About Intellectual Property IP Training IP Outreach IP for… IP and... IP in... Patent & Technology Information Trademark Information Industrial Design Information Geographical Indication Information Plant Variety Information (UPOV) IP Laws, Treaties & Judgements IP Resources IP Reports Patent Protection Trademark Protection Industrial Design Protection Geographical Indication Protection Plant Variety Protection (UPOV) IP Dispute Resolution IP Office Business Solutions Paying for IP Services Negotiation & Decision-Making Development Cooperation Innovation Support Public-Private Partnerships The Organization Working with WIPO Accountability Patents Trademarks Industrial Designs Geographical Indications Copyright Trade Secrets WIPO Academy Workshops & Seminars World IP Day WIPO Magazine Raising Awareness Case Studies & Success Stories IP News WIPO Awards Business Universities Indigenous Peoples Judiciaries Genetic Resources, Traditional Knowledge and Traditional Cultural Expressions Economics Gender Equality Global Health Climate Change Competition Policy Sustainable Development Goals Enforcement Frontier Technologies Mobile Applications Sports Tourism PATENTSCOPE Patent Analytics International Patent Classification ARDI – Research for Innovation ASPI – Specialized Patent Information Global Brand Database Madrid Monitor Article 6ter Express Database Nice Classification Vienna Classification Global Design Database International Designs Bulletin Hague Express Database Locarno Classification Lisbon Express Database Global Brand Database for GIs PLUTO Plant Variety Database GENIE Database WIPO-Administered Treaties WIPO Lex - IP Laws, Treaties & Judgments WIPO Standards IP Statistics WIPO Pearl (Terminology) WIPO Publications Country IP Profiles WIPO Knowledge Center WIPO Technology Trends Global Innovation Index World Intellectual Property Report PCT – The International Patent System ePCT Budapest – The International Microorganism Deposit System Madrid – The International Trademark System eMadrid Article 6ter (armorial bearings, flags, state emblems) Hague – The International Design System eHague Lisbon – The International System of Appellations of Origin and Geographical Indications eLisbon UPOV PRISMA Mediation Arbitration Expert Determination Domain Name Disputes Centralized Access to Search and Examination (CASE) Digital Access Service (DAS) WIPO Pay Current Account at WIPO WIPO Assemblies Standing Committees Calendar of Meetings WIPO Official Documents Development Agenda Technical Assistance IP Training Institutions COVID-19 Support National IP Strategies Policy & Legislative Advice Cooperation Hub Technology and Innovation Support Centers (TISC) Technology Transfer Inventor Assistance Program WIPO GREEN WIPO's Pat-INFORMED Accessible Books Consortium WIPO for Creators WIPO ALERT Member States Observers Director General Activities by Unit External Offices Job Vacancies Procurement Results & Budget Financial Reporting Oversight

WIPO Arbitration and Mediation Center

ADMINISTRATIVE PANEL DECISION

Hartford Fire Insurance Company v. Vicky Laster, Domain Mgr Trs Service

Case No. D2014-1848

1. The Parties

The Complainant is Hartford Fire Insurance Company of Hartford, Connecticut, United States of America (“USA”), represented by Fross Zelnick Lehrman & Zissu, PC, USA.

The Respondent is Vicky Laster, Domain Mgr Trs Service of Elizabeth, New Jersey, USA.

2. The Domain Name and Registrar

The disputed domain name <tehhartford.com> is registered with Dynadot, LLC (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 21, 2014. On October 22, 2014, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 24, 2014, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details.

The Center verified that the Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”).

The Center received Complainant’s Supplemental Filing on November 4, 2014. Additionally on November 4, 2014, the Complainant confirmed that the Complainant had renewed the registration of the disputed domain name, which was about to expire.

In accordance with the Rules, paragraphs 2(a) and 4(a), the Center formally notified the Respondent of the Complaint, and the proceedings commenced on October 24, 2014. In accordance with the Rules, paragraph 5(a), the due date for Response was November 13, 2014. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on November 14, 2014.

The Center appointed William F Hamilton as the sole panelist in this matter on November 26, 2014. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7.

4. Factual Background

The Complainant is a well-known United States insurance and financial services company that was founded in 1810. The Complainant owns two THE HARTFORD marks (collectively, the “Marks”) that were registered, respectively, in 1971 (insurance services) and in 1991 (information and services via the Internet). The Complainant has conducted extensive business operations under the Marks having spent millions of dollars annually promoting its services through placement of the Marks in a broad variety of media.

The disputed domain name was registered on October 26, 2012.

5. Parties’ Contentions

A. Complainant

The Complainant contends that the disputed domain name is confusingly similar to its Marks and that the disputed domain name is a “classic” example of “typosquatting” because the disputed domain name is identical to the Marks except that the letters “h” and “e” are transposed. The Complainant also contends that the Respondent has no rights or legitimate interests in the Marks or the disputed domain name because the Complainant never authorized the Respondent to use the Marks or disputed domain name and because the Respondent has no bona fide business activity associated with the disputed domain name. Finally, the Complainant asserts that the disputed domain name was registered and is being used in bad faith to misdirect and confuse Internet users.

B. Respondent

The Respondent did not reply to the Complainant’s contentions.

6. Discussion and Findings

A. Identical or Confusingly Similar

The Panel finds that the disputed domain name is confusingly similar to the Complainant’s Marks. The disputed domain name would be identical to the Marks, but for the transposition of the letters “h” and “e”. Edmunds.com, Inc. v. Triple E Holding Ltd., WIPO Case No. D2006-1095.

B. Rights or Legitimate Interests

The Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant has specifically stated that the Respondent was never authorized to use the disputed domain name or the Marks, and the Respondent has no apparent bona fide business associated with the disputed domain name. Moreover, the Respondent has failed to respond to the Complaint and present evidence of any bona fide business. Tumblr, Inc. v. Above.com Domain Privacy/Transure Enterprise, Ltd., Host Master, WIPO Case No. D2013-0213.

C. Registered and Used in Bad Faith

The Panel finds that the disputed domain name was registered and is being used in bad faith. The Respondent’s tactic is apparent: to lure to its commercial website unsuspecting customers who make an unnoticed, simple error when typing the Marks into their browser. The Respondent has employed this tactic in the past and been the subject of an adverse UDRP decision. Disney Enterprises, Inc. v. Domain Mgr Trs Service c/o Vicky Laster, NAF Claim Number FA0911001292653; see also The Cartoon Network, Inc. v. Vicky Laster, WIPO Case No. DMX 2012-0010. The Respondent’s bad faith is further highlighted by the Respondent’s initial offer to sell the disputed domain name to the Complainant for $750. The offering price was increased to $1,500 when the Respondent learned that the Complainant was required to renew the registration of the disputed domain name while this proceeding was pending.

7. Decision

For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <tehhartford.com> be transferred to the Complainant.

William F Hamilton
Sole Panelist
Date: December 10, 2014