national arbitration forum

 

DECISION

 

State Farm Mutual Automobile Insurance Company v. Unasi Management, Inc.

Claim Number:  FA0503000440325

 

PARTIES

 

Complainant is State Farm Mutual Automobile Insurance Company (“Complainant”), One State Farm Plaza, A-3, Bloomington, IL 61710.  Respondent is Unasi Management, Inc. (“Respondent”), Galerias Alvear, Via Argentina 2, Ofincina #3, Zona 5, Panama 5235, Panama.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

 

The domain names at issue are <statefarmensurance.com>, <statefarmimsurance.com>, <statefarminaurance.com>, <statefarminsirance.com>, <statefarminsueance.com>, <statefarminsuramce.com>, <statefarminsuranca.com>, <statefarminsuranci.com>, <statefarminsurancw.com>, <statefarminsuranxe.com>, <statefarminsurnce.org>,  <statefarminsuronce.com>, <statefarminzurance.com>, <statefarmnsurance.com>,  <statefarmonsurance.com>, <statefarmunsurance.com>, <statefarninsurance.com> and <astatefarm.com>, registered with Iholdings.com, Inc. d/b/a Dotregistrar.com.

 

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.

 

Louis E. Condon as Panelist.

 

PROCEDURAL HISTORY

 

Complainant submitted a Complaint to the National Arbitration Forum electronically on March 15, 2005; the National Arbitration Forum received a hard copy of the Complaint on March 16, 2005.

 

On March 16, 2005, Iholdings.com, Inc. d/b/a Dotregistrar.com confirmed by e-mail to the National Arbitration Forum that the domain names <statefarmensurance.com>, <statefarmimsurance.com>, <statefarminaurance.com>, <statefarminsirance.com>, <statefarminsueance.com>, <statefarminsuramce.com>, <statefarminsuranca.com>, <statefarminsuranci.com>, <statefarminsurancw.com>, <statefarminsuranxe.com>, <statefarminsurnce.org>,  <statefarminsuronce.com>, <statefarminzurance.com>, <statefarmnsurance.com>,  <statefarmonsurance.com>, <statefarmunsurance.com>, <statefarninsurance.com> and <astatefarm.com> are registered with Iholdings.com, Inc. d/b/a Dotregistrar.com and that Respondent is the current registrant of the names. Iholdings.com, Inc. d/b/a Dotregistrar.com has verified that Respondent is bound by the Iholdings.com, Inc. d/b/a Dotregistrar.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 March 21, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of April 11, 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@statefarmensurance.com, postmaster @statefarmimsurance.com, postmaster@statefarminaurance.com, postmaster@statefarminsirance.com, postmaster@statefarminsueance.com, postmater@statefarminsuramce.com, postmaster@statefarminsuranca.com, postmaster@statefarminsuranci.com, postmaster@statefarminsurancw.com, postmaster@statefarminsuranxe.com, postmaster@statefarminsurnce.org, postmaster@statefarminsuronce.com, postmaster@statefarminzurance.com, postmaster@statefarmnsurance.com, postmaster@statefarmonsurance.com, postmaster@statefarmunsurance.com, postmaster@statefarninsurance.com and postmaster@astatefarm.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 April 18, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Louis E. Condon 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 <statefarmensurance.com>, <statefarmimsurance.com>, <statefarminaurance.com>, <statefarminsirance.com>, <statefarminsueance.com>, <statefarminsuramce.com>, <statefarminsuranca.com>, <statefarminsuranci.com>, <statefarminsurancw.com>, <statefarminsuranxe.com>, <statefarminsurnce.org>,  <statefarminsuronce.com>, <statefarminzurance.com>, <statefarmnsurance.com>,  <statefarmonsurance.com>, <statefarmunsurance.com>, <statefarninsurance.com> and <astatefarm.com> domain names are confusingly similar to Complainant’s STATE FARM and STATE FARM INSURANCE marks.

