do not appear to be valid addresses in Serbia.

 

That the Disputed Domain Names are confusingly similar to the ROBERT HALF Marks and to Complainant's own domain name, each taking the whole of the ROBERT HALF house mark and adding only a descriptive or generic term, in two instances a hyphen, and the ".com" gTLD, none of which is sufficient to distinguish them.

 

That Respondent has no rights or legitimate interests in the Disputed Domain Names. Respondent is not commonly known by them or by any derivation of them; is neither a licensee nor an affiliate of Complainant and has never been authorized to use the ROBERT HALF Marks in any manner; and makes no bona fide, noncommercial or fair use of the names, which resolve to webpages that are inactive, inaccessible and cannot be reached.

 

That Respondent registered and is using the Disputed Domain Names in bad faith. Respondent has intentionally attempted to attract Internet users for commercial gain by creating a likelihood of confusion with the ROBERT HALF Marks, and has disrupted Complainant's business, under Policy ¶¶ 4(b)(iii) and (iv); the inactive holding of the names is itself evidence of bad faith; and Respondent had actual knowledge of Complainant and its rights when it registered the names, or was at the least on constructive notice of them by virtue of Complainant's United States registrations.

 

That the Disputed Domain Names should accordingly be transferred to Complainant.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

The Panel finds the following:

 

Complainant, Robert Half Inc., of Menlo Park, California, provides specialized professional employment staffing and consulting services. The Declaration of Bryan Chu, Complainant's Director of Brand, dated August 3, 2026 (the "Complainant's Declaration"), states that Complainant was founded in 1948, has more than 300 consulting and staffing locations worldwide and over 10,000 employees; that it has used the ROBERT HALF mark continuously and exclusively in connection with those services since 1948; that it has owned and operated the domain name <roberthalf.com> since at least as early as 1995; that over the three-year period ending in 2025 Complainant and its subsidiary Protiviti Inc. rendered services exceeding US$17.5 billion in revenues, many of them under the ROBERT HALF Marks; and that Complainant has been named to the Fortune "Most Admired Companies" list every year since 1998 and by Forbes as "America's Best Professional Recruiting Firm" from 2018 to 2026. That evidence is uncontested.

 

United States Patent and Trademark Office records in evidence show that Complainant owns U.S. Reg. No. 1,156,612 for the service mark ROBERT HALF (the "ROBERT HALF Mark"), registered on June 2, 1981 for employment agency services and now incontestable, and that it also owns U.S. Reg. No. 2,147,434 for an RHI design mark, registered March 31, 1998, and U.S. Reg. Nos. 4,482,350, 4,508,151, 4,527,041 and 4,527,042 for marks incorporating ROBERT HALF or RH, registered in 2014. On the evidence of that continuous use since 1948, a principal registration standing since 1981, revenues of the order stated, and sustained third-party recognition over more than two decades, the Panel finds that the ROBERT HALF Mark is widely known in the field of professional staffing and recruiting services.

 

The WHOIS records show that the Disputed Domain Names were registered on July 1, 2026. For the reasons given in the preliminary issue above, the Panel finds that the Disputed Domain Names are more likely than not held by a single domain-name holder.

 

Respondent is not commonly known by any of the Disputed Domain Names. The registrant names the Registrar disclosed, Victor Kellear and John Dow, bear no resemblance to them, and nothing in the record suggests that Respondent has ever been known by any of them or by any derivation of them. On the uncontested evidence of the Complainant's Declaration, Complainant has neither licensed Respondent nor otherwise permitted it to use the ROBERT HALF Marks, in a domain name or at all, and Respondent has no affiliation with Complainant.

 

Screenshots in the record, each taken on August 3, 2026, show that none of the eight Disputed Domain Names resolves to an active website: each returns a browser error reporting that the server IP address for the name could not be found. Nothing in the record shows any other use of any of the Disputed Domain Names.

 

Complainant alleges that the mailing addresses in the registrant records are not valid Serbian addresses. The Panel makes no finding as to whether either address exists. It does find, for the reasons given in the preliminary issue above, that the contact data Respondent gave the Registrar is unreliable.

 

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).

 

Identical and/or Confusingly Similar

Complainant has established rights in the ROBERT HALF Mark through its registration with the United States Patent and Trademark Office, Reg. No. 1,156,612, registered June 2, 1981. Registration of a mark with a national trademark authority is prima facie evidence of a complainant's rights in the mark for purposes of Policy ¶ 4(a)(i). See WIPO Overview 3.1 at ¶ 1.2.1.

