National Arbitration Forum

 

DECISION

 

Audio Visual Services Corporation v. SIA Netex Galaxy

Claim Number: FA0605000713767

 

PARTIES

Complainant is Audio Visual Services Corporation (“Complainant”), represented by Henry M. Pogorzelski, 3040 Post Oak Boulevard, Suite 1500, Houston, TX 77056.  Respondent is SIA Netex Galaxy (“Respondent”), represented by Anatoly Ostrovsky PO Box 96, Riga 1050 Latvia, LV.

 

REGISTRAR AND DISPUTED DOMAIN NAME 

The domain name at issue is <psav.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.

 

Honourable Sir Ian Barker, QC as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on May 23, 2006; the National Arbitration Forum received a hard copy of the Complaint on May 25, 2006.  The Complainant filed an Amended Complaint on May 31, 2006.

 

On May 25, 2006, Dstr Acquisition Vii, Llc confirmed by e-mail to the National Arbitration Forum that the <psav.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 June 1, 2006, a Notification of Amended Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of June 21, 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@psav.com by e-mail.

 

A timely Response was received and determined to be complete on June 8, 2006.

 

Timely Additional Submissions were received here from the Complainant on June 13, 2006 and from the Respondent on June 16, 2006.

 

On June 14, 2006, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Hon. Sir Ian Barker QC as Panelist.

 

RELIEF SOUGHT

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

 

PARTIES’ CONTENTIONS

 

A. Complainant

 

On May 23, 2006, the Complainant electronically filed its original Complaint with the National Arbitration Forum.  Service copies were concurrently served electronically upon the registrar and the then registrant.  The original complaint named Salvia Corporation as respondent because, as of May 23, 2006, Salvia Corporation was listed as the registrant in the Whois records for the disputed domain name.

 

Immediately upon receiving electronic notice of the original Complaint, Salvia Corporation caused the Whois record for <psav.com> to be modified, so that “SIA Netex Galaxy” became listed as the registrant.  Website content was also removed at that time.

 

On May 26, 2006, Complainant received correspondence from the National Arbitration Forum alleging that the original Complaint was defective because of its failure to name “SIA Netex Galaxy” as respondent.  The Complainant was required to amend its complaint to name SIA Netex Galaxy as sole respondent.

 

The Complainant claims that there has been no bona fide transfer of the disputed domain name registration from Salvia Corporation to the present Respondent, SIA Netex Galaxy.

 

The Complainant is the owner of a United States registered service mark for PSAV (first use October 7, 2002) for rental of audiovisual equipment: staging services, namely, audio, video and lighting production and projection services for live events.  It also owns a registered design mark for PSAV PRESENTATION SERVICES.

 

The disputed domain name is identical to the Complainant’s registered service mark PSAV and confusingly similar to its registered design mark.  The Complainant’s services and products have been advertised and sold throughout the United State for over four years.

The Respondent is guilty of ‘cyberflying’ by purporting to transfer a domain name registration and change website, immediately on receiving notice of a complaint.  See Group Kaitu, LLC, Darkside Prod. Inc. v. Group Kaitu, a/k/a Manila Indus. Inc., D2005-1087 (WIPO Jan. 20, 2006) and other similar precedents where the phenomenon of ‘cyberflying’ has been discussed.

 

The original registrant Salvia Corporation has previously been found to have registered Internet domain names in which it had no rights or legitimate interests.  In Louis Vuitton Malletier S.A. v. Salvia Corp., FA 600968 (Nat. Arb. Forum Jan. 5, 2006), a panel found that Salvia Corporation had shown no rights or legitimate interest in registering <vuiton.com>.  Salvia Corporation had directed Internet users to respondent’s commercial website featuring goods and services competing with those of the complainant.  In Univ. of Houston Sys. v. Salvia Corp., FA 637920 (Nat. Arb. Forum March 21, 2006), the panel came to a similar conclusion.  It found that Salvia Corporation had no rights or legitimate interest in registering <kuhf.com>, and had purposefully directed Internet users to its commercial website, featuring goods and services that compete with the Complainant’s business.

 

The original registrant Salvia Corporation, as well as the Respondent, SIA Netex Galaxy, appear to be nothing more than shell-holding companies for internet domain names.

 

Salvia Corporation acquired the disputed domain name sometime between September 1, 2005, and March 20, 2006.  On September 1, 2005, the “Whois” record from Network Solutions showed that the disputed domain name was registered not to Salvia Corporation, but to “SIA Bouns.”  As of March 20, 2006, the “Whois” record showed the disputed domain name registered to Salvia Corporation.

