National Arbitration Forum

 

DECISION

 

Disney Enterprises, Inc. v. ll

Claim Number: FA1007001336979

 

PARTIES

Complainant is Disney Enterprises, Inc. (“Complainant”), represented by J. Andrew Coombs, of J. Andrew Coombs, A Professional Corporation, California, USA.  Respondent is ll, a.k.a. Joe Comeau, Florida, USA (“Respondent”).

 

REGISTRAR AND DISPUTED DOMAIN NAME 

The domain name at issue is <disneyoffer.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.

 

Paul M. DeCicco, as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on July 22, 2010.

 

On July 23, 2010, Godaddy.com, Inc. confirmed by e-mail to the National Arbitration Forum that the <disneyoffer.com> domain name is registered with Godaddy.com, Inc. and that the Respondent is the current registrant of the name.  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 28, 2010, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 17, 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@disneyoffer.com.  Also on July 28, 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 August 16, 2010.

 

 

On August 24, 2010, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Paul M. DeCicco as Panelist.

 

RELIEF SOUGHT

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

 

PARTIES’ CONTENTIONS

A.     Complainant

Complainant contends as follows:

 

Complainant Disney Enterprises, Inc., and/or its affiliated companies has been for many years the owner of hundreds of registrations for the DISNEY® trademark and other trademarks (collectively "Trademarks"), in countries all over the world. Complainant owns rights in a variety of trademarks registered with the USPTO, most notable of which is the DISNEY® mark (Reg. No. 1,162,727 issued on July 28, 1981).

 

The Trademarks are so widely accepted in the mind of the general public that the Trademarks have become unquestionably famous and distinctive and have acquired secondary meaning and distinctiveness throughout the United States and around the world.

 

Complainant’s mark is confusingly similar to the Trademarks, as it incorporates the Trademarks in their entirety, merely adding a generic word "offer" to the Trademark.

 

Respondent has no legitimate interest in the domain name. Respondent is not authorized by Complainant to use the domain name. Respondent's use of the domain name does not and cannot constitute a bona fide offering of goods or services since Respondent is using the domain name to trade on the Complainant’s mark. Further, Complainant has not authorized Respondent to use its Trademarks or to seek the registration of any domain name incorporating the Trademarks. Respondent must have known when it selected the disputed domain name that the public would incorrectly associate it with Complainant and Complainant's marks. In fact, given the distinctiveness and fame of the Trademarks, there is no plausible explanation for the Respondent's registration of the domain name other than to trade upon the goodwill the Complainant has developed in its Trademarks.

 

Additionally, the domain name is currently parked. Respondent's passive holding of the website for almost five years evidences a lack of legitimate rights.

 

Lastly, Respondent is not and has not been commonly known by the domain name. Respondent does not use the Trademarks to identify himself on the websites or for any other legitimate purpose. Even if Respondent has used the trade names, such an unauthorized use does not establish legitimate interest in the domain name.  Thus, Respondent has no legitimate interest in the domain name.

 

Respondent registered and uses the domain name in bad faith. First, the fame of the Trademarks combined with widespread marketing of Complainant's goods and services and the registration of the Trademarks put Respondent on notice of Complainant's Trademarks. The Trademarks are so internationally distinctive and famous Respondent must have had actual knowledge of the Trademarks prior to the domain name registration.

 

Second, by registering the domain name with actual knowledge of Complainant's Trademarks, Respondent acted in bad faith by breaching its service agreement with the registrar because Respondent falsely represented that the registration does not "infringe on the intellectual property rights of another User or any other person or entity." Thus, the registration constituted bad faith under the UDRP. Respondent's false representation that its domain name did not infringe the rights of any third party as proof of bad faith.

 

Respondent's use of the confusingly similar domain name to intentionally attract Internet users and profit through the receipt of click-through fees by creating a strong likelihood of confusion with Complainant's DISNEY mark is evidence of bad faith pursuant to Section 4(b)(iv) of the UDRP policy.

 

Since Complainant owns the Trademarks, Respondent's registration and use is in bad faith as it failed to check whether the Trademarks were registered prior to his registration of the domain name.

 

Respondent also evidences bad faith in its failure to cease and desist from wrongful use of the domain name by not transferring the wrongfully acquired domain name after being notified by Complainant of the unauthorized use.

 

Further, bad faith should be found where, as here, Respondent has established a pattern of conduct by registering multiple domain names which appear to infringe other famous trademarks including "eBay," "Chevy," "Microsoft," "Earthlink," "George Foreman," "Michael Jordan" and more.

 

B. Respondent

Respondent contends as follows:

 

The domain name <disneyoffer.com> has nothing to do with Complainant. Respondent does not sell any Disney products on this site. The site is not built. It is only parked at GoDaddy.com.
 

