DECISION

 

Hewlett-Packard Company and Hewlett-Packard Development Company, L.P. v. International Aggregate and Darrell Small

Claim Number:  FA0309000196139

 

PARTIES

Complainants are Hewlett-Packard Company and Hewlett-Packard Development Company L.P., Palo Alto, CA (collectively “Complainant”) represented by Molly Buck Richard and Heather C. Brunelli of Thompson & Knight LLP, 1700 Pacific Avenue, Suite 3300, Dallas, TX  75201.  Respondent is Darrell Small and International Aggregate, PO Box # 8471 Scottsdale, AZ  85252 (“Respondent”).

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <hppartsdirect.com> and <shoppinghp.com>, registered with Register.Com.

 

PANEL

The undersigned certifies that she has acted independently and impartially and that to the best of her knowledge, she has no known conflict in serving as Panelist in this proceeding. Hon. Carolyn Marks Johnson sits as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum (the "Forum") electronically September 17, 2003; the Forum received a hard copy of the Complaint September 17, 2003.

 

On September 19, 2003, Register.Com confirmed by e-mail to the Forum that the domain names <hppartsdirect.com> and <shoppinghp.com> are registered with Register.Com and that Respondent is the current registrant of the names. Register.Com verified that Respondent is bound by the Register.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 September 22, 2003, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of October 13, 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@hppartsdirect.com and postmaster@shoppinghp.com 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 October 21, 2003, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the Forum appointed Hon. Carolyn Marks Johnson as Panelist.

 

The Panel notes that Respondent attempted to correspond with the Forum and the Panel by e-mail dated October 22, 2003, after expiration of the deadline for filing a Response, and that Respondent purported to date the attachment to this email as October 10, 2003.  In that attachment, Respondent attempted to raise the defense that its use of  “hp” in the domain names in dispute was not intended to confuse those seeking Complainant’s “hp” goods or services. Further, Respondent attempted to raise the defense that its use of “hp” in the sites attached to the domain names in issue had been going on from perhaps as early as 1991, and that Respondent had registered a d/b/a under the “HP Parts Direct” name. Further, Respondent attempted to raise the issue that its domain name sites include a disclaimer.

 

The Panel is not aware that Respondent complied with the rules for filing a Response or Additional Response in this matter and the Panel has determined that it should not consider the late communication and will decide the case as a default case.  However, the Panel notes that even if it were to consider Respondent’s information, Respondent brought no evidence to the Panel that Respondent had any permission or license to use Complainant’s HP mark in any fashion at any time.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that the Forum 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 names be transferred from Respondent to Hewlett Packard Company.

 

PARTIES' CONTENTIONS

A.  Complainant makes the following assertions:

 

1.      The domain names registered by Respondent, <hppartsdirect.com> and <shoppinghp.com>, are confusingly similar to Complainant’s HP marks.

 

2.      Respondent has no rights to or legitimate interests in the <hppartsdirect.com> and <shoppinghp.com> domain names.

 

3.      Respondent registered and used the <hppartsdirect.com> and <shoppinghp.com> domain names in bad faith.

 

B. Respondent failed to submit a Response in this proceeding that was timely or in compliance with the Rules.

 

FINDINGS

Complainant is the holder of 50 trademarks and service marks registered on the Principal Register of the United States Patent and Trademark Office (“USPTO”) for the HP mark and for marks containing “HP” (collectively, the “HP marks”).  Some of Complainant’s marks registered on the Principal Register include USPTO Registration No. 2,404,023 for the HP mark (registered on August 22, 2000), Registration No. 2,414,234 for the HP VISUALIZE mark (registered on December 19, 2000) and Registration No. 2,261,482 for the HP STAR (registered on July 13, 1999).  Complainant also uses its HP marks worldwide, and has registrations for its HP marks in some 140 countries around the world (for example, Registration No. 52,499 for the HP mark in the European Community). 

 

Complainant uses its marks in connection with computers, hardware, printers, peripherals, software and other related goods and services.  Since at least as early as 1941, Complainant has used its HP marks in association with its goods, services and advertising for its goods and services throughout the world. 

 

Complainant also holds various domain name registrations for domain names incorporating its HP marks.  For example, Complainant operates websites at the <hp.com>, <hp.net> and <hp.org> domain names, which display information about its products and services as well as information about the company.  Complainant also operates a commercial website at the <hpshopping.com> domain name where it offers consumers services related to its products.  In addition, Complainant calls its own parts ordering business “HP Parts Direct,” which is located at the <partsdirect.hp.com> domain name.

 

Respondent registered the domain name <hppartsdirect.com> July 14, 2002, and registered the name <shoppinghp.com> August 23, 2003.  The website located at the <hppartsdirect.com> domain name represents that it resells parts for Complainant’s products directly from the manufacturer.  At the <hppartsdirect.com> domain name, Respondent advertises that it is the “absolute best source” for HP parts.  In addition, although the website at the <shoppinghp.com> domain name appears now to be inactive, Respondent initially used the website to market parts under Complainant’s mark.  Unlike the <shoppinghp.com> domain name, the <hppartsdirect.com> domain name continues to advertise parts and accessories to be used with Complainant’s HP products.

