NATIONAL ARBITRATION FORUM

 

DECISION

 

Post-Newsweek Stations, Inc., Michigan, d/b/a WDIV-TV v. Dayanand Kamble

Claim Number: FA0702000924537

 

PARTIES

Complainant is Post-Newsweek Stations, Inc., Michigan, d/b/a WDIV-TV (“Complainant”), represented by Jane H. Marshall, of Post-Newsweek Stations, Inc., 550 W. Lafayette Blvd., Detroit, MI 48226.  Respondent is Dayanand Kamble (“Respondent”), Kranti Chawl, Pragati Society, Nr Telgu Church, Link Road, Goregoan West, Mumbai IN.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <clickondetriot.com>, registered with Lead Networks Domains Pvt. Ltd.

 

PANEL

The undersigned certifies that she has acted independently and impartially, and to the

best of her knowledge, has no known conflict in serving as Panelist in this proceeding.

 

Carol M. Stoner, Esq. as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on February 23, 2007; the National Arbitration Forum received a hard copy of the Complaint on February 26, 2007.

 

On March 5, 2007, Lead Networks Domains Pvt. Ltd. confirmed by e-mail to the National Arbitration Forum that the <clickondetriot.com> domain name is registered with Lead Networks Domains Pvt. Ltd. and that Respondent is the current registrant of the name.  Lead Networks Domains Pvt. Ltd. has verified that Respondent is bound by the Lead Networks Domains Pvt. Ltd. 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 March 8, 2007, the National Arbitration Forum received Complainant’s amended Complaint, which document conformed Respondent’s name and contact information to that currently found in the Registrar’s Whois database. 

                                                                      

 

 


On March 9, 2007, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of March 29, 2007

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@clickondetriot.com by e-mail.

 

A timely Response was received and determined to be complete on March 29, 2007.

 

On April 5, 2007, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Carol M. Stoner, Esq., as Panelist.

 

RELIEF SOUGHT

Complainant requests that the domain name <clickondetriot.com> be transferred from Respondent to Complainant.

 

PARTIES’ CONTENTIONS

A. Complainant makes the following assertions:

 

The registrant of the domain name <clickondetroit.com> is Post-Newsweek Stations, Michigan, Inc., d/b/a/ WDIV-TV (“WDIV”) according to Whois database search report.

WDIV registered said domain name on April 3, 2000, and first used it shortly thereafter. 

Complainant WDIV provides online information in the fields of news, politics, weather, sports, business, health, real estate, entertainment, travel and classified advertising at its website, located at <clickondetroit.com>.

 

WDIV declares that <clickondetroit.com> is the number one local news website in metro Detroit, with an average of 1.2 million visitors per month, and eyeball time of nine minutes, per viewer, per visit.  WDIV attributes its success to, among other factors, updated website content every fifteen minutes, and a high-impact promotional campaign, valued at $5,000,000.00 annually.

 

WDIV bases the instant Complaint upon its common law rights in its service mark CLICKONDETROIT.  Claimant has a pending United States Patent and Trademark Office (“USPTO”) service mark application for CLICKONDETROIT (serial number 77/035,928).

 

Complainant avers that Respondent, Dayanand Kamble, has registered and has utilized, without authority, the domain name <clickondetriot.com>, which infringes upon WDIV’s distinctive and famous CLICKONDETROIT service mark, as well as WDIV’s domain name <clickondetroit.com>.  

                                                                  

B. Respondent makes the following assertions: 

 

Respondent Dayanand Kamble denies each and every allegation in the Complaint, and puts Complainant to strict proof, thereof.

 

Respondent claims that he wanted to start a social website on the ill effects of riots and

that he purchased and registered the domain name <clickondetriot.com> in 2004 for this purpose.  He says that this purchase itself is a demonstration of making preparations to use the domain name, as provided in UDRP ¶ 4(c)(i).

 

Respondent states that he is not aware of Complainant’s common law use of the mark.

 

Respondent states that Complainant has not approached the Forum with clean hands, 

and furthermore, Complainant is “hand in glove” with the previous owner of the domain name.                                  

