national arbitration forum

 

DECISION

 

Morgan Stanley v. Unasi Management Inc.

Claim Number:  FA0505000471488

 

PARTIES

Complainant is Morgan Stanley (“Complainant”), represented by Baila H. Celedonia of Cowan, Liebowitz & Latman, P.C., 1133 Avenue of the Americas, New York, NY 10036-6799.  Respondent is Unasi Management Inc. (“Respondent”), Galerias Alvear, Via Argentina 2, Oficina #3, Zona 5, Panama 5235, Panama.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <moranstanley.com>, registered with Iholdings.com, Inc. d/b/a Dotregistrar.com.

 

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.

 

Tyrus R. Atkinson, Jr., as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on May 3, 2005; the National Arbitration Forum received a hard copy of the Complaint on May 5, 2005.

 

On May 5, 2005, Iholdings.com, Inc. d/b/a Dotregistrar.com confirmed by e-mail to the National Arbitration Forum that the domain name <moranstanley.com> is registered with Iholdings.com, Inc. d/b/a Dotregistrar.com and that Respondent is the current registrant of the name.  Iholdings.com, Inc. d/b/a Dotregistrar.com has verified that Respondent is bound by the Iholdings.com, Inc. d/b/a Dotregistrar.com 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 11, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of May 31, 2005 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@moranstanley.com by e-mail.

 

Having received no Response from Respondent, using the same contact details and methods as were used for the Commencement Notification, the National Arbitration Forum transmitted to the parties a Notification of Respondent Default.

 

On June 6, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Tyrus R. Atkinson, Jr., 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 <moranstanley.com> domain name is confusingly similar to Complainant’s MORGAN STANLEY mark.

 

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

 

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

 

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

 

FINDINGS

Complainant, Morgan Stanley, is in the investment banking business and has provided financial services and products since 1933.  In 1997, Complainant merged with Dean Witter, Discover & Co. to form Morgan Stanley Dean Witter & Co.  In 2002, this company changed its name to Morgan Stanley. 

 

Complainant holds numerous registrations with the United States Patent and Trademark Office (“USPTO”) for the MORGAN STANLEY mark (including Reg. No. 1,707,196 issued August 11, 1992 and Reg. No. 2,729,993 issued June 24, 2003) and other related marks.  Furthermore, Complainant and its predecessors-in-interest have used the MORGAN STANLEY mark since at least as early as 1935.

 

Additionally, Complainant owns the registration for the <morganstanley.com> domain name, as well as numerous other domain names that incorporate variations of Complainant’s MORGAN STANLEY mark. 

 

Respondent registered the <moranstanley.com> domain name on September 30, 2004.  Respondent is using the disputed domain name to divert Internet users to a website that features a generic search engine and displays links to various third-party websites that offer products and services that compete with Complainant.  Presumably, Respondent earns compensation from click-through fees by diverting Internet users to third-party websites via the links displayed on Respondent’s website.

 

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.

 

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 established presumptive rights in the MORGAN STANLEY mark through registration with the USPTO.  Respondent has failed to respond to the Complainant and has, therefore, failed to dispute Complainant’s prima facie case of rights.  Therefore, the Panel determines that Complainant has established rights in the MORGAN STANLEY mark for the purposes of Policy ¶ 4(a)(i).  See Men’s Wearhouse, Inc. v. Wick, FA 117861 (Nat. Arb. Forum Sept. 16, 2002) (“Under U.S. trademark law, registered marks hold a presumption that they are inherently distinctive and have acquired secondary meaning.”); see also Janus Int’l Holding Co. v. Rademacher, D2002-0201 (WIPO Mar. 5, 2002) (finding that panel decisions have held that registration of a mark is prima facie evidence of validity, which creates a rebuttable presumption that the mark is inherently distinctive.  Respondent has the burden of refuting this assumption).

