national arbitration forum

 

DECISION

 

Tanger Factory Outlet Centers, Inc. v. Domain Administration Limited a/k/a David Halstead a/k/a William Vaughan a/k/a smtm investments ltd

Claim Number: FA0803001157272

 

PARTIES

Complainant is Tanger Factory Outlet Centers, Inc. (“Complainant”), represented by Gary L. Beaver, of Nexsen Pruet, PLLC, North Carolina, USA.  Respondent is Domain Administration Limited a/k/a David Halstead a/k/a William Vaughan a/k/a smtm investments ltd (“Respondent”), New Zealand.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <tangeroutlets.com>, registered with Moniker Online Services, Inc., and <tangeroulet.com>, registered with Innerwise, Inc. d/b/a Itsyourdomain.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.

 

Judge Ralph Yachnin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on March 5, 2008; the National Arbitration Forum received a hard copy of the Complaint on March 10, 2008.

 

On March 6, 2008, Moniker Online Services, Inc., confirmed by e-mail to the National Arbitration Forum that the <tangeroutlets.com> domain name is registered with Moniker Online Services, Inc., and that Respondent is the current registrant of the name.  Moniker Online Services, Inc., has verified that Respondent is bound by the Moniker Online Services, 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 March 7, 2008, Innerwise, Inc. d/b/a Itsyourdomain.com confirmed by e-mail to the National Arbitration Forum that the <tangeroulet.com> domain name is registered with Innerwise, Inc. d/b/a Itsyourdomain.com and that Respondent is the current registrant of the name. Innerwise, Inc. d/b/a Itsyourdomain.com has verified that Respondent is bound by the Innerwise, Inc. d/b/a Itsyourdomain.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 March 26, 2008, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of April 15, 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@tangeroutlets.com and postmaster@tangeroulet.com by e-mail.

 

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

 

On April 22, 2008, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Judge Ralph Yachnin 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 names be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A.  Complainant makes the following assertions:

 

1.      Respondent’s <tangeroutlets.com> domain name is identical to Complainant’s TANGER OUTLETS mark.  Respondent’s <tangeroulet.com> domain name is confusingly similar to Complainant’s TANGER OUTLETS mark.

 

2.      Respondent does not have any rights or legitimate interests in the <tangeroutlets.com> and <tangeroulet.com> domain names.

 

3.      Respondent registered and used the <tangeroutlets.com> and <tangeroulet.com> domain names in bad faith.

 

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

 

FINDINGS

Complainant owns and/or operates factory outlet retail shopping centers.  Complainant’s business was founded in 1981 and was incorporated in 1988.  Complainant registered the TANGER OUTLETS mark with the United States Patent and Trademark Office (“USPTO”) on June 6, 2006 (Reg. No. 3,100,700).  Complainant’s TANGER OUTLETS mark is used to advertise Complainant’s 31 shopping centers to hundreds of thousands of people by signage on site, on company websites, and on highway billboards in at least 22 states in the U.S.

 

Respondent registered the <tangeroutlets.com> domain name on September 9, 2002.  Respondent registered the <tangeroulet.com> domain name on May 18, 2004.  Both disputed domain names resolve to websites that display advertisements and links to third-party sites advertising and selling products in competition with products and services sold at Complainant’s shopping centers. 

 

Respondent has been subject to at least three other UDRP domain name disputes, wherein all the domain names were transferred to the respective complainants.  See Deceuninck NV v. William Vaughan, smtm investments ltd., D2007-1911 (WIPO Feb. 27, 2008) (transferring the <decuinick.com> domain name); see also Am. Int’l Group, Inc. v. Domain Administration Limited c/o William Vaughan, FA 1106369 (Nat. Arb. Forum Dec. 31, 2007) (transferring the <americangenerallifeinsurance.com> domain name); see also Trans World Entm’t Corp. & Trans World N.Y., LLC v. William Vaughan, D2007-1907 (WIPO Feb. 20, 2008) (transferring the <transworldentertainment.com> domain name).

