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DECISION

 

Travelocity.com LP v. Abadaba S.A. c/o Domain Admin a/k/a Abadaba S.A. c/o Administrador de dominios

Claim Number: FA0912001296623

 

PARTIES

Complainant is Travelocity.com LP (“Complainant”), represented by CitizenHawk, Inc., California, USA.  Respondent is Abadaba S.A. c/o Domain Admin a/k/a Abadaba S.A. c/o Administrador de dominios (“Respondent”), Pennsylvania, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <travelocety.com> and <travelowcity.com>, registered with Naugus Limited, Llc., and <travelocoty.com> and <travulocity.com>, registered with Fabulous.com Pty Ltd.

 

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 December 1, 2009; the National Arbitration Forum received a hard copy of the Complaint on December 2, 2009.

 

On December 2, 2009, Fabulous.com Pty Ltd. confirmed by e-mail to the National Arbitration Forum that the <travelocoty.com> and <travulocity.com> domain names are registered with Fabulous.com Pty Ltd., and that Respondent is the current registrant of the names.  Fabulous.com Pty Ltd. has verified that Respondent is bound by the Fabulous.com Pty Ltd. 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 3, 2009, Naugus Limited, Llc. confirmed by e-mail to the National Arbitration Forum that the <travelocety.com> and <travelowcity.com> domain names are registered with Naugus Limited, Llc., and that Respondent is the current registrant of the names.  Naugus Limited, Llc. has verified that Respondent is bound by the Naugus Limited, 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 December 14, 2009, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of January 4, 2010 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@travelocety.com, postmaster@travelocoty.com, postmaster@travelowcity.com, and postmaster@travulocity.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 11, 2010, 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 <travelocety.com>, <travelocoty.com>, <travelowcity.com>, and <travulocity.com> domain names are confusingly similar to Complainant’s TRAVELOCITY mark.

 

2.      Respondent does not have any rights or legitimate interests in the <travelocety.com>, <travelocoty.com>, <travelowcity.com>, and <travulocity.com> domain names.

 

3.      Respondent registered and used the <travelocety.com>, <travelocoty.com>, <travelowcity.com>, and <travulocity.com> domain names in bad faith.

 

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

 

FINDINGS

Complainant, Travelocity.com LP, is an online travel booking company that promotes its services under the TRAVELOCITY mark.  Complainant registered the TRAVELOCITY mark with the United States Patent and Trademark Office (“USPTO”) June 22, 1999 (Reg. No. 2,254,700).  Complainant has used the TRAVELOCITY mark continuously in commerce since at least as early as 1996, and now has over 8 million users monthly.

 

Respondent, Abadaba S.A. c/o Domain Admin aka Abadaba S.A. c/o Administrador de dominios, registered the <travelocety.com> domain name on March 26, 2002, the <travelowcity.com> domain name on April 30, 2005, the <travulocity.com> domain name on October 12, 2005, and the <travelocoty.com> domain name on January 10, 2007.  The disputed domain names resolve to a website that features links to third-party websites that compete with Complainant for business.

 

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

 

Respondent, Abadaba S.A. c/o Domain Admin aka Abadaba S.A. c/o Administrador de dominios, registered the <travelocety.com> domain name on March 26, 2002, The Panel finds that Complainant has established rights in the TRAVELOCITY mark for purposes of Policy ¶ 4(a)(i) through its trademark registration with the USPTO (Reg. No. 2,254,700 issued June 22, 1999).  See Microsoft Corp. v. Burkes, FA 652743 (Nat. Arb. Forum Apr. 17, 2006) (“Complainant has established rights in the MICROSOFT mark through registration of the mark with the USPTO.”); see also Expedia, Inc. v. Tan, FA 991075 (Nat. Arb. Forum June 29, 2007) (“As the [complainant’s] mark is registered with the USPTO, [the] complainant has met the requirements of Policy ¶ 4(a)(i).”).

 

Complainant contends that Respondent’s disputed domain names are confusingly similar to its TRAVELOCITY mark.  The <travelocety.com>, <travelocoty.com>,  and <travulocity.com> domain names differ from Complainant’s mark in only two ways: (1) in each case, a single letter has been replaced with another letter; and (2) the generic top-level domain (“gTLD”) “.com” has been added.  The <travelowcity.com> domain name likewise differs from Complainant’s mark in only two ways: (1) the single letter “w” has been added to the mark; and (2) the generic top-level domain (“gTLD”) “.com” has been added.  The Panel finds that neither the replacement, nor the addition of a single letter sufficiently distinguishes a domain name from an incorporated mark for the purposes of Policy ¶ 4(a)(i). The Panel also finds that the addition of a gTLD also does not reduce the likelihood of confusion between the domain name and the mark, because every domain name must contain a top-level domain.  Therefore, the Panel finds that these changes do not minimize or eliminate the resulting likelihood of confusion, and so Respondent’s disputed domain names are confusingly similar to Complainant’s mark pursuant to Policy ¶ 4(a)(i).  See Neuberger Berman Inc. v. Jacobsen, D2000-0323 (WIPO June 12, 2000) (finding that the respondent’s <newbergerberman.com> domain name was confusingly similar to the complainant’s NEUBERGER BERMAN mark despite the slight difference in spelling); see also Google, Inc. v. DktBot.org, FA 286993 (Nat. Arb. Forum Aug. 4, 2004) (“The mere addition of a single letter to the complainant’s mark does not remove the respondent’s domain names from the realm of confusing similarity in relation to the complainant’s mark pursuant to Policy ¶ 4(a)(i).”); see also Nev. State Bank v. Modern Ltd. – Cayman Web Dev., FA 204063 (Nat. Arb. Forum Dec. 6, 2003) (“It has been established that the addition of a generic top-level domain is irrelevant when considering whether a domain name is identical or confusingly similar under the Policy.”).

