Under paragraph 4(a) of the Policy, the Complainant must prove that each of the following three elements is present:
(i) the disputed domain name is identical or confusingly similar to the Complainant's trademark; and
(ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and
(iii) the disputed domain name has been registered and is being used in bad faith.
1. The Panel accepts that the disputed domain name is confusingly similar to the STAR STABLE marks as it fully incorporates such trademarks despite the addition of the descriptive term “hack”, which clearly refers to a "hacking tool" generated for the game offered by the Respondent. See Star Stable Entertainment AB v. WhoisGuard Protected / WhoisGuard, Inc. / Victor Arreaga, WIPO Case No. D2015-2312 (<starstablehack.club> et al.).
Furthermore, the addition of the generic Top-Level Domain (gTLD) “.club”, does not add any distinctiveness to the disputed domain name. See Sanofi v. Agim Allaraj, WIPO Case No. D2019-1848 (<sanofi-aventis.club>).
2. The Complainant has substantiated that the Respondent has no rights or legitimate interests in the disputed domain name. The Panel finds that the Complainant has fulfilled its obligations under paragraph 4(a)(ii) of the Policy. The Respondent did not deny these assertions in any way and therefore failed to prove any rights or legitimate interests in the disputed domain name.
Based on the evidence, the Panel also finds that the Respondent lacks rights or legitimate interests.
The Respondent's website is using the Complainant's logo and even refers to the Complainant's core website available at www.starstable.com. Further, the Respondent is using the disputed domain name to redirect to a website titled: “Star Stable Hack Star Coin Generator”. Star Stable players are invited to use the Respondent’s software to hack and circumvent the game by using a hack tool. By submitting their personal Star Stable login information on the website, players can, for instance, obtain unlimited Star Coins, that would otherwise have to be bought through Complainant’s official game. Such use is not bona fide under the Policy. See Star Stable Entertainment AB v. Domain Administrator, See PrivacyGuardian.org / Lili Cai, WIPO Case No. D2018-0260 (<starstablehacksz.com>): "The site also encouraged users to provide personal information to the Respondent, akin to a phishing scheme. Such a scheme cannot be considered a bona fide offering of goods or services or a legitimate noncommercial or fair use of the Disputed Domain Name. See CMA CGM v. Diana Smith, WIPO Case No. D2015-1774."
3.1 The Panel is satisfied that the Respondent registered the disputed domain name with full knowledge of the Complainant and its rights in the STAR STABLE Marks as such trademark is highly distinctive and as the Respondent offers services related to the Complainant's software.
3.2 As to bad faith use, the Respondent’s scheme to create a hacking website that encouraged users to provide personal information to the Respondent evidences a clear intent to disrupt the Complainant’s business, deceive its users, and trade off the Complainant’s goodwill by creating an unauthorized association between the Respondent and the Complainant’s STAR STABLE Mark. Herefore, the Respondent was, in all likelihood, trying to divert traffic intended for the Complainant’s website to its own for commercial gain as set out under paragraph 4(b)(iv) of the Policy.
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