national arbitration forum

 

DECISION

 

America Online, Inc. v. Andy Tran d/b/a SmartBuy Corporation

Claim Number:  FA0507000515489

 

PARTIES

Complainant is America Online, Inc. (“Complainant”), represented by James R. Davis of Arent Fox PLLC, 1050 Connecticut Avenue, NW, Washington, DC 20036.  Respondent is Andy Tran d/b/a SmartBuy Corporation (“Respondent”), 1401 North Batavia Street, Suite 111, Orange, CA 92867, US.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <topaol.com>, registered with Tucows Inc. and <softicq.com>, <aolet.com>,  <yougotvoicemail.com>, <yougotfemale.com> and <aimreach.com>, registered with Enom, Inc..

 

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.

 

John J. Upchurch as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on July 14, 2005; the National Arbitration Forum received a hard copy of the Complaint on July 18, 2005.

 

On July 14, 2005, Tucows Inc. confirmed by e-mail to the National Arbitration Forum that the domain name <topaol.com> is registered with Tucows Inc., Enom, Inc. and that Respondent is the current registrant of the name.  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 July 15, 2005, Enom, Inc. confirmed by e-mail to the National Arbitration Forum that the domain names <aolet.com>, <softicq.com>, <yougotvoicemail.com>, <yougotfemale.com> and <aimreach.com> are registered with Enom, Inc. and that Respondent is the current registrant of the names.  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 ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy").

 

On July 25, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of August 15, 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@topaol.com, postmaster@aolet.com, postmaster@softicq.com, postmaster@yougotvoicemail.com, postmaster@yougotfemale.com and postmaster@aimreach.com by e-mail.

 

Having received no Response from Respondent, the National Arbitration Forum transmitted to the parties a Notification of Respondent Default.

 

On August 23, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed John J. Upchurch 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 <topaol.com>, <aolet.com>, <softicq.com>, <yougotvoicemail.com>, <yougotfemale.com> and <aimreach.com> domain names are confusingly similar to Complainant’s AOL, ICQ, AIM and YOU’VE GOT MAIL marks.

 

2.      Respondent does not have any rights or legitimate interests in the <topaol.com>, <aolet.com>, <softicq.com>, <yougotvoicemail.com>, <yougotfemale.com> and <aimreach.com> domain names.

 

3.      Respondent registered and used the <topaol.com>, <aolet.com>, <softicq.com>, <yougotvoicemail.com>, <yougotfemale.com> and <aimreach.com> domain names in bad faith.

 

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

 

FINDINGS

Complainant, America Online, Inc., is a global leader in the computer, entertainment and online services industries.  Complainant uses its AOL, ICQ, AIM and YOU’VE GOT MAIL marks in connection with a wide range of information and services over the Internet and through tradiational media.

 

Complainant holds numerous trademark registrations with the United States Patent and Trademark Office (“USPTO”) for the AOL (Reg. No. 1,977,731 issued June 4, 1996), ICQ (Reg. No. 2,411,657 issued December 12, 2000), AIM (Reg. No. 2,423,368 issued January 23, 2001) and YOU’VE GOT MAIL (Reg. No. 2,628,523 issued October 1, 2002) marks. 

 

Complainant has invested substantial sums of money to develop and market its products, services and famous marks.  Complainant has spent millions of dollars to promote and advertise its marks via network and cable television, radio broadcasts, newspapers and other print periodicals. 

 

Respondent registered the <topaol.com> domain name on November 23, 2003.    Respondent registered the <aimreach.com> domain name on March 6, 2004, the <yougotvoicemail.com> and <yougotfemale.com> domain names on March 7, 2004, the <aolet.com> domain name on April 5, 2004, and the <softicq.com> domain name on April 11, 2004.  The disputed domain names resolve to directory websites that feature generic search engines and links to various third-party businesses.  Presumably, Respondent receives referral fees from these websites. 

 

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.  The Panel is entitled to accept all reasonable allegations and inferences in the Complaint as true.  See Bayerische Motoren Werke AG v. Bavarian AG, FA 110830 (Nat. Arb. Forum June 17, 2002) (finding that, in the absence of a response, the panel is free to make inferences from the very failure to respond and assign greater weight to certain circumstances than it might otherwise do); see also Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (Nat. Arb. Forum July 31, 2000) (holding that the respondent’s failure to respond allows all reasonable inferences of fact in the allegations of the complaint to be deemed true).

 

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 provided evidence of its registrations of the AOL, ICQ and YOU’VE GOT MAIL marks with the USPTO.  Complainant’s registration of its mark with a federal authority is sufficient to establish a prima facie case of Complainant’s rights in the marks for purposes of Policy ¶ 4(a)(i).  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.”); see also Janus Int’l Holding Co. v. Rademacher, D2002-0201 (WIPO Mar. 5, 2002) ("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.").

