DECISION

 

Jim Vitello d/b/a Caution Brand Apparel v. Michael Castello a/k/a Traveler.com LLC

Claim Number: FA0305000159460

 

PARTIES

 

Complainant is Jim Vitello d/b/a Caution Brand Apparel, Covina, CA (“Complainant”). Respondent is Michael Castello a/k/a Traveler.com LLC, Palm Springs, CA (“Respondent”).

 

REGISTRAR AND DISPUTED DOMAIN NAME

 

The domain name at issue is <caution.com> registered with Enom, Inc.

 

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.

 

Hon. Charles A. Kuechenmeister (Ret.) is the Panelist.

 

PROCEDURAL HISTORY

 

Complainant submitted a Complaint to the National Arbitration Forum (the “Forum”) electronically on May 28, 2003; the Forum received a hard copy of the Complaint on May 30, 2003.

 

On June 2, 2003, Enom, Inc. confirmed by e-mail to the Forum that the domain name <caution.com> is registered with Enom, Inc. and that the Respondent is the current registrant of the name. Enom, Inc. has verified that Respondent is bound by the Enom, 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 June 5, 2003, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of June 25, 2003 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@caution.com by e-mail.

 

A timely Response was received and determined to be complete on June 9, 2003.

 

Complainant filed an additional submittal on June 11, 2003.  It was timely received and was considered by the Panel.

 

Respondent filed an additional submittal on June 15, 2003.  It was timely received and was considered by the Panel.

 

On June 17, 2003, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the Forum appointed Hon. Charles A. Kuechenmeister (Ret.) as Panelist.

 

RELIEF SOUGHT

 

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

 

PARTIES’ CONTENTIONS

 

A.        Complainant

 

Complainant is the owner of U.S. Trademark Registration No. 2,195,828 for CAUTION!, and U.S. Trademark Registration No. 2,197,839 for CAUTION! UNDERWEAR, with CAUTION written in a diamond-shaped box resembling a traffic control sign.  Both trademarks show registration dates in October 1998 and first use in December 1996.  The CAUTION! and CAUTION! UNDERWEAR marks are for men's and women's clothing, namely, boxer shorts, boxer briefs, briefs, thongs, lingerie, pajamas, nightshirts, robes and swimwear, in Class 25.

 

Complainant has used the CAUTION! marks since December 1, 1996 in connection with clothing and apparel products, including but not limited to, products such as underwear and tee shirts.  Complainant distributes the CAUTION! brand of goods through non- exclusive licensee’s, specialty chains, discount chains, department store chains and through the CAUTION! websites.  Complainant owns the domains: <caution.us>, <cautionunderwear.com>, <cautionusa.com>, <cautionkids.com>, <cautionwear.com>, <cautionchick.com> and <cautionchicks.com>.   As a result of, among other things, CAUTION!’s continuous use, exclusive use and magazine and television promotion, the CAUTION! Marks are known as identifying Complainant’s exclusive brand of CAUTION! consumer goods.  Thus, Complainant’s CAUTION! marks have acquired a large amount of goodwill and distinctiveness due to the longstanding sales of goods provided to consumers under the trademarked “CAUTION!” brand of goods.

 

Hundreds of thousands of dollars have been spent protecting and building the CAUTION! brand and thousands of units have sold weekly in stores across the USA and millions of consumers have seen the CAUTION! brand name in stores and on nationwide television.

 

The domain name <caution.com>, (the “subject domain name” or “domain name”) fully incorporate Complainant’s CAUTION! mark and the CAUTION! brand name, and is identical to the Complainant’s CAUTION! Mark.  It is thus confusingly similar to Complainant's CAUTION! trademark.

 

Upon information and belief, Respondents have no trademark or intellectual property rights or other legitimate interest in the subject domain name.

 

On January 6, 2000 and September 15, 2000, Complainant sent Respondent notices of its CAUTION! marks and demands that Respondent cease and desist using the <caution.com> domain name.  Respondent has failed and refused to cease using the same.

 

Complainant has never authorized, licensed, or otherwise permitted the Respondent to use the <caution.com> domain name or any of its trademarks.

