National Arbitration Forum

 

DECISION

 

National Gardening Association Inc. v. Texas International Property Associates

Claim Number: FA0907001274880

 

PARTIES

Complainant is National Gardening Association Inc. (“Complainant”), represented by Shapleigh Smith, Jr., of Dinse, Knapp & McAndrew, P.C., Vermont, USA.  Respondent is Texas International Property Associates (“Respondent”), represented by JanPaul Guzman, of ROTHSTEIN ROSENFELDT ADLER, Florida, USA

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <nationalgardeningassociation.com>, registered with Compana, LLC.

 

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.

 

Dawn Osborne of Palmer Biggs Legal.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on July 21, 2009; the National Arbitration Forum received a hard copy of the Complaint on July 27, 2009.

 

On July 22, 2009, Compana, LLC confirmed by e-mail to the National Arbitration Forum that the <nationalgardeningassociation.com> domain name is registered with Compana, LLC and that the Respondent is the current registrant of the name.  Compana, LLC has verified that Respondent is bound by the Compana, LLC 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 July 31, 2009, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of August 20, 2009 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@nationalgardeningassociation.com by e-mail.

 

A timely Response was received and determined to be complete on August 20, 2009.

 

On enter date appointed, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Dawn Osborne as Panelist.

 

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

 

PARTIES’ CONTENTIONS

A. Complainant

 

The Complainant's contentions can be summarized as follows:

 

Complainant's Trademarks: Complainant began using the trademarks NATIONAL

GARDENING ASSOCIATION (U.S. Reg. No. 2,614,791) and NATIONAL GARDENING ASSOCIATION (U.S. Reg. No. 2,614,789) in commerce at least as early as March 15, 2000, and it registered the two trademarks on the Principal Register on September 3, 2002 (collectively, "Complainant's Trademarks").

 

Respondent's Disputed Domain Name and Website: Respondent registered the domain name <nationalgardeningassociation.com> (the "Disputed Domain Name") with Compana, LLC on May 2, 2005. (See Whois search results for <nationalgardeningassociation.com>, attached hereto as Exhibit 3.

 

Respondent's website associated with the Disputed Domain Name does not offer any goods or services. It contains hyperlinks to other pages, which in turn contain hyperlinks to various websites, including those of Complainant's competitors.

 

Respondent may earn click-through fees or other remuneration from providing hyperlinks to Complainant's competitors' websites.

 

Complainant's Cease and Desist Efforts: After learning of Respondent's registration of the Disputed Domain Name, Complainant first contacted Respondent in October 2007, requesting Respondent to cease and desist its use of the Disputed Domain Name. Respondent responded that it would refer the matter to counsel, but Complainant did not receive any communication from Respondent's counsel. Complainant again contacted Respondent in December 2007. Respondent subsequently indicated it would consent to the transfer of the Disputed Domain Name, but then Respondent failed to follow through, despite Complainant's several requests that it do so. Most recently, Complainant sent Respondent a cease and desist letter on May 28, 2009. Complainant conveyed to Respondent its concern that the Disputed Domain Name is identical or confusingly similar to Complainant's Trademarks, and its understanding that Respondent does not have a legitimate interest in the domain name. Complainant offered to pay Respondent for the administrative costs incurred in registering the Disputed Domain Name if Respondent would immediately transfer the Disputed Domain Name to Complainant. On June 3, 2009, Respondent replied that it would not transfer the Disputed Domain Name because that domain name "was created on May 2, 2005, approximately three (3) years before the dates of the Section 8 and 15 filings for the marks NATIONAL GARDENING ASSOCIATION (Reg. No. 2,614,789) and NATIONAL GARDENING ASSOCIATION (Reg. No. 2,614,791)."

 

From February 2007 to the date of this filing, Respondent has been a respondent in approximately 152 domain name disputes before the NAF, and NAF panels have concluded that the disputed domain names registered by Respondent should be transferred or cancelled in 135 of those actions.

 

[a.] The Disputed Domain Name Is Identical Or Confusingly Similar To Complainant's Trademarks.

