national arbitration forum

 

DECISION

 

IndyMac Bank, F.S.B. v. Jason U Carpenter d/b/a Jason U Internet Inc

Claim Number:  FA0505000474818

 

PARTIES

Complainant, IndyMac Bank, F.S.B. (“Complainant”), is represented by B. Brett Heavner, of Finnegan, Henderson, Farabow, Garrett & Dunner, L.L.P., 901 New York Avenue NW, Washington, DC 20001.  Respondent is Jason U Carpenter d/b/a Jason U Internet Inc (“Respondent”), 000 Jackson Ave., Sysosset NY, New York 11791.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <indymak.com> and <indimacloan.com>, registered with Tucows 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.

 

James A, Crary as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on May 11, 2005; the National Arbitration Forum received a hard copy of the Complaint on May 12, 2005.

 

On May 12, 2005, Tucows Inc. confirmed by e-mail to the National Arbitration Forum that the domain names <indymak.com> and <indimacloan.com> are registered with Tucows Inc. and that Respondent is the current registrant of the names.  Tucows Inc. has verified that Respondent is bound by the Tucows Inc. 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 May 13, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of June 2, 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@indymak.com and postmaster@indimacloan.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 June 10, 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 <indymak.com> and <indimacloan.com> domain names are confusingly similar to Complainant’s INDYMAC mark.

 

2.      Respondent does not have any rights or legitimate interests in the <indymak.com> and <indimacloan.com> domain names.

 

3.      Respondent registered and used the <indymak.com> and <indimacloan.com> domain names in bad faith.

 

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

 

FINDINGS

Complainant, IndyMac Bank, F.S.B., is a wholly-owned subsidiary of IndyMac Bancorp, Inc., a public company traded on the New York Stock Exchange.  Complainant is a leading mortgage lender that generated over $37.9 billion in loan production last year and is the largest savings and loan in Los Angeles County and the tenth largest in the nation. 

 

Complainant is also a leading technology-based mortgage bank with proprietary, award-winning systems to facilitate automated underwriting and risk-based pricing on a nationwide basis through the Internet.  Complainant’s mortgage banking group offers multi-channel distribution of its mortgage products and services through a nationwide network of mortgage brokers, mortgage bankers, community financial institutions, realtors and homebuilders in addition to offering its products directly to consumers through the Internet.  Complainant’s full array of web-enhanced banking services include deposits, competitive CD and money market accounts, and online bill payment services.  Complainant showcases its products and services on its main website located at the <indymac.com> and <indymacbank.com> domain names. 

 

Complainant holds a trademark registration with the United States Patent and Trademark Office (“USPTO”) for the INDYMAC mark (Reg. No. 2,212,512, issued December 22, 1998).  Complainant also owns a family of INDYMAC formative marks, including the INDYMAC BANK and INDYMAC BANK EQUITY CARD marks (Reg. No. 2,518,498, issued December 11, 2001 and Reg. No. 2,698,505, issued March 18, 2003).  Complainant has used the INDYMAC mark continuously in connection with its financial and mortgage banking services since as early as June 26, 1997.

 

Respondent registered the <indymak.com> and <indimacloan.com> domain names on December 1, 2004 and March 20, 2005, respectively.  Respondent is using the disputed domain names to redirect Internet users to a revenue generating search engine website at the <domainsponsor.com> domain where Respondent is presumed to receive pay-per-click compensation based on the advertisements of numerous links to Complainant and Complainant’s competitors.

 

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 INDYMAC mark through registration with the United States Patent and Trademark Office and through continued use of of its mark in commerce for the last seven 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  <indymak.com> domain name registered by Respondent is confusingly similar to Complainant’s INDYMAC mark because the domain name is phonetically identical to Complainant’s mark and comprises a misspelling of Complainant’s mark where Respondent has replaced the letter “c” with the letter “k.”  The Panel finds that a domain name that is phonetically identical to Complainant’s mark and incorporates a simple misspelling does not negate the confusing similarity of Respondent’s domain name pursuant to Policy ¶ 4(a)(i).  See Hewlett-Packard Co. v. Cupcake City, FA 93562 (Nat. Arb. Forum Apr. 7, 2000) (finding that a domain name which is phonetically identical to Complainant’s mark satisfies ¶ 4(a)(i) of the Policy); see also YAHOO! Inc. v. Murray, D2000-1013 (WIPO Nov. 17, 2000) (finding that the domain name <yawho.com> is confusingly similar to Complainant’s YAHOO mark); see also 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).