 

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

 

The Panel finds that Complainant’s registration of the TANGER OUTLETS mark gives Complainant rights in the mark pursuant to Policy ¶ 4a)(i).  See Vivendi Universal Games v. XBNetVentures Inc., FA 198803 (Nat. Arb. Forum Nov. 11, 2003) (“Complainant's federal trademark registrations establish Complainant's rights in the BLIZZARD mark.”); 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.").

 

Furthermore, Complainant has used the TANGER OUTLETS mark since its time of incorporation in 1988, if not earlier, to advertise and promote its business to hundred of thousands of customers in 22 U.S. states, as well as on the Internet.  Complainant contends that this gives them common law rights in the TANGER OUTLETS mark, dating from before Respondent registered the disputed domain names in 2002 and 2004.  In light of the fact that Complainant’s contentions have not been rebutted by Respondent, the Panel finds Complainant has established common law rights in the TANGER OUTLETS mark for purposes of Policy ¶ 4(a)(i).  See Fishtech, Inc. v. Rossiter, FA 92976 (Nat. Arb. Forum Mar. 10, 2000) (finding that the complainant has common law rights in the mark FISHTECH that it has used since 1982); see also Bibbero Sys., Inc. v. Tseu & Assoc., FA 94416 (Nat. Arb. Forum May 9, 2000) (finding, while the complainant had registered the BIBBERO SYSTEMS, INC. mark, it also had common law rights in the BIBBERO mark because it had developed brand name recognition with the word “bibbero”); see also Nat’l Ass’n of Prof’l Baseball Leagues v. Zuccarini, D2002-1011 (WIPO Jan. 21, 2003) (finding that the complainant had provided evidence that it had valuable goodwill in the <minorleaguebaseball.com> domain name, establishing common law rights in the MINOR LEAGUE BASEBALL mark). 

 

Complainant contends that Respondent’s <tangeroutlets.com> domain name is identical to its TANGER OUTLETS mark.  The <tangeroutlets.com> domain name differs from Complainant’s mark in two ways: (1) the space between the terms has been removed; and (2) the generic top-level domain (“gTLD”) “.com” has been added.  The Panel finds that these changes do not prevent the domain name from being perceived as identical to Complainant’s mark, and so Respondent’s <tangeroutlets.com> domain name is not sufficiently distinguished from Complainant’s mark pursuant to Policy ¶ 4(a)(i).  See Wembley Nat’l Stadium Ltd. v. Thomson, D2000-1233 (WIPO Nov. 16, 2000) (finding that the domain name <wembleystadium.net> is identical to the WEMBLEY STADIUM mark); see also Daedong-USA, Inc.  v. O’Bryan Implement Sales, FA 210302 (Nat. Arb. Forum Dec. 29, 2003) (“Respondent's domain name, <kioti.com>, is identical to Complainant's KIOTI mark because adding a top-level domain name is irrelevant for purposes of Policy ¶ 4(a)(i).”).

 

Complainant contends that Respondent’s <tangeroulet.com> domain name is confusingly similar to its TANGER OUTLETS mark.  The <tangeroulet.com> domain name differs from Complainant’s mark in four ways: (1) the spaces between the words have been removed; (2) the first letter “T” has been removed from the term “outlets”; (3) the letter “S” has been removed from the end of the term “outlets”; and (4) the generic top-level domain (“gTLD”) “.com” has been added.  The Panel finds that these changes do not minimize or eliminate the resulting likelihood of confusion, and so Respondent’s <tangeroulet.com> domain name is not sufficiently distinguished from Complainant’s mark pursuant to Policy ¶ 4(a)(i).  See Planned Parenthood Fed’n of Am. v. Bucci, 42 U.S.P.Q. 2d 1430 (S.D.N.Y. 1997), cert. denied 525 U.S. 834 (1998) (finding plaintiff’s PLANNED PARENTHOOD mark and defendant’s <plannedparenthood.com> domain name nearly identical); see also Compaq Info. Techs. Group, L.P. v. Seocho, FA 103879 (Nat. Arb. Forum Feb. 25, 2002) (finding that the domain name <compq.com> is confusingly similar to the complainant’s COMPAQ mark because the omission of the letter “a” in the domain name does not significantly change the overall impression of the mark); see also Universal City Studios, Inc. v. HarperStephens, D2000-0716 (WIPO Sept. 5, 2000) (finding that deleting the letter “s” from the complainant’s UNIVERSAL STUDIOS STORE mark did not change the overall impression of the mark and thus made the disputed domain name confusingly similar to it); see also Entrepreneur Media, Inc. v. Smith, 279 F.3d 1135, 1146 (9th Cir. 2002) (“Internet users searching for a company’s Web site often assume, as a rule of thumb, that the domain name of a particular company will be the company name or trademark followed by ‘.com.’”).

