America Online, Inc. v. World Photo Video
& Imaging Corp.
Claim Number: FA0204000109031
PARTIES
Complainant
is America Online, Inc., Dulles, VA
(“Complainant”) represented by James R.
Davis, of Arent Fox Kintner Plotkin
& Kahn. Respondent is World Photo Video & Imaging Corp.,
Brooklyn, NY (“Respondent”).
REGISTRAR AND DISPUTED DOMAIN NAMES
The
domain names at issue are <aolcamera.com>
and <aolcameras.com>, registered with Register.com.
PANEL
The
undersigned certifies that he has acted independently and impartially and, to
the best of his knowledge, has no known conflict in serving as Panelist in this
proceeding.
The
Honorable Charles K. McCotter, Jr. (Ret.) as Panelist.
PROCEDURAL HISTORY
Complainant
submitted a Complaint to the National Arbitration Forum (the “Forum”)
electronically on April 2, 2002; the Forum received a hard copy of the
Complaint on April 4, 2002.
On
April 5, 2002, Register.com confirmed by e-mail to the Forum that the domain
names <aolcamera.com> and <aolcameras.com> are registered with Register.com and that
Respondent is the current registrant of the names. Register.com has verified that Respondent is bound by the Register.com
registration agreement and has thereby agreed to resolve domain-name disputes
brought by third parties in accordance with ICANN’s Uniform Domain Name Dispute
Resolution Policy (the “Policy”).
On
April 5, 2002, a Notification of Complaint and Commencement of Administrative
Proceeding (the “Commencement Notification”), setting a deadline of April 25,
2002 by which Respondent could file a Response to the Complaint, was
transmitted to Respondent via e-mail, post and fax, to all entities and persons
listed on Respondent’s registration as technical, administrative and billing
contacts, and to postmaster@aolcamera.com, and postmaster@aolcameras.com by
e-mail.
Having
received no Response from Respondent, using the same contact details and
methods as were used for the Commencement Notification, the Forum transmitted
to the parties a Notification of Respondent Default.
On
May 7, 2002, pursuant to Complainant’s request to have the dispute decided by a
single-member Panel, the Forum appointed the Honorable Charles K. McCotter, Jr.
(Ret.) as Panelist.
Having
reviewed the communications records, the Administrative Panel (the “Panel”)
finds that the Forum has discharged its responsibility under Paragraph 2(a) of
the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”) “to
employ reasonably available means calculated to achieve actual notice to
Respondent.” Therefore, the Panel may
issue its decision based on the documents submitted and in accordance with the
ICANN Policy, ICANN Rules, the Forum’s Supplemental Rules and any rules and
principles of law that the Panel deems applicable, without the benefit of any
Response from Respondent.
RELIEF SOUGHT
Complainant
requests that the domain names be transferred from Respondent to Complainant.
PARTIES’ CONTENTIONS
A.
Complainant
The
<aolcamera.com> and <aolcameras.com> domain names are
confusingly similar to Complainant's AOL mark.
Respondent
has no rights or legitimate interests in the disputed domain names.
Respondent
registered and used the disputed domain names in bad faith.
B.
Respondent
No
Response was received.
FINDINGS
Complainant is the owner of numerous AOL
trademark registrations worldwide, including U.S. trademark Registration
Numbers 1,977,731 and 1,984,337 registered on June 4, 1996 and July 2, 1996
respectively. Complainant uses its
marks in connection with computer services including leasing access time to
computer databases, computer bulletin boards, computer networks and
computerized research and reference materials.
Complainant’s domain name is
<aol.com> and it also has registered the AOL.COM mark in the U.S. as
Registration Numbers 2,325,291 and 2,325,292.
The mark is used extensively on Complainant’s website and to promote
Complainant’s Internet services.
Respondent registered the disputed domain
names on November 29, 1999. Respondent
offered to sell the disputed domain names to Complainant for between $5,000 and
$8,000. Complainant is using the domain names to sell products under the name
“Sunset Camera.” There is no reference
to “AOLCamera(s)” on the website.