 

Complainant has not authorized Respondent to use its HP marks for any purpose and Respondent is not and has never been a licensee of Complainant’s HP marks.

 

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 timely Response in compliance with the Rules, 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 will draw such inferences as the Panel considers appropriate pursuant to paragraph 14(b) of the Rules.

 

Paragraph 4(a) of the Policy requires Complainant to 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 to and/or Confusingly Similar

 

Complainant presented evidence in this proceeding to establish that it has legal rights in its HP marks through registration of the marks with the USPTO and throughout the world.  Accordingly, the Panel concludes that Complainant has rights in its HP marks pursuant to Policy ¶ 4(a)(i).  See Men’s Wearhouse, Inc. v. Wick, FA 117861 (Nat. Arb. Forum Sept. 16, 2002) (“Under U.S. trademark law, registered marks hold a presumption that they are inherently distinctive and have acquired secondary meaning”); see also Janus Int’l Holding Co. v. Rademacher, D2002-0201 (WIPO Mar. 5, 2002) (finding that Panel decisions have held that registration of a mark is prima facie evidence of validity, which creates a rebuttable presumption that the mark is inherently distinctive.  Respondent has the burden of refuting this assumption).

 

The domain names registered by Respondent, <hppartsdirect.com> and <shoppinghp.com>, contain Complainant’s HP marks along with the descriptive words “parts direct” and “shopping,” respectively.  Both domain names also include the generic top-level domain “.com”.  The mere addition of descriptive words and generic top-level domain names to a famous mark does not eliminate the similarity between the domain names and the mark.  Thus, the Panel finds that Respondent’s domain names are confusingly similar to Complainant’s marks under Policy ¶ 4(a)(i).  See Busy Body, Inc. v. Fitness Outlet Inc., D2000-0127 (WIPO Apr. 22, 2000) (finding that "the addition of the generic top-level domain (gTLD) name ‘.com’ is . . . without legal significance since use of a gTLD is required of domain name registrants"); see also Am. Online, Inc. v. Anytime Online Traffic School, FA 146930 (Nat. Arb. Forum April 11, 2003) (finding that Respondent’s domain names, which incorporated Complainant’s entire mark and merely added the descriptive terms “traffic school,” “defensive driving,” and “driver improvement” did not add any distinctive features capable of overcoming a claim of confusing similarity); see also Westfield Corp., Inc. v. Hobbs, D2000-0227 (WIPO May 18, 2000) (finding the <westfieldshopping.com> domain name confusingly similar because the WESTFIELD mark was the dominant element). 

 

Accordingly, the Panel finds that Policy ¶ 4(a)(i) has been satisfied.

 

Rights to or Legitimate Interests

 

Respondent failed to respond to the Complaint in this proceeding except as set out above.  After Complainant alleged that Respondent has no rights or legitimate interests in the domain names, Respondent had the burden of providing evidence showing that it had such rights and legitimate interest in the domain names at issue.  However, in this case, Respondent failed to provide any circumstances proving that it has rights and legitimate interests in the <hppartsdirect.com> and <shoppinghp.com> domain names.  Thus, the Panel finds that Respondent has no rights or legitimate interests in the domain names under Policy ¶ 4(a)(ii).  See G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002) (holding that where Complainant asserts that Respondent has no rights or legitimate interests with respect to the domain name, it is incumbent on Respondent to come forward with concrete evidence rebutting this assertion because this information is “uniquely within the knowledge and control of the Respondent”); 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”); see also Geocities v. Geociites.com, D2000-0326 (WIPO June 19, 2000) (finding that Respondent has no rights or legitimate interests in the domain name because Respondent never submitted a Response or provided the Panel with evidence to suggest otherwise).

 

Respondent is not authorized to incorporate Complainant’s HP marks in its business and domain names in any manner.   In addition, no evidence before the Panel suggests that Respondent is known by the <hppartsdirect.com> and <shoppinghp.com> domain names and Respondent was not known by these names at any time prior to registration of the domain names.  Consequently, the Panel finds that Respondent is not commonly known by the domain names pursuant to Policy ¶ 4(c)(ii).  See RMO, Inc. v. Burbridge, FA 96949 (Nat. Arb. Forum May 16, 2001) (interpreting Policy ¶ 4(c)(ii) "to require a showing that one has been commonly known by the domain name prior to registration of the domain name to prevail"); 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).   

 

Respondent is using the <hppartsdirect.com> domain name in connection with a website that advertises computer equipment for use with Complainant’s HP products.  In fact, Respondent is advertising replacement parts for Complainant’s products in direct competition with Complainant’s own “HP Parts Direct” parts ordering business, which is located at the <partsdirect.hp.com> domain name.  Respondent’s use of domain names that incorporate Complainant’s HP marks to sell similar goods specifically denoted by Complainant does not evidence use in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) and it is not a legitimate noncommercial fair use pursuant to Policy ¶ 4(c)(iii).  Accordingly, the Panel concludes that Respondent does not have rights or legitimate interests in the <hppartsdirect.com> domain name pursuant to Policy ¶ 4(a)(ii).  See Computerized Sec. Sys., Inc. v. Hu, FA 157321 (Nat. Arb. Forum June 23, 2003) (holding that Respondent’s appropriation of Complainant’s mark to market products that compete with Complainant’s goods does not constitute a bona fide offering of goods and services); see also Fanuc Ltd v. Mach. Control Serv., FA 93667 (Nat. Arb. Forum Mar. 13, 2000) (finding that Respondent violated Policy ¶ 4(b)(iv) by selling used Fanuc parts and robots on website <fanuc.com> because customers visiting the site were confused as to the relationship between Respondent and Complainant).