 

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

 

Rights or Legitimate Interests

 

Complainant contends that Respondent lacks all rights and legitimate interests in the disputed domain names.  Under Policy ¶ 4(a)(ii), after the complainant makes a prima facie case against the respondent, the respondent then has the burden of showing evidence that it does have rights and legitimate interests in the disputed domain name.  Complainant has made a prima facie case under Policy ¶ 4(a)(ii).  See Compagnie Generale des Matieres Nucleaires v. Greenpeace Int’l, D2001-0376 (WIPO May 14, 2001) (“Proving that the Respondent has no rights or legitimate interests in respect of the Domain Name requires the Complainant to prove a negative. For the purposes of this sub paragraph, however, it is sufficient for the Complainant to show a prima facie case and the burden of proof is then shifted on to the shoulders of Respondent.  In those circumstances, the common approach is for respondents to seek to bring themselves within one of the examples of paragraph 4(c) or put forward some other reason why they can fairly be said to have a relevant right or legitimate interests in respect of the domain name in question.”); see also Woolworths plc. v. Anderson, D2000-1113 (WIPO Oct. 10, 2000) (finding that, absent evidence of preparation to use the domain name for a legitimate purpose, the burden of proof lies with the respondent to demonstrate that it has rights or legitimate interests).

 

Complainant contends that Respondent is not commonly known by the disputed domain names nor have they ever been the owner or licensee of the TANGER OUTLETS mark.  The WHOIS record for the <tangeroutlets.com> domain name lists the Respondent as “David hALSTEAD wvaughan@dhg.mu, Domain Administration Limited.”  The WHOIS record for the <tangeroulet.com> domain names lists the Respondent as “William Vaughan, smtm investments ltd.”  This evidence, along with the fact that Respondent has failed to show any evidence contrary to Complainant’s contentions, compels the Panel to find that Respondent is not commonly known as either <tangeroutlets.com> or <tangeroulet.com> pursuant to Policy ¶ 4(c)(ii).  See Broadcom Corp. v. Intellifone Corp., FA 96356 (Nat. Arb. Forum Feb. 5, 2001) (finding no rights or legitimate interests because the respondent is not commonly known by the disputed domain name or using the domain name in connection with a legitimate or fair use); see also Valigene Corp. v. MIC, FA 94860 (Nat. Arb. Forum Aug. 1, 2000) (“The domain name in question is not a mark by which the Respondent is commonly known . . . Rather, the Respondent is known by at least twenty ‘NIC handles’ with at least four different phone numbers, three fax numbers, and eleven e-mail addresses . . . . Under these multiple pseudo-names, the Respondent has registered many domain names which include the famous trademarks of other companies.”); see also Desotec N.V. v. Jacobi Carbons AB, D2000-1398 (WIPO Dec. 21, 2000) (finding that failing to respond allows a presumption that the complainant’s allegations are true unless clearly contradicted by the evidence).

 

Respondent maintains websites at the disputed domain names that subjects visitors to numerous advertisements and hyperlinks that promote products and services offered by Complainant’s competitors.  The Panel finds that this use of the disputed domain names is neither a bona fide offering of goods or services under Policy ¶ 4(c)(i) nor a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).  See 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); see also Gardens Alive, Inc. v. D&S Linx, FA 203126 (Nat. Arb. Forum Nov. 20, 2003) (finding that the respondent used a domain name for commercial benefit by diverting Internet users to a website that sold goods and services similar to those offered by the complainant and thus, was not using the name in connection with a bona fide offering of goods or services nor a legitimate noncommercial or fair use).