DISCUSSION
Paragraph 15(a) of the Rules instructs this Panel to
“decide a complaint on the basis of the statements and documents submitted in
accordance with the Policy, these Rules and any rules and principles of law
that it deems applicable.”
In view
of Respondent's failure to submit a Response, the Panel shall decide this
administrative proceeding on the basis of the Complainant's undisputed
representations pursuant to paragraphs 5(e), 14(a) and 15(a) of the Rules and
draw such inferences it considers appropriate pursuant to paragraph 14(b) of
the Rules.
Paragraph
4(a) of the Policy requires that the Complainant must prove each of the
following three elements to obtain an order that a domain name should be
cancelled or transferred:
(1)
the domain name registered by the Respondent is identical or confusingly similar
to a trademark or service mark in which the Complainant has rights; and
(2)
the Respondent has no rights or legitimate interests in respect of the domain
name; and
(3)
the domain name has been registered and is being used in bad faith.
Identical and/or Confusingly Similar
Complainant has established that it has
rights to the AOL mark through registration and continuous use. Respondent’s domain names are confusingly
similar to Complainant’s mark because they incorporate the entirety of
Complainant’s AOL mark and merely add the generic terms “camera” and
“cameras.” The addition of a generic
term does not create a distinct mark capable of overcoming a claim of confusing
similarity. See Arthur Guinness Son & Co. (Dublin)
Ltd. v. Healy/BOSTH, D2001-0026
(WIPO Mar. 23, 2001) (finding confusing similarity where the domain name in
dispute contains the identical mark of the Complainant combined with a generic
word or term); see also Sony
Kabushiki Kaisha v. Inja, Kil, D2000-1409 (WIPO Dec. 9, 2000) (finding that
“[n]either the addition of an ordinary descriptive word…nor the suffix ‘.com’
detract from the overall impression of the dominant part of the name in each
case, namely the trademark SONY” and thus Policy ¶ 4(a)(i) is satisfied).
The Panel finds that Policy ¶ 4(a)(i) has
been satisfied.
Rights or Legitimate Interests
Respondent has failed to come forward
with a Response and therefore it is presumed that Respondent has no rights or
legitimate interests in the disputed domain name. See Pavillion Agency,
Inc. v. Greenhouse Agency Ltd., D2000-1221 (WIPO Dec. 4, 2000) (finding
that Respondents’ failure to respond can be construed as an admission that they
have no legitimate interest in the domain names).
Furthermore, when Respondent fails to
submit a Response, the Panel is permitted to make all inferences in favor of
Complainant. See Talk City, Inc.
v. Robertson, D2000-0009, (WIPO Feb. 29, 2000)
(“In the absence of a response, it is appropriate to accept as true all
allegations of the Complaint”).
Respondent is using two domain names that
are confusingly similar to Complainant’s mark in order to attract Complainant’s
customers to Respondent’s website for Respondent’s commercial gain. This type of use is not considered to be
bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i), nor a
legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii). See
Toronto-Dominion Bank v. Karpachev, 188 F.Supp.2d
110, 114 (D.Mass
2002) (finding that, because Respondent's sole purpose in selecting the domain
names was to cause confusion with Complainant's website and marks, it's use of
the names was not in connection with the offering of goods or services or any
other fair use); see also Vapor Blast Mfg. Co. v. R & S Tech.,
Inc., FA 96577 (Nat.
Arb. Forum Feb. 27, 2001) (finding that Respondent’s commercial use of the
domain name to confuse and divert Internet traffic is not a legitimate use of
the domain name); see also Big Dog
Holdings, Inc. v. Day, FA 93554 (Nat. Arb. Forum Mar. 9, 2000) (finding no
legitimate use when Respondent was diverting consumers to its own website by
using Complainant’s trademarks).
Respondent is doing business as “Sunset
Camera” and “World Photo Video & Imaging Corp.” not “aolcamera(s),” and
therefore, Respondent is not commonly known as <aolcamera.com> or
<aolcameras.com> pursuant to Policy ¶ 4(c)(ii). See Gallup Inc. v. Amish Country Store, FA 96209 (Nat. Arb. Forum Jan.