 

The Disputed Domain Name is identical or confusingly similar to trademarks in which

Complainant has rights. ICANN Policy ¶ 4(a)(i). Here, the Disputed Domain Name consists entirely of Complainant's Trademarks NATIONAL GARDENING ASSOCIATION followed by ".com." The top level domain ".com" "is not considered in making this determination." See Alive Hospice, Inc. v. Tex. Int’l Prop. Assocs. — NA NA, FA 1211670 (Nat. Arb. Forum Aug. 14, 2008). Because "[t]he domain name wholly incorporates Complainant's [Trademark]," and because Complainant registered its Trademarks with the U.S. Patent and Trademark Office prior to Respondent's registration of the Disputed Domain Name, that domain name "is identical to or confusingly similar to a mark in which Complainant has rights." Id.

 

[b.] Respondent Has No Rights Or Legitimate Interests In Respect Of The

Disputed Domain Name.

 

Respondent has no rights or legitimate interests in respect of the Disputed Domain Name.

ICANN Rule 3(b)(ix)(2); ICANN Policy ¶ 4(a)(ii).

 

First, Respondent has not been commonly known by the Disputed Domain Name or by the mark NATIONAL GARDENING ASSOCIATION. Nothing in the WHOIS information for the Disputed Domain Name implies that Respondent is commonly known by that domain name. See Edible Arrangements, LLC v. Tex. Int'l Prop. Assocs. — NA

NA, FA 1252321 (Nat. Arb. Forum May 4, 2009) (determining that respondent did not have rights or legitimate interests with respect to domain name where it was not commonly known by the disputed domain name); see also Tercent Inc. v. Lee Yi, FA139720 (Nat. Arb. Forum Feb. 10, 2003) (noting that the WHOIS information is one factor in determining that Policy ¶ 4(c)(ii) does not apply).

 

Second, Respondent has no relationship with Complainant and has no authorization to use Complainant's trademarks. See Edible Arrangements, LLC v. Tex. Int'l Prop. Assocs. — NA NA, FA 1252321 (Nat. Arb. Forum May 4, 2009) (determining that respondent did not have rights or legitimate interests with respect to domain name where it was not authorized to use complainant's trademark in any manner); Alive Hospice, Inc. v. Texas Intl Prop. Assocs. — NA NA, FA0806001211670 (Nat. Arb. Forum Aug. 14, 2008) (noting that respondent had no rights or legitimate interest in disputed domain name where respondent had not obtained license from complainant to use complainant's trademark).

 

Third, before Respondent received notice of this dispute, Respondent had not used or made demonstrable preparations to use the Disputed Domain Name in connection with a bona fide offering of goods or services. Respondent's website associated with the Disputed Domain Name merely contains hyperlinks to other pages, which in turn contain hyperlinks to various websites, including those of Complainant's competitors. Respondent may earn click-through fees or other remuneration from providing hyperlinks to Complainant's competitors' websites.  See UnitedHealth Group Inc. v. Total Net Solutions, FA 1204916 (Nat. Arb. Forum Aug. 4, 2007) ("Previous panels have inferred commercial or financial incentive on the part of a respondent when the disputed domain name resolves to, displays links to, or advertises products or services that compete with those offered by the complainant."). This website is not a bona fide offering of goods and services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii). See Alive Hospice, Inc. v. Tex. Intl Prop. Assocs. —NA NA, FA 1211670 (Nat. Arb. Forum Aug. 14, 2008) ("Using an identical or confusingly similar domain name to redirect Internet users to a competitor's website is not a bona fide offering of goods and services."); see also E-Loan, Inc. v. Mountain States Mortgage, FA 1203425 (Nat. Arb. Forum July 29, 2008) (where respondent's domain name displayed several hyperlinks to third party websites in competition with complainant, panel inferred that respondent earned click-through fees and thus had not made bona fide offering of goods and services or a legitimate noncommercial or fair use).

 

Respondent has no rights or legitimate interests in respect of the Disputed Domain Name.

 

[c.] Respondent Has Registered And Used The Disputed Domain Name In Bad Faith.

