national arbitration forum

 

DECISION

 

National Westminster Bank plc v. Media Breakaway Premium

Claim Number: FA0801001126316

 

PARTIES

Complainant is National Westminster Bank plc (“Complainant”), represented by James A. Thomas, North Carolina, USA.  Respondent is Media Breakaway Premium (“Respondent”), Colorado, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <wwwnatwest.com>, registered with Dynamic Dolphin, Inc.

 

PANEL

The undersigned certifies that he or she has acted independently and impartially and to the best of his or her knowledge has no known conflict in serving as Panelist in this proceeding.

 

Sandra J. Franklin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on January 4, 2008; the National Arbitration Forum received a hard copy of the Complaint on January 7, 2008.

 

On January 9, 2008, Dynamic Dolphin, Inc. confirmed by e-mail to the National Arbitration Forum that the <wwwnatwest.com> domain name is registered with Dynamic Dolphin, Inc. and that Respondent is the current registrant of the name.  Dynamic Dolphin, Inc. has verified that Respondent is bound by the Dynamic Dolphin, Inc. 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 January 16, 2008, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of February 5, 2008 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@wwwnatwest.com by e-mail.

 

Having received no response from Respondent, the National Arbitration Forum transmitted to the parties a Notification of Respondent Default.

 

On March 28, 2008, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Sandra J. Franklin as Panelist.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that the National Arbitration 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 National Arbitration 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 name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A.  Complainant makes the following assertions:

 

1.      Respondent’s <wwwnatwest.com> domain name is confusingly similar to Complainant’s NATWEST mark.

 

2.      Respondent does not have any rights or legitimate interests in the <wwwnatwest.com> domain name.

 

3.      Respondent registered and used the <wwwnatwest.com> domain name in bad faith.

 

B.  Respondent failed to submit a Response in this proceeding.

 

FINDINGS

Complainant, National Westminster Bank plc, is a financial institution based in the United Kingdom, offering a range of financial services, including personal and banking services and credit cards to individuals and small business accounts.  Complainant registered the NATWEST mark with the United Kingdom Intellectual Property Office (“UKIPO”) on January 2, 1975 (Reg. No. 1,021,601); with the United States Patent and Trademark Office (“USPTO”) on June 7, 1983 (Reg. No. 1,241454); and with the Office for Harmonization in the Internal Market (“OHIM”) on May 17, 2006 (Reg. No. 4,319,083).  Through its parent company, The Royal Bank of Scotland Group, Complainant also owns and uses the <natwest.com>, <natwestuk.com>, <natwestbank.com>, and <natwestonline.com> domain names. 

 

Respondent registered the <wwwnatwest.com> domain name on August 22, 2000.  Respondent has been using the disputed domain name to display links to financial websites offering services competing with Complainant’s business.  

 

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 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.  The Panel is entitled to accept all reasonable allegations and inferences set forth in the Complaint as true unless the evidence is clearly contradictory.  See Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (Nat. Arb. Forum July 31, 2000) (holding that the respondent’s failure to respond allows all reasonable inferences of fact in the allegations of the complaint to be deemed true); see also 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.”).

 

Paragraph 4(a) of the Policy requires that 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 Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and

(2)   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 registered the NATWEST mark with the UKIPO, the USPTO, and the OHIM, and has therefore established rights to the mark under Policy ¶ 4(a)(i).  See Koninklijke KPN N.V. v. Telepathy Inc., D2001-0217 (WIPO May 7, 2001) (finding that the Policy does not require that the mark be registered in the country in which the respondent operates; therefore it is sufficient that the complainant can demonstrate a mark in some jurisdiction); see also Janus Int’l Holding Co. v. Rademacher, D2002-0201 (WIPO Mar. 5, 2002) ("Panel decisions have held that registration of a mark is prima facie evidence of validity, which creates a rebuttable presumption that the mark is inherently distinctive."). 

