DECISION

 

Merrell Pharmaceuticals Inc. v. Daniel Laforge

Claim Number: FA0502000420671

 

PARTIES

Complainant is Merrell Pharmaceuticals, Inc. (“Complainant”), represented by Baila H. Celedonia of Cowan, Liebowitz & Latman, P.C., 1133 Avenue of the Americas, New York, NY 10036.  Respondent is Daniel Laforge (“Respondent”), 8423 Burger Lane, Stomper Hills, CA 92021.

 

REGISTRAR AND DISPUTED DOMAIN NAME 

The domain name at issue is <buyallegra.us>, registered with Enom, 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.

 

Sandra Franklin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on February 14, 2005; the National Arbitration Forum received a hard copy of the Complaint on February 17, 2005.

 

On February 15, 2005, Enom, Inc. confirmed by e-mail to the National Arbitration Forum that the domain name <buyallegra.us> is registered with Enom, Inc. and that 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 the U. S. Department of Commerce’s usTLD Dispute Resolution Policy (the “Policy”).

 

On February 23, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”) setting a deadline of March 15, 2005 by which Respondent could file a Response to the Complaint, was transmitted to Respondent in compliance with Paragraph 2(a) of the Rules for usTLD Dispute Resolution Policy (the “Rules”).

 

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 March 18, 2005, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Sandra Franklin 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.  Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the Policy, the 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 name be transferred from Respondent to Complainant.

 

PARTIES’ CONTENTIONS

            A. Complainant makes the following assertions:

 

1.      Respondent’s <buyallegra.us> domain name is confusingly similar to Complainant’s ALLEGRA mark.

 

2.      Respondent does not have any rights or legitimate interests in the <buyallegra.us> domain name.

 

3.      Respondent registered or used the <buyallegra.us> domain name in bad faith.

 

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

 

FINDINGS

Complainant, Merrell Pharamaceuticals, Inc., is a subsidiary of Aventis, Inc., which is one of the U.S. pharmaceutical companies that is part of Sanofi-Aventis, a leader worldwide in the pharmaceutical field.  Sanofi-Aventis is the third largest pharmaceutical company worldwide. 

 

Complainant has been selling drugs in the United States under the trademark, ALLEGRA, since at least August 1996.  Complainant holds a registration with the United States Patent and Trademark Office for the ALLEGRA mark (Reg. No. 2,067,728 issued June 3, 1997). 

 

Complainant’s main website is operated at the <allegra.com> domain name.

 

Respondent registered the <buyallegra.us> domain name on December 12, 2004.  Respondent’s domain name resolves to a website that allows Internet users to order various pharmaceutical products. 

 

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(f), 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 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 or is being used in bad faith.

 

Given the similarity between the Uniform Domain Name Dispute Resolution Policy (“UDRP”) and the usTLD Policy, the Panel will draw upon UDRP precedent as applicable in rendering its decision.

 

Identical and/or Confusingly Similar

 

Complainant has established rights in the ALLEGRA mark through registration with the United States Patent and Trademark Office and its use in commerce since 1996.  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.

 

Respondent’s <buyallegra.us> domain name is confusingly similar to the ALLEGRA mark because the domain name fully incorporates the mark and merely adds the generic or descriptive term “buy” and the country-code “.us.”  The mere additions of the term “buy” and the country-code “.us” does not significantly distinguish the domain name from the mark.  See Slep-Tone Entm't Corp. v. Sound Choice Disc Jockeys, Inc., FA 93636 (Nat. Arb. Forum Mar. 13, 2000) (“[L]ikelihood of confusion is further increased by the fact that the Respondent and [Complainant] operate within the same industry”); see also 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; see also Tropar Mfg. Co. v. TSB, FA 127701 (Nat. Arb. Forum Dec. 4, 2002) finding that, because the addition of the country-code “.us” fails to add any distinguishing characteristic to the domain name, the <tropar.us> domain name is identical to Complainant’s TROPAR mark.

 

Therefore, Complainant has established that the disputed domain name is confusingly similar to Complainant’s mark under Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

 

Complainant has alleged that Respondent has no rights or legitimate interests in a domain name that contains in its entirety Complainant’s mark.  The burden shifts to Respondent to show that it does not have rights or legitimate interests once Complainant establishes a prima facie case pursuant to Policy ¶ 4(a)(ii).  Due to Respondent’s failure to respond to the Complaint, the Panel will assume that Respondent lacks rights and legitimate interests in the disputed domain name.    See Compagnie Generale des Matieres Nucleaires v. Greenpeace Int’l, D2001-0376 (WIPO May 14, 2001) (“Proving that the Respondent has no rights or legitimate interests in respect of the Domain Name requires the Complainant to prove a negative. For the purposes of this sub paragraph, however, it is sufficient for the Complainant to show a prima facie case; the burden of proof is then shifted on to the shoulders of Respondent. In those circumstances, the common approach is for respondents to seek to bring themselves within one of the examples of paragraph 4(c) or put forward some other reason why they can fairly be said to have a relevant right or legitimate interests in respect of the domain name in question”); see also G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002) holding that where complainant has asserted 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 Clerical Med. Inv. Group Ltd. v. Clericalmedical.com, D2000-1228 (WIPO Nov. 28, 2000) finding that, under certain circumstances, the mere assertion by complainant that respondent has no rights or legitimate interests is sufficient to shift the burden of proof to respondent to demonstrate that such rights or legitimate interests do exist.

