National Arbitration Forum

 

DECISION

 

Jim Butler Imports LLC and Jim Butler Chevrolet, Inc. v. Vickie Poucher

Claim Number: FA1007001334670

 

PARTIES

Complainant is Jim Butler Imports LLC and Jim Butler Chevrolet, Inc. (“Complainant”), represented by Dan Cohn, Missouri, USA.  Respondent is Vickie Poucher (“Respondent”), Missouri, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAMES 

The domain names at issue are <jimbutlerkia.com> and <jimbutlermitsubishi.com>, registered with GoDaddy.com, Inc.

 

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.

 

David S. Safran, as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on July 12, 2010.

 

On July 12, 2010, GoDaddy.com, Inc. confirmed by e-mail to the National Arbitration Forum that the <jimbutlerkia.com> and <jimbutlermitsubishi.com> domain names are registered with GoDaddy.com, Inc. and that the Respondent is the current registrant of the names.  GoDaddy.com, Inc. has verified that Respondent is bound by the GoDaddy.com, 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 July 19, 2010, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 9, 2010 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent’s registration as technical, administrative, and billing contacts, and to postmaster@jimbutlerkia.com and postmaster@jimbutlermitsubishi.com.  Also on July 19, 2010, the Written Notice of the Complaint, notifying Respondent of the email addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent’s registration as technical, administrative and billing contacts.

 

A timely Response was received and determined to be complete on July 28, 2010.

 

Complainant’s Additional Submission was timely received on July 30, 2010 in compliance with Supplemental Rule 7.

 

On August 6, 2010, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed David S. Safran, as Panelist.

 

In response to an Order from the Panel, a Supplemental Submission was received was received on August 16, 2010.

 

 

RELIEF SOUGHT

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

 

PARTIES’ CONTENTIONS

A. Complainant

Complainant alleges that it has rights in the name Jim Butler due to its operation of vehicle dealerships bearing that name as part of the dealership names for more than 40 years and in the immediate past ten years has spent over $6 Million on advertising for the

various Jim Butler car dealerships and their services and owns websites with domain names that include Jim Butler as part thereof.

 

Complainant also asserts that the domain names at issue, <jimbutlerkia.com> and <jimbutlermitsubishi.com>, are confusingly similar to its Jim Butler marks being incorporated as a whole therein.

 

In addition, Complainant contends that Respondent has no legitimate rights or interests in the disputed domain names since Respondent is not commonly known by either of the domain names, the websites at the disputed domain names are not associated with anyone named Jim Butler and are merely "link farms" containing "Sponsored Links" and "Related Searches" that link to websites of car dealerships that are direct competitors of Complainants.

 

B. Respondent

Respondent did not submit a formal response, but rather merely submitted an e-mail with some general comments.  As best can be determined from Respondent’s comments, it is Respondent’s contention that, since at the time that the disputed domain names were registered, the automobile dealerships Jim Butler Kia and Jim Butler Mitsubishi did not even exist, Respondent’s registration of the disputed domain names could not be in bad faith. It also appears that the Respondent is alleging that the name Jim Butler is not a protected trademark since numerous other domain names exist of which the name Jim Butler forms a part, such as:  <www.jimbutlerinn.com>, <www.jimbutlerfineart.com>, <www.jimbutlermusic.com> and <www.jimbutlerconst.com>.

 

C. Additional Submissions

While still failing to make a positive averment of use of the contested domain names in bad faith (as contrast with registration in bad faith), Complainant has averred facts which evidence use of the domains as “link farms” in bad faith and has cited case relating to bad faith use of a website.

 

FINDINGS

Complainant Jim Butler Chevrolet, Inc. has been using the JIM BUTLER name in

connection with car dealerships for more than 40 years and in conjunction with heavy advertisement the name Jim Butler has acquired secondary meaning in the automotive market. The phrases "jimbutlerkia" and "jimbutlermitsubishi" in the Disputed Domain Names completely encompass the mark JIM BUTLER. The registration of the disputed domain names in close proximity to commencement of business of the Jim Butler Kia and Mitsubishi dealerships raises an inference of knowledge of at least impending commencement of those automotive franchises. Respondent is not commonly known by either of the domain names <jimbutlerkia.com> or <jimbutlermitsubishi.com>. The web sites at <jimbutlerkia.com> and <jimbutlermitsubishi.com> contain only "link farms" containing "Sponsored Links" and "Related Searches" that link to websites of other Kia® and Mitsubishi® car dealerships and to local Nissan, GMC and Chevrolet dealerships which are in direct competition with Complainant. Respondent has a history of registering domain names containing trademarks of third parties with whom Respondent has no known connection.