 

The disputed domain name incorporates the entire NATWEST mark and adds the letters “www” to the front of Complainant’s mark.  The panel in Bank of America Corp. v. InterMos, FA 95092 (Nat. Arb. Forum Aug. 1, 2000) found that the respondent’s domain name <wwwbankofamerica.com> was confusingly similar to the complainant’s registered trademark BANK OF AMERICA because it “takes advantage of a typing error (eliminating the period between the www and the domain name) that users commonly make when searching on the Internet”).  Therefore, the addition of “www” to the beginning of the mark is insufficient for the purposes of distinguishing the disputed domain name from the mark under Policy ¶ 4(a)(i).  Furthermore, the addition of the generic top-level domain (“gTLD”) “.com” to the disputed domain name does not sufficiently distinguish the disputed domain name from Complainant’s NATWEST mark because all registered domain names are required to have a top-level domain.  Therefore, the <wwwnatwest.com> domain name is confusingly similar to Complainant’s NATWEST mark pursuant to Policy ¶ 4(a)(i).  See Marie Claire Album v. Blakely, D2002-1015 (WIPO Dec. 23, 2002) (holding that the letters “www” are not distinct in the “Internet world” and thus the respondent 's <wwwmarieclaire.com> domain name is confusingly similar to the complainant's MARIE CLAIRE trademark); see also Isleworth Land Co. v. Lost in Space, SA, FA 117330 (Nat. Arb. Forum Sept. 27, 2002) (“[I]t is a well established principle that generic top-level domains are irrelevant when conducting a Policy ¶ 4(a)(i) analysis.”).

 

The Panel finds that Policy ¶ 4(a)(i) has been satisfied.

 

Rights or Legitimate Interests

 

Complainant has the initial burden of establishing a prima facie case, showing that Respondent lacks all rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii).  Complainant has asserted that Respondent lacks all rights and legitimate interests, and therefore, the Panel finds that Respondent has made a prima facie case pursuant to Policy ¶ 4(a)(ii), shifting the burden to Respondent.  See Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (holding that, where the complainant has asserted that the respondent has no rights or legitimate interests with respect to the domain name, it is incumbent on the respondent to come forward with concrete evidence rebutting this assertion because this information is “uniquely within the knowledge and control of the respondent”); see also G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002) (“Because Complainant’s Submission constitutes a prima facie case under the Policy, the burden effectively shifts to Respondent. Respondent’s failure to respond means that Respondent has not presented any circumstances that would promote its rights or legitimate interests in the subject domain name under Policy ¶ 4(a)(ii).”).

 

Respondent has failed to respond to the Complaint.  As a result, the Panel presumes that Respondent lacks all rights and legitimate interests in the <wwwnatwest.com> domain name.  However, the Panel will examine all evidence in the record to determine if Respondent does have rights or legitimate interests under Policy ¶ 4(c).  See Parfums Christian Dior v. QTR Corp., D2000-0023 (WIPO Mar. 9, 2000) (finding that by not submitting a response, the respondent has failed to invoke any circumstance which could demonstrate any rights or legitimate interests in the domain name); see also BIC Deutschland GmbH & Co. KG v. Tweed, D2000-0418 (WIPO June 20, 2000) (“By not submitting a response, Respondent has failed to invoke any circumstance which could demonstrate, pursuant to ¶ 4(c) of the Policy, any rights or legitimate interests in the domain name”).

 

Complainant contends that Respondent has not been authorized to use the NATWEST mark.  Moreover, the WHOIS information does not indicate that Respondent is commonly known by the <wwwnatwest.com> domain name.  In Gallup, Inc. v. Amish Country Store, FA 96209 (Nat. Arb. Forum Jan. 23, 2001), the panel found that the respondent did not have rights in a domain name when the respondent was not known by the mark.  Here also, the Panel finds that Respondent is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii).  See Tercent Inc. v. Lee Yi, FA 139720 (Nat. Arb. Forum Feb. 10, 2003) (stating “nothing in Respondent’s WHOIS information implies that Respondent is ‘commonly known by’ the disputed domain name” as one factor in determining that Policy ¶ 4(c)(ii) does not apply).

 

Respondent is using the disputed domain name to display links that redirect Internet users to websites that provide financial services.  The financial services provided at the linked websites are similar to those offered by Complainant.  The Panel finds that such use is neither a bona fide offering of goods or services under Policy ¶ 4(c)(i), or a noncommercial or fair use under Policy ¶ 4(c)(iii).  See Ameritrade Holdings Corp. v. Polanski, FA 102715 (Nat. Arb. Forum Jan. 11, 2002) (finding that the respondent’s use of the disputed domain name to redirect Internet users to a financial services website, which competed with the complainant, was not a bona fide offering of goods or services); see also Coryn Group, Inc. v. Media Insight, FA 198959 (Nat. Arb. Forum Dec. 5, 2003) (finding that the respondent was not using the domain names for a bona fide offering of goods or services nor a legitimate noncommercial or fair use because the respondent used the names to divert Internet users to a website that offered services that competed with those offered by the complainant under its marks).

