national arbitration forum

 

DECISION

 

Lynda Carter v. Alberta Hot Rods

Claim Number: FA0903001253377

 

PARTIES

Complainant is Lynda Carter (“Complainant”), represented by Ryan C. Compton, of DLA Piper LLP (US), Washington, D.C., USA.  Respondent is Alberta Hot Rods (“Respondent”), Canada.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <lyndacarter.com>, registered with Godaddy.com, 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.

 

James A Crary as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on March 20, 2009; the National Arbitration Forum received a hard copy of the Complaint on March 23, 2009.

 

On March 20, 2009, Godaddy.com, Inc. confirmed by e-mail to the National Arbitration Forum that the <lyndacarter.com> domain name is registered with Godaddy.com, Inc. and that Respondent is the current registrant of the name.  Godaddy.com, Inc. has verified that Respondent is bound by the Godaddy.com, 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 March 24, 2009, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of April 13, 2009 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@lyndacarter.com by e-mail.

 

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

 

On April 20, 2009, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed James A Crary 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 <lyndacarter.com> domain name is identical to Complainant’s LYNDA CARTER mark.

 

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

 

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

 

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

 

FINDINGS

Complainant, Lynda Carter, has been a television, film, and stage performer for over twenty-five years.  During this time Complainant has appeared in a variety of productions including the television series Wonder Woman, which aired from 1976-1979. 

 

Respondent registered the disputed domain name on November 20, 1996.  Respondent’s disputed domain name redirects Internet users to a website that provides information and advertisements for third-party celebrities that compete with Complainant. 

 

Respondent has been the respondent in multiple other UDRP proceedings wherein the respective panels found in the respective complainants’ favor.  See e.g. Crichton v. Alberta Hot Rods, D2002-0872 (WIPO Nov. 25, 2002); see also Catherine Cookson Charitable Trust v. Alberta Hot Rods, D2008-0888 (WIPO July 30, 2008); see also King v. Alberta Hot Rods, D2005-0570 (WIPO July 21, 2005).

 

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

 

Complainant has not registered her LYNDA CARTER mark with a governmental authority.  The Panel finds registration of a mark with a governmental authority is not necessary to obtain rights in a mark under Policy ¶ 4(a)(i), provided Complainant can provide evidence of common law rights in her LYNDA CARTER mark through a showing of sufficient secondary meaning.  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); see also Winterson v. Hogarth, D2000-0235 (WIPO May 22, 2000) (finding that ICANN Policy does not require that the complainant have rights in a registered trademark and that it is sufficient to show common law rights in holding that the complainant has common law rights to her name).

 

Complainant asserts she has been a television, film, and stage performer for over twenty-five years.  During this time Complainant alleges she has appeared in a variety of productions including the television series Wonder Woman, which aired from 1976-1979.  Complainant has provided evidence of Complainant’s biography and filmography as evidence of these contentions.  The Panel finds Complainant’s use of her LYNDA CARTER mark in connection with her television, film, and stage performance career is sufficient to establish Complainant’s rights in her LYNDA CARTER mark pursuant to Policy ¶ 4(a)(i).  See Estate of Tupac Shakur v. Shakur Info Page, AF-0346 (eResolution Sept. 28, 2000) (“A person may acquire such a reputation in his or her own name as to give rise to trademark rights in that name at common law …”); see also Garnett v. Trap Block Techs., FA 128073 (Nat. Arb. Forum Nov. 21, 2002) (holding that the complainant had accrued common law rights in the KEVIN GARNETT mark).

 

Respondent’s <lyndacarter.com> domain name fully incorporates Complainant’s LYNDA CARTER mark with the mere deletion of a space and the addition of the generic top-level domain (“gTLD”) “.com.”  The deletion of a space from a mark in a disputed domain name is not relevant because spaces are not permissible in domain names.  Also, the addition of a gTLD is not relevant when determining whether a disputed domain name is identical to a mark pursuant to Policy ¶ 4(a)(i) because a gTLD is a required element in every domain name.  Therefore, the Panel finds Respondent’s disputed domain name is identical to Complainant’s mark under Policy ¶ 4(a)(i).  See Hannover Ruckversicherungs-AG v. Ryu, FA 102724 (Nat. Arb. Forum Jan. 7, 2001) (finding <hannoverre.com> to be identical to HANNOVER RE, “as spaces are impermissible in domain names and a generic top-level domain such as ‘.com’ or ‘.net’ is required in domain names”); see also Croatia Airlines v. Kwen Kijong, AF-0302 (eResolution Sept. 25, 2000)  (finding that the domain name <croatiaairlines.com> is identical to the complainant's CROATIA AIRLINES trademark).

 

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

 

Rights or Legitimate Interests

 

Complainant has alleged Respondent does not have rights or legitimate interests in the disputed domain name.  Once Complainant presents a prima facie case supporting these allegations, the burden shifts to Respondent to establish it does have rights or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(a)(ii).  The Panel finds Complainant has presented a sufficient prima facie case to support its allegations.  Respondent failed to submit a response in these proceedings.  Therefore, the Panel may assume Respondent does not have rights or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(a)(ii).  However, the Panel will inspect the record and determine whether Respondent has rights or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(c).  See Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (holding that once the complainant asserts that the respondent has no rights or legitimate interests with respect to the domain, the burden shifts to the respondent to provide “concrete evidence that it has rights to or legitimate interests in the domain name at issue”); see also Desotec N.V. v. Jacobi Carbons AB, D2000-1398 (WIPO Dec. 21, 2000) (finding that failing to respond allows a presumption that the complainant’s allegations are true unless clearly contradicted by the evidence).