 

The <topaol.com>, <aolet.com>, <softicq.com> and <aimreach.com> domain names include either Complainant’s AOL, ICQ or AIM mark in its entirety in addition to a generic or descriptive term or combination of letters and the generic top-level domain (“gTLD”) “.com.”  The addition of a generic or descriptive term or letter combination and a gTLD to Complainant’s registered and famous marks is not sufficient to distinguish the disputed domain names from Complainant’s mark.  Therefore, the <topaol.com>, <aolet.com>, <softicq.com> and <aimreach.com> domain names are confusingly similar to Complainant’s marks pursuant to Policy ¶ 4(a)(i).  See Busy Body, Inc. v. Fitness Outlet Inc., D2000-0127 (WIPO Apr. 22, 2000) (finding that "the addition of the generic top-level domain (gTLD) name ‘.com’ is . . . without legal significance since use of a gTLD is required of domain name registrants"); see also Am. Online, Inc. v. Tencent Commc’ns Corp., FA 93668 (Nat. Arb. Forum Mar. 21, 2000) (finding that <oicq.net> and <oicq.com> are confusingly similar to the complainant’s mark, ICQ); see also L.L. Bean, Inc. v. ShopStarNetwork, FA 95404 (Nat. Arb. Forum Sept. 14, 2000) (finding that combining the generic word “shop” with the complainant’s registered mark “llbean” does not circumvent the complainant’s rights in the mark nor avoid the confusing similarity aspect of the Policy).  

 

The <yougotvoicemail.com> domain name is confusingly similar to Complainant’s YOU’VE GOT MAIL mark, because the disputed domain name is comprised of the dominant features of Complainant’s mark, omitting only the contraction “’ve” and adding the generic or descriptive term “voice.”  See Modern Props, Inc. v. Wallis, FA 152458 (Nat. Arb. Forum June 2, 2003) (“Notwithstanding the analysis by Respondent, ‘modprops’ is a contraction or shorthand for ‘Modern Props.’ ‘Mod’ cononotes [sic] ‘modern’ regardless of any other dictionary meanings, so the names are substantially similar in meaning.”); see also Down E. Enter. Inc. v. Countywide Commc’ns, FA 96613 (Nat. Arb. Forum Apr. 5, 2001) (finding the domain name <downeastmagazine.com> confusingly similar to the complainant’s common law mark DOWN EAST, THE MAGAZINE OF MAINE); 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).

 

The Panel finds that Complainant has satisfied Policy ¶ 4(a)(i) for the <topaol.com>, <aolet.com>, <softicq.com>, <yougotvoicemail.com> and <aimreach.com> domain names.

 

Although the <yougotfemale.com> domain name might sound somewhat similar to Complainant’s YOU’VE GOT MAIL mark, the Panel does not find the domain name to be confusingly similar to the mark.  See Copart, Inc. v. SalvageNow, D2000-0417 (WIPO June 28, 2000) (finding that the domain name at issue <copart.net> is not identical to nor substantially similar to the mark registered and used by the complainant, "CI Copart Inc. Salvage Auto Auctions"); see also Dollar Fin. Group, Inc. v. Oakridge, FA 94977 (Nat. Arb. Forum July 17, 2000) (finding that the domain names, <tillpaydayloan.com>, <tillpaydayloans.com>, <untilpaydayloan.com>, and <untilpaydayloans.com> are not identical or confusingly similar to the complainant’s CASH ‘TIL PAYDAY and CASH ‘TIL PAYDAY LOANS trademarks and service marks).

 

Thus, the Panel finds that Complainant has not satisfied Policy ¶ 4(a)(i) for the <yougotfemale.com> domain name.

 

Rights or Legitimate Interests

 

It has been established under the Policy that the complainant has the initial burden of proving that the respondent lacks rights and legitimate interests in the disputed domain names.  In Compagnie Generale des Matieres Nucleaires v. Greenpeace Int’l, D2001-0376 (WIPO May 14, 2001), the panel held:

 

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 and 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.

 

Id.; see also Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (holding that where the complainant has asserted that the respondent has no rights or legitimate interests with respect to the domain name it is incumbent on the respondent to come forward with concrete evidence rebutting this assertion because this information is “uniquely within the knowledge and control of the respondent”).  Having found that Complainant has met its initial burden by establishing a prima facie case, the Panel will now analyze whether Respondent has met its burden to establish rights or legitimate interests in the disputed domain names under Policy ¶ 4(c).

 

Complainant argues that Respondent is not commonly known by the disputed domain names and that Complainant has not authorized or licensed Respondent to use any of Complainant’s registered marks.  The WHOIS information for Respondent does not indicate any affiliation with the <topaol.com>, <aolet.com>, <softicq.com>, <yougotvoicemail.com>, <yougotfemale.com> and <aimreach.com> domain names other than Respondent’s registration of the domain names.  Without a response from Respondent, the Panel has before it no evidence to challenge Complainant’s assertions that Respondent is not commonly known by the disputed domain names.  Therefore, Respondent has not established rights or legitimate interests in the disputed domain names under Policy ¶ 4(c)(ii).  See Gallup, Inc. v. Amish Country Store, FA 96209 (Nat. Arb. Forum Jan. 23, 2001) (finding that the respondent does not have rights in a domain name when the respondent is not known by the mark); see also Wells Fargo & Co. v. Onlyne Corp. Services11, Inc., FA 198969 (Nat. Arb. Forum Nov. 17, 2003) (“Given the WHOIS contact information for the disputed domain [name], one can infer that Respondent, Onlyne Corporate Services11, is not commonly known by the name ‘welsfargo’ in any derivation.”); 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").