 

Prior to the present proceeding, Salvia Corporation used the disputed domain name to misdirect Internet users interested in Complainant’s services to websites offering similar services and products in competition with Complainant’s business.

 

When an Internet user typed in the disputed domain name, the user initially saw a pop-up advertisement.  Once the pop-up was closed, the user was diverted to a web-page entitled “psav.com – Top Categories and Popular Categories.”  This web page advertised and solicited sales of services and products, that compete with Complainant’s services and products, by inviting the user to click on several links to a variety of terms, e.g., Psav, Presentation Services, Avsc, Avhq.  At least four of the links corresponded to registered trademarks owned by Complainant.

 

By following the link for “audio visual services” in the “Popular Categories” section of the <psav.com> web page, the user was then directed to a Salvia Corporation’s web-page entitled “audio visual services – Top Categories” and “Sponsored Links”.  On this web-page was a list of service and product lines competing with the Complainant’s products and services.

 

Salvia Corporation’s use of the disputed domain name “was not a use in connection with a bona fide offering of goods or services” pursuant to Policy ¶ 4(c)(1).

 

Neither Salvia Corporation nor SIA Netex Galaxy has been commonly known by any name remotely similar to the disputed domain name.  Neither has acquired any trademark or service mark rights in any name remotely similar to the disputed domain name. 

 

Salvia Corporation and SIA Netex Galaxy do not make any “legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers.”

 

Salvia Corporation, with the intent for commercial gain, has used the disputed domain name, along with several of Complainant’s other registered trademarks, for the illegitimate, commercial and unfair purpose of misleadingly diverting consumers from the Complainant’s competitors offering similar services and products.

 

Salvia Corporation’s registration and use has been for the intentional purpose of attracting Internet users interested in Complainant’s products.  Until the initiation of the present proceeding, Salvia Corporation was clearly operating its website for commercial gain by misleadingly attracting and directing Internet users to websites featuring competing services and products.  Salvia Corporation no doubt received click-through advertising fees for diverting Internet users to these websites.  Internet consumers, attempting to obtain information about Complainant’s services and products, were likely to access the website, believing it to be affiliated with Complainant.  This is strong evidence of bad faith.  ICANN Policy ¶ 4(b)(iv).  Arbitration panels involving Salvia Corporation have previously found that such use of an identical or nearly identical “domain name constitutes bad faithful registration and use pursuant to Policy ¶ 4(b)(iv).”  E.g. Malletier at page 4.

 

Paragraph 4(b)(iii) of the Policy provides that evidence of bad faith shall also include circumstances in which a respondent has “registered the domain name primarily for the purpose of disrupting the business of a competitor”.

 

Here, Salvia Corporation registered and used a domain name identical to the Complainant’s PSAV mark.  Salvia Corporation used the disputed domain name to misdirect Internet users to its commercial website, which featured competing services and goods.  Such conduct has also been found to evidence bad faith pursuant to Policy ¶ 4(b)(iii). 

 

It is not possible to conceive of any plausible actual or contemplated active use of the disputed domain name by SIA Netex Galaxy that would not be illegitimate.  Panels have held that under these conditions, even passive use of a disputed domain name is considered to be in bad faith.  E.g. Group Kaitu, LLC, Darkside Prods., Inc. v. Group Kaitu LLC a/k/a Manila Indus., Inc., D2005-1087 (WIPO January 6, 2006) (citing Telstra Corp. Ltd. v. Nuclear Marshmallows, D2000-0003 (WIPO Feb. 18, 2000).

 

The cyberflying exercise provides still more clear evidence of bad faith under ¶ 4(a)(iii) of the ICANN Policy.  See, e.g. MB Financial Bank, N.A. v. MBBANK, FA 644517 (Nat. Arb. Forum April 4, 2006) (“[C]yberflight [is a] tactic employed by bad faith cybersquatters.”); Group Kaitu, LLC, Darkside Productions, Inc. v. Group Kaitu LLC aka Manila Indus., Inc., D2005-1087 (WIPO January 6, 2006) (“Prior Panels have found [cyberflying] to be clear evidence of a respondent’s bad faith under the [ICANN] Policy.  This is a conclusion with which this Panel agrees.”) (internal citations omitted).

 

B. Respondent

 

The disputed domain name was registered by SIA Bouns on April 22, 1999.  The Complainant’s mark was first used in commerce on October 21, 2002.

