national arbitration forum

 

DECISION

 

Broadcom Corporation v. Paul DeLand

Claim Number:  FA0503000447319

 

PARTIES

Complainant is Broadcom Corporation (“Complainant”), represented by Gary J. Nelson, of Christie, Parker and Hale LLP, 350 West Colorado Boulevard, Suite 500, P.O. Box 7068, Pasadena, CA 91109-7068.  Respondent is Paul DeLand (“Respondent”), 9112 Hwy 80 West, #364, Fort Worth, TX 76116.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <vipbroadcom.com>, <vipbroadcom.net>, <vipbroadcom.org> and <vipbroadcom.info>, registered with Innerwise, Inc. d/b/a Itsyourdomain.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.

 

James A. Crary as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on March 28, 2005; the National Arbitration Forum received a hard copy of the Complaint on March 30, 2005.

 

On April 1, 2005, Innerwise, Inc. d/b/a Itsyourdomain.com, confirmed by e-mail to the National Arbitration Forum that the domain names <vipbroadcom.com>, <vipbroadcom.net>, <vipbroadcom.org> and <vipbroadcom.info> are registered with Innerwise, Inc. d/b/a Itsyourdomain.com, and that Respondent is the current registrant of the names.  Innerwise, Inc. d/b/a Itsyourdomain.com, has verified that Respondent is bound by the Innerwise, Inc. d/b/a Itsyourdomain.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 April 6, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of April 26, 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@vipbroadcom.com, postmaster@vipbroadcom.net, postmaster@vipbroadcom.org and postmaster@vipbroadcom.info 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 May 3, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed James A. Crary 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 <vipbroadcom.com>, <vipbroadcom.net>, <vipbroadcom.org> and <vipbroadcom.info> domain names are confusingly similar to Complainant’s BROADCOM mark.

 

2.      Respondent does not have any rights or legitimate interests in the <vipbroadcom.com>, <vipbroadcom.net>, <vipbroadcom.org> and <vipbroadcom.info> domain names.

 

3.      Respondent registered and used the <vipbroadcom.com>, <vipbroadcom.net>, <vipbroadcom.org> and <vipbroadcom.info> domain names in bad faith.

 

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

 

FINDINGS

Complainant, Broadcom Corporation holds at least five registrations with the United States Patent and Trademark Office for the BROADCOM mark (Reg. No. 2,132,930, issued January 27, 1998; Reg. No. 2,392,925, issued October 10, 2000; Reg. No. 2,326,387, issued March 7, 2000; Reg. No. 2,625,799, issued September 24, 2002; Reg. No. 2,595,174, issued July 16, 2002). 

 

Complainant has used the BROADCOM mark in connection with providing highly integrated semiconductor solutions that enable broadband communications and networking of voice, video and data services since as early as November 1994.  Complainant also designs, develops and supplies complete system-on-a-chip solutions, incorporating digital, analog and radio frequency technologies, as well as related hardware and software system-level applications.  Complainant’s portfolio includes solutions for digital cable and satellite set-top boxes; high definition television; cable and DSL modems and residential gateways; high speed transmission and switching for local, metropolitan, wide area and storage networking, home and wireless networking; cellular and terrestrial wireless communications; Voice over Internet Protocol gateway and telephony systems; broadband network processors and system I/O server solutions.

 

Respondent registered the <vipbroadcom.com> and <vipbroadcom.net> domain names on February 25, 2005 and the <vipbroadcom.org> and <vipbroadcom.info> domain names on February 26, 2005.  Respondent is using the disputed domain names to redirect Internet users to a webpage advertising domain name registration services. 

 

Respondent’s registrar provides a service that allows its customers to register domain names while concealing Respondent’s true identity behind a Registrar-owned company operating as SecureWhois, Inc.  Thus, the initial information provided in the WHOIS database did not identify the true owner and host of the contested domain names.  However, the Registrar has subsequently provided the correct ownership information to the National Arbitration Forum, who in turn has provided that information to Complainant.  However, as of the date the Amended Complaint was filed, the WHOIS record continues to identify the incorrect owner of the disputed domain names.

