national arbitration forum

 

DECISION

 

Reed Elsevier Inc., Reed Elsevier Properties Inc. and Seisint, Inc. v. DO NOT DISCLOSE

Claim Number:  FA0508000536271

 

PARTIES

Complainants are Reed Elsevier Inc., Reed Elsevier Properties Inc. and Seisint, Inc. (collectively “Complainant”), represented by Tara M. Vold of Fulbright & Jaworski L.L.P., 801 Pennsylvania Avenue, N.W., Washington, DC 20004.  Respondent is DO NOT DISCLOSE (“Respondent”), 15511 N. Hayden Rd., Ste 160, PMB 353, Scottsdale, Arizona 85260.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <lexisnexisonline.com> and <acurint.com>, registered with Go Daddy Software, 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.

Tyrus R. Atkinson, Jr., as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on August 9, 2005; the National Arbitration Forum received a hard copy of the Complaint on August 10, 2005.

 

On August 11, 2005, Go Daddy Software, Inc. confirmed by e-mail to the National Arbitration Forum that the <lexisnexisonline.com> and <acurint.com> domain names are registered with Go Daddy Software, Inc. and that Respondent is the current registrant of the names.  Go Daddy Software, Inc. has verified that Respondent is bound by the Go Daddy Software, 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 August 12, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of September 1, 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@lexisnexisonline.com and postmaster@acurint.com by e-mail.

 

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

 

On September 7, 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 names be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A.  Complainant makes the following assertions:

 

1.      Respondent’s <lexisnexisonline.com> and <acurint.com> domain names are confusingly similar to Complainant’s LEXISNEXIS and ACCURINT marks.

 

2.      Respondent does not have any rights or legitimate interests in the <lexisnexisonline.com> and <acurint.com> domain names.

 

3.      Respondent registered and used the <lexisnexisonline.com> and <acurint.com> domain names in bad faith.

 

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

 

FINDINGS

Through its LexisNexis operating division, Complainant, Reed Elsevier Inc., offers a wide range of comptuer software, computer assisted research services and other computer-related services under its LEXISNEXIS family of marks.  Complainant, Reed Elsevier Properties Inc., owns numerous registrations with the United States Patent and Trademark Office (“USPTO”) for the LEXISNEXIS mark (including Reg. No. 2,673,044 issued January 7, 2003; Reg. No. 2,670,069 issued December 31, 2002; and Reg. No. 2,670,068 issued December 31, 2002), which it licenses to Complainant Reed Elsevier Inc.  Complainant has used its LEXISNEXIS mark since at least as early as 1983.

 

Complainant, Seisint, Inc., is a wholly-owned subsidiary of Reed Elsevier Inc.  Complainant provides individual background information services under its ACCURINT mark.  Complainant holds registrations with the USPTO for the ACCURINT mark (Reg. No. 2,624,319 issued September 24, 2002, filed June 20, 2001 and Reg. No. 2,941,345 issued April 19, 2005, filed January 29, 2004).  Complainant began using its ACCURINT mark in commerce in April 2001. 

 

Complainant has spent tens of millions of dollars promoting its LEXISNEXIS and ACCURINT marks and the products and services associated therewith.  Complainant offers its products and services via websites at the <lexis.com>, <nexis.com>, <lexisnexis.com> and <accurint.com> domain names.

 

Respondent registered the <acurint.com> domain name on October 28, 2001 and the <lexisnexisonline.com> domain name on April 16, 2005.  The disputed domain names divert Internet users to a third-party website of one of Complainant’s competitors.

 

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 asserts rights in the LEXISNEXIS and ACCURINT marks based on its registrations of the marks with the USPTO.  It is well established under the Policy that a complainant’s registration of a mark with a federal authority establishes a prima facie case of the complainant’s rights.  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 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.”).