 

Each of the Disputed Domain Names reproduces the ROBERT HALF Mark in its entirety, omitting only the space between its two words, which cannot be represented in a domain name, and adds a single descriptive term: "employment," "sourcing," "skillsearch," "experts," "talentmatch" or "pros." Every one of those terms describes the very services Complainant renders under the Mark, so that each Disputed Domain Name reads as an address of Complainant's staffing business. The Mark remains clearly recognizable in each name, and the addition of such a term does not prevent a finding of confusing similarity. See WIPO Overview 3.1 at ¶ 1.8. The hyphen appearing in the <roberthalf-sourcing.com> and <roberthalf-employment.com> domain names is a punctuation mark of no distinguishing significance. The ".com" gTLD is a technical requirement of registration and is disregarded in the comparison. See WIPO Overview 3.1 at ¶ 1.11.1.

 

The Panel finds that each of the Disputed Domain Names is confusingly similar to Complainant's ROBERT HALF 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 Names, at which point the burden shifts to Respondent to show that it does have rights or legitimate interests. See WIPO Overview 3.1 at ¶ 2.1.

 

As found above, Respondent is not commonly known by any of the Disputed Domain Names within Policy ¶ 4(c)(ii), and Complainant has not licensed or otherwise authorized Respondent to use the ROBERT HALF Marks. See Charter Commc'ns Holding Co., LLC v. Jason Malone / Corporate Servs. Direct, FA 1813790 (Forum Dec. 6, 2018).

 

Nor is there any use of the Disputed Domain Names capable of giving rise to rights or legitimate interests. As found above, none of the eight resolves to an active website and the record discloses no other use of them. Holding a domain name that is confusingly similar to another's mark without putting it to any use is neither a bona fide offering of goods or services under Policy ¶ 4(c)(i) nor a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii). See Michelin North America, Inc. v. Ed Brewmaker, FA 1475767 (Forum Jan. 30, 2013); see also Robert Half International Inc. v. Erika Slade, FA 1773441 (Forum Mar. 29, 2018) (holding that the inactively held <roberthalf-us.com> supported neither a bona fide offering nor a legitimate noncommercial or fair use under Policy ¶¶ 4(c)(i) and (iii)).

 

Complainant having made its prima facie showing, and Respondent having come forward with nothing to rebut it, the Panel finds that Respondent has no rights or legitimate interests in respect of the Disputed Domain Names under Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

Respondent registered the Disputed Domain Names on July 1, 2026, forty-five years after the ROBERT HALF Mark was registered and long after it had become widely known in professional staffing and recruiting. Respondent took the whole of the Mark into eight domain names on a single day, pairing it in each case with a term describing Complainant's own services. The Panel finds that Respondent had actual knowledge of Complainant's rights in the ROBERT HALF Mark when it registered the Disputed Domain Names, and that it registered them in order to target that Mark. See WIPO Overview 3.1 at ¶ 3.1.4.

 

Complainant asks the Panel to find that Respondent intentionally attempted to attract Internet users for commercial gain by creating a likelihood of confusion with the ROBERT HALF Marks under Policy ¶ 4(b)(iv), and that it disrupted Complainant's business under Policy ¶ 4(b)(iii). Neither circumstance is made out here: no website, no e-mail, and no other use of any of the Disputed Domain Names is in evidence, and Respondent is not shown to be a competitor of Complainant. The Panel declines those findings. The circumstances listed in Policy ¶ 4(b) are not exhaustive, and bad faith is established on other grounds.

 

Respondent has held all eight Disputed Domain Names without making any active use of them. Passive holding does not prevent a finding of bad faith use where the surrounding circumstances point to it. See WIPO Overview 3.1 at ¶ 3.3. Those circumstances are present here: the ROBERT HALF Mark is widely known in the field the eight names evoke; Respondent concealed its identity behind a privacy service and, when that was lifted, gave unreliable contact data; Respondent has not answered the Complaint; and no use this Respondent might make of a domain name pairing Complainant's Mark with a description of Complainant's own services would avoid misleading Internet users as to a connection with Complainant. The failure to make any active use of the Disputed Domain Names accordingly evidences bad faith registration and use. See Morgan Stanley v. Dari Darling, FA 1965150 (Forum Oct. 27, 2021); see also Regions Bank v. Darla atkins, FA 1786409 (Forum June 20, 2018).

 

Respondent registered eight domain names incorporating the ROBERT HALF Mark on one day, under two registrant identities, taking for itself eight of the addresses at which Complainant's clients and candidates might expect to find it. That is a pattern of registering domain names in order to prevent the owner of a mark from reflecting the mark in corresponding domain names, evidencing bad faith under Policy ¶ 4(b)(ii). The Panel rests that finding on the eight Disputed Domain Names alone.

 

Complainant relies in the alternative on constructive notice arising from its United States registrations. Actual knowledge having been established, the Panel rests its finding there and makes no finding on constructive notice.

 

The Panel finds that Respondent registered and is using the Disputed Domain Names 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 <roberthalfemployment.com>, <roberthalf-sourcing.com>, <roberthalfsourcing.com>, <roberthalfskillsearch.com>, <roberthalf-employment.com>, <roberthalfexperts.com>, <roberthalftalentmatch.com> and <roberthalfpros.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

 

David L. Kreider, Panelist

Dated: September 1, 2026