National Arbitration Forum

 

DECISION

 

Association of Texas Professional Educators, Inc. v. Salvia Corporation

Claim Number: FA0604000685104

 

PARTIES

Complainant is Association of Texas Professional Educators, Inc. (“Complainant”), represented by W. Reid Wittliff, of Graves, Dougherty, Hearon & Moody, P.C., 401 Congress Ave., Suite 2200, Austin, TX 78701.  Respondent is Salvia Corporation (“Respondent”), represented by Anatoly Ostrovsky, P.O. Box 96, Riga, Latvia, LV 1050.

 

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <atpe.com>, registered with Dstr Acquisition Vii, LLC.

 

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.

 

Clive Elliott as Panelist.

 

PROCEDURAL HISTORY

 

Complainant submitted a Complaint to the National Arbitration Forum electronically on April 20, 2006; the National Arbitration Forum received a hard copy of the Complaint on April 26, 2006.

 

On April 27, 2006, Dstr Acquisition Vii, LLC confirmed by e-mail to the National Arbitration Forum that the <atpe.com> domain name is registered with Dstr Acquisition Vii, LLC and that the Respondent is the current registrant of the name.  Dstr Acquisition Vii, LLC has verified that Respondent is bound by the Dstr Acquisition Vii, LLC 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 2, 2006, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of May 22, 2006 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@atpe.com by e-mail.

 

A timely Response was received and determined to be complete on May 11, 2006.

 

A timely Additional Submission was received from Complainant on May 16, 2006 and determined to be complete according to Supplemental Rule #7.

 

On 17 May 2006, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Clive Elliott as Panelist.

 

RELIEF SOUGHT

 

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

 

PARTIES’ CONTENTIONS

 

A. Complainant

Complainant, the Association of Texas Professional Educators, Inc. (“ATPE”), is a Texas non-profit corporation based in Austin, Texas.  ATPE has operated for about twenty-five years and is the largest independent association of public school educators in the United States.  It serves over 105,000 public school teachers in Texas and provides resources and services, including: teaching and professional development tools, insurance services, and advocacy and legal services. 

Complainant asserts that it has used the “ATPE” trademark for approximately twenty-five years and has sought trademark protection of its “ATPE” mark before the United States Patent & Trademark Office (“USPTO”).  This application is pending.

Complainant asserts that it has operated an interactive website at <atpe.org> for approximately ten years, allowing internet users to apply for ATPE membership or renew their memberships on this website.  It also provides information about its organization and the services it offers on this website.

Complainant says that it is commonly known by individuals, other organizations and groups as “ATPE”.

Complainant asserts that Respondent has operated a website under the <atpe.com> domain name that is confusingly similar to ATPE’s site and intentionally designed to divert Internet users from Complainant’s site to Respondent’s site.  It says that prior to receiving a cease and desist letter, Respondent used the <atpe.com> domain name to resolve to a website entitled: “Association of Texas Professional Educators.”

It goes on to say that after receiving the cease and desist letter, Respondent modified its website by deleting the specific reference to “Association of Texas Professional Educators” and by removing some of the links from the site but that it continued to use the <atpe.com> domain name to generate revenue by resolving the site to a revenue generating Internet portal that paid Respondent based on “click throughs”.

Complainant submits that Respondent has no rights or legitimate interests in the <atpe.com> domain name and that there is no evidence that Respondent has ever been known or used the “ATPE” name other than to use the name to mimic Complainant’s website or to redirect visitors to a generic revenue-generating Internet portal.

Complainant points out that Respondent previously registered <vuiton.com> when it had no rights to the name.  See Louis Vuitton Malletier S.A. v. Salvia Corporation, FA-600968 (Nat. Arb. Forum Jan. 5, 2006) (finding respondent Salvia Corporation had no rights or legitimate interests in <vuiton.com>).

 

Accordingly, it submits that Respondent must have known about Complainant’s mark when it registered the subject domain name and that Respondent intended to profit from the confusion it created by registering the <atpe.com> domain name. 

 

B. Respondent

 

Respondent in turn asserts that Complainant has not established exclusive rights in the ATPE trademark.  Firstly, it points out that Complainant has only recently filed an application for the ATPE trademark.  Secondly, it states that at least two other entities are using the same name and that Complainant is unable to lay unique and exclusive rights to the contested domain name.  

It contends that although Latvia recognizes common law trademarks, to establish its common law trademark rights in Latvia, Complainant must file its Complaint through a relevant judiciary institution in Latvia, such as Arbitration at the Latvian Chamber of Commerce.

It submits that Respondent’s registered <atpe.com> domain name cannot be deemed confusingly similar to Complainant’s trademarks due to the lack of Complainant’s exclusive rights in all domain names containing the letters in the abbreviation ‘ATPE’.  It also notes that Complainant bears the burden of proof that Internet users interpret ‘ATPE’ as an abbreviation of ‘Association of Texas Professional Educators.