 

The <moranstanley.com> domain name is comprised of a simple misspelling of Complainant’s MORGAN STANLEY mark in which the letter “g” is omitted as well as the addition of the generic top-level domain (gTLD) “.com” and the omission of the space between the words in Complainant’s mark.  Numerous panels have held that such small changes are insignificant in determining confusing similarity under Policy ¶ 4(a)(i).  Therefore, the Panel finds that the disputed domain name is confusingly similar to Complainant’s registered mark.  See Compaq Info. Techs. Group, L.P. v. Seocho, FA 103879 (Nat. Arb. Forum Feb. 25, 2002) (finding that the domain name <compq.com> is confusingly similar to Complainant’s COMPAQ mark because the omission of the letter “a” in the domain name does not significantly change the overall impression of the mark); see also Busy Body, Inc. v. Fitness Outlet Inc., D2000-0127 (WIPO Apr. 22, 2000) (finding that "the addition of the generic top-level domain (gTLD) name ‘.com’ is . . . without legal significance since use of a gTLD is required of domain name registrants"); see also Tech. Props., Inc. v. Burris, FA 94424 (Nat. Arb. Forum May 9, 2000) (finding that the domain name <radioshack.net> is identical to the complainant’s RADIO SHACK mark).

 

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

 

Rights or Legitimate Interests

 

Respondent’s failure in this instance to submit a response to the allegations of the Complaint entitles the Panel to accept all reasonable allegations and inferences in the Complaint as true unless clearly contradicted by the evidence.  See 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.”); see also Bayerische Motoren Werke AG v. Bavarian AG, FA 110830 (Nat. Arb. Forum June 17, 2002) (finding that in the absence of a response a panel is free to make inferences from the very failure to respond and assign greater weight to certain circumstances than it might otherwise do).

 

Complainant asserts that Respondent has no rights or legitimate interests in the <moranstanley.com> domain name that contains a confusingly similar variation of Complainant’s MORGAN STANLEY mark.  Complainant has made a prima facie case in support of its allegations, which shifts the burden to Respondent to make a showing that it does have rights or legitimate interests pursuant to Policy ¶ 4(a)(ii).  However, Respondent has failed to respond to Complainant’s allegations and to provide evidence of rights or legitimate interests.  Respondent has, therefore, failed to meet its burden and the Panel concludes that Respondent lacks rights and legitimate interests in the disputed domain name.  See Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (finding that, once a complainant asserts that a respondent has no rights or legitimate interests with respect to the domain, the burden shifts to that respondent to provide credible evidence that substantiates its claim of rights and legitimate interests in the domain name); 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 a complainant that a respondent has no rights or legitimate interests is sufficient to shift the burden of proof to that respondent to demonstrate that such rights or legitimate interests do exist); see also Geocities v. Geociites.com, D2000-0326 (WIPO June 19, 2000) (finding that the respondent has no rights or legitimate interests in the domain name because the respondent never submitted a response or provided the panel with evidence to suggest otherwise).

 

Complainant asserts that the <moranstanley.com> domain name diverts Internet users to a website that displays links to third-party websites that offer financial services that compete with Complainant.  Furthermore, the Panel infers that Respondent receives click-through fees for linking Internet users to third-party websites via Respondent’s website.  In light of these circumstances, the Panel finds that Respondent is using a domain name that is confusingly similar to Complainant’s registered MORGAN STANLEY mark to attract Internet users searching for Complainant’s financial products and services to Respondent’s website, where Respondent earns click-through fees for linking these diverted users to third-party websites.  It is well-established precedent under the Policy that this type of diversionary use, presumably for the purpose of benefiting from click-through compensation, is not a use in connection with 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) and, therefore, does not bestow rights and legitimate interests upon Respondent under Policy ¶ 4(a)(ii).  See WeddingChannel.com Inc. v. Vasiliev, FA 156716 (Nat. Arb. Forum June 12, 2003) (finding that the respondent’s use of the disputed domain name to redirect Internet users to websites unrelated to the complainant’s mark, websites where the respondent presumably receives a referral fee for each misdirected Internet user, was not a bona fide offering of goods or services as contemplated by the Policy); see also Disney Enters., Inc. v. Dot Stop, FA 145227 (Nat. Arb. Forum Mar. 17, 2003) (finding that the respondent’s diversionary use of the complainant’s mark to attract Internet users to its own website, which contained a series of hyperlinks to unrelated websites, was neither a bona fide offering of goods or services nor a legitimate noncommercial or fair use of the disputed domain names); see also Black & Decker Corp. v. Clinical Evaluations, FA 112629 (Nat. Arb. Forum June 24, 2002) (holding that the respondent’s use of the disputed domain name to redirect Internet users to commercial websites, unrelated to the complainant and presumably with the purpose of earning a commission or pay-per-click referral fee did not evidence rights or legitimate interests in the domain name).