 

2.      Respondent does not have any rights or legitimate interests in the <statefarmensurance.com>, <statefarmimsurance.com>, <statefarminaurance.com>, <statefarminsirance.com>, <statefarminsueance.com>, <statefarminsuramce.com>, <statefarminsuranca.com>, <statefarminsuranci.com>, <statefarminsurancw.com>, <statefarminsuranxe.com>, <statefarminsurnce.org>,  <statefarminsuronce.com>, <statefarminzurance.com>, <statefarmnsurance.com>,  <statefarmonsurance.com>, <statefarmunsurance.com>, <statefarninsurance.com> and <astatefarm.com> domain names.

 

3.      Respondent registered and used the <statefarmensurance.com>, <statefarmimsurance.com>, <statefarminaurance.com>, <statefarminsirance.com>, <statefarminsueance.com>, <statefarminsuramce.com>, <statefarminsuranca.com>, <statefarminsuranci.com>, <statefarminsurancw.com>, <statefarminsuranxe.com>, <statefarminsurnce.org>,  <statefarminsuronce.com>, <statefarminzurance.com>, <statefarmnsurance.com>,  <statefarmonsurance.com>, <statefarmunsurance.com>, <statefarninsurance.com> and <astatefarm.com> domain names in bad faith.

 

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

 

FINDINGS

 

Complainant, State Farm Mutual Automobile Insurance Company is a nationally known company that has been doing business under the STATE FARM and STATE FARM INSURANCE marks since 1930.  Complainant uses the STATE FARM and STATE FARM INSURANCE marks in connection with offering insurance and banking-related products and services. 

 

Complainant holds numerous trademark registrations with the United States Patent and Trademark Office for the STATE FARM and STATE FARM INSURANCE marks (Reg. No. 645,890, issued May 21, 1957 and Reg. No. 1,087,834, issued Mar. 21, 1978).  Complainant has also owns trademark registrations for the STATE FARM and STATE FARM INSURANCE marks in Canada, the European Community and Mexico. (Reg. No. 405,034, issued November 20, 1992 in Canada and Reg. No. 000,175,844, issued June 18, 1998 in Mexico).

 

Respondent registered the <astatefarm.com> domain name on February 4, 2005 and the <statefarmensurance.com>, <statefarmimsurance.com>, <statefarminaurance.com>, <statefarminsirance.com>, <statefarminsueance.com>, <statefarminsuramce.com>, <statefarminsuranca.com>, <statefarminsuranci.com>, <statefarminsurancw.com>, <statefarminsuranxe.com>, <statefarminsurnce.org>,  <statefarminsuronce.com>, <statefarminzurance.com>, <statefarmnsurance.com>,  <statefarmonsurance.com>, <statefarmunsurance.com> and <statefarninsurance.com> domain names on March 6, 2005.  Respondent is using the disputed domain names to redirect Internet users to a search engine website where Internet users are provided various links to different  third party websites offering services such as car insurance, insurance quotes and a link for an unauthorized website offering information about Complainant’s company. 

 