 

Respondent has registered and used the Disputed Domain Name in bad faith by: (1) using it in order to prevent Complainant from reflecting the mark in a corresponding domain name, where Respondent has engaged in a pattern of such conduct, in violation of Policy ¶ 4(b)(ii); (2) registering the Disputed Domain Name primarily for the purpose of disrupting the business of a competitor, in violation of Policy ¶ 4(b)(iii); and (3) using the Disputed Domain Name for the purpose of intentionally attempting to attract, for commercial gain, internet users to its website by creating a likelihood of confusion with Complainant's Trademarks, in violation of Policy ¶ 4(b)(iv).

 

1. Respondent has registered the Disputed Domain Name in order to prevent Complainant from reflecting the mark in a corresponding domain name, and Respondent has engaged in a pattern of such conduct, in violation of Policy ¶ 4(b)(ii).

 

Respondent repeatedly has registered domain names containing trademarks of other complainants, those other complainants have brought UDRP actions against Respondent, and in 135 cases to date, 89% of all the cases brought, NAF panels have ordered the transfer or cancellation of Respondent's domain names. These previous actions demonstrate Respondent's pattern of registering domain names to prevent the owners of the trademarks from reflecting the marks in corresponding domain names, in violation of ICANN Policy ¶ 4(b)(ii). See Hewlett-Packard Co. v. Tex. Int'l Prop. Assocs. — NA NA, FA 1248985 (Nat. Arb. Forum Apr. 16, 2009) (determining that Respondent's previous actions show that it "has engaged in a pattern of bad faith registration and use under Policy ¶ 4(b)(ii)"); see also IMT Servs. Corp. v. Tex. Int'l Prop. Assocs. —NA NA, FA 1259913 (Nat. Arb. Forum June 15, 2009) (finding respondent's pattern of registering and using domain names containing others' trademarks, resulting in multiple UDRP proceedings where panels concluded that respondent registered and used domain names in bad faith, "evidences Respondent's bad faith registration and use of the [] domain name pursuant to Policy ¶ 4(b)(ii)"); see also Westcoast Contempo Fashions Ltd. v. Manila Indus., Inc., FA 814312 (Nat. Arb. Forum Nov. 29, 2006) (finding bad faith registration and use under Policy ¶ 4(b)(ii) where respondent had been subject to numerous UDRP proceedings where panels ordered the transfer of disputed domain names containing trademarks of complainants).

 

2. Respondent has registered the Disputed Domain Name primarily for the purpose of disrupting the business of a competitor, in violation of Policy ¶ 4(b)(iii).

 

Respondent's use of the Disputed Domain Name diverts Internet customers seeking Complainant's website to Respondent's website, which links to pages containing hyperlinks to Complainant's competitors. (See Exhibit 4.) This conduct constitutes bad faith registration and use pursuant to Policy ¶ 4(b)(iii). See IMT Servs. Corp. v. Tex. Int'l Prop. Assocs. — NA NA, FA 1259913 (Nat. Arb. Forum June 15, 2009); see also Edible Arrangements, LLC v. Tex. Intl Prop. Assocs. — NA NA, FA 1252321 (Nat. Arb. Forum May 4, 2009) (finding bad faith registration and use under Policy ¶ 4(b)(iii) where disputed domain names resolve to websites "that display links to third-party competing websites"); see also Persohn v. Lim, FA 874447 (Nat. Arb. Forum Feb. 19, 2007) (finding bad faith registration and use under Policy ¶ 4(b)(iii) where respondent used disputed domain name to operate commercial search engine with links to complainant's competitors).

 

3. Respondent, by using the Disputed Domain Name, has intentionally attempted to attract, for commercial gain, Internet users to its web site by creating a likelihood of confusion with Complainant's mark as to the source, sponsorship, affiliation, or endorsement of Respondent's website, in violation of Policy ¶ 4(b)(iv).