 

The Respondent could not have registered the disputed domain name in bad faith because the Complainant had no trademark rights as at that date.  UDRP cases show that the trademark must predate the domain name.  E.g. Aspen Grove Inc. v Aspen Grove, D2001-0798 (WIPO Oct. 17, 2001).  A complainant must prove that a domain name was registered as well as being used in bad faith.

 

The Respondent has never attempted to sell the disputed domain to the Complainant or a competitor.

 

The Respondent does not deny that trademark infringement has occurred with the Respondent’s use of the disputed domain name but alleges that such is outside the scope of the Policy.

 

The Respondent seeks a declaration against the Complainant of reverse domain name hijacking because in April 1999, the Complainant did not employ its mark in commerce.

 

Complainant’s Additional Submission

 

SIA Netex Galaxy, Salvia Corporation and SIA Bouns are each shown on internet records as having different addresses in Riga, Latvia.  Salvia Corporation is a Panamanian corporation.  The others are in Latvian.

 

Prior panels have established that a transferee of an Internet domain name cannot escape a finding of bad faith registration under the Policy by relying upon a lack of bad faith of the prior registrant.  E.g. Webjet Mktg. Pty. Ltd. v. Brad Norrish, D2005-1096 (WIPO Dec. 29, 2005); Ideenhaus Kommunikationsagentur GmbH v. Ideenhaus GmbH, D2004-0016 (WIPO Feb 25, 2004).

 

Prior decisions have uniformly held that for the transferee of a domain name, registration under the Policy refers to the date when the transfer took place.  See, e.g. BWR Resources Ltd. V Waitomo Assoc. Ltd., D2000-0861 (WIPO Oct. 4, 2000) (“[R]egistration in the case of this Respondent refers to the date when it acquired the name from the person who first registered it.”).

 

On this point, the following quotation from Gewista-Werbegesellschaft mbH v. Unasi Inc., D2005-1051 (WIPO Nov. 22, 2005) is apposite:

 

            [H]aving reviewed earlier decisions of panels, the Panel believes, that the fact, that the Respondent did not register the disputed domain name itself but acquired it form the previous owner, does not mean that the Respondent has not ‘registered’ the Domain Name within the meaning of the Policy since there is no reason to differentiate between a direct registration and registration after transfer.  The domain name at issue was in fact “registered” within the meaning of the Policy when it had been acquired by the Respondent [from a prior registrant].  [Emphasis added]

 

SIA Netex Galaxy, Salvia Corporation, and SIA Bouns, are each separate legal entities.  They maintain separate offices, and Salvia Corporation has a citizenship different from that of SIA Netex Galaxy and SIA Bouns.  There is no basis for the Panel to disregard the separate corporate identities of these three legal entities.  Under all standard registration agreements, domain names are required to be registered in the name of the true owner. 

 

The Respondent (as well as Salvia Corporation) should be estopped from asserting that its activities are legally equivalent to those performed by the prior registrant, SIA Bouns.  The Respondent, SIA Netex Galaxy (and Salvia Corporation) have held themselves out as separate corporations by, for example, providing different contact information to the registrar relating to the disputed domain name.  They have provided unique contact information to the United States Patent and Trademark Office, confirming their corporate status and identity as separate from that of SIA Bouns.  Having gone through the process to transfer the domain name from SIA Bouns to Salvia Corporation some time between September 2005 and March 2006, Salvia Corporation (and the Respondent, SIA Netex Bouns) should not now be heard to assert that such transfer had no real legal effect.

 

The Respondent and Salvia Corporation both have “unclean hands”.  As discussed in the Amended Complaint, the recent cyberflying episode, jointly orchestrated by the Respondent and Salvia Corporation, is itself evidence of bad faith.  Accordingly, it would be inequitable to allow the Respondent (or Salvia Corporation) to seek the benefit of conduct attributable to the prior registrant, SIA Bouns.

 

After filing the Amended Complaint, a panel appointed by the National Arbitration Forum issued a decision in which the Respondent, Salvia Corporation, was again found to have registered and used a domain in bad faith.  Ass’n of Tex. Prof’l Educators, Inc. v. Salvia Corp., FA 685104 (Nat. Arb. Forum May 31, 2006).