Respondent has never used the domain name <disneyoffer.com> to solicit the Disney Brand or sell any products in association with Walt Disney. Respondent has the name only parked at GoDaddy.com and the GoDaddy website puts corresponding links relating to whatever the domain name resembles the most. Respondent did not obtain this domain name in bad faith or in order to exploit their company in any way.

 

Since the Walt Disney Company was contacting Respondent in their interest to obtain the disputed domain name, Respondent offered to turn over the disputed domain name to Complainant for fair market value. Respondent has held onto the name for several years and has had renewal fees associated with this domain.

 

Just because Complainant holds onto the name “disney” it does not have the right to squash and try to control every other holder of the word “disney” in the English speaking community or every domain name with the word “disney” in it. They own the market and brand name, but they do not own the word “disney” across the entire English language as long as those interests pose no threat or try to infringe upon their business.

 

 If Respondent has to turn over the domain name to Complainant, it should at least in good faith have to give Respondent the renewal fees paid over the past few years.

 

FINDINGS

Complainant has rights in the trademark DISNEY by virtue of its registration of said mark with the United States Patent and Trademark Office and otherwise.

 

At the time the time Respondent registered the disputed domain name, Respondent knew of Complainant’s trademark rights in DISNEY.

 

The registrant is listed on the WHOIS record as “II.”

 

A “Joe Comeau” responded to the Complaint.

 

The website referenced by the at-issue domain name contains links to Complainant’s competitors.

 

Respondent’s out-of-pocket costs with regard to the at-issue domain name are less than $100.

 

Respondent offered the at-issue domain for sale on the registrar’s website for a starting bid of $2,500.

 

Respondent offered to sell the at-issue domain name to the Complainant after Respondent became aware of the dispute.

 

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

 

Complainant registered its DISNEY mark with the United States Patent and Trademark Office (“USPTO”) (e.g. Reg. No. 1,162,727 issued July 28, 1981). Complainant’s registration of its DISNEY mark is sufficient evidence of Complainant’s rights in the mark under Policy ¶ 4(a)(i).  See 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).”); see also 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.”).

 

The at-issue domain name wholly contains Complainant’s well-known trademark. Concatenating the dictionary word “offers” to Complainant’s mark forms the entire second level domain name and this addition along with the further addition of the required top level domain (TLD), here “.com,” is insufficient to differentiate the domain name from the Complainant’s trademark for the purposes of Policy ¶4(a). See Warner Bros. Entm’t Inc. v. Rana, FA 304696 (Nat. Arb. Forum Sept. 21, 2004) (finding that the addition of the generic term “collection” to Complainant’s HARRY POTTER mark failed to distinguish the domain name from the mark); see also Hannover Ruckversicherungs-AG v. Ryu, FA 102724 (Nat. Arb. Forum Jan. 7, 2001) (finding <hannoverre.com> to be identical to HANNOVER RE, “as … a generic top-level domain such as ‘.com’ or ‘.net’ is required in domain names”).

 

Therefore, under Policy ¶4(a)i the disputed domain name is confusingly similar to a mark in which Complainant has rights.

 

Rights or Legitimate Interests

 

The practical analysis of Policy ¶ 4(a)(ii) is two‑tiered. Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in the disputed domain name. The threshold for such showing is low.  See Hanna-Barbera Prods., Inc. v. Entm’t Commentaries, FA 741828 (Nat. Arb. Forum Aug. 18, 2006) (holding that the complainant must first make a prima facie case that the respondent lacks rights and legitimate interests in the disputed domain name under UDRP ¶ 4(a)(ii) before the burden shifts to the respondent to show that it does have rights or legitimate interests in a domain name).  Once Complainant establishes a prima facie case the burden effectively shifts to Respondent who must demonstrate that he nevertheless has rights and legitimate interests in the at-issue domain name.

 

Respondent is not commonly known by the disputed domain name.  Complainant has not authorized Respondent to use its mark or to register a domain name incorporating Complainant’s mark.  WHOIS information identifies the registrant as “II,” and indicates that Respondent is not commonly known by the disputed domain name pursuant to Policy ¶ 4(c)(ii).  See Braun Corp. v. Loney, FA 699652 (Nat. Arb. Forum July 7, 2006) (concluding that the respondent was not commonly known by the disputed domain names where the WHOIS information, as well as all other information in the record, gave no indication that the respondent was commonly known by the disputed domain names, and the complainant had not authorized the respondent to register a domain name containing its registered mark); 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). Therefore Complainant has met its small initial burden.