 

Respondent is using the <buyallegra.us> domain name to redirect Internet users to a site that allows Internet users to order various pharmaceutical products, including those offered by Complainant.  Respondent’s use of a domain name that is confusingly similar to Complainant’s ALLEGRA mark to redirect users interested in Complainant’s products to a commercial website that offers identical pharmaceutical products is not a use in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(ii) or a legitimate noncommercial or fair use of the domain name pursuant to Policy ¶ 4(c)(iv).  See eBay Inc. v. Sunho Hong, D2000-1633 (WIPO Jan. 18, 2001) stating that the "use of complainant’s entire mark in infringing domain names makes it difficult to infer a legitimate use"; see also G.D. Searle & Co. v. Pelham, FA 117911 (Nat. Arb. Forum Sept. 19, 2002) finding that because respondent is using the infringing domain name to sell prescription drugs it can be inferred that respondent is opportunistically using complainant’s mark in order to attract Internet users to its website; see also G.D. Searle & Co. v. Mahoney, FA 112559 (Nat. Arb. Forum June 12, 2002) finding Respondent’s use of the disputed domain name to solicit pharmaceutical orders without a license or authorization from Complainant does not constitute a bona fide offering of goods or services under UDRP ¶ 4(c)(i).

 

Moreover, Respondent has offered no evidence and there is no proof in the record suggesting that Respondent is commonly known by the <buyallegra.us> domain name or that Respondent has rights in the ALLEGRA mark.  Thus, Respondent has not established rights or legitimate interests in the disputed domain name pursuant to UDRP ¶¶ 4(c)(ii).  See Tercent Inc. v. Yi, FA 139720 (Nat. Arb. Forum Feb. 10, 2003) stating “nothing in Respondent’s WHOIS information implies that Respondent is ‘commonly known by’ the disputed domain name” as one factor in determining that UDRP ¶ 4(c)(ii) does not apply; see also 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 Compagnie de Saint Gobain v. Com-Union Corp., D2000-0020 (WIPO Mar. 14, 2000) finding no rights or legitimate interests where respondent was not commonly known by the mark and never applied for a license or permission from complainant to use the trademarked name.

 

Therefore, Complainant has established Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

 

Respondent is using the disputed domain name to advertise and sell pharmacy products.  Complainant’s business is a subsidiary of the third largest pharmaceutical company worldwide.  The Panel finds that, by creating confusion around Complainant’s mark, Respondent is attempting to disrupt the business of a competitor.  Respondent’s use of Complainant’s mark to sell goods similar to Complainant’s goods and services is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).  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 Fossil, Inc. v. NAS, FA 92525 (Nat. Arb. Forum Feb. 23, 2000) transferring the <fossilwatch.com> domain name from respondent, a watch dealer not otherwise authorized to sell complainant’s goods, to complainant; see also Nokia Corp. v. Uday Lakhani, D2000-0833 (WIPO Oct. 19, 2000) transferring <nokias.com> from respondent cellular phone dealer to complainant.

 

Complainant’s registration of its ALLEGRA mark with the United States Patent and Trademark Office put Respondent on constructive notice of Complainant’s rights in its mark.  In addition, Respondent must have known about Complainant’s mark because the link between the pharmaceutical content on the website and Complainant’s business is apparent.  Thus, the Panel concludes that Respondent acted in bad faith pursuant to Policy ¶ 4(a)(iii) when it registered the <buyallegra.us> domain name because it had constructive knowledge of Complainant’s ALLEGRA mark prior to registering the disputed domain name.  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 Exxon Mobil Corp. v. Fisher, D2000-1412 (WIPO Dec. 18. 2000) finding that respondent had actual and constructive knowledge of Complainant’s EXXON mark given the worldwide prominence of the mark and thus respondent registered the domain name in bad faith; 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”); see also Pfizer, Inc. v. Papol Suger, D2002-0187 (WIPO Apr. 24, 2002) finding that because the link between complainant’s mark and the content advertised on respondent’s website was obvious, respondent “must have known about the complainant’s mark when it registered the subject domain name”.

 

Respondent’s <buyallegra.us> domain name diverts Internet users wishing to search under Complainant’s well-known mark to Respondent’s commercial website through the use of a domain name confusingly similar to Complainant’s mark.  Respondent’s practice of diversion, motivated by commercial gain, through use of a confusingly similar domain name, evidences bad faith registration and use 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; see also G.D. Searle & Co. v. Celebrex Drugstore, FA 123933 (Nat. Arb. Forum Nov. 21, 2002) finding that respondent registered and used the domain name in bad faith pursuant to Policy ¶ 4(b)(iv) because respondent was using the confusingly similar domain name to attract Internet users to its commercial website.

 

Complainant has established Policy ¶ 4(a)(iii).

 

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 <buyallegra.us> domain name be TRANSFERRED from Respondent to Complainant.

 

 

Sandra Franklin, Panelist

Dated: March 31, 2005

 

 

 

 

Click Here to return to the main Domain Decisions Page.

 

Click Here to return to our Home Page

 


National Arbitration Forum