It submits that Respondent has not registered the contested domain name in bad faith because Respondent could not have been reasonably aware of Complainant’s trademark rights at the time of domain name registration on January 7, 2000, since Complainant does not offer its goods and services in Latvia.  It asserts that Complainant offers no evidence that its ATPE trademark is associated with Complainant in areas outside and beyond its market in United States, especially in Latvia.

It asserts that it currently rents the contested domain name to a third party Domain Sponsor, which uses an algorithm similar to popular search engines of Yahoo and Google to put up content that potential visitors may find interesting, relevant, or useful. The process is automatic and cannot account for all possible trademark infringements and dilutions.

Finally, it points out that Respondent has never contacted Complainant and has never offered the contested domain name for sale to Complainant or to a competitor of Complainant.

 

C. Additional Submissions

Complainant’s Additional Submissions

Complainant reaffirms its submission that it was the first commercial user of the ATPE mark, using the ATPE mark in commerce to offer services to professional educators since April 1, 1980.

As to the separate jurisdictions argument, it relies on University of Houston System v. Salvia Corp., FA 637920 (Nat. Arb. Forum Mar. 21, 2006), where Respondent argued that the University of Houston System had not established trademark rights in the call letters for its listener-supported public radio station, KUHF, because it had not established trademark rights in “Internet commerce.”  It submits that the Panel rejected Respondent’s claim noting:

It is not necessary for Complainant to establish trademark rights in every jurisdiction in the world, nor to file for every imaginable domain name which could be used to find its radio stations.  To establish common law trademark rights, one must establish commercial use and give sufficient evidence that the mark function to identify the source of the goods or services, which Complainant has done … It would be impossible for any Complainant to establish commercial use across every corner of the Internet …

It submits that contrary to Respondent’s assertion, simply filing an “intent to use” trademark application, as Respondent has done in the USA, does not provide Respondent any legitimate interests in the ATPE mark.

It submits that Respondent has never been known by the letters ATPE and has never used the ATPE mark to conduct any legitimate business.

It repeats that other National Arbitration Forum panels have found Respondent does not have any rights or legitimate interests in other domain names in circumstances similar to those here.  In particular it relies on the assertion that Respondent not only used Complainant’s precise name on this website, it specifically designed the website to mimic Complainant’s legitimate website at <atpe.org>.

Finally, it says that Respondent’s history of cybersquatting is further evidence of its bad faith.

Respondent’s Additional Submissions

Respondent asserts that Complainant offers no new evidence to support its trademark claim of alleged reputation and actual distinctiveness and offers no evidence in the form of business sales figures, revenues, advertising expenditures, number of consumers served, and strong customer association.

It also notes that Complainant offers no evidence of Internet user confusion (e.g. customer complaints) with regard to the links placed on the website.  It repeats its submission that since Complainant has never offered its goods and services in Latvia that it cannot claim bad faith domain name registration against its trademark rights among equal entities with similar trademark rights.

 

FINDINGS

Having considered the Complaint, the Panel finds that:

 

(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.

 

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 asserts that it has continuously and extensively used the ATPE mark for over twenty-five years in association with its non-profit educational association in the state of Texas.  Complainant claims that it is the largest independent association of public school educators in the United States and provides over 105,000 public school teachers with a vast array of goods and services, including teaching tools, insurance services and legal aid.  Complainant also alleges that it has filed a trademark registration application for the ATPE mark with the USPTO (Serial No. 78/832,228 filed March 8, 2006).  Complainant also claims to have operated an interactive website at the <atpe.org> domain name for over ten years. 

 

The Panel finds that Complainant’s ATPE mark has acquired secondary meaning in connection with its educational products and services and thus Complainant has established common law rights in the ATPE mark sufficient to satisfy Policy ¶ 4(a)(i).  See Tuxedos By Rose v. Nunez, FA 95248 (Nat. Arb. Forum Aug. 17, 2000) (finding common law rights in a mark where its use was continuous and ongoing, and secondary meaning was established); see also Keppel TatLee Bank v. Taylor, D2001-0168 (WIPO Mar. 28, 2001) (“[O]n account of long and substantial use of [KEPPEL BANK] in connection with its banking business, it has acquired rights under the common law.”).

 

The main thrust of Respondent’s argument is essentially that Complainant has no protectable rights or interests in Latvia.  Complainant is required to show that the name ATPE has become a distinctive identifier associated with Complainant or its goods and services.  Relevant evidence of such “secondary meaning” includes the nature and extent of the use of the mark/name.  The fact that the secondary meaning may only exist in one country (USA) does, in and of itself not limit Complainant’s rights in a common law trademark in another country (Latvia).  The Panel thus finds that even though Complainant does not do business in Latvia, it has acquired common law rights in the ATPE mark sufficient to satisfy Policy ¶ 4(a)(i).  See Australian Trade Comm’n v. Reader, D2002-0786 (WIPO Nov. 12, 2002) (“[e]ven if secondary meaning had been acquired only in a limited geographical area, Complainant would nevertheless have established sufficient common law trademark rights within the meaning of Paragraph 1(a)(i) of the Policy.”); see also UEFA v. Fuzi Furniture, D2000-0710 (WIPO Oct. 22, 2000) (holding that a complainant does not have to establish exclusive rights across all territorial boundaries, just a bona fide basis for making the complaint).