 

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

 

Registration and Use in Bad Faith

 

Complainant contends that Respondent is using the disputed domain name to divert Internet customers from Complainant’s website to Respondent’s website, through the confusion caused by the similarity between the TANGER OUTLETS mark and the disputed domain names.  The Panel finds that Respondent’s use of the disputed domain names disrupts Complainant’s business, and is evidence of registration and use in bad faith pursuant to Policy ¶ 4(b)(iii).  See Puckett, Individually v. Miller, D2000-0297 (WIPO June 12, 2000) (finding that the respondent has diverted business from the complainant to a competitor’s website in violation of Policy ¶ 4(b)(iii)); see also Travant Solutions, Inc. v. Cole, FA 203177 (Nat. Arb. Forum Dec. 6, 2003) (“Respondent registered and used the domain name in bad faith, pursuant to Policy ¶ 4(b)(iii), because it is operating on behalf of a competitor of Complainant . . .”); see also Caterpillar Inc. v. Vine, FA 97097 (Nat. Arb. Forum June 22, 2001) (“Respondent registered each of the disputed domain names in order to gain customers and to disrupt Complainant's business of authorizing dealers to sell its CATERPILLAR equipment.”). 

 

Complainant also contends that Respondent is gaining commercially through this diversion, both through click-through fees and through the competing goods and services that Respondent is offering.  The Panel finds that this is an intentional use of the disputed domain names for commercial gain through a likelihood of confusion with Complainant’s mark, and so, pursuant to Policy ¶ 4(b)(iv), this use is also evidence of registration and use in bad faith.  See Am. Univ. v. Cook, FA 208629 (Nat. Arb. Forum Dec. 22, 2003) (“Registration and use of a domain name that incorporates another's mark with the intent to deceive Internet users in regard to the source or affiliation of the domain name is evidence of bad faith.”); see also Associated Newspapers Ltd. v. Domain Manager, FA 201976 (Nat. Arb. Forum Nov. 19, 2003) (“Respondent's prior use of the <mailonsunday.com> domain name is evidence of bad faith pursuant to Policy ¶ 4(b)(iv) because the domain name provided links to Complainant's competitors and Respondent presumably commercially benefited from the misleading domain name by receiving ‘click-through-fees.’”). 

 

Complainant also contends that Respondent has a history of registering infringing domain names that incorporate third-party trademarks, in order to host commercial search engines and websites containing sponsored links.  See Deceuninck NV v. William Vaughan, smtm investments ltd., D2007-1911 (WIPO Feb. 27, 2008) (transferring the <decuinick.com> domain name); see also Am. Int’l Group, Inc. v. Domain Administration Limited c/o William Vaughan, FA 1106369 (Nat. Arb. Forum Dec. 31, 2007) (transferring the <americangenerallifeinsurance.com> domain name); see also Trans World Entm’t Corp. & Trans World N.Y., LLC v. William Vaughan, D2007-1907 (WIPO Feb. 20, 2008) (transferring the <transworldentertainment.com> domain name).  The Panel finds that Respondent’s pattern of behavior is evidence of registration and use in bad faith pursuant to Policy ¶ 4(b)(ii).  See Nat’l Abortion Fed’n v. Dom 4 Sale, Inc., FA 170643 (Nat. Arb. Forum Sept. 9, 2003) (finding bad faith pursuant to Policy ¶ 4(b)(ii) because the domain name prevented the complainant from reflecting its mark in a domain name and the respondent had several adverse decisions against it in previous UDRP proceedings, which established a pattern of cybersquatting); see also Arai Helmet Americas, Inc. v. Goldmark, D2004-1028 (WIPO Jan. 22, 2005 ((finding that “Respondent has registered the disputed domain name, <aria.com>, to prevent Complainant from registering it” and taking notice of another UDRP proceeding against the respondent to find that “this is part of a pattern of such registrations”); see also Gamesville.com, Inc. v. Zuccarini, FA 95294 (Nat. Arb. Forum Aug. 30, 2000) (finding that the respondent engaged in a pattern of conduct of registering domain names to prevent the owner of the trademark from reflecting the mark in a corresponding domain name, which is evidence of registration and use in 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 <tangeroutlets.com> and <tangeroulet.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

Hon. Ralph Yachnin, Panelist

Justice, Supreme Court, NY (Ret.)

 

Dated:  May 5, 2008

 

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