national arbitration forum

 

DECISION

 

Gaiam, Inc. v. Domain Management SPM

Claim Number: FA0812001237207

 

PARTIES

Complainant is Gaiam, Inc. (“Complainant”), represented by CitizenHawk, Inc., California, USA.  Respondent is Domain Management SPM (“Respondent”), Western Samoa.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <baiam.com>, <faiam.com>, <fgaiam.com>, <ga8am.com>, <ga9am.com>, <gaianm.com>, <gaiasm.com>, <gaiwm.com>, <gaixm.com>, <gaizm.com>, <gfaiam.com>, <ggaiam.com>, <ghaiam.com>, <gqiam.com>, <gsaiam.com>, <gwiam.com>, <gxiam.com>, <gziam.com>, <hgaiam.com>, <raiam.com>, <vaiam.com> and <yaiam.com>, registered with Wild West Domains, Inc..

 

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 RalphYachnin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on December 5, 2008; the National Arbitration Forum received a hard copy of the Complaint on December 8, 2008.

 

On December 5, 2008, Wild West Domains, Inc. confirmed by e-mail to the National Arbitration Forum that the <baiam.com>, <faiam.com>, <fgaiam.com>, <ga8am.com>, <ga9am.com>, <gaianm.com>, <gaiasm.com>, <gaiwm.com>, <gaixm.com>, <gaizm.com>, <gfaiam.com>, <ggaiam.com>, <ghaiam.com>, <gqiam.com>, <gsaiam.com>, <gwiam.com>, <gxiam.com>, <gziam.com>, <hgaiam.com>, <raiam.com>, <vaiam.com> and <yaiam.com> domain names are registered with Wild West Domains, Inc. and that Respondent is the current registrant of the names.  Wild West Domains, Inc. has verified that Respondent is bound by the Wild West Domains, 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 December 10, 2008, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of December 30, 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@baiam.com, postmaster@faiam.com, postmaster@fgaiam.com, postmaster@ga8am.com, postmaster@ga9am.com, postmaster@gaianm.com, postmaster@gaiasm.com, postmaster@gaiwm.com, postmaster@gaixm.com, postmaster@gaizm.com, postmaster@gfaiam.com, postmaster@ggaiam.com, postmaster@ghaiam.com, postmaster@gqiam.com, postmaster@gsaiam.com, postmaster@gwiam.com, postmaster@gxiam.com, postmaster@gziam.com, postmaster@hgaiam.com, postmaster@raiam.com, postmaster@vaiam.com and postmaster@yaiam.com by e-mail.

 

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

 

On January 6, 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 <baiam.com>, <faiam.com>, <fgaiam.com>, <ga8am.com>, <ga9am.com>, <gaianm.com>, <gaiasm.com>, <gaiwm.com>, <gaixm.com>, <gaizm.com>, <gfaiam.com>, <ggaiam.com>, <ghaiam.com>, <gqiam.com>, <gsaiam.com>, <gwiam.com>, <gxiam.com>, <gziam.com>, <hgaiam.com>, <raiam.com>, <vaiam.com> and <yaiam.com> domain names are confusingly similar to Complainant’s GAIAM mark.

 

2.      Respondent does not have any rights or legitimate interests in the <baiam.com>, <faiam.com>, <fgaiam.com>, <ga8am.com>, <ga9am.com>, <gaianm.com>, <gaiasm.com>, <gaiwm.com>, <gaixm.com>, <gaizm.com>, <gfaiam.com>, <ggaiam.com>, <ghaiam.com>, <gqiam.com>, <gsaiam.com>, <gwiam.com>, <gxiam.com>, <gziam.com>, <hgaiam.com>, <raiam.com>, <vaiam.com> and <yaiam.com> domain names.

 

3.      Respondent registered and used the <baiam.com>, <faiam.com>, <fgaiam.com>, <ga8am.com>, <ga9am.com>, <gaianm.com>, <gaiasm.com>, <gaiwm.com>, <gaixm.com>, <gaizm.com>, <gfaiam.com>, <ggaiam.com>, <ghaiam.com>, <gqiam.com>, <gsaiam.com>, <gwiam.com>, <gxiam.com>, <gziam.com>, <hgaiam.com>, <raiam.com>, <vaiam.com> and <yaiam.com> domain names in bad faith.

 

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

 

FINDINGS

Complainant, Gaiam, Inc., is a provider of information, goods, and services to customers that value a sustainable economy, the environment, and healthy lifestyles.  Complainant had revenues of US $262.9 million in 2007, and has over 460,000 monthly visitors to its website at the <gaiam.com> domain name.  Complainant has several registrations of its GAIAM mark with the United States Patent and Trademark Office (“USPTO”) (i.e. Reg. No. 2,244,895 issued May 11, 1999). 