23, 2001) (finding that Respondent does not have rights in a domain name when
Respondent is not known by the mark); see also Compagnie de Saint Gobain v. Com-Union Corp., D2000-0020 (WIPO
Mar. 14, 2000) (finding no rights or legitimate interest where Respondent was
not commonly known by the mark and never applied for a license or permission
from Complainant to use the trademarked name).
The Panel finds that Policy ¶ 4(a)(ii)
has been satisfied.
Registration and Use in Bad Faith
Respondent is using confusingly similar
domain names in order to attract Complainant’s customers to Respondent’s
website for Respondent’s own commercial gain.
This is evidence of bad faith pursuant to Policy ¶ 4(b)(iv). See State Fair of Texas v. Granbury.com, FA 95288 (Nat. Arb. Forum
Sept. 12, 2000) (finding bad faith where Respondent registered the domain name
<bigtex.net> to infringe on Complainant’s goodwill and attract Internet
users to Respondent’s website); see also State Farm Mut. Auto. Ins. Co. v. Northway, FA 95464 (Nat. Arb.
Forum Oct. 11, 2000) (finding that Respondent registered the domain name
<statefarmnews.com> in bad faith because Respondent intended to use
Complainant’s marks to attract the public to the web site without permission
from Complainant).
Respondent offered to sell the disputed
domains to Complainant for a price between $5,000-$8,000. This price is far above Respondent’s
out-of-pocket expenses in relation to the registration of the two domain names
and therefore this offer of sale is evidence of bad faith pursuant to Policy ¶
4(b)(i). See Am. Online, Inc. v. Avrasya Yayincilik Danismanlik Ltd., FA 93679
(Nat. Arb. Forum Mar. 16, 2000) (finding bad faith where Respondent offered
domain names for sale); see also Dynojet
Research, Inc. v. Norman, AF-0316 (eResolution Sept. 26, 2000) (finding
that Respondent demonstrated bad faith when he requested monetary compensation
beyond out of pocket costs in exchange for the registered domain name).
Furthermore, based on the fame of
Complainant’s AOL mark it can be inferred that Respondent was on notice as to
Complainant’s rights in the AOL mark when it registered the infringing domain
names. Therefore, Respondent’s
registration of the disputed domain names despite this notice is evidence of
bad faith. See Samsonite Corp. v. Colony Holding, FA
94313 (Nat. Arb. Forum Apr. 17, 2000) (finding that evidence of bad faith
includes actual or constructive knowledge of a commonly known mark at the time
of registration); see also Ty Inc.
v. Parvin, D2000-0688 (WIPO Nov. 9, 2000) (finding that Respondent’s
registration and use of an identical and/or confusingly similar domain name was
in bad faith where Complainant’s BEANIE BABIES mark was famous and Respondent
should have been aware of it).
Respondent registered two infringing
domain names at the same time. This is
evidence of a pattern of conduct and therefore bad faith registration pursuant
to Policy ¶ 4(b)(ii). See YAHOO!
Inc. v. Syrynx, Inc., D2000-1675
(WIPO Jan. 30, 2001) (finding a bad faith pattern pursuant to Policy ¶ 4(b)(ii)
in Respondent's registration of two domain names incorporating Complainant's
YAHOO! mark); see also Caterpillar
Inc. v. Miguel Miyar Jr., FA 95623 (Nat. Arb. Forum Dec. 14, 2000) (finding that registering multiple
domain names in a short time frame indicates an intention to prevent the mark
holder from using its mark and provides evidence of a pattern of conduct).
The Panel finds that Policy ¶ 4(a)(iii)
has been satisfied.
DECISION
Having established all three elements
required under the ICANN Policy, the Panel concludes that the requested relief
shall be hereby granted.
Accordingly, it is Ordered that the
domain names <aolcamera.com> and <aolcameras.com> be
transferred from Respondent to Complainant.
The Honorable Charles K. McCotter, Jr.
(Ret.), Panelist
Dated: May 13, 2002
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