 

The fact that the website associated with the Disputed Domain Name links to Complainant's competitors, and that Respondent likely receives compensation for such links (see supra), evidences Respondent's bad faith registration and use of the Disputed Domain Name. See Alive Hospice, Inc. v. Tex. Intl Prop. Assocs. — NA NA, FA 1211670 (Nat. Arb. Forum Aug. 14, 2008) ("Respondent's continuing use of the name to redirect Internet users to Complainant's competitors by use of a confusingly similar name is clearly in bad faith."); see also Santarus, Inc. v. St Kitts Registry, FA 1210668 (Nat. Arb. Forum Aug. 6, 2008) ("because Respondent receives click-through fees from the hyperlinks displayed on the website that resolves from the disputed domain name Respondent commercially benefited from these fee[s], and, accordingly Respondent's practice constitutes bad faith registration and use"); see also Edible Arrangements, LLC v. Tex. Intl Prop. Assocs. — NA NA, FA 1252321 (Nat. Arb. Forum May 4, 2009) (under similar factual circumstances, determining that "Respondent is attempting to profit from the goodwill Complainant has established in its [trademark], in violation of Policy ¶ 4(b)(iv)").

 

Further, Respondent has used Complainant's Trademarks in their entirety in the Disputed Domain Name without justification. Respondent knew or should have known of

Complainant's rights in Complainant's Trademarks as those marks were registered with the U.S. Patent and Trademark Office at the time Respondent registered the Disputed Domain Name. Respondent's use of a disputed domain name that is confusingly similar with Complainant's Trademarks is an attempt to profit from the goodwill associated with

Complainant's marks, and it constitutes bad faith registration and use in violation of Policy ¶ 4(b)(iv). See Horizon Hobby, Inc. v. Lambert, FA 1176662 (Nat. Arb. Forum May 28, 2008).

 

Respondent's actions show that its registration and use of the Disputed Domain Name was in bad faith.

 

B. Respondent

 

The Respondent's contentions can be summarised as follows:

 

The Respondent agrees to the relief requested by the Complainant and offers unilateral consent to transfer.

 

Where the Complainant has sought transfer of the domain name and the Respondent consents then pursuant to paragraph 10 of the Rules the Panel can proceed immediately to make an order for transfer.

 

The Respondent requests that the Panel order the immediate transfer of the domain name. 

 

FINDINGS

The Complainant is the owner of US Registered Trade Marks for NATIONAL GARDENING ASSOCIATION and has been using the mark in commerce since 2000.

 

The Respondent registered the Domain Name on May 2, 2005 and now requests that it be transferred to the Complainant.

 

DISCUSSION

Paragraph 15(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (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.”

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;

(2) the 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 Panelist's opinion is that the Complainant has rights in a trade mark that is identical to the Domain Name for the purposes of the Policy and that the Respondent has no legitimate interest in the name and has used it in bad faith.

However, it has been held that in circumstances such as this where the Respondent has not contested the transfer of the Domain Name and agrees to transfer the Domain Name to the Complainant, the Panel may decide to forego the lengthy traditional UDRP analysis and order an immediate transfer of the domain name. See Boehringer Ingelheim Int’l GmbH v. Modern Ltd. – Cayman Web Dev., FA 133625 (Nat. Arb. Forum Jan. 9, 2003) (transferring the domain name registration where the respondent stipulated to the transfer); see also Malev Hungarian Airlines, Ltd. v. Vertical Axis Inc., FA 212653 (Nat Arb. Forum Jan. 13, 2004) (“In this case, the parties have both asked for the domain name to be transferred to the Complainant . . . Since the requests of the parties in this case are identical, the Panel has no scope to do anything other than to recognize the common request, and it has no mandate to make findings of fact or of compliance (or not) with the Policy.”); see also Disney Enters., Inc. v. Morales, FA 475191 (Nat. Arb. Forum June 24, 2005) (“[U]nder such circumstances, where Respondent has agreed to comply with Complainant’s request, the Panel felt it to be expedient and judicial to forego the traditional UDRP analysis and order the transfer of the domain names.”). The Panel also notes that the Respondent has received the benefit of legal advice. As such the Panel will order the transfer of the Domain Name to the Complainant.

DECISION

Having established all three elements required under the ICANN Policy and having reviewed the Complainant’s request for relief and the Respondent’s consent to that relief with legal advice the Panel concludes that relief shall be GRANTED.

 

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 <nationalgardeningassociation.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Dawn Osborne of Palmer Biggs Legal, Panelist
Dated: September 9, 2009

 

 

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