 

Respondent registered the <faiam.com>, <gaianm.com> and <gaiasm.com> domain names on December 11, 2004; the <fgaiam.com>, <gfaiam.com>, <ggaiam.com>, <ghaiam.com>, <gsaiam.com> and <hgaiam.com> domain names on January 8, 2005; and the <baiam.com>, <ga8am.com>, <ga9am.com>, <gaiwm.com>, <gaixm.com>, <gaizm.com>, <gqiam.com>, <gwiam.com>, <gxiam.com>, <gziam.com>, <raiam.com>, <vaiam.com> and <yaiam.com> domain names on June 14, 2005.  Each of the disputed domain names resolves to Complainant’s website through Complainant’s affiliate program.

 

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

 

Because Complainant has submitted evidence of its trademark registrations for the GAIAM mark with the USPTO, the Panel finds that Complainant has sufficient rights in the mark under Policy ¶ 4(a)(i).  See Intel Corp. v. Macare, FA 660685 (Nat. Arb. Forum Apr. 26, 2006) (finding that the complainant had established rights in the PENTIUM, CENTRINO and INTEL INSIDE marks by registering the marks with the USPTO); see also Miller Brewing Co. v. Miller Family, FA 104177 (Nat. Arb. Forum Apr. 15, 2002) (finding that the complainant had established rights to the MILLER TIME mark through its federal trademark registrations).

 

Respondent’s disputed domain names contain Complainant’s GAIAM mark with the generic top-level domain “.com;” though each disputed domain name contains one of following alterations: (1) the addition of an extra letter; or (2) the substitution of one letter for another letter or number.  The Panel finds that the addition of a top-level domain name remains immaterial.  See Trip Network Inc. v. Alviera, FA 914943 (Nat. Arb. Forum Mar. 27, 2007) (concluding that the addition of a gTLD, whether it be “.com,” “.net,” “.biz,” or “.org,” is irrelevant to a Policy ¶ 4(a)(i) analysis).  Moreover, the addition of letters or substitution of letters for other characters fails to create a meaningful distinction—the sole product is a typographical error.  See Dow Jones & Co., Inc. v. Powerclick, Inc., D2000-1259 (WIPO Dec. 1, 2000) (holding that the deliberate introduction of errors or changes, such as the addition of a fourth “w” or the omission of periods or other such “generic” typos do not change respondent’s infringement on a core trademark held by the complainant); see also Am. Online, Inc. v. Avrasya Yayincilik Danismanlik Ltd., FA 93679 (Nat. Arb. Forum Mar. 16, 2000) (finding that the respondent’s domain name, <americanonline.com>, is confusingly similar to the complainant’s famous AMERICA ONLINE mark).  Therefore, the Panel finds that the disputed domain names are confusingly similar to Complainant’s mark under Policy ¶ 4(a)(i).

 

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

 

Rights or Legitimate Interests

 

Complainant has alleged that Respondent lacks rights and legitimate interests in the disputed domain names.  Based upon the allegations made in the Complaint, the Panel finds that Complainant has established a prima facie case pursuant to Policy ¶ 4(a)(ii), thus shifting the burden of proof to Respondent.  Since Respondent has not responded to the Complaint, the Panel may presume that Respondent lacks rights and legitimate interests in the disputed domain names pursuant to Policy ¶ 4(a)(ii).  However, the Panel in its discretion chooses to examine the record to determine whether Respondent has any rights or legitimate interests pursuant to the factors outlined in Policy ¶ 4(c).  See AOL LLC v. Gerberg, FA 780200 (Nat. Arb. Forum Sept. 25, 2006) (“Complainant must make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light.  If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interest in the subject domain names.”); see also Hanna-Barbera Prods., Inc. v. Entm’t Commentaries, FA 741828 (Nat. Arb. Forum Aug. 18, 2006) (holding that the complainant must first make a prima facie case that the respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii) before the burden shifts to the respondent to show that it does have rights or legitimate interests in a domain name); see also Broadcom Corp. v. Ibecom PLC, FA 361190 (Nat. Arb. Forum Dec. 22, 2004) (“Respondent’s failure to respond to the Complaint functions as an implicit admission that [Respondent] lacks rights and legitimate interests in the disputed domain name.  It also allows the Panel to accept all reasonable allegations set forth…as true.”).

 

Complainant contends that Respondent is not permitted to use Complainant’s marks in any fashion.  Moreover, the WHOIS information lists Respondent as “Domain Management SPM.”  Without evidence to the contrary, the Panel finds that Respondent is not commonly known by any of the disputed domain names under Policy ¶ 4(c)(ii).  See IndyMac Bank F.S.B. v. Eshback, FA 830934 (Nat. Arb. Forum Dec. 7, 2006) (finding that the respondent failed to establish rights and legitimate interests in the <emitmortgage.com> domain name as the respondent was not authorized to register domain names featuring the complainant’s mark and failed to submit evidence of that it is commonly known by the disputed domain name); see also 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 Policy ¶ 4(c)(ii) based on the WHOIS information and other evidence in the record).

