Habitat for Humanity International, Inc. v. Colin Shields
Claim Number: FA0904001260203
Complainant is Habitat for Humanity International, Inc. (“Complainant”), represented by Alex
Fonoroff, of Kilpatrick Stockton, LLP, Georgia,
REGISTRAR AND DISPUTED DOMAIN
NAME
The domain name at issue is <habitatcareers.org>, registered with Abacus America Inc.
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.
Complainant submitted a Complaint to
the National Arbitration Forum electronically on
On
On
Having received no response from Respondent, the National Arbitration Forum transmitted to the parties a Notification of Respondent Default.
On June 3, 2009, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed the Honorable Charles K. McCotter, Jr. (Ret.) 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.
Complainant requests that the domain name be transferred from Respondent to Complainant.
A. Complainant makes the following assertions:
1. Respondent’s <habitatcareers.org> domain name is confusingly similar to Complainant’s HABITAT FOR HUMANITY mark.
2. Respondent does not have any rights or legitimate interests in the <habitatcareers.org> domain name.
3. Respondent registered and used the <habitatcareers.org> domain name in bad faith.
B. Respondent failed to submit a Response in this proceeding.
Complainant, Habitat for
Humanity International, Inc., is a nonprofit organization founded in 1976 for
the purpose of building affordable homes for low income individuals and
families. Complainant holds several
registrations of the HABITAT FOR HUMANITY mark with trademark
authorities worldwide, including the United States Patent and Trademark Office
(“USPTO”) (i.e. Reg. No. 2,169,719 issued
Respondent registered the <habitatcareers.org>
domain name on
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
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.
The Panel finds that Complainant, by registering its mark
with the USPTO, has established its rights in the HABITAT FOR HUMANITY mark
pursuant to Policy ¶ 4(a)(i). See Honeywell Int’l Inc. v. r9.net,
FA 445594 (Nat. Arb. Forum
Respondent’s <habitatcareers.org>
domain name consists of the first word of Complainant’s HABITAT FOR HUMANITY
mark, the word “careers,” and the generic top-level domain (gTLD) “.org.” The Panel finds that the disputed domain name
is confusingly similar to Complainant’s mark pursuant to Policy ¶ 4(a)(i). See Isleworth Land Co. v.
Lost in Space, SA, FA 117330 (Nat. Arb. Forum
The Panel finds that Complainant has satisfied Policy ¶ 4(a)(i).
Pursuant to Policy
¶ 4(a)(ii), Complainant must first establish a prima
facie case that Respondent has no rights or legitimate interests in the <habitatcareers.org> domain name. If
the Panel finds that Complainant’s allegations establish such a prima facie case,
the burden shifts to Respondent to show that it does indeed have rights or
legitimate interests in the disputed domain name pursuant to the guidelines in
Policy ¶ 4(c). The Panel finds
that Complainant’s allegations are sufficient to establish a prima facie case that Respondent has no
rights or legitimate interests in the <habitatcareers.org>
domain name pursuant to Policy ¶ 4(a)(ii). Since
no response was submitted in this case, the Panel may presume that Respondent
has no rights or legitimate interests in the disputed domain name. However, the Panel will still examine the
record in consideration of the factors listed in Policy ¶ 4(c). See Domtar, Inc. v. Theriault., FA 1089426 (Nat. Arb.
Forum
The Panel finds no evidence in the record suggesting that
Respondent is commonly known by the <habitatcareers.org>
domain name. Complainant asserts that
Respondent has no license or agreement with Complainant authorizing Respondent
to use the HABITAT FOR HUMANITY mark, and the WHOIS information identifies
Respondent as “Colin Shields.” Thus, Respondent has not established rights
or legitimate interests in the disputed domain name under Policy ¶ 4(c)(ii). See Coppertown Drive-Thru Sys., LLC v. Snowden, FA
715089
(Nat. Arb. Forum
The <habitatcareers.org>
domain name resolves to a website that fraudulently purports to be
Complainant’s official career opportunity website. Respondent is attempting to pass itself off as
Complainant. The Panel finds Respondent
is using the website to phish personal information from people wishing to work
for Complainant. A phishing scheme is a
practice “intended to defraud consumers into revealing personal and proprietary
information.” Capital One Fin. Corp. v. Howel, FA 289304 (Nat. Arb. Forum
The Panel finds that Complainant has satisfied Policy ¶ 4(a)(ii).
The Panel infers that the disputed domain name is being used
as part of a phishing scheme. Respondent
is attempting, or possibly has, commercially gained from the personal
information gained through its use of the confusingly similar <habitatcareers.org> domain
name. The Panel finds this constitutes
bad faith registration and use pursuant to Policy ¶ 4(b)(iv). See Juno Online Servs.,
Inc. v. Iza, FA 245960 (Nat. Arb. Forum
To engage in this phishing scheme, Respondent is attempting
to pass itself off as Complainant by imitating Complainant’s official
website. This demonstrates bad faith
registration and use pursuant to Policy ¶ 4(a)(iii). See Monsanto Co. v.
Decepticons, FA 101536 (Nat. Arb. Forum
The Panel finds that Complainant has satisfied Policy ¶ 4(a)(iii).
Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <habitatcareers.org> domain name be TRANSFERRED from Respondent to Complainant.
The Honorable Charles K. McCotter, Jr. (Ret.), Panelist
Dated: June 16, 2009
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