Reddit, Inc. v asderg

WIPO Case No. D2023-3875

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Reddit, Inc. v. asderg

Case No. D2023-3875

1. The Parties

The Complainant is Reddit, Inc., United States of America (“United States”), internally represented.

The Respondent is asderg, United States.

2. The Domain Name and Registrar

The Disputed Domain Name <reddit-sso.com> is registered with NameSilo, LLC (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 15,

2023. On September 18, 2023, the Center transmitted by email to the Registrar a request for registrar
verification in connection with the Disputed Domain Name. On September 18, 2023, 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 (Unnamed) and contact information
in the Complaint. The Center sent an email communication to the Complainant on September 20, 2023,
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

September 20, 2023.

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 September 22, 2023. In accordance with the Rules, paragraph 5, the due date for Response was October 12, 2023. The Respondent did not submit any

response. Accordingly, the Center notified the Respondent’s default on October 16, 2023.

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The Center appointed Colin T. O'Brien as the sole panelist in this matter on October 24, 2023. 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 an online social platform where over 57 million daily active unique visitors engage with
more than 100.000 active communities. The Complainant owns and operates the domain name

<reddit.com> in addition to dozens of other REDDIT domain names throughout the world, including many

domain names for “reddit” in various country-code top-level domains. The Complainant is the owner of the

registered trademarks and service marks REDDIT and REDDIT & Design, among others (collectively, the

“REDDIT Marks”). The Complainant has used the REDDIT Marks since its launch in 2005, in connection

with a variety of goods and services.

According to the Semrush website traffic checker, <reddit.com> is the seventh most visited website globally as of June, 2023.

The Complainant’s registered trademarks and/or service marks relating to the REDDIT Marks in the United

States and the European Union include but are not limited to the following:

-REDDIT, Reg. No. 5019343, United States, registered on August 9, 2016, in Class 9,

-REDDIT, Reg. No. 5053433, United States, registered on October 4, 2016, in Class 38,

-REDDIT, Reg. No. 3786519, United States, registered on May 11, 2010, in Class 41,

-REDDIT, Reg. No. 5103419, United States, registered on December 20, 2016, in Class 42,

-REDDIT, Reg. No. 5008166, United States, registered on July 26, 2016, in Class 45,

- Reg. No. 3474493, United States, registered on July 29, 2008, in Class 41,

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The Disputed Domain Name incorporates the Complainant’s distinctive trademark REDDIT in its entirety and adds the descriptive acronym “sso”, i.e., “single sign-on”. The Complainant’s registered trademark REDDIT

is the dominant portion of the domain name. The addition of the word “sso” does nothing to minimize the risk

of confusion but serves the nefarious purposes of the Respondent, namely, conducting a cyberattack

whereby the Respondent mimics Complainant’s SSO page to trick the Complainant’s employees into

thinking they have landed onto the Complainant’s legitimate SSO page.

The Respondent has no rights or legitimate interests in respect of the Disputed Domain Name. The

Respondent’s bad faith is evidenced by the fact that the Respondent used the Disputed Domain Name to

conduct a cyberattack against the Complainant, namely gain unauthorized employee account access for the

purpose of phishing confidential company information.

B. Respondent

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

6. Discussion and Findings

A. Identical or Confusingly Similar

The Complainant has demonstrated it owns registered trademark rights in the REDDIT mark. The addition of

“-sso” does not prevent the Complainant’s trademark from being recognizable in the Disputed Domain Name.

The generic Top-Level Domain (“gTLD”) “.com” is viewed as a standard registration requirement and as such

is typically disregarded under the first element confusing similarity test. Accordingly, the Disputed Domain

Name is confusingly similar to a mark in which the Complainant has rights.

See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition

(“WIPO Overview 3.0”), sections 1.8 and 1.11.1, and F. Hoffmann-La Roche AG v. Domain Admin, Privacy

Protection Service INC d/b/a PrivacyProtect.org / Conan Corrigan, WIPO Case No. D2015-2316.

Accordingly, the Disputed Domain Name is confusingly similar to a mark in which the Complainant has rights.

B. Rights or Legitimate Interests

The Complainant has presented a prima facie case that the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name and has not been commonly known by the Disputed Domain Name. The fact that the Respondent obtained the Disputed Domain Name years after the Complainant had begun

using its REDDIT mark indicates that the Respondent sought to piggyback on the mark for illegitimate
reasons.

After a complainant has made a prima facie case, the burden of production shifts to a respondent to present evidence demonstrating rights or legitimate interests in the domain name. See, e.g., Croatia Airlines d.d. v. Modern Empire Internet Ltd., WIPO Case No. D2003-0455.

The Respondent has provided no evidence of any rights or legitimate interests in the Disputed Domain

Name. Moreover, the Disputed Domain Name incorporates the Complainant’s trademark in its entirety along with the “-sso”, potentially conveying to unsuspecting Internet users the false belief that any email connected

to the Disputed Domain Name is associated with the Complainant. Such a risk of affiliation or association

with the Complainant and its mark cannot constitute fair use.

In the absence of any evidence rebutting the Complainant’s prima facie case indicating the Respondent’s

lack of rights or legitimate interests in respect of the Disputed Domain Name, the Panel finds that the
Complainant has satisfied paragraph 4(a)(ii) of the Policy.

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C. Registered and Used in Bad Faith

The Disputed Domain Name was registered years after the Complainant first registered and used its sufficient to satisfy the Panel that, at the time the Disputed Domain Name was registered, the Respondent

REDDIT marks. The evidence provided by the Complainant with respect to the extent of use and fame of its

undoubtedly knew of the Complainant’s widely-known REDDIT marks, and knew it had no rights or legitimate

interests in the Disputed Domain Name.

Moreover, UDRP panels have consistently found that the mere registration of a domain name that is confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. See section 3.1.4 of the WIPO Overview 3.0.

There is prima facie no reason for the Respondent to have registered the Disputed Domain Name containing the entirety of the REDDIT trademark. While the Disputed Domain Name does not currently resolve to an active website there is ample evidence of bad faith use on the part of the Respondent specifically using it to engage in a sophisticated phishing attack on the secure potentially sensitive information from the

Complainant’s employees and customers. UDRP panels have found that the use of a domain name for

purposes other than to host a website may constitute bad faith. Such purposes include sending email,

phishing, identity theft, or malware distribution. See section 3.4 of the WIPO Overview 3.0.

Accordingly, the Panel finds that the Complainant has satisfied paragraph 4(a)(iii) of the Policy.

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 <reddit-sso.com> be transferred to the Complainant.

/Colin T. O'Brien/

Colin T. O'Brien

Sole Panelist
Date: November 7, 2023

-REDDIT, Reg. No. 1348086, European Union, registered on June 14, 2016, in Class 9,

-REDDIT, Reg. No. 9386111, European Union, registered on November 30, 2012, in Classes 38, 41,

42, and 45.

The Disputed Domain Name was created on February 5, 2023, and it resolved to a website stating “Sign in with your Reddit, Inc. account to access Okta Dashboard” along with a login screen that asked the users for

username and password.

5. Parties’ Contentions

A. Complainant

The Complainant has spent a substantial amount of time, money, and resources to promote, advertise, and protect the REDDIT Marks in connection with its on-going business activities and services throughout the world.

The Respondent used the Disputed Domain Name to conduct a cyberattack against the Complainant, which involved unauthorized account access/hacking, impersonation, and phishing.