 

FINDINGS

1.   Respondent’s <clickondetriot.com> domain name is confusingly similar to Complainant’s common-law-based service mark of CLICKONDETROIT.

 

2.   Respondent does not have any rights or legitimate interests in the <clickondetriot.com> domain name.

 

3.   Respondent registered and used the <clickondetriot.com> domain name 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 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;

 

(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 asserts common law rights in the CLICKONDETROIT service mark. Complainant submitted a service mark application with the United States Patent and Trademark Office (“USPTO”) for the CLICKONDETROIT mark (Serial No. 77/035,

928, submitted November 3, 2006), but the application is still pending.  Nevertheless, the Panel finds that a service mark or trademark registration is not required for Complainant to establish rights in the CLICKONDETROIT mark.  See Great Plains Metromall, LLC v. Creach, FA 97044 (Nat. Arb. Forum May 18, 2001) (“The Policy does not require that a trademark be registered by a governmental authority for such rights to exist.”); see also 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).  Rather, Complainant may establish common law rights in the CLICKONDETROIT mark by showing that the mark has acquired sufficient secondary meaning through extensive commercial use.  See Hiatt v. Pers. Fan & Official Site Builders : we build great sites, FA 881460 (Nat. Arb. Forum Feb. 21, 2007) (“[R]egistration with a trademark authority is unnecessary under Policy ¶ 4(a)(i) in instances where a mark has gained secondary meaning through extensive commercial use and common law rights have been established.”).

 

Complainant has proffered substantial and credible evidence of extensive, continuous and ongoing commercial use of <clickondetroit.com> and CLICKONDETROIT.

 

Complainant registered the <clickondetroit.com> domain name on April 3, 2000, and since that time has used this domain name to provide online news information on a variety of topics.  Complainant contends that the website which resolves from the <clickondetroit.com> domain name is the top online provider of local news in the Detroit area, and Complainant spends nearly $5 million annually to promote this website on its WDIV television station; and that, on average, more than 14 million people per month visit Complainant’s website at the <clickondetroit.com> domain name for an average of nine minutes spent per visit.

 

Thus, secondary meaning in the CLICKONDETROIT mark is established, in that through this extensive, continuous and ongoing use, the mark functions as a specific identifier of Complainant’s online news services provided in the Detroit area.  See BroadcastAmerica.com, Inc. v. Quo, DTV2000-0001 (WIPO Oct. 4, 2000) (finding that the complainant has common law rights in BROADCASTAMERICA.COM, given

extensive use of that mark to identify the complainant as the source of broadcast services over the Internet, and evidence that there is wide recognition with the

BROADCASTAMERICA.COM mark among Internet users as to the source of broadcast services); see also S.A. Bendheim Co., Inc. v. Hollander Glass, FA 142318 (Nat. Arb. Forum Mar. 13, 2003) (holding that the complainant established rights in the descriptive RESTORATION GLASS mark through proof of secondary meaning associated with the mark). 

 

Complainant alleges that Respondent’s <clickondetriot.com> domain name is confusingly similar to Complainant’s CLICKONDETROIT service mark.  The disputed domain name transposes the letters “i” and “o” in the “Detroit” portion of Complainant’s mark, and adds the generic top-level domain “.com.” 

 

The transposition of the letters “i” and “o” in the Detroit portion of the disputed domain name is an example of typosquatting (the intentional misspelling of words) which will be addressed in the Registration and Use in Bad Faith portion of this Decision.  

Suffice it to say here, that the resultant slight spelling variation is not sufficient to distinguish the disputed name from Complainant’s mark. See Pier 1 Imps., Inc. v. Success Work, D2001-0419 (WIPO  May 16, 2001) (finding that the domain name <peir1.com> is confusingly similar to the complainant's PIER1 mark). 

 

The Panel also finds that the mere addition of a gTLD, i.e., “.com,” should be disregarded when comparing a domain name to a mark.  So the Panel concludes that Policy ¶ 4(a)(i), wherein the domain name is not sufficiently distinguished from the mark, has been satisfied.  See Pomellato S.p.A. v. Tonetti, D2000-0493 (WIPO July 07, 2000) (finding <pomellato.com> identical to the complainant’s mark because the generic top-level domain (gTLD) “.com” after the name POMELLATO is not relevant); see also Snow Fun, Inc. v. O’Connor, FA 96578 (Nat. Arb. Forum Mar. 8, 2001) (finding that the domain name <termquote.com> is identical to the complainant’s TERMQUOTE mark).