 

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.

 

Identical and/or Confusingly Similar

The Panel finds that Complainant is not required to have a trademark registered with a governmental trademark authority in order to have rights in the mark so long as Complainant can establish sufficient secondary meaning in the mark to demonstrate common law rights.  See Zee TV USA, Inc. v. Siddiqi, FA 721969 (Nat. Arb. Forum July 18, 2006) (finding that the complainant need not own a valid trademark registration for the ZEE CINEMA mark in order to demonstrate its rights in the mark under Policy ¶ 4(a)(i)); see also Artistic Pursuit LLC v. calcuttawebdevelopers.com, FA 894477 (Nat. Arb. Forum Mar. 8, 2007) (finding that Policy ¶ 4(a)(i) does not require a trademark registration if a complainant can establish common law rights in its mark).

 

Complainant asserts that it has used the JIM BUTLER mark in connection with car dealerships for over 40 years, beginning in 1968.  Complainant indicates that it operates dealerships under the JIM BUTLER KIA and JIM BUTLER MITSUBISHI marks.  Complainant alleges that from the year 2000 through the present, it has spent over $6 million on advertising for its various JIM BUTLER dealerships and their services.  Complainant further alleges that its JIM BUTLER dealerships have grossed tens of millions of dollars in sales in that same time.  The Panel finds that Respondent’s extensive advertising and sales are sufficient evidence of Complainant’s acquired secondary meaning in the JIM BUTLER mark and as such, that Complainant has common law rights in the JIM BUTLER mark pursuant to Policy ¶ 4(a)(i).  See Ass’n of Tex. Prof’l Educators, Inc. v. Salvia Corp., FA 685104 (Nat. Arb. Forum May 31, 2006) (holding that the complainant had demonstrated common law rights in the ATPE mark through continuous use of the mark in connection with educational services for over twenty-five years); see also Jerry Damson, Inc. v. Tex. Int’l Prop. Assocs., FA 916991 (Nat. Arb. Forum Apr. 10, 2007) (finding that the complainant had common law rights in the JERRY DAMSON ACURA mark because it provided sufficient evidence of its continuous use of the mark since 1989 in connection with a car dealership).

 

Complainant asserts that Respondent’s <jimbutlerkia.com> and <jimbutlermitsubishi.com> domain names are confusingly similar to Complainant’s JIM BUTLER mark.  Complainant further asserts that Respondent deletes the space between the terms in Complainant’s mark and merely adds the descriptive terms “kia” and “mitsubishi,” as well as the generic top-level domain (“gTLD”) “.com” to the entirety of Complainant’s mark.  The Panel finds that these alterations are not sufficient to distinguish Respondent’s disputed domain names from Complainant’s mark.  See Bond & Co. Jewelers, Inc. v. Tex. Int’l Prop. Assocs., FA 937650 (Nat. Arb. Forum Apr. 30, 2007) (finding that the elimination of spaces between terms and the addition of a gTLD do not establish distinctiveness from the complainant’s mark under Policy ¶ 4(a)(i); see also Kohler Co. v. Curley, FA 890812 (Nat. Arb. Forum Mar. 5, 2007) (finding confusing similarity where <kohlerbaths.com>, the disputed domain name, contained the complainant’s mark in its entirety adding “the descriptive term ‘baths,’ which is an obvious allusion to complainant’s business.”); see also Miller Brewing Co. v. Domain Active Pty. Ltd., FA 243606 (Nat. Arb. Forum Apr. 23, 2004) (finding that the <millerbeers.com> domain name was confusingly similar to the complainant’s MILLER mark, because “[t]he addition of a descriptive term that describes Complainant’s business to Complainant’s registered mark, does not remove the domain from the realm of confusing similarity  with regard to Policy ¶ 4(a)(i).”); see also Jerry Damson, Inc. v. Tex. Int’l Prop. Assocs., FA 916991 (Nat. Arb. Forum Apr. 10, 2007) (“The mere addition of a generic top-level domain (“gTLD”) “.com” does not serve to adequately distinguish the Domain Name from the mark.”).