 

The Respondent registered and is using <caution.com> in bad faith.

 

Respondent registered and has used the subject domain name in connection with its business activities related to the travel industry.  It uses <caution.com> as the name for a website that immediately sends visitors to its related <traveler.com> website, with its links or banner ads to travel and other related services.

 

Respondent is trading on Complainant's goodwill to divert traffic to book airfares, hotel rooms and to sell advertising on its websites which are linked to <caution.com>.

 

Respondent is intentionally creating consumer confusion and attempting to direct for itself web traffic that is rightfully intended for Complainant.

 

Respondent is attempting to reap financial gain from selling the subject domain name for a price that is well in excess of what he paid to register the same and is actually selling advertisements for same on his linked websites.

 

Respondent has registered the <caution.com> domain name in order to prevent the Complainant, as the owner of the CAUTION! trademark, from reflecting that mark in a corresponding domain name and has engaged in a pattern of such conduct.

 

Respondent is not using the subject domain name in connection with the bonafide offering of goods and services.

 

On the date that Respondent registered the subject domain name, it had at least constructive notice of Complainant's use of the CAUTION! trademark in that some five days prior to the registration, Complainant ran full page advertisements in magazines targeted to Palm Springs, Laguna Beach, Los Angeles and San Diego, areas where Respondent maintains a presence.  It is probable that Respondent saw these ads and registered its domain name in an attempt to trade on Complainant's advertising and notoriety.

 

B.        Respondent

 

Many other entities have registered U.S. trademarks using the word "caution."  Examples are Caution Condoms, Caution Closures, Caution Dakota Hats, Caution Kitty, and Caution Crew.

 

Complainant's trademarks are registered with the exclamation point.  Respondent's use of the subject domain name does not include the exclamation point.

 

A visitor to the <caution.com> website would never confuse Respondent's intent, usage or appearance with that of Complainant.  They have absolutely nothing to do with each other.  Since purchasing the domain in 1997, Respondent has consistently utilized <caution.com> as an integral part of its travel network services, travel advisories, travel warnings, online bookings, etc.

 

Respondents were located in Boynton Beach, Florida in May of 1997, when it registered the subject domain name, and had no knowledge whatever of the advertisements run earlier in the named California cities by Complainant.  Respondent's selection of the word "caution" in its domain name resulted solely from an idea relating to the common meaning of the word as related to its travel-oriented business activities.

 

C.        Additional Submissions

 

The Additional Submissions of both parties contain extensive argument with little if any additional material factual allegations or information not contained in the Complaint and the Response.

 

FINDINGS AND 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 owns two U.S. Patent and Trademark Office (USPTO) registrations for its CAUTION!, including registration numbers 2,195,828 and 2,197,839.  Complainant has used the CAUTION! Mark in the U.S. beginning as early as December 1996 and has been using the mark continuously ever since.

 

Respondent’s <caution.com> domain name is identical to Complainant’s CAUTION! mark because the disputed domain name appropriates Complainant’s mark and simply omits the exlamation point at the end of the mark.  The omission of the exclamation point does not sufficiently differentiate the domain name from the mark under Policy ¶ 4(a)(i) because punctuation marks such as exclamation points are impermissible in a domain name on the Internet.  See Mrs. World Pageants, Inc. v. Crown Promotions, FA 94321 (Nat. Arb. Forum Apr. 24, 2000) (finding that punctuation is not significant in determining the similarity of a domain name and mark); see also Chernow Communications Inc. v. Kimball, D2000-0119 (WIPO May 18, 2000) (holding “that the use or absence of punctuation marks, such as hyphens, does not alter the fact that a name is identical to a mark").

 

Based upon the foregoing, the Panel finds and determines that <caution.com> is identical or confusingly similar to the mark CAUTION! And CAUTION! UNDERWEAR, in which Complainant has rights.