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 that it has rights in the STATE FARM and STATE FARM INSURANCE marks through registration with the United States Patent and Trademark Office and through continuous use of its mark in commerce for the last seventy years.  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 <statefarmensurance.com>, <statefarmimsurance.com>, <statefarminaurance.com>, <statefarminsirance.com>, <statefarminsueance.com>, <statefarminsuramce.com>, <statefarminsuranca.com>, <statefarminsuranci.com>, <statefarminsurancw.com>, <statefarminsuranxe.com>, <statefarminsurnce.org>,  <statefarminsuronce.com>, <statefarminzurance.com>, <statefarmnsurance.com>,  <statefarmonsurance.com>, <statefarmunsurance.com> and <statefarninsurance.com> domain names registered by Respondent are confusingly similar to Complainant’s STATE FARM INSURANCE mark because the domain names all consist of misspelled versions of Complainant’s mark, namely, the misspelling of the word “insurance” in the domain names.  The Panel finds that Respondent’s registration of domain names consisting of typographically erroneous versions of Complainant’s mark does not negate the confusing similarity of the domain names with Complainant’s mark pursuant to Policy ¶ 4(a)(i).  See Reuters Ltd. v. Global Net 2000, Inc., D2000-0441 (WIPO July 13, 2000) (finding that a domain name which differs by only one letter from a trademark has a greater tendency to be confusingly similar to the trademark where the trademark is highly distinctive); see also Victoria’s Secret v. Zuccarini, FA 95762 (Nat. Arb. Forum Nov. 18, 2000) (finding that, by misspelling words and adding letters to words, a Respondent does not create a distinct mark but nevertheless renders the domain name confusingly similar to Complainant’s marks); see also State Farm Mut. Auto. Ins. Co. v. Try Harder & Co., FA 94730 (Nat. Arb. Forum June 15, 2000) (finding that the domain name <statfarm.com> is confusingly similar to Complainant’s STATE FARM mark); see also Hewlett-Packard Co. v. Zuccarini, FA 94454 (Nat. Arb. Forum May 30, 2000) (finding the domain name <hewlitpackard.com> to be identical or confusingly similar to Complainant’s HEWLETT-PACKARD mark).

 

Additionally, Respondent’s <astatefarm.com> domain name is confusingly similar to Complainant’s STATE FARM mark because the addition of the letter “a” does not sufficiently distinguish the domain name from Complainant’s STATE FARM mark.  See Am. Online, Inc. v. Tencent Communications Corp., FA 93668 (Nat. Arb. Forum Mar. 21, 2000) (finding that <oicq.net> and <oicq.com> are confusingly similar to Complainant’s mark ICQ); see also Am. Online, Inc. v. iDomainNames.com, FA 93766 (Nat. Arb. Forum Mar. 24, 2000) (finding that Respondent’s domain name <go2AOL.com> was confusingly similar to Complainant’s AOL mark).

Furthermore, the addition of the generic top-level domain “.com” is irrelevant in determining whether the disputed domain names are confusingly similar to Complainant’s STATE FARM and STATE FARM INSURANCE marks.  See Sony Kabushiki Kaisha v. Inja, Kil, D2000-1409 (WIPO Dec. 9, 2000) (finding that “[n]either the addition of an ordinary descriptive word . . . nor the suffix ‘.com’ detract from the overall impression of the dominant part of the name in each case, namely the trademark SONY” and thus Policy ¶ 4(a)(i) is satisfied); see also Pomellato S.p.A v. Tonetti, D2000-0493 (WIPO July 7, 2000) (finding <pomellato.com> identical to Complainant’s mark because the generic top-level domain (gTLD) “.com” after the name POMELLATO is not relevant).

 

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

 

Rights or Legitimate Interests

 

Complainant alleges that Respondent has no rights or legitimate interests in the disputed domain name.  The burden shifts to Respondent to show that it does 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, it is assumed that Respondent lacks rights and legitimate interests in the disputed domain name.  See 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); see also Pavillion Agency, Inc. v. Greenhouse Agency Ltd., D2000-1221 (WIPO Dec. 4, 2000) (finding that Respondents’ failure to respond can be construed as an admission that they have no legitimate interests in the domain names).

 

Moreover, the Panel may accept all reasonable allegations and inferences in the Complaint as true because Respondent has not submitted a response.  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 Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (Nat. Arb. Forum July 31, 2000) (holding that Respondent’s failure to respond allows all reasonable inferences of fact in the allegations of the Complaint to be deemed true); see also Desotec N.V. v. Jacobi Carbons AB, D2000-1398 (WIPO Dec. 21, 2000) (finding that failing to respond allows a presumption that Complainant’s allegations are true unless clearly contradicted by the evidence).

