NATIONAL ARBITRATION FORUM

 

DECISION

 

WorldPay Limited v. remarkableliving llc c/o Jose Arango

Claim Number: FA0807001213444

 

PARTIES

Complainant is Worldpay Limited, (“Complainant”) represented by James A. Thomas, of Troutman Sanders LLP, North Carolina, USA.  Respondent is remarkableliving llc c/o Jose Arango, (“Respondent”), Panama.

 

REGISTRAR AND DISPUTED DOMAIN NAMES 

The domain names at issue are <world-paymotors.us>, <worldpay-auto.us>, <worldpayauto.us>, <worldpayvehicles.us>, <worldpay-vehicles.us>, <worldpayautos.us> and <worldpay-autos.us>, registered with Directi Internet Solutions Pvt. Ltd. d/b/a Publicdomainregistry.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 (the “Forum”) electronically on July 1, 2008; the Forum received a hard copy of the Complaint on July 2, 2008.

 

On July 2, 2008, Directi Internet Solutions Pvt. Ltd. d/b/a Publicdomainregistry.com confirmed by e-mail to the Forum that the <world-paymotors.us>, <worldpay-auto.us>, <worldpayauto.us>, <worldpayvehicles.us>, <worldpay-vehicles.us>, <worldpayautos.us> and <worldpay-autos.us> domain names are registered with Directi Internet Solutions Pvt. Ltd. d/b/a Publicdomainregistry.com and that Respondent is the current registrant of the names.  Directi Internet Solutions Pvt. Ltd. d/b/a Publicdomainregistry.com has verified that Respondent is bound by the Directi Internet Solutions Pvt. Ltd. d/b/a Publicdomainregistry.com registration agreement and has thereby agreed to resolve domain-name disputes brought by third parties in accordance with the U. S. Department of Commerce’s usTLD Dispute Resolution Policy (the “Policy”).

 

On July 8, 2008, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of July 28, 2008 by which Respondent could file a Response to the Complaint, was transmitted to Respondent in compliance with Paragraph 2(a) of the Rules for usTLD Dispute Resolution Policy (the “Rules”).

 

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

 

On August 4, 2008, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the Forum appointed Judge RalphYachnin 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.  Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the Policy, the 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

 

1.      Respondent’s <world-paymotors.us>, <worldpay-auto.us>, <worldpayauto.us>, <worldpayvehicles.us>, <worldpay-vehicles.us>, <worldpayautos.us> and <worldpay-autos.us> domain names are confusingly similar to Complainant’s WORLDPAY mark.

 

2.      Respondent does not have any rights or legitimate interests in the <world-paymotors.us>, <worldpay-auto.us>, <worldpayauto.us>, <worldpayvehicles.us>, <worldpay-vehicles.us>, <worldpayautos.us> and <worldpay-autos.us> domain names.

 

3.      Respondent registered and used the <world-paymotors.us>, <worldpay-auto.us>, <worldpayauto.us>, <worldpayvehicles.us>, <worldpay-vehicles.us>, <worldpayautos.us> and <worldpay-autos.us> domain names in bad faith.

 

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

 

FINDINGS

Complainant, WorldPay Limited, was founded in 1993 and develops comprehensive electronic payment processing systems.  Complainant has over 20,000 customers, as well as 1,200 banking and e-commerce partners worldwide.  Complainant has registered its WORLDPAY mark with numerous governmental trademark authorities worldwide, including the United Kingdom Intellectual Property Office (“UKIPO”) (Reg. No. 2,230,627 issued November 17, 2000), United States Patent and Trademark Office (“USPTO”) (Reg. No. 2,245,537 issued May 18, 1999), and the European Union Office for Harmonization in the Internal Market (“OHIM”) (Reg. No. 1,945,310 issued March 4, 2002).

 

Respondent registered the following disputed domain names on their respective dates: <world-paymotors.us> (April 14, 2008), <worldpay-auto.us> (April 17, 2008), <worldpayauto.us> (April 17, 2008), <worldpayvehicles.us> (April 17, 2008), <worldpay-vehicles.us> (April 22, 2008), <worldpayautos.us> (May 15, 2008) and <worldpay-autos.us> (May 15, 2008).  Respondent is currently using the <world-paymotors.us>, <worldpayauto.us> and <worldpay-vehicles.us domain names to resolve to websites that fraudulently imitate Complainant’s legitimate website at the <worldpay.com> domain name.  Respondent is not making any active use of the <worldpay-auto.us>, <worldpayautos.us>, <worldpayvehicles.us> and <worldpay-autos.us> domain names. 

 

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(f), 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 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 or is being used in bad faith.

 

Given the similarity between the Uniform Domain Name Dispute Resolution Policy (“UDRP”) and the usTLD Policy, the Panel will draw upon UDRP precedent as applicable in rendering its decision.

