National Arbitration Forum

 

DECISION

 

Marshalls of Nevada, Inc. v. Kim Jongsub

Claim Number: FA0506000495434

 

PARTIES

Complainant is Marshalls of Nevada, Inc. (¡°Complainant¡±), represented by Larry C. Jones of Alston & Bird, LLP, Bank of America Plaza, 101 S. Tryon Street, Suite 4000, Charlotte, NC 28280-4000, USA.  Respondent is Kim Jongsub (¡°Respondent¡±), 960-1, Jisan 1-dong, Suseong-gu, Daegu, 706841, KR.

 

REGISTRAR AND DISPUTED DOMAIN NAME
 

The domain name at issue is <marshals.com>, registered with Cydentity, Inc. d/b/a Cypack.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.

 

Kyung Jik Kwak is the Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on June 13, 2005; the National Arbitration Forum received a hard copy of the Complaint on June 15, 2005.

 

On June 14, 2005, Cydentity, Inc. Dba Cypack.com confirmed by e-mail to the National Arbitration Forum that the domain name <marshals.com> is registered with Cydentity, Inc. d/b/a Cypack.com and that Respondent is the current registrant of the name.  Cydentity, Inc. d/b/a Cypack.com has verified that Respondent is bound by the Cydentity, Inc. d/b/a Cypack.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 June 27, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the ¡°Commencement Notification¡±), setting a deadline of July 18, 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@marshals.com by e-mail.

 

A timely Response was received and determined to be complete on July 18, 2005.


As noted below, additional submissions by both parties were made in a timely manner according to the Forum¡¯s Supplement Rule 7.

On July 21, 2005, Complainant submitted a Complainant¡¯s Reply in Further Support of its Complaint (¡°Complainant¡¯s Reply¡±) to the National Arbitration Forum. On the same date, Complainant¡¯s Reply along with its Korean translation was sent to Respondent via email.

On July 25, 2005, Respondent submitted Additional Response against Complainant¡¯s Reply in Further Support of its Complaint in Korean (¡°Respondent¡¯s Additional Response¡±), which was sent to Complainant via email.

On July 27, 2005, pursuant to Complainant¡¯s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Kyung Jik Kwak as Panelist.

 

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

 

PARTIES¡¯ CONTENTIONS

A. Complainant

1.            Complainant states: (1) that it is a corporation duly organized and existing under the laws of the State of Nevada, having a principal place of business in North Las Vegas, Nevada, (2) that it has offered retail store services in the United States under the MARSHALLS mark since at least as early as 1966, (3) that there are more than 700 MARSHALLS stores operating in 42 states and Puerto Rico, (4) that it owns several registrations for the MARSHALLS mark, either as a singular word mark or combined with other terms, including U.S. Trademark Registration No. 1,978,509 for the MARSHALLS mark issued June 4, 1996, that covers ¡°retail department store services,¡± (5) that it owns valid and enforceable common law rights in its MARSHALLS mark in the United States by virtue of its continuous use of such mark for several years as well as valid statutory rights in its MARSHALLS mark in the United States by virtue of its longstanding use and registration of that mark with the United States of Patent and Trademark Office, and (6) that its affiliate, The TJX Companies, Inc., owns the <marshallsonline.com> domain name, which is used to direct users to Complainant¡¯s website.

2.            Complainant adds: that (1) Respondent is the owner of the
<marshals.com> domain name, (2) that Respondent is using <marshals.com> to provide links to numerous third party websites that purport to offer a variety of goods and services, and that such links are identified by such items as ¡°Online shopping,¡± ¡°Womens [sic] Clothing,¡± ¡°Shoes,¡± etc.