 

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 BROADCOM mark through registration with the United States Patent and Trademark Office and through continuous use of the mark in commerce for the last eleven 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 domain names registered by Respondent are confusingly similar to Complainant’s BROADCOM mark because the domain names incorporate Complainant’s mark in its entirety and deviate from it by adding the generic or descriptive acronym, “vip.”  The acronym is universally understood to mean “very important person” and in the high tech industry, it is understood to mean “variable information processing.”  The mere addition of a generic or descriptive acronym to a registered mark does not negate the confusing similarity of Respondent’s domain names pursuant to Policy ¶ 4(a)(i).  See Magnum Piering, Inc. v. Mudjackers, D2000-1525 (WIPO Jan. 29, 2001) (finding that the generic term “INC” does not change the confusing similarity); see also Am. Online Inc. v. Neticq.com Ltd., D2000-1606 (WIPO Feb. 12, 2001) (finding that the addition of the generic word “Net” to Complainant’s ICQ mark, makes the <neticq.com> domain name confusingly similar to Complainant’s mark); 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 AXA China Region Ltd. v. KANNET Ltd., D2000-1377 (WIPO Nov. 29, 2000) (finding that common geographic qualifiers or generic nouns can rarely be relied upon to differentiate the mark if the other elements of the domain name comprise a mark or marks in which another party has rights).

 

Moreover, the addition of the generic top-level domains “.com,” “.net,” “.org” or “.info” is irrelevant in determining whether the disputed domain names are confusingly similar to Complainant’s BROADCOM mark.  See 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); see also 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 Rollerblade, Inc. v. McCrady, D2000-0429 (WIPO June 25, 2000) (finding that the top level of the domain name such as “.net” or “.com” does not affect the domain name for the purpose of determining whether it is identical or confusingly similar); see also Koninklijke Philips Elecs. NV v. Goktas, D2000-1638 (WIPO Feb. 8, 2001) (finding that the domain name <philips.org> is identical to Complainant’s PHILIPS mark).

 

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 names.  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).

 

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 website containing commercial content; specifically, Respondent’s website offers the sale of domain name registration services.  The Panel finds Respondent’s use of confusingly similar domain names to redirect Internet users to a commercial website 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 pursuant to Policy ¶ 4(c)(iii).  See MSNBC Cable, LLC v. Tysys.com, D2000-1204 (WIPO Dec. 8, 2000) (finding no rights or legitimate interests in the famous MSNBC mark where Respondent attempted to profit using Complainant’s mark by redirecting Internet traffic to its own website); see also Am. Online, Inc. v. Tencent Comm. Corp., FA 93668 (Nat. Arb. Forum Mar. 21, 2000) (finding that use of Complainant’s mark “as a portal to suck surfers into a site sponsored by Respondent hardly seems legitimate”); see also State Farm Mut. Auto. Ins. Co. v. LaFaive, FA 95407 (Nat. Arb. Forum Sept. 27, 2000) (finding that “unauthorized providing of information and services under a mark owned by a third party cannot be said to be the bona fide offering of goods or services”); see also Pfizer, Inc. v. Internet Gambiano Prods., D2002-0325 (WIPO June 20, 2002) (finding that because the VIAGRA mark was clearly well-known at the time of Respondent’s registration of the domain name it can be inferred that Respondent is attempting to capitalize on the confusion created by the domain name’s similarity to the mark).

 

Furthermore, Respondent is not commonly known by the disputed domain names, and does not have Complainant’s authorization to use the BROADCOM mark or offer goods and services under Complainant’s BROADCOM mark.  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). 

 

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

 

Registration and Use in Bad Faith

 

Respondent is incorporating Complainant’s mark in its domain names to lead Internet users to a commercial website.  The Panel finds that Respondent is using the domain names to attract Internet users to Respondent’s website for Respondent’s commercial gain, which constitutes bad faith 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 Am. Online, Inc. v. Tencent Comm. Corp., FA 93668 (Nat. Arb. Forum Mar. 21, 2000) (finding bad faith where Respondent registered and used an infringing domain name to attract users to a website sponsored by Respondent); see also H-D Michigan, Inc. v. Petersons Auto. a/k/a Larry Petersons, FA 135608 (Nat. Arb. Forum Jan. 8, 2003) (finding that the disputed domain name was registered and used in bad faith pursuant to Policy ¶ 4(b)(iv) through Respondent’s registration and use of the infringing domain name to intentionally attempt to attract Internet users to its fraudulent website by using Complainant’s famous marks and likeness); 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).

 

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 <vipbroadcom.com>, <vipbroadcom.net>, <vipbroadcom.org> and <vipbroadcom.info> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

 

James A. Crary, Panelist

Dated:  May 17, 2005

 

 

 

 

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