 

Identical and/or Confusingly Similar

 

The Panel finds that Complainant has established its rights in the WORLDPAY mark through its predating registrations of the mark with numerous governmental trademark authorities worldwide, including the UKIPO, USPTO, and the OHIM pursuant to Policy ¶ 4(a)(i).  See Honeywell Int’l Inc. v. r9.net, FA 445594 (Nat. Arb. Forum May 23, 2005) (“Complainant’s numerous registrations for its HONEYWELL mark throughout the world are sufficient to establish Complainant’s rights in the HONEYWELL mark under the [UDRP] Policy ¶ 4(a)(i).”); see also ESPN, Inc. v. MySportCenter.com, FA 95326 (Nat. Arb. Forum Sept. 5, 2000) (concluding that the complainant demonstrated its rights in the SPORTSCENTER mark through its valid trademark registrations with the USPTO and similar offices around the world).

 

Respondent’s disputed domain names include Complainant’s entire and unaltered WORLDPAY mark with the addition of hyphens, generic terms such as “motors,” “auto,” “autos,” or “vehicles,” as well as the country-code top-level domain (“ccTLD”) “.us.”  The Panel finds that the ccTLD and hyphen additions are irrelevant under Policy ¶ 4(a)(i).  Moreover, the Panel finds that the addition of generic words such as these do nothing to differentiate the disputed domain names.  Therefore, the Panel finds that all of the disputed domain names are confusingly similar to Complainant’s mark under Policy ¶ 4(a)(i).  See Future Steel Holdings Ltd. v. Majercik, FA 224964 (Nat. Arb. Forum Mar. 15, 2004) (“The <steelmaster.us> domain name is identical to the STEEL MASTER mark.  The only difference is the omission of the space between the words and the addition of the ccTLD “.us,” which does not significantly distinguish the domain name from the mark.”); see also Pirelli & C. S.p.A. v. Tabriz, FA 921798 (Apr. 12, 2007) (finding that the addition of a hyphen between terms of a registered mark did not differentiate the <p-zero.org> domain name from the P ZERO mark under UDRP Policy ¶ 4(a)(i)); see also Warner Bros. Entm’t Inc. v. Sadler, FA 250236 (Nat. Arb. Forum May 19, 2004) (finding the addition of generic terms to Complainant’s HARRY POTTER mark in the respondent’s <shop4harrypotter.com> and <shopforharrypotter.com> domain names failed to alleviate the confusing similarity between the mark and the domain names).

 

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

 

Rights or Legitimate Interests

 

The Panel finds that Complainant has met its burden of setting forth a prima facie case supporting its allegation that Respondent lacks rights and legitimate interests in the dispute domain names.  Therefore, Respondent receives the burden of demonstrating its rights or legitimate interests.  See SEMCO Prods., LLC v. dmg world media (uk) ltd, FA 913881 (Nat. Arb. Forum Apr. 9, 2007) (concluding that under UDRP Policy ¶ 4(a)(ii) and the factors listed in UDRP Policy ¶ 4(c), a complainant must first make a prima facie case that the respondent has not used or made demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services, that the respondent is not commonly known by the disputed domain name, and that the respondent is not making a legitimate noncommercial or fair use of the disputed domain name before the burden shifts to the respondent to show otherwise); see also F. Hoffmann-La Roche AG v. Di Salvatore, D2006-1417 (WIPO Feb. 1, 2007) (“Proper analysis of paragraph 4(a)(ii) of the Policy shows that the burden of proof shifts from the Complainant to the Respondent once the Complainant has made out a prima facie case that the Respondent has no rights or interests in the domain names.”).

 

There is no evidence in the record to conclude that Respondent owns any service marks or trademarks that reflect the disputed domain name.  Therefore the Panel finds that Respondent does not have rights and legitimate interests pursuant to Policy ¶ 4(c)(i).  See Meow Media Inc. v. Basil, FA 113280 (Nat. Arb. Forum Aug. 20, 2002) (finding that there was no evidence that Respondent was the owner or beneficiary of a mark that is identical to the <persiankitty.com> domain name); see also Pepsico, Inc. v Becky, FA 117014 (Nat. Arb. Forum Sept. 3, 2002) (holding that because Respondent did not own any trademarks or service marks reflecting the <pepsicola.us> domain name, it had no rights or legitimate interests pursuant to Policy ¶ 4(c)(i)).

 

There is no information in the record indicating that Respondent is commonly known by any of the disputed domain names.  Respondent is listed in the WHOIS registration as “remarkableliving llc c/o Jose Arango.”  Moreover, Complainant has not authorized Respondent to use the WORLDPAY mark in any fashion.  Therefore, the Panel finds that Respondent is not commonly known by the disputed domain names under Policy ¶ 4(c)(iii).  See M. Shanken Commc’ns v. WORLDTRAVELERSONLINE.COM, FA 740335 (Nat. Arb. Forum Aug. 3, 2006) (finding that the respondent was not commonly known by the <cigaraficionada.com> domain name under UDRP Policy ¶ 4(c)(ii) based on the WHOIS information and other evidence in the record); see also Educ. Broad. Corp. v. DomainWorks Inc., FA 882172 (Nat. Arb. Forum Apr. 18, 2007) (concluding that the respondent was not commonly known by the <thirteen.com> domain name based on all evidence in the record, and the respondent did not counter this argument in its response).