 

Respondent asserts that the disputed domain names all resolve to Complainant’s website, but that Respondent has violated the terms of Complainant’s affiliate program.  Complainant asserts that Respondent thereby profits from this diversion of Internet users.  The Panel finds that Respondent has diverted Internet users for such presumed commercial gain, and that therefore Respondent has failed to create a bona fide offering of goods or services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).  See Cricket Commc’ns, Inc. v. Oliver, FA 954005 (Nat. Arb. Forum May 29, 2007) (concluding that the respondent had no rights or legitimate interests in disputed domain names containing the complainant’s marks even though it was a part of the complainant’s affiliate program, as the affiliate agreement expressly stated that affiliates could not register domain names containing the CRICKET mark); see also Sports Auth. Mich., Inc. v. Jablome, FA 124861 (Nat. Arb. Forum Nov. 4, 2002) (by signing up for the complainant’s affiliate program upon registering the domain name, which was a misspelling of the complainant’s mark, the respondent intended to use the domain name to generate profit at the complainant’s expense, thereby evidencing a lack of rights and legitimate interests in the domain name under Policy ¶¶ 4(c)(i) and (iii)).

 

Complainant asserts that Respondent has engaged in typosquatting, which is defined as the practice of registering domain names containing typographical errors of a complainant’s mark.  The Panel notes that each of the disputed domain names in the instant dispute contains solely Complainant’s mark along with a typographical error.  The Panel finds that Respondent has engaged in typosquatting, which constitutes additional evidence of Respondent’s lack of rights and legitimate interests under Policy ¶ 4(a)(ii).  See IndyMac Bank F.S.B. v. Ebeyer, FA 175292 (Nat. Arb. Forum Sept. 19, 2003) (finding that the respondent lacked rights and legitimate interests in the disputed domain names because it “engaged in the practice of typosquatting by taking advantage of Internet users who attempt to access Complainant's <indymac.com> website but mistakenly misspell Complainant's mark by typing the letter ‘x’ instead of the letter ‘c’”); see also LTD Commodities LLC v. Party Night, Inc., FA 165155 (Nat. Arb. Forum Aug. 14, 2003) (finding that the <ltdcommadities.com>, <ltdcommmodities.com>, and <ltdcommodaties.com> domain names were intentional misspellings of Complainant's LTD COMMODITIES mark and this “‘typosquatting’ is evidence that Respondent lacks rights or legitimate interests in the disputed domain names”).

 

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

 

Registration and Use in Bad Faith

 

Respondent’s disputed domain names resolve to Complainant’s website.  However, Respondent has violated Complainant’s terms in its affiliate program.  Respondent has sought to obtain commercial profit by routing Internet users seeking Complainant through the confusingly similar disputed domain names.  The Panel considers this to be sufficient evidence of Respondent’s bad faith registration and use under Policy ¶ 4(b)(iv).  See Deluxe Corp. v. Dallas Internet, FA 105216 (Nat. Arb. Forum Apr. 10, 2002) (finding the respondent registered and used the <deluxeform.com> domain name in bad faith pursuant to Policy ¶ 4(b)(iv) by redirecting its users to the complainant’s <deluxeforms.com> domain name, thus receiving a commission from the complainant through its affiliate program); see also Sports Auth. Mich., Inc. v. Internet Hosting, FA 124516 (Nat. Arb. Forum Nov. 4, 2002) (“Redirecting Internet users attempting to reach a complainant’s website in order to gain a profit off of a complainant is one example of bad faith use and registration under the Policy.”).

 

The Panel has already determined that Respondent has engaged in typosquatting.  This activity also constitutes additional evidence of Respondent’s bad faith registration and use under Policy ¶ 4(a)(iii).  See Sports Auth. Mich., Inc. v. Domhold Co., FA 135011 (Nat. Arb. Forum Jan. 9, 2003) (finding that registering a domain name which differs by one letter from the complainant’s commercial website, and using that domain name to redirect Internet consumers to the complainant’s website as a part of the complainant’s affiliates program is not a bona fide offering of goods or services nor a noncommercial use of the domain name); see also Zone Labs, Inc. v. Zuccarini, FA 190613 (Nat. Arb. Forum Oct. 15, 2003) (“Respondent’s registration and use of [the <zonelarm.com> domain name] that capitalizes on the typographical error of an Internet user is considered typosquatting. Typosquatting, itself is evidence of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).”).

 

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 <baiam.com>, <faiam.com>, <fgaiam.com>, <ga8am.com>, <ga9am.com>, <gaianm.com>, <gaiasm.com>, <gaiwm.com>, <gaixm.com>, <gaizm.com>, <gfaiam.com>, <ggaiam.com>, <ghaiam.com>, <gqiam.com>, <gsaiam.com>, <gwiam.com>, <gxiam.com>, <gziam.com>, <hgaiam.com>, <raiam.com>, <vaiam.com> and <yaiam.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

Hon. Ralph Yachnin, Panelist

Justice Supreme Court NY (Ret.)

 

Dated:  January 19, 2009

 

 

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