3.            Complainant argues that Respondent¡¯s
<marshals.com> domain name is strikingly similar to Complainant¡¯s MARSHALLS mark. Complainant points out that <marshals.com> is identical to MARSHALLS except that the former contains a typographic error by omitting the second ¡°l¡± in the latter. Complainant argues that the former differs from the latter only by one letter and is likely to result from a typographical error or misspelling by an Internet user who intuitively enters  <marshals.com> in seeking Complainant¡¯s website

4.            Complainant argues that Respondent has no rights or legitimate interests in
 <marshals.com> as a domain name. Complainant notes that Respondent does not allege that he is commonly known as MARSHALS or that he has operated a business under this name.

5.            Complainant points out that Respondent did not register <marshals.com> until January 11, 2000, long after Complainant¡¯s MARSHALLS mark had acquired its fame. Complainant argues that without any preexisting rights in <marshals.com> as a trademark or a service mark, it may be assumed that Respondent adopted, registered, and is using the <marshals.com> domain name because of the fame and goodwill associated with Complainant¡¯s MARSHALLS mark.

6.            Complainant also notes that Respondent is permitting another entity to use the
<marshals.com> domain name to direct Internet traffic to a website that promotes the ¡°Online shopping¡± services of others and the ¡°Womens [sic] clothing,¡± ¡°Shoes,¡± and ¡°Jewelry¡± merchandise of other businesses. Complainant argues that such promotional activities are clear evidence of the sort of bad faith under Policy ¢Ò¢Ò 4(b)(ii) and (iv).

B. Respondent

1.            Respondent states: (1) that he is a professional web designer conducting active internet business, (2) that he needed to secure domain names to be used in his web design business, (3) and that he is now operating a number of websites for business. Respondent states that he is operating websites at <worldmovie.com>, <mana1004.net>, <budongsan.net>, <buydomain.com> and <buddhakorea.net> for movies, cartoons, real property, domain registration and Korean Buddhism images, respectively.

2.            Respondent argues that there is no possibility that Respondent was aware of the registrations of Complainant¡¯s MARSHALLS mark and that he did not know and need not know where Complainant is located or even whether it has ever been established. Respondent further argues that there are few among people in Korea who know about the existence of Complainant.

3.            Respondent argues that his
<marshals.com> domain name is neither identical nor confusingly similar to Complainant¡¯s MARSHALLS mark. Respondent argues there is a distinct difference between  <marshals.com> and MARSHALLS, because  ¡°marshal¡± is a common noun that means a police officer or a highest ranking military officer while ¡°MARSHALL¡± is a word not found in a dictionary. 
 
4.            Respondent adds that since ¡°
marshal¡± is a common noun, it (or its plural form marshals) is not registrable as a trademark or service mark in Korea. Respondent emphasizes that Complainant does not have trademark or service mark rights in either ¡°marshal¡± or ¡°marshals.¡± Respondent alleges that he was not aware of the existence of Complainant let alone its MARSHALLS trademark or service mark.

5.            Respondent argues that he has rights and legitimate interests in
<marshals.com>. Respondent argues that in case of a domain name that consists of a common noun, the first registrant obtains rights and legitimate interests by only expressing his/her intent to use such domain name.

 

6.            Respondent argues that he intends to conduct the business of the provision of online services for checking and curing virus and network security in the future and that he will use <marshals.com> website for such business. Respondent admits that he is not currently running such business and that he permits a ¡°domain sponsor¡± (www.domainsponsor.com) to use <marshals.com>  to direct Internet traffic to a website that promotes, among other things, ¡°Online shopping,¡± ¡°Womens [sic] clothing,¡± and ¡°Shoes.¡± Respondent argues that such permission is temporary until he will have secured enough capital to launch the business of virus checking and network security.

7.            Respondent argues that
<marshals.com> has neither been registered nor is being used in bad faith. Respondent argues that he has registered and is holding <marshals.com> not to sell but to use for his future business himself. Respondent argues that he has never proposed to sell <marshals.com> to Complainant and that he does not intend to sell it to a third party. Respondent explains that the reason why he permits ¡°domain sponsor¡± to provide links is because he is postponing the construction of his website (for his intended business) due to his financial situation. Respondent adds that if he finds financial solutions, he will immediately construct and operate the website.
 
