national arbitration forum

 

DECISION

 

Burroughs & Chapin Company, Inc. v. Web Marketing inc.

Claim Number: FA0706001021018

 

PARTIES

Complainant is Burroughs & Chapin Company, Inc. (“Complainant”), represented by John C. McElwaine, of Nelson Mullins Riley & Scarborough, LLP, 151 Meeting Street, Charleston, SC 29402.  Respondent is Web Marketing inc. (“Respondent”), 39 Cayman loop., Pawleys Island, SC 29585.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <grandeduneshomesonline.com>, registered with Wild West Domains, Inc.

 

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.

 

Judge Harold Kalina (Ret.) as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on June 26, 2007; the National Arbitration Forum received a hard copy of the Complaint on June 27, 2007.

 

On June 27, 2007, Wild West Domains, Inc. confirmed by e-mail to the National Arbitration Forum that the <grandeduneshomesonline.com> domain name is registered with Wild West Domains, Inc. and that Respondent is the current registrant of the name.  Wild West Domains, Inc. has verified that Respondent is bound by the Wild West Domains, 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 June 28, 2007, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of July 18, 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@grandeduneshomesonline.com by e-mail.

 

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

 

On July 25, 2007, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Judge Harold Kalina (Ret.) 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 name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A.  Complainant makes the following assertions:

 

1.      Respondent’s <grandeduneshomesonline.com> domain name is confusingly similar to Complainant’s GRANDE DUNES mark.

 

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

 

3.      Respondent registered and used the <grandeduneshomesonline.com> domain name in bad faith.

 

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

 

FINDINGS

Complainant, Burroughs & Chapin Company, Inc., is the owner and developer of Grande Dunes, a private, master-planned, luxury community located in Myrtle Beach, South Carolina.  Complainant develops, markets, operates and acts as real estate broker and manager of Grande Dunes and all of its associated amenities.  Complainant has used the GRANDE DUNES mark in connection with the development since 1995 and holds a federal trademark registration with the United States Patent and Trademark Office (“USPTO”) for the mark (Reg. No. 2,781,055 issued November 11, 2003).  Complainant currently markets its Grande Dunes community online at the <grandedunes.com> domain name.

 

Respondent registered the <grandeduneshomesonline.com> domain name on February 2, 2006.  Respondent’s domain name resolves to a website sponsored by a real estate brokerage company in direct competition with Complainant.  The website displays Complainant’s GRANDE DUNES mark, advertises homes for sale in the Grande Dunes development, and contains links to the rival company’s homepage, which sells competing real estate throughout the Myrtle Beach area.  The website at the disputed domain name also contains a disclaimer asserting that Respondent and the competing real estate company are not part of or affiliated with Complainant. 

 

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 set forth in the Complaint as true unless the evidence is clearly contradictory.  See 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); see also Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (“In the absence of a response, it is appropriate to accept as true all allegations of the Complaint.”).

 

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

 

Under Policy ¶ 4(a)(i), Complainant must show that it has rights in the GRANDE DUNES mark.  The Panel finds that Complainant’s registration of the GRANDE DUNES mark with the USPTO sufficiently establishes its rights in the mark pursuant to 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 U.S. Office of Pers. Mgmt. v. MS Tech. Inc., FA 198898 (Nat. Arb. Forum Dec. 9, 2003) (“[O]nce the USPTO has made a determination that a mark is registrable, by so issuing a registration, as indeed was the case here, an ICANN panel is not empowered to nor should it disturb that determination.”).

 

Complainant alleges that Respondent’s <grandeduneshomesonline.com> domain name is confusingly similar to Complainant’s GRANDE DUNES mark.  The Panel agrees, as the disputed domain name includes the entire mark, simply adding the word “homes,” which describes Complainant’s business, and the generic term “online” onto the end of the mark.  These additions do not negate any confusing similarity between the disputed domain name and the GRANDE DUNES mark.  Moreover, the addition of the generic top-level domain “.com” is irrelevant to the Policy ¶ 4(a)(i) analysis, as a top-level domain is a required element of all domain names.  Thus, the Panel finds that the <grandeduneshomesonline.com> domain name is confusingly similar to Complainant’s GRANDE DUNES mark pursuant to Policy ¶ 4(a)(i).  See Space Imaging LLC v. Brownell, AF-0298 (eResolution Sept. 22, 2000) (finding confusing similarity where the respondent’s domain name combines the complainant’s mark with a generic term that has an obvious relationship to the complainant’s business); see also Broadcom Corp. v. Domain Depot, FA 96854 (Nat. Arb. Forum Apr. 23, 2001) (finding the <broadcomonline.com> domain name is confusingly similar to the complainant’s BROADCOM mark); see also Rollerblade, Inc. v. McCrady, D2000-0429 (WIPO June 25, 2000) (finding that the top level of the domain name such as “.net” or “.com” does not affect the domain name for the purpose of determining whether it is identical or confusingly similar); see also Isleworth Land Co. v. Lost in Space, SA, FA 117330 (Nat. Arb. Forum Sept. 27, 2002) (“[I]t is a well established principle that generic top-level domains are irrelevant when conducting a Policy ¶ 4(a)(i) analysis.”).

 

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

 

Rights or Legitimate Interests

 

Complainant alleges that Respondent lacks rights or legitimate interests in the <grandeduneshomesonline.com> domain name.  Under Policy ¶ 4(a)(ii), Complainant has the initial burden of showing that Respondent lacks rights or legitimate interests in the disputed domain name.  Once Complainant has made a prima facie case, however, the burden shifts to Respondent to prove that it does have rights or legitimate interests in the disputed domain name.  In the present case, the Panel finds that Complainant has established a prima facie case under the Policy.  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”); see also Clerical Med. Inv. Group Ltd. v. Clericalmedical.com, D2000-1228 (WIPO Nov. 28, 2000) (finding that, under certain circumstances, the mere assertion by the complainant that the respondent has no right or legitimate interest is sufficient to shift the burden of proof to the respondent to demonstrate that such a right or legitimate interest does exist).