Rights or Legitimate Interests

Complainant argues that Respondent is not commonly known by either of the disputed domain names.  Complainant further argues that Respondent has no legitimate claim to any trademark or service mark rights to either the <jimbutlerkia.com> and <jimbutlermitsubishi.com> domain names.  The WHOIS information for both disputed domain names lists the registrant as “Vickie Poucher” which the Panel finds is not similar to the disputed domain names.  Therefore, the Panel finds that, without evidence to the contrary, Respondent is not commonly known by the disputed domain names pursuant to Policy ¶ 4(c)(ii).  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 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).

 

Complainant asserts that Respondent’s <jimbutlerkia.com> and <jimbutlermitsubishi.com> domain names resolve to websites that contain only “link farms” containing links to the websites of other Kia and Mitsubishi car dealerships that are direct competitors of Complainant.  The Panel finds that Respondent’s use of the disputed domain names for such a purpose is not a bona fide offering of goods and services pursuant to Policy ¶ 4(c)(i) nor a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).  See Tesco Pers. Fin. Ltd. v. Domain Mgmt. Servs., FA 877982 (Nat. Arb. Forum Feb. 13, 2007) (finding that the respondent was not using the <tesco-finance.com> domain name in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use by maintaining a web page with misleading links to the complainant’s competitors in the financial services industry); see also Persohn v. Lim, FA 874447 (Nat. Arb. Forum Feb. 19, 2007) (finding that the respondent was not using a disputed domain name in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use by redirecting Internet users to a commercial search engine website with links to multiple websites that may be of interest to the complainant’s customers and presumably earning “click-through fees” in the process).

 

Registration and Use in Bad Faith

Complainant argues that Respondent registered, and is using, the disputed domain names in an attempt to disrupt Complainant’s business.  The Panel finds that Respondent’s registration of the domains in close proximity to the commencement of business of Complainant’s Kia and Mitsubishi dealerships coupled with Respondent’s established practice of registering domains containing the marks of third parties with whom no connection exists evidences registration in bad faith; as to past conduct as evidence of bad faith registration, see: The Washington Post Company and Washingtonpost.Newsweek Interactive Company LLC v. Wasingtonpost.com aka Washingtonpos.com aka weatherpos.com, FA0112000102968 (Nat. Arb. Forum Feb. 5, 2002); Twentieth Century Fox Film Corporation v. Cupcake Confidential a/k/a John Zuccarini, FA0011000096118 (Nat. Arb. Forum Jan. 18, 2001); see also Gamesville.com, Inc. v. Zuccarini, FA 95294 (Nat. Arb. Forum Aug. 30, 2000), and Respondent’s use of the disputed domain name to display links to car dealerships that directly compete with Complainant is evidence of Respondent’s use in bad faith pursuant to Policy ¶ 4(b)(iii).  See Tesco Pers. Fin. Ltd. v. Domain Mgmt. Servs., FA 877982 (Nat. Arb. Forum Feb. 13, 2007) (concluding that the use of a confusingly similar domain name to attract Internet users to a directory website containing commercial links to the websites of a complainant’s competitors represents bad faith registration and use under Policy ¶ 4(b)(iii)); 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 argues that Respondent’s registration and use of the disputed domain names to display competing links to Complainant’s competitors in the car dealership industry will likely create confusion among Internet users who are searching for information on Complainant’s car dealerships.  The Panel may find that Respondent’s registration of the confusingly similar disputed domain names is evidence of Respondent’s bad faith under Policy ¶ 4(b)(iv).  See Perot Sys. Corp. v. Perot.net, FA 95312 (Nat. Arb. Forum Aug. 29, 2000) (finding bad faith where the domain name in question is obviously connected with the complainant’s well-known marks, thus creating a likelihood of confusion strictly for commercial gain); see also Identigene, Inc. v. Genetest Labs., D2000-1100 (WIPO Nov. 30, 2000) (finding bad faith where the respondent's use of the domain name at issue to resolve to a website where similar services are offered to Internet users is likely to confuse the user into believing that the complainant is the source of or is sponsoring the services offered at the site).

 

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 <jimbutlerkia.com> and <jimbutlermitsubishi.com> domain names be TRANSFERRED from Respondent to Complainant.

 

                                               

David S. Safran, Panelist
Dated: August 31, 2010

 

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