 

The <lexisnexisonline.com> domain name differs from Complainant’s LEXISNEXIS mark with the addition of the common or descriptive term “online,” while the <acurint.com> domain name simply omits one letter “c” from Complainant’s ACCURINT mark.  It is well-established under the Policy that the addition of a common or descriptive term to or the omission of a letter from a mark is inadequate to negate the confusing similarity between a domain name and a mark.  See Christie’s Inc. v. Tiffany’s Jewelry Auction, Inc., D2001-0075 (WIPO Mar. 6, 2001) (finding that the domain name  <christiesauction.com> is confusingly similar to the complainant's mark since it merely adds the word “auction” used in its generic sense); see also Guinness UDV N. Am., Inc. v. Dallas Internet Servs., D2001-1055 (WIPO Dec. 12, 2001) (finding the <smirnof.com> domain name confusingly similar to the complainant’s SMIRNOFF mark because merely removing the letter “f” from the mark was insignificant).  Additionally, adding the generic top-level domain “.com” to Complainant’s marks is irrelevant in making a determination of similarity under Policy ¶ 4(a)(i).  See Isleworth Land Co. v. Lost in Space, SA, FA 117330 (Nat. Arb. Forum Sept. 27, 2002) (finding it is a “well established principle that generic top-level domains are irrelevant when conducting a Policy ¶ 4(a)(i) analysis”).  Thus, the Panel finds that the disputed domain names are confusingly similar to Complainant’s marks pursuant to Policy ¶ 4(a)(i). 

 

Complainant has satisfied Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

 

It has been established under the Policy that the complainant has the initial burden of proving that the respondent lacks rights and legitimate interests in the disputed domain name.  In Compagnie Generale des Matieres Nucleaires v. Greenpeace Int’l, D2001-0376 (WIPO May 14, 2001), the panel held:

 

Proving that the Respondent has no rights or legitimate interests in respect of the Domain Name requires the Complainant to prove a negative. For the purposes of this sub paragraph, however, it is sufficient for the Complainant to show a prima facie case and the burden of proof is then shifted on to the shoulders of Respondent.  In those circumstances, the common approach is for respondents to seek to bring themselves within one of the examples of paragraph 4(c) or put forward some other reason why they can fairly be said to have a relevant right or legitimate interests in respect of the domain name in question.

 

Id.; see also 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”).  Having found that Complainant has met its initial burden by establishing a prima facie case, the Panel will now analyze whether Respondent has met its burden to establish rights or legitimate interests in the disputed domain names under Policy ¶ 4(c).

 

Nothing in the record suggests that Respondent is commonly known by the <lexisnexisonline.com> and <acurint.com> domain names, and Complainant asserts that Respondent is not licensed or otherwise authorized to use Complainant’s LEXISNEXIS and ACCURINT marks for any purpose.  Additionally, Complainant asserts that its marks are unique and arbitrary, so it is unlikely that Respondent would have coined the terms on its own for use in the domain names.  Because Respondent has failed to respond to any of Complainant’s contentions, the Panel is left with no evidence to rebut Complainant’s assertions that Respondent is not commonly known by the disputed domain name.  Thus, the Panel finds that Respondent has not established rights or legitimate interests in the disputed domain names 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 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 Vanguard Group, Inc. v. Collazo, FA 349074 (Nat. Arb. Forum Dec. 1, 2004) (finding that because Respondent failed to submit a Response, “Complainant’s submission has gone unopposed and its arguments undisputed.  In the absence of a Response, the Panel accepts as true all reasonable allegations . . . unless clearly contradicted by the evidence.”); see also Medline, Inc. v. Domain Active Pty. Ltd., FA 139718 (Nat. Arb. Forum Feb. 6, 2003) (“Considering the nonsensical nature of the [<wwwmedline.com>] domain name and its similarity to Complainant’s registered and distinctive [MEDLINE] mark, the Panel concludes that Policy ¶ 4(c)(ii) does not apply to Respondent”).

 

Furthermore, Complainant maintains that Respondent is using the <lexisnexisonline.com> and <acurint.com> domain names to divert Internet users searching for Complainant’s websites to a third-party website that offers competing services, presumably so that Respondent can earn referral fees for diversions through its domain names.  Respondent cannot establish that it is making 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) when Respondent is using confusingly similar domain names to redirect Internet users to a competing website for Respondent’s commercial gain.  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 DLJ Long Term Inv. Corp. v. BargainDomainNames.com, FA 104580 (Nat. Arb. Forum Apr. 9, 2002) (“Respondent is not using the disputed domain name in connection with a bona fide offering of goods and services because Respondent is using the domain name to divert Internet users to <visual.com>, where services that compete with Complainant are advertised.”).  Moreover, Respondent has not provided a response and, therefore, has neglected to provide any evidence that would challenge Complainant’s prima facie case.  Consequently, the Panel finds that Respondent has not established rights or legitimate interests in the disputed domain name under Policy ¶ 4(c)(i) or (iii).  See Euromarket Designs, Inc. v. Domain For Sale VMI, D2000-1195 (WIPO Oct. 26, 2000) (“In the absence of direct evidence, the complainant and the panel must resort to reasonable inferences from whatever evidence is in the record.  In addition . . . Paragraph 14(b) of the Rules [authorizes] a panel to draw such inferences from respondent’s failure to respond ‘as it considers appropriate.’”).