 

Respondent’s failure to answer the Complaint raises the presumption that Respondent lacks rights or legitimate interests in the <grandeduneshomesonline.com> domain name.  See Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (“Given Respondent’s failure to submit a substantive answer in a timely fashion, the Panel accepts as true all of the allegations of the complaint.”); see also Am. Express Co. v. Fang Suhendro, FA 129120 (Nat. Arb. Forum Dec. 30, 2002) (“[B]ased on Respondent's failure to respond, it is presumed that Respondent lacks all rights and legitimate interests in the disputed domain name.”).  Nevertheless, the Panel will now examine all evidence in the record to determine if Respondent has rights or legitimate interests under Policy ¶ 4(c).

 

Respondent’s <grandeduneshomesonline.com> domain name resolves to a website featuring content and links in direct competition with Complainant.  The Panel presumes that Respondent profits when Internet users take advantage of the services offered on this website.  This does not qualify as either a bona fide offering of goods or services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).  See U.S. Franchise Sys., Inc. v. Howell, FA 152457 (Nat. Arb. Forum May 6, 2003) (holding that the respondent’s use of the complainant’s mark and the goodwill surrounding that mark as a means of attracting Internet users to an unrelated business was not a bona fide offering of goods or services); see also Computerized Sec. Sys., Inc. v. Hu, FA 157321 (Nat. Arb. Forum June 23, 2003) (“Respondent’s appropriation of [Complainant’s] SAFLOK mark to market products that compete with Complainant’s goods does not constitute a bona fide offering of goods and services.”).

 

Complainant alleges that Respondent is not commonly known by the <grandeduneshomesonline.com> domain name, which indicates that Respondent lacks rights or legitimate interests in the disputed domain name.  Respondent’s WHOIS information does not indicate, and there is nothing further in the record to suggest that Respondent is commonly known by the disputed domain name.  Moreover, Respondent is not licensed or authorized to use Complainant’s GRANDE DUNES mark.  Thus, the Panel finds that Respondent lacks rights and legitimate interests in the <grandeduneshomesonline.com> domain name pursuant to 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 Compagnie de Saint Gobain v. Com-Union Corp., D2000-0020 (WIPO Mar. 14, 2000) (finding no rights or legitimate interest where the respondent was not commonly known by the mark and never applied for a license or permission from the complainant to use the trademarked name).

 

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

 

 

 

Registration and Use in Bad Faith

 

Respondent’s <grandeduneshomesonline.com> domain name, which is confusingly similar to Complainant’s GRANDE DUNES mark, redirects Internet users to a website in direct competition with Complainant.  This constitutes a disruption of Complainant’s business and is evidence of bad faith registration and use under Policy ¶ 4(b)(iii).  See S. Exposure v. S.  Exposure, Inc., FA 94864 (Nat. Arb. Forum July 18, 2000) (finding that the respondent registered the domain name in question to disrupt the business of the complainant, a competitor of the respondent); see also Travant Solutions, Inc. v. Cole, FA 203177 (Nat. Arb. Forum Dec. 6, 2003) (“Respondent registered and used the domain name in bad faith, pursuant to Policy ¶ 4(b)(iii), because it is operating on behalf of a competitor of Complainant . . .”).

 

The Panel presumes that Respondent benefits commercially when Internet users employ the services of the competing real estate company that sponsors the <grandeduneshomesonline.com> domain name.  Respondent is thus capitalizing on the likelihood that Internet users will confuse the source of the website at the disputed domain name as being affiliated with Complainant.  This is further evidence that Respondent registered and is using the disputed domain name in bad faith pursuant to Policy ¶ 4(b)(iv).  See Amazon.com, Inc. v. Shafir, FA 196119 (Nat. Arb. Forum Nov. 10, 2003) (“As Respondent is using the domain name at issue in direct competition with Complainant, and giving the impression of being affiliated with or sponsored by Complainant, this circumstance qualifies as bad faith registration and use of the domain name pursuant to Policy ¶ 4(b)(iv).”); 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.”).

 

Respondent also includes a disclaimer on the website that resolves from the <grandeduneshomesonline.com> domain name, which asserts that the website is not affiliated with Complainant in any way.  However, the inclusion of the disclaimer on the website does not counter the initial expectation of Internet users that the disputed domain is associated with Complainant.  The Panel finds that the disclaimer is not enough to mitigate the requirement that Respondent registered and is using the disputed domain name in bad faith pursuant to Policy ¶ 4(a)(iii).  See DaimlerChrysler Corp. v. Bargman, D2000-0222 (WIPO May 29, 2000) (finding that addition of a disclaimer, when the domain name consists of the complainant’s well-known trademark, does not counter the expectation of Internet users that the domain name is sponsored by the complainant); see also Ciccone v. Parisi, D2000-0847 (WIPO Oct. 12, 2000) (“Respondent’s use of a disclaimer on its website is insufficient to avoid a finding of bad faith.  First, the disclaimer may be ignored or misunderstood by Internet users.  Second, a disclaimer does nothing to dispel initial interest confusion that is inevitable from Respondent’s actions.  Such confusion is a basis for finding a violation of Complainant’s rights.”).

 

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

 

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

 

 

Judge Harold Kalina (Ret.), Panelist

Dated:  August 6, 2007

 

 

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