National Arbitration Forum

 

DECISION

 

Amazon.com, Inc. v. Amazon4u.com c/o Muhammad Yassir

Claim Number: FA0508000535524

 

PARTIES

Complainant is Amazon.com, Inc. (“Complainant”), represented by Kevin M. Hayes of Klarquist Sparkman, LLP, One World Trade Center, Suite 1600, 121 SW Salmon Street, Portland, OR 97204.  Respondent is Amazon4u.com c/o Muhammad Yassir (“Respondent”), Ahmed Mansion, Suite #1, Peshawar, NWFP 25000, PK.

 

REGISTRAR AND DISPUTED DOMAIN NAME 

The domain name at issue is <amazon4u.com>, registered with Network Solutions, Inc.

 

PANEL

The undersigned certify that we have acted independently and impartially and that to the best of our knowledge we have no known conflict in serving as Panelists in this proceeding.  G. Gervaise Davis, III, Esq., Edward C. Chiasson, Q.C. and Hon. Carolyn Marks Johnson sit as Panelists.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically August 8, 2005; the National Arbitration Forum received a hard copy of the Complaint August 10, 2005.

 

On August 11, 2005, Network Solutions, Inc. confirmed by e-mail to the National Arbitration Forum that the domain name <amazon4u.com> is registered with Network Solutions, Inc. and that the Respondent is the current registrant of the name.  Network Solutions, Inc. verified that Respondent is bound by the Network Solutions, Inc. registration agreement and thereby has agreed to resolve domain-name disputes brought by third parties in accordance with ICANN’s Uniform Domain Name Dispute Resolution Policy (the “Policy”).

 

On August 16, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of September 6, 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@amazon4u.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 September 26, 2005, pursuant to Complainant’s request to have the dispute decided by a three-member Panel, the National Arbitration Forum appointed G. Gervaise Davis, III, Esq.; Edward C. Chiasson, Esq., and Hon. Carolyn Marks Johnson as Panelists.

 

Having reviewed the communications records, the Administrative Panelists (the "Panel") find that the National Arbitration Forum 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 allegations in this proceeding:

 

1.      Respondent registered a domain name that is confusingly similar to Complainant’s AMAZON.COM mark. 

 

2.      Respondent has no rights to or legitimate interests in the domain name that contains in its entirety Complainant’s protected AMAZON.COM mark.

 

3.      Respondent registered and used the domain name in bad faith.

 

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

 

FINDINGS

Complainant established rights in the AMAZON.COM mark through registration of the mark with the United States Patent and Trademark Office (“USPTO”) (Reg. No. 2,078,496 issued July 15, 1997) and with various trademark authorities throughout the world.  Complainant also registered its mark in forty other nations and the European Union.

 

Complainant sells books through it Amazon.com Internet website, along with electronics, toys, apparel, household items and services such as movie listings.

 

In 2004, Complainant had sales in excess of $6.9 billion, including international sales of $3 billion. 

 

Complainant has spent some $240 million on advertising the AMAZON trademarks since 1996.

 

Respondent registered the disputed domain name on April 4, 2004, and is using it to compete in the same area of commerce in which Complainant is active.

 

Respondent has no license or permission to use Complainant’s protected mark.

 

Given the fame that attaches to Complainant’s mark, it is a reasonable inference that Respondent, known to the panel through its agent Muhammad Yassir, knew of Complainant’s rights in the AMAZON trademark and Respondent has done nothing to preclude such an inference.  In addition, nothing in the record would support an inference that Respondent was commonly known by that mark.

 

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.”

 

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 will draw such inferences as the Panelists consider appropriate pursuant to paragraph 14(b) of the Rules.  The Panel accepts all reasonable factual allegations set forth by Complainant as true and may draw inferences that flow from them unless the information 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 statements of fact in 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 factual assertions of the Complaint.”).

 

Paragraph 4(a) of the Policy requires Complainant to 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)    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 established with extrinsic proof in this proceeding that it established rights in the AMAZON.COM mark through registration of the mark with the United States Patent and Trademark Office (“USPTO”) (Reg. No. 2,078,496 issued July 15, 1997) and with various trademark authorities throughout the world.  See Janus Int’l Holding Co. v. Rademacher, D2002-0201 (WIPO Mar. 5, 2002) ("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."); 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.”).

 

Respondent’s addition of the numeral “4” and the letter “u” to Complainant’s AMAZON.COM mark is not enough to avoid a finding of confusing similarity between the <amazon4u.com> domain name and Complainant’s mark pursuant to Policy ¶ 4(a)(i).  See Victoria’s Secret v. Zuccarini, FA 95762 (Nat. Arb. Forum Nov. 18, 2000) (finding that, by misspelling words and adding letters to words, a respondent does not create a distinct mark but nevertheless renders the domain name confusingly similar to the complainant’s marks); see also Am. Online Inc. v. Chinese ICQ Network, D2000-0808 (WIPO Aug. 31, 2000) (finding that the addition of the numeral 4 in the domain name <4icq.com> does nothing to deflect the impact on the viewer of the mark ICQ and is therefore confusingly similar).     

 

The Panel finds that Complainant satisfied the requirements of ICANN Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

 

Complainant alleged and submitted extrinsic evidence in this proceeding that permitted the Panel to find that it has rights to and legitimate interests in the AMAZON.COM mark that is contained in its entirety in the domain name that Respondent registered.  Complainant asserted as fact that Respondent has no such rights to or legitimate interests in the mark contained within the domain name.  Once Complainant makes a prima facie case in support of its allegations, the burden shifts to Respondent to show that it does have rights or legitimate interests pursuant to Policy ¶ 4(a)(ii). We rely on the following cases, but note that this Respondent chose not to come forward with proof.   See Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (holding that, where Complainant has asserted that Respondent has no rights or legitimate interests with respect to the domain name, it is incumbent on 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 G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002) (“Because Complainant’s Submission constitutes a prima facie case under the Policy, the burden effectively shifts to Respondent.”).

