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DECISION

 

H-D Michigan Inc. v. William Martin d/b/a Maramco

Claim Number:  FA0501000396800

 

PARTIES

Complainant is H-D Michigan Inc. (“Complainant”), represented by David Kelly, of Finnegan Henderson Farabow Garrett & Dunner L.L.P., 901 New York Avenue NW, Washington, DC 20001.  Respondent is William Martin d/b/a Maramco (“Respondent”), 20440 International Blvd. #68, Seatac, WA 98198.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <paradiceharley.com>, <paradiceharleydavidson.com>, <paradiseharley.com> and <paradiseharleydavidson.com>, registered with Register.com.

 

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.

 

Honorable Paul A. Dorf (Ret.) as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on January 3, 2005; the National Arbitration Forum received a hard copy of the Complaint on January 4, 2005.

 

On January 4, 2005, Register.com confirmed by e-mail to the National Arbitration Forum that the domain names <paradiceharley.com>, <paradiceharleydavidson.com>, <paradiseharley.com> and <paradiseharleydavidson.com> are registered with Register.com and that Respondent is the current registrant of the names. Register.com has 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 January 5, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of January 25, 2005 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@paradiceharley.com, postmaster@paradiceharleydavidson.com, postmaster@paradiseharley.com and postmaster@paradiseharleydavidson.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 National Arbitration Forum transmitted to the parties a Notification of Respondent Default.

 

On January 31, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Honorable Paul A. Dorf (Ret.) as Panelist.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that the National Arbitration 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 National Arbitration 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 Complainant.

 

PARTIES' CONTENTIONS

A.  Complainant makes the following assertions:

 

1.      Respondent’s <paradiceharley.com>, <paradiceharleydavidson.com>, <paradiseharley.com> and <paradiseharleydavidson.com> domain names are confusingly similar to Complainant’s HARLEY and HARLEY-DAVIDSON marks.

 

2.      Respondent does not have any rights or legitimate interests in the <paradiceharley.com>, <paradiceharleydavidson.com>, <paradiseharley.com> and <paradiseharleydavidson.com> domain names.

 

3.      Respondent registered and used the <paradiceharley.com>, <paradiceharleydavidson.com >, <paradiseharley.com> and <paradiseharleydavidson.com> domain names in bad faith.

 

B.  Respondent failed to submit a Response in this proceeding.

 

FINDINGS

Complainant, H-D Michigan, Inc., has engaged in the manufacture, advertising, and sale of motorcycles under the HARLEY-DAVIDSON mark since 1903.  In addition, Complainant has provided motorcycle parts, motorcycle accessories, motorcycle clothing, travel-related products and services, toys, calendars, posters, jewelry and novelties under the HARLEY and HARLEY-DAVIDSON marks for decades.

 

Complainant owns almost 850 trademarks and service mark registrations in more than 75 countries around the world for the HARLEY and HARLEY-DAVIDSON marks.  Complainant has registered the HARLEY (Reg. Nos. 1,352,679 issued August 6, 1985; 1,406,876 issued August 26, 1986) and HARLEY-DAVIDSON (Reg. Nos. 1,078,871 issued December 6, 1977; 1,311,457 issued December 25, 1984; 2,496,088 issued October 9, 2001) marks with the United States Patent and Trademark Office (“USPTO”).

 

Complainant markets its motorcycles, motorcycle parts and accessories, clothing and travel services through a network of authorized dealers.  Complainant has more than 1,500 authorized dealers throughout the world.  One of Complainant’s authorized dealerships, located in Tigard, Oregon, is named Paradise Harley-Davidson.

 

Respondent registered the <paradiceharley.com> and <paradiceharleydavidson.com> domain names on July 22, 2004 and the <paradiseharley.com> and <paradiseharleydavidson.com> domain names on July 24, 2004.  Respondent’s domain names resolve to a website that features links to various competing motorcycle-related websites.

 

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 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 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 rights in the HARLEY and HARLEY-DAVIDSON marks through registration with the USPTO as well as through continuous use of the marks in commerce.  See Am. Online, Inc. v. Thomas P. Culver Enters., D2001-0564 (WIPO June 18, 2001) (finding that successful trademark registration with the United States Patent and Trademark Office creates a presumption of rights in a mark); see also 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.”).

 

Respondent’s domain names are confusingly similar to Complainant’s famous marks because the domain names incorporate either the HARLEY or HARLEY-DAVIDSON mark in its entirety and merely add the term “paradise” or “paradice,” which describes Complainant’s authorized dealership in Tigard, Oregon.  Such minor changes are not enough to overcome a finding of confusing similarity pursuant to Policy ¶ 4(a)(i).  See Arthur Guinness Son & Co. (Dublin) Ltd. v. Healy/BOSTH, D2001-0026 (WIPO Mar. 23, 2001) (finding confusing similarity where the domain name in dispute contains the identical mark of Complainant combined with a generic word or term); see also Space Imaging LLC v. Brownell, AF-0298 (eResolution Sept. 22, 2000) (finding confusing similarity where Respondent’s domain name combines Complainant’s mark with a generic term that has an obvious relationship to Complainant’s business).

