Thrifty, Inc. and Thrifty Rent-a-Car
System, Inc. v. Ameriasa
Claim Number: FA0211000133618
PARTIES
Complainant
is Thrifty, Inc. and Thrifty Rent-a-Car System, Inc., Tulsa, OK, USA (“Complainant”)
represented by David R. Haarz, of Dickinson Wright, PLLC. Respondent is Ameriasa, Poppel, Ravels, BELGIUM (“Respondent”).
REGISTRAR AND DISPUTED DOMAIN NAME
The
domain name at issue is <thrifty-car-rental.net>,
registered with Intercosmos Media Group,
Inc. d/b/a Directnic.com.
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.
James
A. Carmody, Esq., as Panelist.
PROCEDURAL HISTORY
Complainant
submitted a Complaint to the National Arbitration Forum (the “Forum”)
electronically on November 12, 2002; the Forum received a hard copy of the
Complaint on November 14, 2002.
On
November 12, 2002, Intercosmos Media Group, Inc.d/b/a Directnic.com confirmed
by e-mail to the Forum that the domain name <thrifty-car-rental.net> is registered with Intercosmos Media
Group, Inc. d/b/a Directnic.com and that Respondent is the current registrant
of the name. Intercosmos Media Group,
Inc. d/b/a Directnic.com has verified that Respondent is bound by the Intercosmos
Media Group, Inc. d/b/a Directnic.com 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
November 15, 2002, a Notification of Complaint and Commencement of
Administrative Proceeding (the “Commencement Notification”), setting a deadline
of December 5, 2002 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@thrifty-car-rental.net by e-mail.
Having
received no Response from Respondent, using the same contact details and
methods as were used for the Commencement Notification, the Forum transmitted
to the parties a Notification of Respondent Default.
On
December 19, 2002, pursuant to Complainant’s request to have the dispute
decided by a single-member Panel, the Forum appointed James A. Carmody, Esq.,
as Panelist.
Having
reviewed the communications records, the Administrative Panel (the “Panel”)
finds that the 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 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 name be transferred from Respondent to Complainant.
PARTIES’ CONTENTIONS
A.
Complainant
The
<thrifty-car-rental.net>
domain name is confusingly similar to Complainant's THRIFTY CAR RENTAL mark.
Respondent
has no rights or legitimate interests in the disputed domain name.
Respondent
registered and used the disputed domain name in bad faith.
B.
Respondent
Respondent
failed to submit a Response.
FINDINGS
Complainant is one of the largest car
rental companies in the United States and the world. Complainant rents cars from over 1300 locations in 58 countries
and territories. Complainant owns more
than sixteen trademark registrations with the United States Patent and
Trademark Office for THRIFTY and THRIFTY CAR RENTAL, including Registration
Number 1,566,277. Complainant also owns
trademark registrations in over seventy-five countries including the Benelux
countries (Belgium, Luxembourg and the Netherlands) (Reg. No. 427,419),
Respondent’s place of domicile.
Respondent registered the disputed domain
name on July 12, 2001. Respondent is using
the disputed domain name in order to divert Internet users to
<lowest-airfare.com>. Respondent
does not have a license or permission from Complainant to use the THRIFTY CAR
RENTAL mark.
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 the 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.
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 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
Complainant has established that it has
rights in the THRIFTY CAR RENTAL mark through registration with the United
States Patent and Trademark Office as well as registration in the Benelux
countries.
Respondent’s <thrifty-car-rental.net>
domain name is confusingly similar to Complainant’s mark because it
incorporates Complainant’s entire mark and merely adds hyphens between the
words and the generic top-level domain “.net.”
The addition of hyphens between words does not create any distinct
characteristics because Complainant’s mark is still the dominant element of the
domain name. See Easyjet
Airline Co. Ltd. v. Harding, D2000-0398 (WIPO June 22, 2000) (finding it
obvious that the domain name <easy-jet.net> was virtually
identical to Complainant's EASYJET mark and therefore that they are confusingly
similar); see also Dollar Fin. Group, Inc. v. Advanced Legal
Sys., Inc., FA 95102
(Nat. Arb. Forum Aug. 14, 2000) (finding that the domain name
<loan-mart.com> is confusingly similar to Complainant’s mark).
Furthermore, the addition of the generic
top-level domain name “.com” does not add any identifying characteristics to
the domain name because it is a required feature of all domain names. Therefore, it is irrelevant when determining
whether a domain name is confusingly similar or not. See Pomellato S.p.A
v. Tonetti, D2000-0493 (WIPO July 7, 2000) (finding <pomellato.com>
identical to Complainant’s mark because the generic top-level domain (gTLD)
“.com” after the name POMELLATO is not relevant); see also Rollerblade, Inc. v. McCrady, D2000-0429
(WIPO June 25, 2000) (finding that the top-level of the domain name such as
“.net” or “.com” does not affect the domain name for the purpose of determining
whether it is identical or confusingly similar).