 

Complainant has submitted evidence that the disputed domain names are being used to forward Internet users searching for Complainant’s products and services to directory websites that feature generic search engines and links to various businesses unrelated to Complainant.  Presumably, Respondent earns commissions for linking Internet users to these third-party websites through Respondent’s websites.  Respondent’s use of domain names that are confusingly similar to Complainant’s marks for Respondent’s commercial benefit is not in connection with a bona fide offering of goods or services under Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use of the domain names under Policy ¶ 4(c)(iii).  See Bank of Am. Corp. v. Nw. Free Cmty. Access, FA 180704 (Nat. Arb. Forum Sept. 30, 2003) (“Respondent's demonstrated intent to divert Internet users seeking Complainant's website to a website of Respondent and for Respondent's benefit is not a bona fide offering of goods or services under Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).”); see also WeddingChannel.com Inc. v. Vasiliev, FA 156716 (Nat. Arb. Forum June 12, 2003) (finding that the respondent’s use of the disputed domain name to redirect Internet users to websites unrelated to the complainant’s mark, websites where the respondent presumably receives a referral fee for each misdirected Internet user, was not a bona fide offering of goods or services as contemplated by the Policy).  Furthermore, in failing to submit a response to Complainant’s allegations, Respondent has neglected to provide any evidence that would challenge Complainant’s prima facie case.  Thus, the Panel finds that Respondent has not established rights or legitimate interests in the disputed domain names under Policy ¶ 4(c)(i) or (iii).  See Charles Jourdan Holding AG v. AAIM, D2000-0403 (WIPO June 27, 2000) (finding it appropriate for the panel to draw adverse inferences from the respondent’s failure to reply to the complaint); see also CMGI, Inc. v. Reyes, D2000-0572 (WIPO Aug. 8, 2000) (finding that the respondent’s failure to produce requested documentation supports a finding for the complainant). 

 

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

 

Registration and Use in Bad Faith

 

The disputed domain names resolve to websites that features generic search engines and links to a variety of products and services.  By using Complainant’s famous marks in the disputed domain names, Respondent is creating a likelihood of confusion and attempting to attract Internet users to Respondent’s website for Respondent’s commercial gain.  Respondent’s activities are evidence of bad faith registration and use under Policy ¶ 4(b)(iv).  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 ¶ 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); see also Am. Univ. v. Cook, FA 208629 (Nat. Arb. Forum Dec. 22, 2003) (“Registration and use of a domain name that incorporates another's mark with the intent to deceive Internet users in regard to the source or affiliation of the domain name is evidence of bad faith.”); see also Drs. Foster & Smith, Inc. v. Lalli, FA 95284 (Nat. Arb. Forum Aug. 21, 2000) (finding bad faith where the respondent directed Internet users seeking the complainant’s site to its own website for commercial gain).

 

Furthermore, based on the fame of Complainant’s AOL, ICQ, AIM and YOU’VE GOT MAIL marks, Respondent’s use of the marks within the disputed domain names suggests that Respondent knew of Complainant’s rights in the marks when Respondent registered the disputed domain names and intended to take advantage of Complainant’s goodwill in the mark.  In addition, Complainant’s registration of its marks with the USPTO bestows upon Respondent constructive knowledge of Complainant’s rights in its marks.  Thus, Respondent’s registration of domain names that are confusingly similar to Complainant’s marks despite knowledge of Complainant’s rights in the marks is evidence of bad faith registration and use under Policy ¶ 4(a)(iii).  See Digi Int’l v. DDI Sys., FA 124506 (Nat. Arb. Forum Oct. 24, 2002) (holding that “there is a legal presumption of bad faith, when Respondent reasonably should have been aware of Complainant’s trademarks, actually or constructively”); see also 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 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.”).

 

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

 

DECISION

Having established all three elements required under the ICANN Policy as to the <topaol.com>, <aolet.com>, <softicq.com>, <yougotvoicemail.com> and <aimreach.com> domain names, the Panel concludes that relief shall be GRANTED in regards to these domain names.

 

Accordingly, it is Ordered that the <topaol.com>, <aolet.com>, <softicq.com>, <yougotvoicemail.com> and <aimreach.com> domain names be TRANSFERRED from Respondent to Complainant.

 

However, having failed to establish the first element required under the ICANN Policy, the Panel concludes that relief shall be DENIED as to the <yougotfemale.com> domain name.

 

 

 

 

 

John J. Upchurch, Panelist

Dated:  August 29, 2005

 

 

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