C. Additional Contentions

The contentions by the parties restated respectively in the above section A and B reflect not just Complaint and Reply but also additional submissions by the parties, Complainant¡¯s Reply and Respondent¡¯s Additional Response, except the following:

Respondent extensively argues that there is a distinct difference between <marshallsonline.com> and
<marshals.com>. Respondent also argues that <marshallsonline.com> has not become distinctively known yet throughout the world.

To this, Complainant responds that the proper comparison is between the subject name, here
<marshals.com> and the mark to which Complainant has rights, here MARSHALLS under Policy ¢Ò 4(a)(i), and thus any similitude between <marshals.com> and <marshallsonline.com> is irrelevant for purpose of the UDRP, as is the relative fame of the <marshallsonline.com> domain name.

FINDINGS

The Panelist finds the following facts based on statements and documents submitted by the parties.

Complainant is a corporation duly organized and existing under the laws of the State of Nevada, having a principal place of business in North Las Vegas, Nevada. It has offered retail store services in the United States under the MARSHALLS mark since at least as early as 1966 and there are more than 700 MARSHALLS stores operating in 42 states and Puerto Rico. Complainant owns several registrations for the MARSHALLS mark, either as a singular word mark or combined with other terms, including U.S. Trademark Registration No. 1,978,509 for the MARSHALLS mark issued June 4, 1996, that covers ¡°retail department store services.¡±

The services of Complainant have been and are being advertised and promoted extensively under the MARSHALLS mark, among other things, on the Internet. Complainant¡¯s affiliate, The TJX Companies, Inc., owns the <marhsallsonline.com> domain name, which is used to direct users to Complainant¡¯s website.

Respondent is a Korean citizen residing in Daegu, Korea. He is currently operating a number of websites for business, including <worldmovie.com>, <mana1004.net> and <budongsan.net> for movies, cartoons and real property, respectively, in the Korean language, and <buydomain.com> and <buddhakorea.net> for domain registration and Korean Buddhism, respectively, in the English language.

On January 11, 2000, Respondent registered the
<marshals.com> domain name. While Respondent states that he intends to conduct the business of the provision of online services for checking and curing virus and network security in the future and that he will use <marshals.com> website for such business; as a matter of fact he is not currently conducting such business and is not using the domain name for such business.

Rather Respondent permits a ¡°domain sponsor¡± (www.domainsponsor.com) to use
<marshals.com> to direct Internet traffic to a website that promotes, among other things, ¡°Online shopping,¡± ¡°Womens [sic] clothing,¡± and ¡°Shoes.¡±

Further, the said webpage at <marshals.com>, as of April 5, 2005, attached as Complainant¡¯s evidence Exhibit 2 of Exhibit B, shows the link ¡°Make this your homepage.¡±

DISCUSSION
 

Paragraph 15(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (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.¡±

 

Paragraph 4(a) of the Policy requires that the 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 the Respondent is identical or confusingly similar to a trademark or service mark in which the Complainant has rights;

(2)    the 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 mark MARSHALLS by its registration of the mark with the United States Patent and Trademark Office (Reg. No. 1,978,509). The fact that ¡°marshals¡± is a common noun and is not a registered mark either in Korea or in the United States does not affect Complainant¡¯s legitimate rights in the mark MARSHALLS.  See Innomed Techs., Inc. v. DRP Servs., FA 221171 (Nat. Arb. Forum Feb. 18, 2004) (¡°Registration of the NASAL-AIRE mark with the USPTO establishes Complainant's rights in the mark.¡±).

Respondent¡¯s
<marshals.com> domain name differs from Complainant¡¯s mark MARSHALLS by the omission of only one letter, ¡°l.¡± With the exact same pronunciation and sequence of letters of the two, such difference is insufficient to distinguish Respondent¡¯s domain name from Complainant¡¯s mark.  See Compaq Info. Techs. Group, L.P. v. Seocho, FA 103879 (Nat. Arb. Forum Feb. 25, 2002) (finding that the domain name <compq.com> is confusingly similar to the complainant¡¯s COMPAQ mark because the omission of the letter ¡°a¡± in the domain name does not significantly change the overall impression of the mark).