 

Complainant claims that Respondent is not commonly known by the <moranstanley.com> domain name.  Furthermore, Complainant contends that Respondent is not a licensee of Complainant nor is Respondent authorized in any way to use Complainant’s MORGAN STANLEY mark.  Respondent has not filed a response and has not, therefore, provided the Panel with any evidence to rebut Complainant’s assertion.  Therefore, the Panel finds that Respondent has not established rights or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(c)(ii).  See RMO, Inc. v. Burbridge, FA 96949 (Nat. Arb. Forum May 16, 2001) (interpreting Policy ¶ 4(c)(ii) "to require a showing that one has been commonly known by the domain name prior to registration of the domain name to prevail"); 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 rights in the mark precede the respondent’s registration; (3) the respondent is not commonly known by the domain name in question).

 

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

 

Registration and Use in Bad Faith

 

Respondent is using the <moranstanley.com> domain name to profit from consumer confusion by intentionally attracting Internet users searching for Complainant’s MORGAN STANLEY products and services.  The Panel finds that Respondent profits from these intentional diversions through click-through fees earned by diverting Internet users to the third-party websites linked through Respondent’s website.  Therefore, the Panel determines that Respondent’s attempts to divert Internet users for commercial gain by attracting them to Respondent’s website through a likelihood of confusion with Complainant’s mark is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iv).  See H-D Michigan, Inc. v. Petersons Auto., FA 135608 (Nat. Arb. Forum Jan. 8, 2003) (finding that the disputed domain name was registered and used in bad faith pursuant to Policy ¶ 4(b)(iv) through the respondent’s registration and use of the infringing domain name to intentionally attempt to attract Internet users to its fraudulent website by using the complainant’s famous marks and likeness); see also Kmart v. Khan, FA 127708 (Nat. Arb. Forum Nov. 22, 2002) (finding that if the respondent profits from its diversionary use of the complainant's mark when the domain name resolves to commercial websites and the respondent fails to contest the complaint, it may be concluded that the respondent is using the domain name in bad faith pursuant to Policy ¶ 4(b)(iv)).

 

The Policy lists four circumstances under Policy ¶ 4(b), which constitute evidence of bad faith registration and use.  However, this list is not intended to be comprehensive, and the Panel has, therefore, chosen to consider additional factors which support its finding of bad faith registration and use.  See Twentieth Century Fox Film Corp. v. Risser, FA 93761 (Nat. Arb. Forum May 18, 2000) (finding that in determining if a domain name has been registered in bad faith, the Panel must look at the “totality of circumstances”); see also Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (“[T]he examples [of bad faith] in Paragraph 4(b) are intended to be illustrative, rather than exclusive.”).

 

Respondent is engaging in the practice of “typosquatting” by taking advantage of a potential typographical error made by Internauts intending to reach Complainant’s website at the <morganstanley.com> domain name who inadvertently omit the letter “g.”  Under the Policy, typosquatting is itself evidence of bad faith registration and use of the disputed domain name and the Panel finds no reason to distinguish Respondent’s use of the practice in this instance.  See Nat’l Ass’n of Prof’l Baseball Leagues v. Zuccarini, D2002-1011 (WIPO Jan. 21, 2003) (“Typosquatting is the intentional misspelling of words with 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.”); see also Zone Labs, Inc. v. Zuccarini, FA 190613 (Nat Arb. Forum Oct. 15, 2003) (finding that the respondent registered and used the <zonelarm.com> domain name in bad faith pursuant to Policy ¶ 4(a)(iii) because the name was merely a typosquatted version of the complainant’s ZONEALARM mark); see also K.R. USA, Inc. v. So So Domains, FA 180624 (Nat Arb. Forum Sept. 18, 2003) (finding that the <philadelphiaenquirer.com> and <tallahassedemocrat.com> domain names were typosquatted versions of Complainant’s THE PHILADELPHIA INQUIRER and TALLAHASSEE DEMOCRAT marks and that this practice “has been deemed behavior in bad faith”).

 

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

 

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

 

 

 

 

Tyrus R. Atkinson, Jr., Panelist

Dated:  June 20, 2005

 

 

 

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