 

Complainant has also proffered credible evidence that, not only is the disputed domain name confusingly similar on its face, but also that the counterfeit domain name has caused actual confusion on the part of an important advertising customer.  In accordance with Complainant’s Exhibit 10, Affidavit of Ted Pearse, VP/Director of Sales for WDIV, a client advertiser was misled by the layout of the counterfeit site into believing that he was at WDIV’s website.

 

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

 

Rights or Legitimate Interests

 

Where Complainant has made a prima facie case that Respondent lacks rights and

legitimate interests in the disputed domain name, the burden of production shifts to Respondent to show that it does have rights or legitimate interests under Policy ¶ 4(a)(ii).  See WIPO Overview of WIPO Panel Views on Selected UDRP Issues §2.1; see also

Document Techs., Inc. v. Int’l Elec. Commc’ns, Inc., D2000-0270 (WIPO June 06, 2000).

 

In the case at bar, Complainant has made a prima facie showing that Respondent

lacks a legitimate interest in the disputed domain name, in that Respondent is not commonly known by the <clickondetriot.com> domain name.  The Whois information

identifies respondent as “Dayanand Kamble,” and there is no other

evidence in the record indicating that Respondent is commonly known by the <clickondetriot.com> domain name.  See Instron Corp. v. Kaner, FA 768859 (Nat. Arb. Forum Sept. 21, 2006) (finding that the respondent was not commonly known by the <shoredurometer.com> and <shoredurometers.com> domain names because the WHOIS information listed Andrew Kaner c/o Electromatic a/k/a Electromatic Equip’t as the registrant of the disputed domain name and there was no other evidence in the record to suggest that the respondent was commonly known by the domain names in dispute); see also St. Lawrence Univ. v. Nextnet Tech, FA 881234 (Nat. Arb. Forum Feb. 21, 2007) (concluding a respondent has no rights or legitimate interests in a disputed domain name where there is no evidence in the record indicating that the respondent is commonly known by the disputed domain name).

 

Respondent does not then meet its burden of production to show that it does have rights or legitimate interests under Policy ¶ 4(a)(ii).  The filed Response consists largely of a broad denial of all claims, and assertions of Claimant’s inequitable conduct.  The lone substantive responses are in ¶ 5 wherein he states that “[R]espondent is preparing to use the domains for bona fide offerings of information to the society” and ¶ 7 wherein he states that “[R]espondent has full legitimate interest in the domain name as he has proved demonstration for use of the domain name.  Respondent wants to start a social site on Riots which is of great importance in a country like India and hence has purchased the domain name.”  Despite Respondent’s stated intent, and his three years from 2004 from which to exercise his intent, Complainant’s Exhibit No. 9 of screen prints of <clickondetriot.com> do not evidence any showing of content on “riots.”

 

Respondent is using the <clickondetriot.com> domain name to display hyperlinks advertising competing news services.  Respondent’s use of the disputed domain name to operate a website advertising competing news services for Respondent’s own commercial benefit does not constitute a bona fide offering of goods and services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).  See Computerized Sec. Sys., Inc. v. Hu, FA 157321 (Nat. Arb. Forum June 23, 2004) (“Respondent’s appropriation of the SAFLOK mark to market products that compete with Complainant’s goods does not constitute a bona fide offering of goods and services”); see also Glaxo Group Ltd. v. WWW Zban, FA 203164 (Nat. Arb. Forum Dec. 1, 2003) (finding that the respondent was not using the domain name within the parameters of Policy ¶ 4(c)(i) or (iii) because the respondent used the domain name to take advantage of the complainant's mark by diverting Internet users to a competing commercial site).