 

Complainant has satisfied Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

 

Complainant argues that Respondent is using the <lexisnexisonline.com> and <acurint.com> domain names to resolve to a website that offers products and services that compete with those of Complainant.  The Panel infers that Respondent receives referral fees for forwarding Complainant’s potential customers to a competitor’s website.  Respondent’s use of Complainant’s well-known and distinctive LEXISNEXIS and ACCURINT marks in the domain names creates a likelihood of confusion and suggests an attempt on the part of Respondent to attract Internet users to Respondent’s competing website for Respondent’s commercial gain.  The Panel finds that there is sufficient evidence of bad faith registration and use under 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 MathForum.com, LLC v. Weiguang Huang, D2000-0743 (WIPO Aug. 17, 2000) (finding bad faith under Policy ¶ 4(b)(iv) where the respondent registered a domain name confusingly similar to the complainant’s mark and the domain name was used to host a commercial website that offered similar services offered by the complainant under its mark); see also Luck's Music Library v. Stellar Artist Mgmt., FA 95650 (Nat. Arb. Forum Oct. 30, 2000) (finding that the respondent engaged in bad faith use and registration by using domain names that were identical or confusingly similar to the complainant’s mark to redirect users to a website that offered services similar to those offered by the complainant).

 

Furthermore, Respondent’s registration of the <lexisnexisonline.com> and <acurint.com> domain names, which contain confusingly similar versions of Complainant’s distinctive LEXISNEXIS and ACCURINT marks, and Complainant’s registration of its marks with the USPTO suggest that Respondent knew of Complainant’s rights in the marks.  Complainant has spent millions of dollars to advertise and promote its marks and has acquired substantial goodwill in its marks, causing the public to associate the LEXISNEXIS and ACCURINT marks with Complainant’s goods and services.  In light of these circumstances, the Panel finds that Respondent chose the disputed domain names due to the distinctive qualities of Complainant’s marks.  Respondent’s registration of domain names that contain Complainant’s marks despite Respondent’s knowledge of Complainant’s rights in the marks 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); see also Exxon Mobil Corp. v. Fisher, D2000-1412 (WIPO Dec. 18, 2000) (finding that the respondent had actual and constructive knowledge of the complainant’s EXXON mark given the worldwide prominence of the mark and thus the respondent registered the domain name in bad faith); see also Victoria’s Cyber Secret Ltd. v. V Secret Catalogue, Inc., 161 F.Supp.2d 1339, 1349 (S.D.Fla. 2001) (noting that “a Principal Register registration [of a trademark or service mark] is constructive notice of a claim of ownership so as to eliminate any defense of good faith adoption” pursuant to 15 U.S.C. § 1072).

 

Furthermore, the <acurint.com> domain name registered by Respondent consists of a misspelled version of Complainant’s well-known ACCURINT mark.  Thus, 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 <accurint.com> domain name, who inadvertently forget to type the letter “c.”  Under the Policy, typosquatting is sufficient evidence of bad faith registration and use of the disputed domain name.  The Panel, therefore, finds that Respondent registered and used the disputed domain name in bad faith pursuant to Policy ¶ 4(a)(iii).  See Canadian Tire Corp. v. domain adm’r no.valid.email@worldnic.net 1111111111, D2003-0232 (WIPO May 22, 2003) (finding the respondent registered and used the domain name in bad faith because the respondent “created ‘a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s web site or location’. . . through Respondent’s persistent practice of ‘typosquatting’”); see also 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.”).

 

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 <lexisnexisonline.com> and <acurint.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

 

Tyrus R. Atkinson, Jr., Panelist

Dated:  September 21, 2005

 

 

Click Here to return to the main Domain Decisions Page.

 

Click Here to return to our Home Page

 

National Arbitration Forum