 

Rights or Legitimate Interests

 

Respondent maintains legitimate Internet travel networks.  It uses the <caution.com> domain name in connection with its travel-related business by directing visitors to the <caution.com> website to a legitimate travel-oriented site actively operated by Respondent.  This appears to be a bona fide offering of goods and services pursuant to Policy ¶ 4(c)(i).  See Sweeps Vacuum & Repair Ctr., Inc. v. Nett Corp., D2001-0031 (WIPO Apr. 13, 2001) (finding bona fide use of a generic domain name, <sweeps.com>, where Respondent used a legitimate locator service (goto.com) in connection with the domain name); see also First Am. Funds, Inc. v. Ult.Search, Inc., D2000-1840 (WIPO Apr. 20, 2001) (finding that, absent bad faith, the operation of a portal website is a legitimate interest).

 

It appears that the first time Respondent had notice of Complainant’s dispute with Respondent’s using <caution.com> or “caution” in any context was the January 2002 cease and desist notice sent by Complainant.  Respondent was already using the disputed domain name as above-described at that time in connection with its bona-fide Internet travel businesses.

 

Were Complainant’s CAUTION! or CAUTION! UNDERWEAR marks less generic in nature, or were they more universally recognized as representing Complainant as distinguished from the common meaning of the word “caution,” the Panel might be more receptive to the allegation that Respondent is trading on Complainant’s fame.  Here, however, Complainant’s evidence falls well short of the mark.  On balance, due to the generic nature of the <caution.com> domain name, Complainant has failed to demonstrate that Respondent has no rights or legitimate interests in the domain name. See FilmNet Inc. v. Onetz, FA 96196 (Nat. Arb. Forum Feb. 12, 2001) (finding that Complainant failed to establish that Respondent did not have rights or legitimate interests in the <filmnet.com> domain name, where the disputed domain name is wholly comprised of generic words, even though Complainant is the owner of the FILMNET mark); see also Energy Source Inc. v. Your Energy Source, FA 96364 (Nat. Arb. Forum Feb. 19, 2001) (finding that Respondent has rights and legitimate interests in the domain name where “Respondent has persuasively shown that the domain name is comprised of generic and/or descriptive terms, and, in any event, is not exclusively associated with Complainant’s business”).

 

Based upon the foregoing, the Panel finds and determines that Complainant has failed to demonstrate that Respondent has no right or legitimate interest in respect of the disputed domain-name.

 

Registration and Use in Bad Faith

 

Ordinarily, having found against Complainant on the element of Respondent’s right or legitimate interest in <caution.com> , the Panel would not address the bad faith element.  Here, however, given the relationship between this element and Respondent’s right or ligitimate interest in the subject domain name, the Panel does address the allegations directed at bad faith.

 

First, the only evidence of bad faith registration is Complainant’s assertion that Respondent had constructive notice of Complainant’s marks because of the print ads in Palm Springs, Laguna Beach, San Diego and Los Angeles, run on May 22, 1997, five days before it secured its registration of <caution.com> on May 27, 1997.  Respondent denies actual knowledge of Complainant’s mark as of the date of registration, and its assertion that it had no presence in those cities and in fact was based in Florida in May of 1997 was unrefuted.  This eliminates the constructive notice claim.  Further, Respondent registered <caution.com> before either of Complainant’s marks were registered with the USPTO.  There is no credible evidence of registration in bad faith.

 

As to both registration and use, the generic nature of the disputed domain name itself rebuts any allegation by Complainant that Respondent registered or used the disputed domain name in bad faith. See Lowestfare.com LLC v. US Tours & Travel, Inc., AF-0284 (eResolution Sept. 9, 2000) (finding no bad faith where Respondent was using the descriptive domain name <thelowestfare.com> to lead consumers to a source of lowest fares in good faith); see also Zero Int'l Holding v. Beyonet Servs., D2000-0161 (WIPO May 12, 2000) (stating that "[c]ommon words and descriptive terms are legitimately subject to registration as domain names on a 'first-come, first-served' basis").

 

Based upon the foregoing, the Panel finds and determines that Complainant failed to demonstrate that the Respondent registered and is using <caution.com> in bad faith.

 

DECISION

 

Based upon the foregoing findings and discussion, the relief sought in the Complaint is DENIED.

 

 

 

 

Honorable Charles A. Kuechenmeister (Ret.)

Dated:  July 1, 2003

 

 

 

Click Here to return to the main Domain Decisions Page.

 

Click Here to return to our Home Page