 

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

 

Registration and Use in Bad Faith

 

Respondent has registered and has continued to use the domain name <clickondetriot.com> since 2004.  However, there is no reasonable explanation for the selection of <clickondetriot.com> as a domain name for the disputed site.  Respondent’s answer that he selected the site name to house a discussion of the social impact of riots, lacks credibility, as there is no accounting for the “Detroit” aspect of the name with regards to purported riots in India, and also, the site lacks any content regarding the phenomenon or social implications of riots.     

 

Respondent is using a confusingly similar domain name, that is, <clickondetriot.com>,

to display hyperlinks that advertise news services that compete with Complainant WDIV. The Panel's analysis of  the screen prints of Complainant and Respondent (see Complainant's Exhibits Nos. 5 and 9) is that both sites share not only the same “look and feel” in graphics and typographics, but also that both sites share similar content, such as in their listings of hyperlinks for news outlets and commercial products and services such as travel and mortgages.  The Panel rules that Respondent’s registration and use of the <clickondetriot.com> domain name, in a manner calculated to divert customers to a competitior’s website, constitute bad faith pursuant to Policy ¶ 4(b)(iii).  See Tesco Pers. Fin. Ltd. v. Domain Mgmt. Svcs., FA 877982 (Nat. Arb. Forum Feb. 13, 2007) (finding that the respondent registered and used the disputed domain name in bad faith pursuant to Policy ¶ 4(b)(iii) when the disputed domain name resolved to a website that displayed commercial links to the websites of the complainant’s competitors); see also Puckett, Individually v. Miller, D2000-0297 (WIPO June 12, 2000) (finding that the respondent has diverted business from the complainant to a competitor’s website in violation of Policy ¶ 4(b)(iii). 

 

The copycat use of a look-a-like website, clothed in a confusingly similar name, would likely confuse customers as to the affiliation, endorsement or sponsorship of the news services advertised on Respondent’s <clickondetriot.com> domain name.  Moreover, WDIV has proffered credible evidence of actual customer confusion, as discussed in the Identical and/or Confusingly Similar Section of this Decision.  As a result of this trading- off of the name and reputation of Complainant WDIV, it is a fair inference that Respondent will gain commercial advantage thereby, both through sponsor advertising and pay-per-click revenue. The Panel therefore finds, that Respondent has registered and is using the <clickondetriot.com> domain name in bad faith pursuant to Policy ¶ 4(b)(iv).  See Metro. Life Ins. Co. v. Bonds, FA 873143 (Nat. Arb. Forum Feb. 16, 2007) (“The Panel finds such use to constitute bad faith registration and use pursuant to Policy ¶ 4(b)(iv), because [r]espondent is taking advantage of the confusing similarity between the <metropolitanlife.us> domain name and Complainant’s METLIFE mark in order to profit from the goodwill associated with the mark.”); see also Perot Sys. Corp. v. Perot.net, FA 95312 (Nat. Arb. Forum Aug. 29, 2000) (finding bad faith where the domain name in question is obviously connected with the complainant’s well-known marks, thus creating a likelihood of confusion strictly for commercial gain).

 

The Panel also finds that Respondent has engaged in “typosquatting” through the transposition of the letters “i” and “o” in the “Detroit” portion of the disputed domain name <clickondetriot.com>.  The natural and consequential, if not calculated, purpose of this typosquatting was to disrupt Complainant’s business.  This blatant typosquatting serves as inherent and egregious evidence of Respondent’s bad faith registration and use of domain name <clickondetriot.com> pursuant to Policy ¶ 4(a)(iii).  See Nat’l Ass’n of Prof’l Baseball League, Inc. v. Zuccarini, D2002-1011 (WIPO Jan. 21, 2003) (“Typosquatting...is the intentional misspelling of words with [the] intent to intercept and siphon off traffic from its intended destination, by preying on Internauts who make common typing errors.  Typosquatting is inherently parasitic and of itself, evidence of bad faith.”). 

 

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

 

DECISION

Having established all three elements under the ICANN Policy, the Panel

concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <clickondetriot.com> domain name

be TRANSFERRED from Respondent to Complainant.

 

 

                    

                                       Carol M. Stoner, Esq., Panelist

                                           Dated: April 19, 2007

                                                               

                                                                 

 

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