It is established that Respondent¡¯s domain name and Complainant¡¯s mark are confusingly similar to each other.

Rights or Legitimate Interests

 

A marshal is a common noun, the meaning of which is found in a dictionary. Respondent is the first registrant of the <marshals.com> domain name, which consists of that common noun. Respondent argues that the expression of his intent to use such domain name should establish that Respondent has rights or legitimate interests in the domain name. The panelist disagrees with Respondent¡¯s argument for the following reasons.

It is clear that Respondent is not commonly known by the
<marshals.com> domain name. While Respondent states that he intends to conduct the business of the provision of online services for checking and curing virus and network security in the future and that he will use <marshals.com> website for such business, as a matter of fact he admits that he is not currently conducting such business and is not using the domain name for such business. Moreover, Respondent fails to provide any evidence of demonstrable preparations to use the domain name in connection with such business or any other bona fide offering of goods or services in the future.

Respondent alleges that he is postponing the construction of the website and provision of virus checking and network security services using the domain name due to his financial situation. That allegation, coupled with the fact that he now diverts Internet users to third-party websites via Respondent¡¯s website only leads to the conclusion that he is neither preparing to conduct such business using the domain name in any meaningful way in any foreseeable future nor making a legitimate noncommercial or fair use of the domain name.  See
Am. Online, Inc. v. Advanced Membership Servs., Inc., FA 180703 (Nat. Arb. Forum Sept. 26, 2003) (¡°Respondent's registration and use of the <gayaol.com> domain name with the intent to divert Internet users to Respondent's website suggests that Respondent has no rights to or legitimate interests in the disputed domain name pursuant to Policy Paragraph 4(a)(ii).¡±).

It is established that Respondent has no rights or legitimate interests in respect of the domain name.

Registration and Use in Bad Faith

 

Respondent registered <marshals.com> on January 11, 2000, long after Complainant had acquired rights in MARSHALLS mark.

While not conducting any business himself using it, Respondent is permitting another entity to use the
<marshals.com> domain name to direct Internet traffic to a website that promotes the ¡°Online shopping¡± services of others and the ¡°Womens [sic] clothing,¡± ¡°Shoes,¡± and ¡°Jewelry¡± merchandise of other businesses. Such promotional activities clearly overlap the business activities of Complainant in terms of goods and services as well as methods. 

Such overlap of promotional activities along with such similarity between Respondent¡¯s domain name and Complainant¡¯s mark lead to the conclusion that there are circumstances that Respondent has allowed a third party to intentionally attempt to attract, for commercial gain, Internet users to the said website or other on-line location, by creating a likelihood of confusion with Complainant¡¯s mark as to the source, sponsorship, affiliation, or endorsement of the said website. 
See H-D Michigan, Inc. v. Petersons Auto., FA 135608 (Nat. Arb. Forum Jan. 8, 2003) (finding that the disputed domain name was registered and used in bad faith pursuant to Policy ¢Ò 4(b)(iv) through the respondent¡¯s registration and use of the infringing domain name to intentionally attempt to attract Internet users to its fraudulent website by using the complainant¡¯s famous marks and likeness).

Moreover, while Respondent argues that he does not intend to sell it to the third party, the link ¡°Make this your homepage¡± shown in the said webpage <marshals.com> as of April 5, 2005, attached as Complainant¡¯s evidence Exhibit 2 of Exhibit B, clearly indicates that Respondent has a willingness to sell the domain name to any high bidder.

Thus, Complainant has successfully established that Respondent¡¯s domain name has been registered and is being used in bad faith.

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 <marshals.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

 

Kyung Jik Kwak, Panelist
Dated:
August 10, 2005

 

 

 

 

 

 

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