 

Respondent is currently using the <world-paymotors.us>, <worldpayauto.us> and <worldpay-vehicles.us> domain names to resolve to websites that fraudulently imitate Complainant’s legitimate website at the <worldpay.com> domain name, presumably to receive commercial benefit by stealing Internet users’ private date through a phishing scheme.  Moreover, Respondent is not making any active use of the <worldpay-auto.us>, <worldpayautos.us>, <worldpayvehicles.us> and <worldpay-autos.us> domain names.  The Panel therefore finds that Respondent cannot show any actual use or demonstrable preparation to use any of the disputed domain names for a bona fide offering of goods or services under Policy ¶ 4(c)(ii) or a legitimate noncommercial or fair use under Policy ¶ 4(c)(iv).  See Juno Online Servs., Inc. v. Iza, FA 245960 (Nat. Arb. Forum May 3, 2004) (finding that using a domain name to redirect “Internet users to a website that imitates Complainant’s billing website, and is used to fraudulently acquire personal information from Complainant’s clients,” is neither a bona fide offering of goods or services nor a legitimate noncommercial or fair use); see also Bloomberg L.P. v. SC Media Servs. & Info. SRL, FA 296583 (Nat. Arb. Forum Sept. 2, 2004) (“Respondent is wholly appropriating Complainant’s mark and is not using the <bloomberg.ro> domain name in connection with an active website.  The Panel finds that the passive holding of a domain name that is identical to Complainant’s mark is not a bona fide offering of goods or services pursuant to [UDRP] Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use of the domain name pursuant to [UDRP] Policy  ¶ 4(c)(iii).”).

 

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

 

Registration or Use in Bad Faith

 

Respondent is currently using the <world-paymotors.us>, <worldpayauto.us> and <worldpay-vehicles.us domain names to resolve to websites that fraudulently imitate Complainant’s legitimate website.  The Panel finds that Respondent has intentionally attempted to manipulate the confusing similarity between the mark and these disputed domain names for fraudulent commercial gain, which constitutes bad faith registration or use under Policy ¶ 4(b)(iv).  See AOL LLC v. iTech Ent, LLC, FA 726227 (Nat. Arb. Forum July 21, 2006) (finding that the respondent took advantage of the confusing similarity between the <theotheraol.com> and <theotheraol.net> domain names and the complainant’s AOL mark, which indicates bad faith registration and use pursuant to Policy ¶ 4(b)(iv)); see also Allianz of Am. Corp. v. Bond, FA 680624 (Nat. Arb. Forum June 2, 2006) (finding bad faith registration and use under Policy ¶ 4(b)(iv) where the respondent was diverting Internet users searching for the complainant to its own website and likely profiting).

 

Moreover, the Panel finds that Respondent’s attempts to engage in phishing via the <world-paymotors.us>, <worldpayauto.us> and <worldpay-vehicles.us domain names constitutes bad faith registration or use under Policy ¶ 4(a)(iii).  See Wells Fargo & Co. v. Maniac State, FA 608239 (Nat. Arb. Forum Jan. 19, 2006) (finding bad faith where the respondent registered the <wellsbankupdate.com> domain name in order to fraudulently acquire the personal and financial information of the complainant’s customers); see also Juno Online Servs., Inc. v. Iza, FA 245960 (Nat. Arb. Forum May 3, 2004) (finding that using a domain name that “is confusingly similar to Complainant’s mark, redirects Internet users to a website that imitates Complainant’s billing website, and is used to fraudulently acquire personal information from Complainant’s clients” is evidence of bad faith registration and use).

 

Moreover, Respondent is not making any active use of the <worldpay-auto.us>, <worldpayautos.us>, <worldpayvehicles.us> and <worldpay-autos.us> domain names.  The Panel finds that Respondent’s inactive holding of these disputed domain names constitutes bad faith registration or use under Policy ¶ 4(a)(iii).  See Am. Broad. Cos., Inc. v. Sech, FA 893427 (Nat. Arb. Forum Feb. 28, 2007) (concluding that the respondent’s failure to make active use of its domain name in the three months after its registration indicated that the respondent registered the disputed domain name in bad faith); see also Pirelli & C. S.p.A. v. Tabriz, FA 921798 (Nat. Arb. Forum Apr. 12, 2007) (holding that non-use of a confusingly similar domain name for over seven months constitutes bad faith registration and use).

 

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

 

DECISION

Having established all three elements required under the usTLD Policy, the Panel concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <world-paymotors.us>, <worldpay-auto.us>, <worldpayauto.us>, <worldpayvehicles.us>, <worldpay-vehicles.us>, <worldpayautos.us> and <worldpay-autos.us> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

Hon. Ralph Yachnin, Panelist

Justice, Supreme Court, NY (Ret.)

 

Dated: August 6, 2008

 

 

 

 

 

Click Here to return to the main Domain Decisions Page.

 

Click Here to return to our Home Page