 

Respondent is using the disputed domain names to redirect Internet users to a search engine website where Internet users are provided with various links to different third party websites offering services such as car insurance, insurance quotes and a false link for a website offering information about Complainant’s company that is false and misleading.  The Panel assumes that Respondent receives click-through fees in return for linking third party websites to the disputed domain names.  Respondent’s use of domain names that are confusingly similar to Complainant’s STATE FARM and STATE FARM INSURANCE marks to redirect Internet users interested in Complainant’s services to a search engine website that offers links to competing websites is not a use in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i), nor a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).  See Pioneer Hi-Bred Int’l Inc. v. Chan, FA 154119 (Nat. Arb. Forum May 12, 2003) (finding that Respondent did not have rights or legitimate interests in a domain name that used Complainant’s mark and redirected Internet users to a website that pays domain name registrants for referring those users to its search engine and pop-up advertisements); see also 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 Tercent Inc. v. Lee Yi, FA 139720 (Nat. Arb. Forum Feb. 10, 2003) (holding that Respondent’s use of the disputed domain name to host a series of hyperlinks and a banner advertisement was neither a bona fide offering of goods or services nor a legitimate noncommercial or fair use of the domain name).

 

Moreover, Respondent is not commonly known by the disputed domain names, and has never been known to operate any businesses under the domain names.  Respondent has not presented any evidence and there is no proof in the record suggesting that Respondent is commonly known by the disputed domain names.  Therefore, Respondent has not established rights or legitimate interests in the disputed domain names pursuant to Policy ¶ 4(c)(ii).  See 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); 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 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"). 

 

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

 

Registration and Use in Bad Faith

 

Respondent incorporated Complainant’s marks in its domain names to lead Internet users to a website that offers links to competing websites that offer banking and insurance-related services.  Respondent presumably received click-through fees from these third party companies.  The Panel finds that Respondent is intentionally creating a likelihood of confusion with Complainant’s mark to attract Internet users to Respondent’s website for Respondent’s commercial gain, pursuant to Policy ¶ 4(b)(iv).  See Kmart v. Kahn, 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 Identigene, Inc. v. Genetest Lab., D2000-1100 (WIPO Nov. 30, 2000) (finding bad faith where Respondent's use of the domain name at issue to resolve to a website where similar services are offered to Internet users is likely to confuse the user into believing that Complainant is the source of or is sponsoring the services offered at the site); see also Luck's Music Library v. Stellar Artist Mgmt., FA 95650 (Nat. Arb. Forum Oct. 30, 2000) (finding that Respondent had engaged in bad faith use and registration by linking the domain name to a website that offers services similar to Complainant’s services, intentionally attempting to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with Complainant’s marks).

 

Moreover, Respondent registered the confusingly similar domain names for the purpose of disrupting Complainant’s business by redirecting Internet traffic intended for Complainant to a hub for competing websites offering similar banking and insurance-related services.  Registration of domain names confusingly similar to a Complainant’s mark for the purpose of disrupting Complainant’s business is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).  See Lubbock Radio Paging v. Venture Tele-Messaging, FA 96102 (Nat. Arb. Forum Dec. 23, 2000) (concluding that domain names were registered and used in bad faith where Respondent and Complainant were in the same line of business in the same market area); see also 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).

 

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

 

DECISION

 

Complainant having established all three elements required under the ICANN Policy, the Panel concludes that relief should be granted.

 

Accordingly, it is Ordered that the <statefarmensurance.com>, <statefarmimsurance.com>, <statefarminaurance.com>, <statefarminsirance.com>, <statefarminsueance.com>, <statefarminsuramce.com>, <statefarminsuranca.com>, <statefarminsuranci.com>, <statefarminsurancw.com>, <statefarminsuranxe.com>, <statefarminsurnce.org>,  <statefarminsuronce.com>, <statefarminzurance.com>, <statefarmnsurance.com>,  <statefarmonsurance.com>, <statefarmunsurance.com>, <statefarninsurance.com> and <astatefarm.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

 

 

Louis E. Condon, Panelist

Dated:  April 29, 2005

 

 

 

 


 

 

 

 

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