Halliburton Energy Services, Inc. v Alejandro Alberto Ruiz Morillo

WIPO Case No. D2025-2226

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Halliburton Energy Services, Inc. v. Alejandro Alberto Ruiz Morillo

Case No. D2025-2226

1. The Parties

The Complainant is Halliburton Energy Services, Inc., United States of America (“United States” or “US”), represented by Polsinelli P.C., United States.

The Respondent is Alejandro Alberto Ruiz Morillo, Mexico.

2. The Domain Name and Registrar

The disputed domain name <halliburtonmexico.com> is registered with IONOS SE (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 6, 2025. On June 12, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 12, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 16, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amendment to the Complaint on June 16, 2025.

The Center verified that the Complaint together with the amendment to 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”).

In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on June 17, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 7, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 9, 2025.

The Center appointed Federica Togo as the sole panelist in this matter on July 15, 2025. 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.

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4. Factual Background

It results from the Complainant’s undisputed allegations that it is a wholly owned subsidiary of the Halliburton than 40,000 employees and operations in approximately 70 countries, it serves the upstream oil and gas industry throughout the lifecycle of the reservoir as well as optimizing production through the life of the field. Halliburton is a leader in the global energy industry. It operates its official website at “

The Complainant is the registered owner of many trademarks for HALLIBURTON, e.g., US trademark registration No. 2,575,819, registered on June 4, 2002 for services in classes 37, 40 and 42.

The disputed domain name was registered on June 4, 2025. Furthermore, the undisputed evidence provided by the Complainant proves that the disputed domain name resolves to a website displaying in a prominent way the Complainant’s HALLIBURTON mark.

5. Parties’ Contentions

A. Complainant

The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name.

Notably, the Complainant contends that the disputed domain name <halliburtonmexico.com>, is confusingly similar to its well-known trademark HALLIBURTON, having merely added a country name (Mexico) to the end of distinctive HALLIBURTON mark.

The Complainant contends that its trademark HALLIBURTON is distinctive.

The Complainant further contends that the Respondent has no rights or legitimate interests in the disputed domain name. According to the Complainant, the Respondent is not affiliated with Halliburton, licensed to use the Complainant’s HALLIBURTON mark, or licensed to register or use domain names, or associated

email accounts, incorporating the HALLIBURTON mark. By registering a domain name confusingly similar to domain name for the sole purpose of exploiting the Complainant’s rights, title, interest and goodwill in the HALLIBURTON mark. Specifically, the disputed domain name resolves to a website that holds itself out to be tied with the Complainant, even using the Complainant’s trademarks.

Finally, the Complainant contends that the disputed domain name was registered and was being used in bad faith. According to the Complainant, its trademark is well-known. It is clear from the relevant circumstances that the Respondent was well aware of the Complainant and had the Complainant’s HALLIBURTON mark

firmly in mind when registering the disputed domain name. The disputed domain name is identical to the identity of the actual underlying registrant is an indication of bad faith.

Complainant’s distinctive HALLIBURTON trademark with only the addition of the country “Mexico”.

B. Respondent

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

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6. Discussion and Findings

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 a complainant to prove each of the following three elements in order to obtain an order that the domain name be transferred or cancelled:

(i)        the domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights; and

(ii)       the respondent has no rights or legitimate interests in respect of the domain name; and

(iii)      the domain name has been registered and is being used in bad faith.

The Panel will therefore proceed to analyze whether the three elements of paragraph 4(a) of the Policy are satisfied.

A. Identical or Confusingly Similar

It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.7.

The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy.
WIPO Overview 3.0, section 1.2.1.

The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7.

Although the addition of other terms, here “mexico”, may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8.

The Panel finds the first element of the Policy has been established.

B. Rights or Legitimate Interests

Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name.

Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1.

Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise.

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Moreover, the Panel notes that the disputed domain name contains the Complainant’s registered trademark entirely and the geographic term “mexico”. The nature of this disputed domain name carries a risk of implied affiliation: in fact, geographic terms are seen as tending to suggest sponsorship or endorsement by the

trademark owner, see WIPO Overview 3.0 at section 2.5.1.

The Panel finds the second element of the Policy has been established.

C. Registered and Used in Bad Faith

The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith.

One of these circumstances is that the Respondent by using the disputed domain name, has intentionally attempted to attract, for commercial gain, Internet users to its website or other online location, by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of its website or location or of a product or service on its website or location (paragraph 4(b)(iv) of the Policy).

In the present case, the Panel notes that it results from the Complainant’s documented allegations that the disputed domain name resolves to a website displaying without authorization the Complainant’s registered trademark and logo.

By the time the disputed domain name was registered, the Panel considers it to be unlikely that the Respondent did not have knowledge of the Complainant and its mark (entirely included in the disputed domain name), which has been existing by many years at the time the disputed domain name was registered. Consequently, and in the absence of any evidence to the contrary, the Panel is convinced that the Respondent also knew that the disputed domain name included the Complainant’s trademark when it registered the disputed domain name.

Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1.

In this regard, the further circumstances surrounding the disputed domain name’s registration and use confirm the Panel’s findings that the Respondent has registered and is using the disputed domain name in bad faith:

(i) the nature of the disputed domain name (wholly incorporating the Complainant’s mark followed by the

geographical term “mexico”);

(ii) the content of the website to which the disputed domain name resolved (i.e. displaying without

authorization the Complainant’s registered trademark and logo);

(iii) a clear absence of rights or legitimate interests coupled with no response for the Respondent’s choice of

the disputed domain name;

(iv) the Respondent concealing its identity through a privacy service.

The Panel finds that the Complainant has established the third element of the Policy.

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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 <halliburtonmexico.com> be transferred to the Complainant.

/Federica Togo/
Federica Togo
Sole Panelist
Date: July 29, 2025