 

Moreover, because Respondent is engaging in typosquatting, benefiting from a common typing error, the Panel finds further evidence that Respondent lacks all rights and legitimate interests in the dispute domain name under Policy ¶ 4(a)(ii).  See Diners Club Int’l Ltd. v. Domain Admin******It's all in the name******, FA 156839 (Nat. Arb. Forum June 23, 2003) (holding that the respondent’s <wwwdinersclub.com> domain name, a typosquatted version of the complainant’s DINERS CLUB mark, was evidence in and of itself that the respondent lacks rights or legitimate interests in the disputed domain name vis á vis the complainant); see also Encyclopaedia Britannica, Inc. v. Zuccarini, D2000-0330 (WIPO June 7, 2000) (finding that fair use does not apply where the domain names are misspellings of the complainant's mark).

 

The Panel finds that Policy ¶ 4(a)(ii) has been satisfied.

 

Registration and Use in Bad Faith

 

Respondent is using the <wwwnatwest.com> domain name to advertise competing financial websites, receiving profit by redirecting Internet users to these competing websites.  Respondent’s use of the disputed domain name is capable of creating confusion with Complainant as to the source, sponsorship, affiliation, or endorsement of the website that resolves from the disputed domain name.  The panel in G.D. Searle & Co. v. Celebrex Drugstore, FA 123933 (Nat. Arb. Forum Nov. 21, 2002) found that the respondent registered and used the domain name in bad faith pursuant to Policy ¶ 4(b)(iv) because the respondent was using the confusingly similar domain name to attract Internet users to its commercial website.  The Panel here also finds that the use of the disputed domain name to attract Internet users to its website is evidence of registration and use in bad faith under Policy ¶ 4(b)(iv).  See Drs. Foster & Smith, Inc. v. Lalli, FA 95284 (Nat. Arb. Forum Aug. 21, 2000) (finding bad faith where the respondent directed Internet users seeking the complainant’s site to its own website for commercial gain).

 

In addition, previous panels have found evidence of registration and use in bad faith under Policy ¶ 4(b)(iii) when competing products or services are advertised on the website that resolves from the disputed domain name.  Therefore, the Panel finds Respondent’s use of the disputed domain name to display links to competing financial services further demonstrates registration and use in bad faith under Policy ¶ 4(b)(iii).  See S. Exposure v. S. Exposure, Inc., FA 94864 (Nat. Arb. Forum July 18, 2000) (finding the respondent acted in bad faith by attracting Internet users to a website that competes with the complainant’s business); see also Disney Enters., Inc. v. Noel, FA 198805 (Nat. Arb. Forum Nov. 11, 2003) (“Respondent registered a domain name confusingly similar to Complainant's mark to divert Internet users to a competitor's website. It is a reasonable inference that Respondent's purpose of registration and use was to either disrupt or create confusion for Complainant's business in bad faith pursuant to Policy ¶¶ 4(b)(iii) [and] (iv).”).

 

Furthermore, because Respondent is engaging in typosquatting, there is additional evidence that Respondent registered and is using the disputed domain name in bad faith.  In Black & Decker Corp. v. Khan, FA 137223 (Nat. Arb. Forum Feb. 3, 2003), the panel found that the <wwwdewalt.com> domain name was registered to “ensnare those individuals who forget to type the period after the ‘www’ portion of [a] web-address,” which was evidence that the domain name was registered and used in bad faith.  Here, the Panel finds that Respondent has registered and is using the <wwwnatwest.com> domain name in bad faith under Policy ¶ 4(a)(iii).  See RE/MAX Int’l, Inc. v. Seocho, FA 142046 (Nat. Arb. Forum Feb. 25, 2003) (inferring that the respondent’s registration of the <wwwremax.com> domain name, incorporating the complainant’s entire mark, was done with actual notice of the complainant’s rights in the mark prior to registering the infringing domain name, evidencing bad faith). 

 

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 relief shall be GRANTED.

 

Accordingly, it is Ordered that the <wwwnatwest.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Sandra J. Franklin, Panelist

Dated:  April 8, 2008

 

 

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