 

Respondent’s failure to respond to the Complaint evidences that Respondent has chosen not to challenge Complainant’s contentions and factual assertions that Respondent lacks rights to and legitimate interests in the <amazon4u.com> domain name.  Such refusal to come forward leaves the fact undisputed and permits an inference that Respondent lacks rights to and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii).  See Parfums Christian Dior v. QTR Corp., D2000-0023 (WIPO Mar. 9, 2000) (finding that by not submitting a response, the respondent has failed to invoke any circumstance which could demonstrate any rights or legitimate interests in the domain name); see also Pavillion Agency, Inc. v. Greenhouse Agency Ltd., D2000-1221 (WIPO Dec. 4, 2000) (finding that the respondents’ failure to respond can be construed as an admission that they have no legitimate interest in the domain names).

 

Complainant contends that Respondent is using the disputed domain name to operate a website that purports to sell various consumer electronic goods.  Such commercial use of a confusingly similar domain name is not a use in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).  See G.D. Searle & Co. v. Pelham, FA 117911 (Nat. Arb. Forum Sept. 19, 2002) (finding that because Respondent is using the infringing domain name to sell prescription drugs, the panel could infer that Respondent is using the complainant’s mark to attract Internet users to its website for commercial benefit); see also Bank of Am. Corp. v. Nw. Free Cmty. Access, FA 180704 (Nat. Arb. Forum Sept. 30, 2003) (“Respondent's demonstrated intent to divert Internet users seeking Complainant's website to a website of Respondent and for Respondent's benefit is not a bona fide offering of goods or services under Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).”).

 

Furthermore, Complainant asserted that, despite being listed in the WHOIS information as “Amazon4u.com,” Respondent is not commonly known by the <amazon4u.com> domain name and is not licensed or authorized to register domain names featuring Complainant’s mark, and Respondent has not provided proof that would establish that Respondent has such rights to or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(c)(ii).  See Yoga Works, Inc. v. Arpita, FA 155461 (Nat. Arb. Forum June 17, 2003) (finding that Respondent was not “commonly known by” the <shantiyogaworks.com> domain name despite listing its name as “Shanti Yoga Works” in its WHOIS contact information because there was “no affirmative evidence before the Panel that the respondent was ever ‘commonly known by’ the disputed domain name prior to its registration of the disputed domain name”); see also Nature’s Path Foods Inc. v. Natures Path, Inc., FA 237452 (Nat. Arb. Forum Apr. 2, 2004) (“In its WHOIS contact information, Respondent lists its name and its administrative contact as ‘Natures Path, Inc.’  However, since Respondent failed to respond to the Complaint, no affirmative evidence has been provided to the Panel showing that Respondent was commonly known by the disputed domain name.”).             

 

Complainant has met its burden under Policy ¶ 4(a)(ii).  See Lush LTD v. Lush Environs, FA 96217 (Nat. Arb. Forum Jan. 13, 2001) (finding that even when the respondent does file a response, the complainant must allege facts, which if true, would establish that the respondent does not have any rights or legitimate interests in the disputed domain name); see also Graman USA Inc. v. Shenzhen Graman Indus. Co. FA 133676 (Nat. Arb. Forum Jan. 16, 2003) (finding that absent a showing of any facts by the complainant that establish the respondent lacks rights or legitimate interests in the disputed domain name, the panel may decline to transfer the disputed domain name).

 

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

 

Registration and Use in Bad Faith

 

Respondent is capitalizing on the confusingly similar aspects of its <amazon4u.com> domain name to attract Internet users to its commercial website.  Such use constitutes bad faith registration and use pursuant to Policy ¶ 4(b)(iv).  See 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.”); see also G.D. Searle & Co. v. Celebrex Drugstore, FA 123933 (Nat. Arb. Forum Nov. 21, 2002) (finding that the respondent registered and used the domain name in bad faith pursuant to Policy ¶ 4(b)(iv) because the respondent was using the confusingly similar domain name to attract Internet users to its commercial website); 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)).

 

Furthermore, Complainant asserted that Respondent registered the <amazon4u.com> domain name with actual knowledge of Complainant’s rights in the AMAZON.COM mark due to the immense international fame associated with the mark.  Registration of a domain name that is confusingly similar to another’s mark, despite actual or constructive knowledge of the mark holder’s rights, is evidence of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).  See Digi Int’l v. DDI Sys., FA 124506 (Nat. Arb. Forum Oct. 24, 2002) (“[T]here is a legal presumption of bad faith, when Respondent reasonably should have been aware of Complainant’s trademarks, actually or constructively.”); see also Samsonite Corp. v. Colony Holding, FA 94313 (Nat. Arb. Forum Apr. 17, 2000) (finding that evidence of bad faith includes actual or constructive knowledge of a commonly known mark at the time of registration).   

 

The Panel finds that Complainant satisfied the requirements of ICANN 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 <amazon4u.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Hon. Carolyn Marks Johnson, Panel Chair

G. Gervaise Davis, III, Esq. & Edward C. Chiasson, Q.C., Panelists
Dated: October 10, 2005

 

Click Here to return to the main Domain Decisions Page.

 

Click Here to return to our Home Page

 

National Arbitration Forum