 

Respondent offers no evidence which might tend to show that he has rights in respect of  the domain name pursuant to Policy ¶4(c), or otherwise. Respondent offers no explanation as to why he registered a domain name which overtly references Complainant’s DISNEY trademark and he admits he has not built a website associated with the disputed domain name. Respondent states that the webpage referenced by the at-issue domain name is merely a holding page provided by the registrar, Go-Daddy. Respondent makes no claims regarding any intended use for the domain name.  Furthermore, Respondent makes no claims that he is somehow making a legitimate non-commercial or fair use of the domain name. 

 

The Panel thus finds that Respondent has no rights and legitimate interests in respect of the disputed domain name.

 

 

Registration and Use in Bad Faith

 

Complainant’s DISNEY trademark is well known throughout the United States and abroad. Although Respondent claims to have not acted in bad faith he nevertheless fails to offer any explanation whatsoever for registering <disneyoffer.com>.  Similarly, Respondent does not explain why he used “II” as the name of the registrant although the apparent real party-in-interest, Joe Comeau, is listed as administrative contact and technical contact in the registration record. Joe Comeau, as an individual, signed the first-person voiced Response.

 

Respondent surely knew of the Complainant’s trademark in DISNEY at the time he registered the disputed domain name and thus his silence regarding the reasons for registering the disputed domain name is telling. It suggests that Respondent registered the disputed domain name precisely for its trademark value, rather than in spite of it. Indeed, Respondent is no stranger to registering domain names which appear to infringe well-known trademarks including EBAY and CHEVY among others.  Therefore, the Panel agrees with Complainant. Respondent acted in bad faith by breaching its service agreement with the registrar. Respondent falsely represented that registering the disputed domain name did not infringe on the intellectual property rights of another User or any other person or entity when he knew or should have known that it did.

 

Furthermore, after receiving Complainant’s “cease and desist” letter, Respondent offered to sell the disputed domain name to Complainant for an unspecified amount.  Perhaps more importantly the record shows, and Respondent does not deny that the disputed domain name was publically offered for sale via the registrar’s web-based auction facility. The starting bid was listed as $2,500. Thus there can be no conclusion that Complainant instigated Respondent’s offer to sell or that Respondent’s offer was an attempt to settle the parties’ dispute and as such an offer-in -compromise that is arguably  outside the purview of Policy ¶4(b)(i).   Notably, the amount Respondent listed as a starting bid for the disputed domain name is far in excess of Respondent’s out-of-pocket costs. By Respondent’s admission those costs are equal to no more than a few years of registration fees. And even if Respondent’s offer to sell were not specific as to price, a general offer to sell a disputed domain name to a complainant is nonetheless evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(i).  ¶(b)I See Am. Online, Inc. v. Avrasya Yayincilik Danismanlik Ltd., FA 93679 (Nat. Arb. Forum Mar. 16, 2000) (finding bad faith where the respondent offered domain names for sale); see also Am. Anti-Vivisection Soc’y v. “Infa dot Net” Web Serv., FA 95685 (Nat. Arb. Forum Nov. 6, 2000) (finding that “general offers to sell the domain name, even if no certain price is demanded, are evidence of bad faith”).  

 

Although Respondent claims that the disputed domain name resolves to a parking website and its content is outside of his control, in the instant case where there is a famous trademark involved and Respondent shows no concern for the rights of trademark holder this Panel finds that Respondent is ultimately responsible for any offending material on his website as if he placed the material there himself. One who registers a famous mark in in whole or in part should in effect “inspect and make safe” any website referenced by such domain name to be sure there is no infringement. He is accountable when he does not and the website infringes another’s trademark.  See generally, Gold Medal Travel Grp. plc v. Kruzicevic, D2007-1902 (WIPO Mar. 12, 2008) (where the disputed domain name had been parked, the panel found the “the Registrant is responsible for the content of the material appearing on the webpage associated with the domain name in dispute.”). Therefore, Respondent’s registration and use of the disputed domain name, a domain name that resolves to a website featuring links to third-parties offering  goods and services that compete with Complainant is further evidence of Respondent’s bad faith pursuant to Policy ¶4(b)(iii).  See 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); see also St. Lawrence Univ. v. Nextnet Tech, FA 881234 (Nat. Arb. Forum Feb. 21, 2007) (“This Panel concludes that by redirecting Internet users seeking information on Complainant’s educational institution to competing websites, Respondent has engaged in bad faith registration and use pursuant to Policy ¶ 4(b)(iii).”). 

 

Given the forgoing, the Panel finds that Respondent registered and used <disneyoffer.com> in bad faith.

 

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

 

 

Paul M. DeCicco, Panelist
Dated: August 31, 2010

 

 

Click Here to return to the main Domain Decisions Page.

 

Click Here to return to our Home Page

 

National Arbitration Forum