 

Respondent is using its <lyndacarter.com> domain name to redirect Internet users to Respondent’s commercial <celebrity1000.com> domain name, which contains information about a variety of entertainers and advertisements in competition with Complainant’s business as a performer.  The Panel finds this use is not a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i), or a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).  See 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.”); see also Or. State Bar v. A Special Day, Inc., FA 99657 (Nat. Arb. Forum Dec. 4, 2001) (“Respondent's advertising of legal services and sale of law-related books under Complainant's name is not a bona fide offering of goods and services because Respondent is using a mark confusingly similar to the Complainant's to sell competing goods.”).

 

The WHOIS information and record do not indicate Respondent is commonly known by the <lyndacarter.com> domain name.  The WHOIS information lists Respondent as “Alberta Hot Rods.”  The record indicates Complainant has never authorized Respondent to use her LYNDA CARTER mark.  Therefore, the Panel finds Respondent is not commonly known by the disputed domain name pursuant to Policy ¶ 4(c)(ii).  See 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 Charles Jourdan Holding AG v. AAIM, D2000-0403 (WIPO June 27, 2000) (finding no rights or legitimate interests where (1) the respondent is not a licensee of the complainant; (2) the complainant’s prior rights in the domain name precede the respondent’s registration; (3) the respondent is not commonly known by the domain name in question).

 

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

 

Registration and Use in Bad Faith

 

Complainant has asserted Respondent is a seasoned cybersquatter who has been a party to numerous UDRP decisions in which the domain names at issue were transferred to the respective complainants in those proceedings.  See, e.g., Crichton v. Alberta Hot Rods, D2002-0872 (WIPO Nov. 25, 2002); see also Catherine Cookson Charitable Trust v. Alberta Hot Rods, D2008-0888 (WIPO July 30, 2008); see also King v. Alberta Hot Rods, D2005-0570 (WIPO July 21, 2005).  The Panel finds Respondent’s actions constitute a pattern of bad faith registration and use pursuant to Policy ¶ 4(b)(ii).  See Arai Helmet Americas, Inc. v. Goldmark, D2004-1028 (WIPO Jan. 22, 2005 ((finding that “Respondent has registered the disputed domain name, <aria.com>, to prevent Complainant from registering it” and taking notice of another UDRP proceeding against the respondent to find that “this is part of a pattern of such registrations”); see also Nat’l Abortion Fed’n v. Dom 4 Sale, Inc., FA 170643 (Nat. Arb. Forum Sept. 9, 2003) (finding bad faith pursuant to Policy ¶ 4(b)(ii) because the domain name prevented the complainant from reflecting its mark in a domain name and the respondent had several adverse decisions against it in previous UDRP proceedings, which established a pattern of cybersquatting).

 

Respondent’s disputed domain name redirects Internet users to celebrity information and advertisements that compete with Complainant’s performance business.  The Panel finds Respondent’s use constitutes disruption of Complainant’s business and is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).  See S. Exposure v. S. Exposure, Inc., FA 94864 (Nat. Arb. Forum July 18, 2000) (finding the respondent acted in bad faith by attracting Internet users to a website that competes with the complainant’s business); see also Disney Enters., Inc. v. Noel, FA 198805 (Nat. Arb. Forum Nov. 11, 2003) (“Respondent registered a domain name confusingly similar to Complainant's mark to divert Internet users to a competitor's website. It is a reasonable inference that Respondent's purpose of registration and use was to either disrupt or create confusion for Complainant's business in bad faith pursuant to Policy ¶¶ 4(b)(iii) [and] (iv).”).

 

Respondent is using the website resolving from its confusingly similar disputed domain name to redirect Internet users to a website that contains information and advertisements that compete with Complainant.  Respondent presumably profits from this use of the confusingly similar disputed domain name in the form of click-through fees.  Additionally, Respondent’s use of Complainant’s LYNDA CARTER mark creates a likelihood of confusion regarding the source of the content resolving from the disputed domain name.  The Panel finds this is an attempt by Respondent to profit from the goodwill associated with Complainant’s mark.  Therefore, the Panel finds Respondent’s attempt to profit from its use of the confusingly similar disputed domain name constitutes registration and use in bad faith pursuant to Policy ¶ 4(b)(iv).  See Identigene, Inc. v. Genetest Labs., D2000-1100 (WIPO Nov. 30, 2000) (finding bad faith where the respondent's use of the domain name at issue to resolve to a website where similar services are offered to Internet users is likely to confuse the user into believing that the complainant is the source of or is sponsoring the services offered at the site); see also 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).”).

 

The Panel finds 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 <lyndacarter.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

James A. Crary, Panelist

Dated:  May 4, 2009

 

 

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