WIPO Arbitration and Mediation Center ADMINISTRATIVE PANEL DECISION Universal Services of America, LP d/b/a Allied Universal v. Cybernet Systech Private Limited Case No. D2018-1544 1. The Parties

The Complainant is Universal Services of America, LP d/b/a Allied Universal of Santa Ana, California, United States of America (“United States”), represented by Cozen O’Connor, United States.

The Respondent is Cybernet Systech Private Limited of Mumbai, India. 2. The Domain Name and Registrar

The disputed domain name (the “Domain Name”) is registered with PDR Ltd. d/b/a PublicDomainR (the “Registrar”). 3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 10, 2018. On July 11, 2018, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On July 12, 2018, 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”).

In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on July 19, 2018. In accordance with the Rules, paragraph 5, the due date for Response was August 8, 2018. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 13, 2018.

The Center appointed Nicholas Smith as the sole panelist in this matter on August 17, 2018. 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, which trades under the name “Allied Universal” is a security services company that trades in North America, with over 150,000 employees. The Complainant maintains a website, located at “”, “aus” being an abbreviation of “Allied Universal Services”.

The Complainant holds a registered trademark in the United States for the word mark ALLIED UNIVERSAL (“ALLIED Mark”), which was filed on May 6, 2016 and registered on February 7, 2017. The ALLIED Mark is registered for various services in classes 31, 41, 42, and 45 that relate to the Complainant’s security services.

The Domain Name was registered by the Respondent on February 26, 2018. It redirects to a website (the “Respondent’s Website”) that contains what are described as Sponsored Listings (also known as pay-per-click links) purporting to relate to security services and potentially the Complainant itself (“Allied Security” and “Allied Security Jobs”). 5. Parties’ Contentions A. Complainant

The Complainant makes the following contentions:

(i) that the Domain Name is identical or confusingly similar to the Complainant’s ALLIED Mark,

(ii) that the Respondent has no rights or legitimate interests in respect of the Domain Name, and

(iii) that the Domain Name has been registered and is being used in bad faith.

The Complainant is the owner of the ALLIED Mark, having registered the ALLIED Mark in the United States. The Domain Name is confusingly similar to the ALLIED Mark, containing the ALLIED Mark in its entirety and the abbreviation “aus”, which is used by the Complainant as its website (“”) and as an abbreviation of its name.

There are no rights or legitimate interests held by the Respondent in respect of the Domain Name. The Respondent is not commonly known as the Domain Name nor has the Complainant provided a licence or authorization to register the Domain Name or any domain name incorporating the ALLIED Mark. There is no evidence, since the Respondent registered the Domain Name, of the Respondent’s use of, or demonstrable preparations to use the Domain Name or a name corresponding to the Domain Name in connection with a bona fide offering of goods or services or for a legitimate noncommercial purpose. The Domain Name resolves to a link farm: a page with links to businesses that will cause confusion for the Complainant’s customers. This does not provide the Respondent with rights or legitimate interests.

The Domain Name was registered and is being used in bad faith. Given the use of the Respondent’s Website to provide links to services identical to those offered by the Complainant, Respondent had knowledge of the ALLIED Mark at the time of registration. Such