 

Respondent’s <indimacloan.com> domain name is also confusingly similar to Complainant’s INDYMAC mark because not only does it include a phonetically misspelled version of Complainant’s mark, but it merely adds the word “loan,” which describes Complainant’s business.  The Panel finds that combining a misspelled version of Complainant’s mark with the addition of a generic term that describes Complainant’s business is insufficient to distinguish the disputed domain name from Complainant’s INDYMAC mark.  See VeriSign, Inc. v. VeneSign C.A., D2000-0303 (WIPO June 28, 2000) (finding that the pronunciation and spelling between the domain name <venesign.com> and Complainant’s VERISIGN mark are so close that confusion can arise in the mind of the consumer); see also Victoria's Secret v. Internet Inv. Firm Trust, FA 94344 (Nat. Arb. Forum May 9, 2000) (finding the domain name <victoriasecret.com> to be confusingly similar to Complainant’s VICTORIA’S SECRET mark); 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 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 Brown & Bigelow, Inc. v. Rodela, FA 96466 (Nat. Arb. Forum Mar. 5, 2001) (finding that the <hoylecasino.net> domain name is confusingly similar to Complainant’s HOYLE mark, and that the addition of “casino,” a generic word describing the type of business in which Complainant is engaged, does not take the disputed domain name out of the realm of confusing similarity).

 

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

 

Rights or Legitimate Interests

 

Complainant established its rights in the INDYMAC mark and alleges that Respondent has no such 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, the Panel assumes 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 also accepts 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 <indymak.com> and <indimacloan.com> domain names, which are confusingly similar to Complainant’s INDYMAC mark, to operate a search engine website that features links to competing mortgage and financial websites.  Such competing use is not a use in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i).  See 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); see also 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).

 

Complainant asserts that Respondent is not commonly known by the  <indymak.com> and <indimacloan.com> domain names pursuant to paragraph 4(c)(ii) of the Policy.  Nothing in the record clearly contradicts this assertion.  Thus, the Panel finds Respondent did not establish rights or legitimate interests in the disputed domain name under this element.  See 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").

 

Respondent is using the disputed domain names to redirect Internet users to <domainsponsors.com> where Respondent then receives click-through fees for redirecting Internet traffic to the numerous advertised commercial links.  The Panel finds that Respondent’s commercial use of the disputed domain names by receiving click-through fees from redirecting Internet users to a pay-per-click website, is not a legitimate noncommercial or fair use of the domain name pursuant to Policy ¶ 4(c)(iii).  See FAO Schwarz v. Zuccarini, FA 95828 (Nat. Arb. Forum Dec. 1, 2000) (finding no rights or legitimate interests in the domain names <faoscwartz.com>, <foaschwartz.com>, <faoshwartz.com>, and <faoswartz.com> where Respondent was using these domain names to link to an advertising website); see also 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 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).

 

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

 

Registration and Use in Bad Faith

 

Respondent is using the <indymak.com> and <indimacloan.com> domain names, which are confusingly similar to Complainant’s INDYMAC mark, to redirect Internet users to a search engine website that features links to mortgage and financial services-related websites.  The Panel finds that such competing use constitutes disruption and is evidence that Respondent registered and used the domain names in bad faith pursuant to Policy ¶ 4(b)(iii).  See Puckett v. Miller, D2000-0297 (WIPO June 12, 2000) (finding that Respondent has diverted business from Complainant to a competitor’s website in violation of Policy ¶ 4(b)(iii)); 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 infers that Respondent receives click-through fees for diverting Internet users to the <domainsponsor.com> website.  Since Respondent’s <indymak.com> and <indimacloan.com> domain names are confusingly similar to Complainant’s INDYMAC mark, consumers accessing Respondent’s domain names may become confused as to Complainant’s affiliation with the resulting search engine website.  Thus, the Panel finds that Respondent’s commercial use of the disputed domain names constitutes bad faith registration and use pursuant to 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 Qwest Communications Int’l Inc. v. Ling Shun Shing, FA 187431 (Nat. Arb. Forum Oct. 6, 2003) (Respondent's attempt to commercially benefit from the misleading domain name is evidence of bad faith pursuant to Policy ¶ 4(b)(iv).”).

 

Furthermore, Respondent registered the <indymak.com> and <indimacloan.com> domain names with actual or constructive knowledge of Complainant’s rights in the INDYMAC mark due to Complainant’s registration of the mark with the USPTO.  Moreover, the Panel infers that Respondent had actual knowledge of Complainant’s mark due to the obvious connection between the content advertised on Respondent’s website and Complainant’s business.  Registration of a domain name that is confusingly similar to a mark, despite actual or constructive knowledge of another’s rights in the mark, is evidence of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).  See 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. 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”).

 

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 <indymak.com> and <indimacloan.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

 

James A. Crary, Panelist

Dated:  June 24, 2005

 

 

 

 

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