 

In addition, the fact that the <shoppinghp.com> domain name is now inactive does not change the fact that Respondent has no rights or legitimate interests in the domain name.  Respondent used the <shoppinghp.com> domain name in the same illegitimate manner that it currently uses the <hppartsdirect.com> domain name.  When Respondent’s website at the <shoppinghp.com> domain name was active, Respondent was advertising replacement parts for Complainant’s products in direct competition with Complainant.  Furthermore, Respondent could resume an infringing use of the domain name at any time.  Moreover, inactive websites do not evidence rights and legitimate interests in a domain name. 

 

Thus, the Panel finds that Respondent has no rights and legitimate interests in the <shoppinghp.com> domain name under Policy ¶¶ 4(c)(i) or 4(c)(iii).  See Clear Channel Communications, Inc. v. Beaty Enters., FA 135008 (Nat. Arb. Forum Jan. 2, 2003) (finding that Respondent, as a competitor of Complainant, had no rights or legitimate interests in a domain name that utilized Complainant’s mark for its competing website); see also Fed. Nat’l Mortgage Ass’n v. Domain Stuff.com, FA114620 (Nat. Arb. Forum July, 29, 2002). (finding that Respondent had no rights or legitimate interests in a domain name where the domain name was inactive at the time of the domain name dispute but had previously been used to redirect Internet users to commercial websites that displayed pornographic content).

 

Accordingly, the Panel finds that Policy ¶ 4(a)(ii) has been satisfied.

 

Registration and Use in Bad Faith

 

Respondent has knowingly registered and used the <hppartsdirect.com> and <shoppinghp.com> domain names to intentionally attract, for commercial gain, Internet users to Respondent’s websites by creating a likelihood of confusion with Complainant’s HP marks as to the source, sponsorship, affiliation, or endorsement of Respondent’s website.  Given the fact that both domain names incorporate Complainant’s entire HP mark, consumers visiting Respondent’s websites are likely to believe that the websites registered by Respondent that contain Complainant’s mark and sell Complainant’s products are sponsored by Complainant.  In addition, it is likely that Internet users would be surprised to learn that Complainant is not the source of Respondent’s websites since Respondent advertises its websites as the “absolute best source” for HP parts and that the parts purportedly are provided directly from the manufacturer.  Furthermore, the fact that Complainant sells its own parts through its “HP Parts Direct” business and operates a website at the <hpshopping.com> domain name only furthers the likelihood of consumer confusion.  Thus, the Panel appropriately concludes that Respondent is using the domain names in bad faith pursuant to Policy ¶ 4(b)(iv).  See Computerized Sec. Sys., Inc. v. Hu, FA 157321 (Nat. Arb. Forum June 23, 2003) (finding that Respondent’s use of the <saflock.com> domain name to offer goods competing with Complainant’s illustrates Respondent’s bad faith registration and use of the domain name, evidence of bad faith registration and use pursuant to Policy 4(b)(iv)); see also TM Acquisition Corp. v. Carroll, FA 97035 (Nat. Arb. Forum May 14, 2001) (finding bad faith where Respondent used the domain name, for commercial gain, to intentionally attract users to a direct competitor of Complainant).

 

Furthermore, the wide notoriety of Complainant’s HP marks, Complainant’s registration of its HP marks on the USPTO’s Principal Register, and the fact that Respondent is knowingly selling Complainant’s products all permit the inference that Respondent knew of Complainant’s rights in its HP marks prior to registering the <hppartsdirect.com> and <shoppinghp.com> domain names.  Registering another’s mark with knowledge of another’s rights in its mark is evidence of bad faith use and registration.  Thus, the Panel finds that Respondent registered the domain names in bad faith pursuant to Policy ¶ 4(a)(iii).  See Samsonite Corp. v. Colony Holding, FA 94313 (Nat. Arb. Forum Apr. 17, 2000) (finding that evidence of bad faith includes actual or constructive knowledge of a commonly known mark at the time of registration); see also Orange Glo Int’l v. Blume, FA 118313 (Nat. Arb. Forum Oct. 4, 2002) (“Complainant’s OXICLEAN mark is listed on the Principal Register of the USPTO, a status that confers constructive notice on those seeking to register or use the mark or any confusingly similar variation thereof”).    

 

Accordingly, 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 <hppartsdirect.com> and < shoppinghp.com> domain names be TRANSFERRED from Respondent to Complainant, Hewlett-Packard Company.

 

 

Hon. Carolyn Marks Johnson, Panelist

Dated: November 3, 2003.

 

 

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