The Panel finds that Policy ¶ 4(a)(i) has
been satisfied.
Rights or Legitimate Interests
Respondent has failed to come forward
with a Response. Therefore, it is
presumed that Respondent has no rights or legitimate interests in the disputed
domain name. See Pavillion Agency, Inc. v. Greenhouse Agency
Ltd., D2000-1221 (WIPO Dec. 4, 2000) (finding that Respondents’ failure to
respond can be construed as an admission that they have no legitimate interest
in the domain names).
Furthermore, when Respondent fails to
submit a Response the Panel is permitted to make all inferences in favor of
Complainant. See 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”).
Respondent is using the disputed domain
name in order to divert Internet users to <lowest-airfare.com>. Using Complainant’s mark to divert Internet
users to an unconnected website is not considered to be a use in connection
with 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). See Vapor Blast Mfg. Co. v. R & S Tech., Inc., FA 96577 (Nat. Arb.
Forum Feb. 27, 2001) (finding that Respondent’s commercial use of the domain
name to confuse and divert Internet traffic is not a legitimate use of the
domain name); see also N. Coast
Med., Inc. v. Allegro Med., FA 95541 (Nat. Arb. Forum Oct. 2, 2000)
(finding no bona fide use where Respondent used the domain name to divert
Internet users to its competing website).
There is no evidence on record that
Respondent is known by any other name than Ameriasa. Respondent has not come forward with any evidence to establish
that it is commonly known as THRIFTY-CAR-RENTAL or <thrifty-car-rental.net>,
therefore the Panel finds that Respondent has failed to establish that it has
any rights or legitimate interests in the disputed domain name pursuant to
Policy ¶ 4(c)(ii). See Gallup Inc. v. Amish Country Store, FA
96209 (Nat. Arb. Forum Jan. 23, 2001) (finding that Respondent does not have
rights in a domain name when Respondent is not known by the mark); see also
Charles Jourdan Holding AG v. AAIM, D2000-0403 (WIPO June 27, 2000) (finding no
rights or legitimate interests where (1) Respondent is not a licensee of
Complainant; (2) Complainant’s prior rights in the domain name precede
Respondent’s registration; (3) Respondent is not commonly known by the domain
name in question).
The Panel finds that Policy ¶ 4(a)(ii)
has been satisfied.
Registration and Use in Bad Faith
Respondent is using a confusingly similar
domain name to divert Internet users to <lowest-airfare.com>. It can be inferred that Respondent is making
a profit from the Internet traffic that it is diverting to this website. Therefore, Respondent is causing a
likelihood of confusion for its own commercial gain, which is evidence of bad
faith registration and use pursuant to Policy ¶ 4(b)(iv). See Kmart v. Kahn, FA 127708 (Nat.
Arb. Forum Nov. 22, 2002) (finding that if Respondent profits from its
diversionary use of Complainant's mark when the domain name resolves to
commercial websites and Respondent fails to contest the Complaint, it may be
concluded that Respondent is using the domain name in bad faith pursuant to
Policy 4(b)(iv)); see also Drs.
Foster & Smith, Inc. v. Lalli, FA 95284 (Nat. Arb. Forum Aug. 21, 2000)
(finding bad faith where Respondent directed Internet users seeking
Complainant’s site to its own website for commercial gain).
Based on the fame of Complainant’s mark
and its registrations in the Benelux countries where Respondent resides, it can
be inferred that Respondent had knowledge of Complainant’s mark before it
registered the disputed domain name.
Registration of a domain name, despite actual or constructive knowledge
of Complainant’s rights, is evidence of bad faith registration pursuant to
Policy ¶ 4(a)(iii). See Digi Int’l
v. DDI Sys., FA 124506 (Nat. Arb. Forum Oct. 24, 2002) (holding that “there
is a legal presumption of bad faith, when Respondent reasonably should have
been aware of Complainant’s trademarks, actually or constructively”); see
also Entrepreneur Media, Inc. v. Smith, 279 F.3d 1135,
1148 (9th
Cir. Feb. 11, 2002) (finding that "[w]here an alleged infringer chooses a
mark he knows to be similar to another, one can infer an intent to
confuse").
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 the requested relief
shall be hereby GRANTED.
Accordingly, it is Ordered that the
domain name <thrifty-car-rental.net>
be TRANSFERRED from Respondent to Complainant.
James A. Carmody, Esq., Panelist
Dated: December 30, 2002
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