 

Furthermore, the addition of the generic top-level domain “.com” and the omission of the hyphen from the HARLEY-DAVIDSON mark is insufficient to negate the confusing similarity between Respondent’s domain names and Complainant’s marks pursuant to Policy ¶ 4(a)(i).  See Nev. State Bank v. Modern Ltd. – Cayman Web Dev., FA 204063 (Nat. Arb. Forum Dec. 6, 2003) (“It has been established that the addition of a generic top-level domain is irrelevant when considering whether a domain name is identical or confusingly similar under the Policy.”); see also Isleworth Land Co. v. Lost in Space, SA, FA 117330 (Nat. Arb. Forum Sept. 27, 2002) (finding it is a “well established principle that generic top-level domains are irrelevant when conducting a Policy ¶ 4(a)(i) analysis”); see also Ritz-Carlton Hotel Co. v. Club Car Executive Transp., D2000-0611 (WIPO Sept. 18, 2000) (finding that removing a hyphen in the domain names is not sufficient to differentiate the domain names from the mark).

 

The Panel finds that Policy ¶ 4(a)(i) has been satisfied.

 

Rights or Legitimate Interests

 

Respondent has failed to respond to the Complaint.  Therefore, the Panel may accept all reasonable allegations and assertions set forth in the Complaint as true.  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.”); see also Ziegenfelder Co. v. VMH Enter., Inc., D2000-0039 (WIPO Mar. 14, 2000) (drawing two inferences based on Respondent’s failure to respond: (1) Respondent does not deny the facts asserted by Complainant, and (2) Respondent does not deny conclusions which Complainant asserts can be drawn from the facts).

 

In addition, the Panel may consider Respondent’s failure to respond as evidence that Respondent lacks rights and legitimate interests in the domain names pursuant to Policy ¶ 4(a)(ii).  See Bank of Am. Corp. v. McCall, FA 135012 (Nat. Arb. Forum Dec. 31, 2002) (“Respondent's failure to respond not only results in its failure to meet its burden, but also will be viewed as evidence itself that Respondent lacks rights and legitimate interests in the disputed domain name.”); 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).

 

There is no indication that Respondent is commonly known by the disputed domain names or that Respondent is authorized to register domain names that incorporate Complainant’s HARLEY or HARLEY-DAVIDSON marks.  Therefore, the Panel concludes that Respondent lacks rights and legitimate interests in the domain name pursuant to Policy ¶ 4(c)(ii).  See Ian Schrager Hotels, L.L.C. v. Taylor, FA 173369 (Nat. Arb. Forum Sept. 25, 2003) (finding that without demonstrable evidence to support the notion that a respondent is commonly known by a domain name, the notion must be rejected); see also Compagnie de Saint Gobain v. Com-Union Corp., D2000-0020 (WIPO Mar. 14, 2000) (finding no rights or legitimate interest where Respondent was not commonly known by the mark and never applied for a license or permission from Complainant to use the trademarked name).

 

Furthermore, Respondent is using the disputed domain names, which contain confusingly similar versions of Complainant’s marks, to market competing motorcycle-related websites.  Such use is not 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 of the mark pursuant to Policy ¶ 4(c)(iii).  See DLJ Long Term Inv. Corp. v. BargainDomainNames.com, FA 104580 (Nat. Arb. Forum Apr. 9, 2002) (“Respondent is not using the disputed domain name in connection with a bona fide offering of goods and services because Respondent is using the domain name to divert Internet users to <visual.com>, where services that compete with Complainant are advertised.”); see also N. Coast Med., Inc. v. Allegro Med., FA 95541 (Nat. Arb. Forum Oct. 2, 2000) (finding no rights or legitimate interests in a domain name that diverted Internet users to Respondent’s competing website through the use of Complainant’s mark).

 

The Panel finds that Policy ¶ 4(a)(ii) has been satisfied.

 

Registration and Use in Bad Faith

 

Respondent has registered and used the disputed domain names in bad faith pursuant to Policy ¶ 4(b)(iii) by using the domain names, which contain confusing similar versions of Complainant’s HARLEY and HARLEY-DAVIDSON marks, to market competing motorcycle-related websites.  See S. Exposure v. S. Exposure, Inc., FA 94864 (Nat. Arb. Forum July 18, 2000) (finding Respondent acted in bad faith by attracting Internet users to a website that competes with Complainant’s business); see also EthnicGrocer.com, Inc. v. Unlimited Latin Flavors, Inc., FA 94385 (Nat. Arb. Forum July 7, 2000) (finding that the minor degree of variation from Complainant's marks suggests that Respondent, Complainant’s competitor, registered the names primarily for the purpose of disrupting Complainant's business).

 

Furthermore, Respondent is capitalizing on the goodwill of the HARLEY and HARLEY-DAVIDSON marks by using the disputed domain names to divert Internet users to a website featuring links to competing motorcycle-related websites.  The Panel infers that Respondent receives click-through fees for redirecting Internet users to these competing websites.  Since the disputed domain names contain Complainant’s marks, consumers searching for Complainant would become confused as to Complainant’s affiliation with the resulting website.  Therefore, Respondent’s opportunistic use of the disputed domain names represents bad faith registration and use under Policy ¶ 4(b)(iv).  See Kmart v. Khan, 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 Reuters Ltd. v. Global Net 2000, Inc., D2000-0441 (WIPO July 13, 2000) (finding bad faith where Respondent attracted users to a website sponsored by Respondent and created confusion with Complainant’s mark as to the source, sponsorship, or affiliation of that website).

 

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 <paradiceharley.com>, <paradiceharleydavidson.com >, <paradiseharley.com> and <paradiseharleydavidson.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

 

Honorable Paul A. Dorf (Ret.), Panelist

Dated:  February 16, 2005

 

 

 

 

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