 

The present circumstances are similar to the facts in the Ideenhaus case cited above.  There, the disputed domain name was originally registered in 1999, apparently in the name of the Respondent’s managing director.  After notice of a trademark dispute, the domain was transferred from the name of the managing director directly to the respondent corporation.  In assessing the issue of registration in bad faith, the panel stated as follows:

                       

            The Respondent did not register the Domain Name directly with the registrar but became the new owner by way of a transfer after acquiring the Domain Name from its managing director.  It is the Panel’s view that this does not mean that the Respondent has not ‘registered’ the Domain Name within the meaning of the Policy, indeed, there is no reason to differentiate between a direct registration and registration after a transfer (see also Dixons Group Plc v Mr. Abu Abdullaah WIPO Case No. D2000-1406, and Societé Air France v. Vladimir Federov WIPO Case No. D2003-0639).  The Domain Name was in fact ‘registered’ within the meaning of the Policy after it had been acquired by the Respondent between June 6, 2001, and January 17, 2002.

 

C.  Respondent’s Additional Submissions

 

All the examples cited by the Complainant where a Panel has treated transfers of a domain name as equivalent to registration for the purposes of the Policy, were cases where no response had been filed.

 

The Complainant has not proved that the disputed domain name was transferred.  Both SIA Bouns and Salvia Corporation shared the same registrar, IP address and location and technical contacts.

 

Even if there were a transfer, SIA Bouns and Salvia Corporation should be treated as the same because both are wholly owned by the same person.  A change in registrant information between two ‘legal fictions” owned by the same person does not constitute the transfer of a domain name but is merely a lawful change in legal identity.

 

FINDINGS

 

The Complainant has rights in a registered US service mark for PVAC with effect from October 21, 2002. 

 

The disputed domain name was registered by SIA Bouns on April 22, 1999.  Some time between September 2005 and March 2006, registration of the disputed domain name was transferred to Salvia Corporation.  

 

After the Complaint had been filed with the National Arbitration Forum and served electronically on the registrar and Salvia Corporation, the name of the registrant was changed to SIA Netex Galaxy. 

 

SIA Bouns, Salvia Corporation are SIA Netex Galaxy are all controlled by Vladimir Ostrovsky of Riga, Latvia, although Salvia Corporation is a Panamanian corporation.

 

The Complaint gave no rights to any of the above three corporations to use its mark in any way.  At the time of the filing of the original Complaint, the website operated by Salvia Corporation directed internet users to the products of the Complainant and others.

 

It was not denied by the Respondent that Salvia Corporation had been a respondent in three proceedings under the Policy where transfer of the disputed domain names had been ordered.  Nor was the ‘cyberflying’ transfer of registration denied.

 

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

 

It is not disputed by the Respondent that the disputed domain name is identical to one of the Complainant’s registered marks and confusingly similar to the other.

 

Rights or Legitimate Interests

 

The Complainant gave the Respondent no rights in the marks.  Nor does the Respondent really attempt to bring itself (or its predecessor registrants) into the ambit of ¶ 4(c) of the Policy.  However, the discussion on bad faith which is to follow has a bearing on the question whether the Respondent had rights in the disputed domain name before the Complainant acquired rights.

 

Registration and Use in Bad Faith

 

The two principal questions raised in this proceeding are:

 

(a)                Whether the transfer of the disputed domain name to the Respondent is equivalent to registration. 

(b)               Can the Complainant prove bad faith registration, although bad faith use may be shown?

 

The Panel has considered and agrees with the findings in the precedents cited by the Complainant on the point that bad faith should be assessed at the time of a transfer of a disputed domain name, even if the original registration could not be shown to have been in bad faith.  The quotations in the Complainant’s Additional Submissions noted above are expressly approved, as is the following dictum from Webjet Marketing Pty Ltd v. Brid Norrish, D2005-1096 (WIPO Dec. 29, 2005).

 

As mentioned above, the domain name was first registered in 1995 and transferred to the Respondent in October 2005.  The Complainant provided no evidence that there was any bad faith in the initial registration.  However, in this case the issue is whether the Policy applies where there is bad faith use following a good faith initial registration.  The Complainant relies on the precedent in BWR Resources Ltd v. Waitomo Adventures Ltd, WIPO Case No. D2000-0861; where the Panel “accepts that ‘registration’… refers to the date when it (the respondent] acquired the name from the person who first registered it”.  Other cases supporting the concept that the Policy applies to respondents who are domain name transferees include Dicons Group Plc v. Mr. Abu Abdullaah, WIPO Case No. D2000-1406 and Ideenhaus Kommunikationsagentur GmbH v. Ideenhaus GmbH, WIPO Case No. D2004-0016.  In the latter case the Panel’s view was that “there is no reason to differentiate between a direct registration and registration after a transfer.