 

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.  The Panel finds that Complainant has made a prima facie case under Policy ¶ 4(a)(ii).  Respondent has not responded to the Complaint in this case.  See 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); see also Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (holding that once the complainant asserts that the respondent has no rights or legitimate interests with respect to the domain, the burden shifts to the respondent to provide “concrete evidence that it has rights to or legitimate interests in the domain name at issue”).

 

Complainant contends that Respondent is not commonly known by the disputed domain names nor has it ever been the owner or licensee of the TRAVELOCITY mark.  The WHOIS records for the disputed domain names do not indicate Respondent has ever been commonly known by any variation of the disputed domain names.  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 by the disputed domain names pursuant to Policy ¶ 4(c)(ii).  See Instron Corp. v. Kaner, FA 768859 (Nat. Arb. Forum Sept. 21, 2006) (finding that the respondent was not commonly known by the <shoredurometer.com> and <shoredurometers.com> domain names because the WHOIS information listed Andrew Kaner c/o Electromatic a/k/a Electromatic Equip't as the registrant of the disputed domain names and there was no other evidence in the record to suggest that the respondent was commonly known by the domain names in dispute); see also Am. Online, Inc. v. World Photo Video & Imaging Corp., FA 109031 (Nat. Arb. Forum May 13, 2002) (finding that the respondent was not commonly known by <aolcamera.com> or <aolcameras.com> because the respondent was doing business as “Sunset Camera” and “World Photo Video & Imaging Corp.”).

 

The disputed domain names resolve to a website that features links to websites offering the products and services of Complainant’s competitors.  The Panel finds that the use of the disputed domain names to promote Complainant’s competitors 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 Vance Int’l, Inc. v. Abend, FA 970871 (Nat. Arb. Forum June 8, 2007) (concluding that the operation of a pay-per-click website at a confusingly similar domain name does not represent a bona fide offering of goods or services or a legitimate noncommercial or fair use, regardless of whether or not the links resolve to competing or unrelated websites or if the respondent is itself commercially profiting from the click-through fees); see also Bond & Co. Jewelers, Inc. v. Tex. Int’l Prop. Assocs., FA 937650 (Nat. Arb. Forum Apr. 30, 2007) (finding that the use of the disputed domain name to operate a website displaying links to competing goods and services was not a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii)).

 

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 names, all registered in 2002 or afterwards, to divert Internet customers to the competitive websites that resolve from the confusingly similar 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 Disney Enters., Inc. v. Noel, FA 198805 (Nat. Arb. Forum Nov. 11, 2003) (“Respondent registered a domain name confusingly similar to Complainant's mark to divert Internet users to a competitor's website. It is a reasonable inference that Respondent's purpose of registration and use was to either disrupt or create confusion for Complainant's business in bad faith pursuant to Policy ¶¶ 4(b)(iii) [and] (iv).”); see also Persohn v. Lim, FA 874447 (Nat. Arb. Forum Feb. 19, 2007) (finding bad faith registration and use pursuant to Policy ¶ 4(b)(iii) where a respondent used the disputed domain name to operate a commercial search engine with links to the complainant’s competitors). 

 

Complainant also contends that Respondent is gaining commercially through this diversion, through click-through fees that Respondent is presumably receiving from its use of the disputed domain names. The Panel finds that Respondent is intentionally using the disputed domain names for commercial gain through a likelihood of confusion with Complainant’s mark, and so, pursuant to Policy ¶ 4(b)(iv), the Panel finds that this use for commercial gain also constitutes evidence of registration and use in bad faith.  See Zee TV USA, Inc. v. Siddiqi, FA 721969 (Nat. Arb. Forum July 18, 2006) (finding that the respondent engaged in bad faith registration and use by using a domain name that was confusingly similar to the complainant’s mark to offer links to third-party websites that offered services similar to those offered by the complainant); see also Asbury Auto. Group, Inc. v. Tex. Int’l Prop. Assocs., FA 958542 (Nat. Arb. Forum May 29, 2007) (finding that the respondent’s use of the disputed domain name to advertise car dealerships that competed with the complainant’s business would likely lead to confusion among Internet users as to the sponsorship or affiliation of those competing dealerships, and was therefore evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iv)).

 

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 <travelocety.com>, <travelocoty.com>, <travelowcity.com>, and <travulocity.com> domain names be TRANSFERRED from Respondent to Complainant.

 

Hon. Ralph Yachnin, Panelist

Justice, Supreme Court, NY (Ret.)

Dated:  January 25, 2010

 

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