 

The registration of a mark with a governmental trademark authority such as the United States Patent and Trademark Office (“USPTO”) is not required under the Policy.  See SeekAmerica Networks Inc. v. Masood, D2000-0131 (WIPO Apr. 13, 2000) (finding that the Rules do not require that the complainant's trademark or service mark be registered by a government authority or agency for such rights to exist).

 

On this basis it is found that the ground is made out.

 

Rights or Legitimate Interests

 

Respondent relies on the fact that the burden of proof lies on Complainant.  While the overall burden of proof rests with Complainant, panels have recognized that this could result in the difficult task of proving a negative, requiring information that is often primarily within the knowledge of a respondent.  Therefore, Complainant is required to make out an initial prima facie case that Respondent lacks rights or legitimate interests. Once it does so, Respondent carries the burden of demonstrating rights or legitimate interests in the domain name.  See 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”).

 

Complainant maintains that Respondent is not commonly known by the <atpe.com> domain name, because the WHOIS information lists “Salvia Corporation” as the registrant of the domain name, and there is no other evidence in the record to suggest that Respondent is commonly known by the <atpe.com> domain name.  The Panel concludes that Respondent does not have any rights or legitimate interests in the domain names pursuant to Policy ¶ 4(c)(ii).  See Ian Schrager Hotels, L.L.C. v. Taylor, FA 173369 (Nat. Arb. Forum Sept. 25, 2003) (finding that without demonstrable evidence to support the assertion that a respondent is commonly known by a domain name, the assertion must be rejected).

 

Complainant also argues that prior to the filing of this Complaint, Respondent was using the disputed domain name to operate a website virtually identical to Complainant’s website at the <atpe.org> domain name.  Complainant asserts that Respondent’s website at the <atpe.com> domain name displayed Complainant’s ATPE mark and had links very similar to the links and text on Complainant’s website.  Complainant claims that after it filed this Complaint, Respondent changed its use of the <atpe.com> domain name to an Internet portal website displaying links to various third-party websites.  The Panel finds that Respondent is diverting Internet users seeking Complainant’s products and services under the ATPE mark to its own website for commercial gain by presumably earning click-through fees for each consumer it diverts to other websites. 

 

The Panel is of the view that under the present circumstances that such conduct does not constitute a bona fide offering of goods or services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use of the disputed domain name under Policy ¶ 4(c)(iii).  See Coryn Group, Inc. v. Media Insight, FA 198959 (Nat. Arb. Forum Dec. 5, 2003) (finding that the respondent was not using the domain names for a bona fide offering of goods or services nor a legitimate noncommercial or fair use because the respondent used the names to divert Internet users to a website that offered services that competed with those offered by the complainant under its marks).

 

Accordingly, for these reasons the ground is established.

 

Registration and Use in Bad Faith

 

Complainant claims that Respondent is diverting Internet users seeking Complainant’s educational goods and services to its own website at the disputed domain name for commercial gain, because Respondent’s website displays Complainant’s ATPE mark and at one time displayed content virtually identical to Complainant’s own website at the <atpe.org> domain name.  Complainant also alleges that the <atpe.com> domain name now resolves to a web directory featuring links to various third-party websites unrelated to Complainant. 

 

The Panel considers that Respondent’s past and present uses of the <atpe.com> domain name provide evidence of bad faith registration and use under Policy ¶ 4(b)(iv).  See Associated Newspapers Ltd. v. Domain Manager, FA 201976 (Nat. Arb. Forum Nov. 19, 2003) (“Respondent's prior use of the <mailonsunday.com> domain name is evidence of bad faith pursuant to Policy ¶ 4(b)(iv) because the domain name provided links to Complainant's competitors and Respondent presumably commercially benefited from the misleading domain name by receiving ‘click-through-fees.’”).

 

Furthermore, Complainant asserts that prior to its filing of the Complaint, Respondent was operating a website at the <atpe.com> domain name virtually identical to its own website at the <atpe.org> domain name.  The Panel finds that Respondent has registered and used the disputed domain name for the primary purpose of disrupting Complainant’s business pursuant to Policy ¶ 4(b)(iii).  See Mission KwaSizabantu v. Rost, D2000-0279 (WIPO June 7, 2000) (defining “competitor” as “one who acts in opposition to another and the context does not imply or demand any restricted meaning such as commercial or business competitor.

 

In doing so, the Panel rejects the explanations given by Respondent for its registration and use of the disputed domain name.  Nor does it accept the submissions made by Respondent.

 

Accordingly, the ground is made out.

 

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

 

 

 

 

Clive Elliott, Panelist
Dated: May 31, 2006

 

 

 

 

 

 

 

 

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