 

Similarly, in Mamas & Papas (Holdings) Limited, Mamas & Papas (Retail) Limited v. QTK Internet/Name Proxy, WIPO Case No. D2004-0496 the Panel argued that the “registration or acquisition” wording of paragraph 4(b)(i) recognizes that the acquisition must be from a third party who has previously registered the domain name in question.  In that case the Panel argued that the Policy must be construed as a whole and so produce a sensible interpretation, that is, the paragraph refers to both the registration and subsequent acquisition of the domain name by transfer.  The Panel concluded that the Policy must be interpreted in such a way as to give effect to the aims ad purposes of the Policy.

 

This Panel agrees with the Complainant’s submission that the fact that the Respondent was not the first registrant of the domain name does not preclude a finding that the domain name was registered and is being used in bad faith.

 

Of importance is the responsibility of a transferee of a domain name as articulated by the Panel in the Gewista-Werbegesellschaft mbH v. Unasi Inc., D2005-1051 (WIPO Nov. 22, 2005).

 

After having acquired the disputed domain name, the Respondent became party to the Registration agreement and all its terms and conditions.  The Panel believes that the Respondent was also aware of this.  Art. 9.1. of the registration agreement (annex D to the Complaint) provides among others, that the original owner of the domain name agrees that prior to transferring ownership of its domain name to another person (the “Transferee”), the original owner of the domain name shall require the Transferee to agree, in writing to be bound by all the terms and conditions of this Agreement, that the domain name will not be transferred until the domain name registrar receives such written assurances or other reasonable assurance that the Transferee has been bound by the contractual terms of this Agreement (such reasonable assurance as determined by the Registrar in its sole discretion) along with the applicable transfer fee and that if the Transferee fails to be bound in a reasonable fashion (as determined by the Registrant in its sole discretion) to the terms and conditions of such an Agreement, any such transfer will be null and void.

 

Such conditions included to be bound by the “dispute policy […] developed by ICANN” (Art. 8).  This means, that the Respondent is bound by the same terms and conditions than its predecessor in title even if it has not necessarily registered the disputed domain name directly of personally with the Registrar (see e.g. Hebdomag Inc. v. IlluminatyMarketing, WIPO Case No. D2001-0206; Société Air France v. Vladimir Federov WIPO Case No. D2003-0639).

 

The Respondent’s contention that these precedents should not be followed just because they were undefended cases, is not tenable.  Nothing the Respondent has submitted provides any ground for the Panel not following these precedents which are reasoned and in accordance with the intentions of the Policy.

 

Next, the Panel considers that SIA Bouns, Salvia Corporation and the present Respondent are all separate legal entities and must be treated as such.  The fact that they have a common proprietor or shareholder is irrelevant.

 

The register must be taken at its face value, proclaiming to all the world the identity of the registrant.  The integrity of the registration system demands nothing less.  Persons searching the Register should not have to enquire beyond the information there provided.

 

The change of registrant must be regarded as a transfer and not an update of information.  The situation might be different if a registrant changes its corporate name.  Here, the Respondent’s submissions make it clear that there are three different corporate entities.

 

Accordingly, the Panel finds that there has been a transfer from the original registrant to Salvia Corporation and then to the Respondent.  Although there is no proof of bad faith registration in 1999 by the original registrant, the cyberflying episode infers bad faith registration by the present Respondent at the time of the transfer to it. 

 

There was ample evidence of bad faith use by Salvia Corporation up until the date of the transfer to the Respondent, i.e. the time of the filing of the Complaint.  The website accessed by the disputed domain name clearly infringed the Complainant’s mark and would lead any internet user to believe that the Complainant was associated with the website.  It would clearly direct misleadingly consumers from the Complainant to competitors.  The proper website for consideration is that existing at the time the Complaint was filed.  MB Fin. Bank v. MB Bank, FA 644517 (Nat. Arb. Forum April 4, 2006).

 

Moreover, bad faith is shown by the track record of Salvia Corporation in at least three other proceedings under the Policy and by the cyberflying incident.

 

Accordingly, each of the elements in the Policy has been established and the Complaint succeeds.  It follows that the Respondent’s counterclaim for a declaration of reverse domain name hijacking must fail.

 

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

 

 

 

 

 

 

Hon. Sir Ian Barker, QC, Panelist
Dated: June 27, 2006

 

 

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