national arbitration forum

 

DECISION

 

Bealls, Inc. v. Marketing Total S.A.

Claim Number: FA0701000882153

 

PARTIES

Complainant is Bealls, Inc. (“Complainant”), represented by Paul W. Kruse, of Bone McAllester Norton PLLC, 511 Union Street, Suite 1600, Nashville, TN 37219.  Respondent is Marketing Total S.A. (“Respondent”), P.O. Box 556, Main Street, Charlestown, West Indies KN.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <beallsonline.com>, registered with Domaindoorman, LLC.

 

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.

 

Sandra F. Franklin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on January 5, 2007; the National Arbitration Forum received a hard copy of the Complaint on January 5, 2007.

 

On January 5, 2007, Domaindoorman, LLC confirmed by e-mail to the National Arbitration Forum that the <beallsonline.com> domain name is registered with Domaindoorman, LLC and that Respondent is the current registrant of the name.  Domaindoorman, LLC has verified that Respondent is bound by the Domaindoorman, LLC 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 January 18, 2007, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of February 7, 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@beallsonline.com by e-mail.

 

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

 

On February 14, 2007, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Sandra J. Franklin 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 <beallsonline.com> domain name is confusingly similar to Complainant’s BEALLS mark.

 

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

 

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

 

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

 

FINDINGS

Complainant, Bealls, Inc., operates hundreds of retail department stores under the BEALLS and BEALLS OUTLET marks.  Complainant has been continuously using the BEALLS mark in connection with retail department store services since as early as 1932 and the BEALLS OUTLET mark since at least 1983.  Complainant also maintains a significant presence online.  Complainant has registered over 418 domain names including the BEALLS mark and numerous variations, including <beallsflorida.com> and <beallsoutlet.com>.  Last year alone, Complainant spent over $30.2 million on promoting and marketing its marks.

 

Respondent’s <beallsonline.com> domain name, which it registered on October 2, 2005, resolves to a web page featuring sponsored links to Complainant’s competitors in the retail department store industry.

 

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 the BEALLS mark with any trademark authority but under Policy ¶ 4(a)(i), Complainant need not own a trademark registration in order to establish its rights in a mark, for common law rights are sufficient.  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 Zee TV USA, Inc. v. Siddiqi, FA 721969 (Nat. Arb. Forum July 18, 2006) (finding that the complainant need not own a valid trademark registration for the ZEE CINEMA mark in order to demonstrate its rights in the mark under Policy ¶ 4(a)(i)).

 

Through longstanding, continuous use of the BEALLS mark since at least 1932, Complainant’s mark has acquired secondary meaning in connection with Complainant’s department store services.  Complainant operates hundreds of stores under the mark and maintains registrations for hundreds of domain names containing the mark.  Therefore, Complainant has submitted sufficient evidence to show it has common law rights in the BEALLS mark pursuant to Policy ¶ 4(a)(i).  See Stellar Call Ctrs. Pty Ltd. v. Bahr, FA 595972 (Nat. Arb. Forum Dec. 19, 2005) (finding that the complainant established common law rights in the STELLAR CALL CENTRES mark because the complainant demonstrated that its mark had acquired secondary meaning); see also Ass’n of Tex. Prof’l Educators, Inc. v. Salvia Corp., FA 685104 (Nat. Arb. Forum May 31, 2006) (holding that the complainant had demonstrated common law rights in the ATPE mark through continuous use of the mark in connection with educational services for over twenty-five years).

 

Respondent’s <beallsonline.com> domain name fully incorporates Complainant’s BEALLS mark and appends the term “online.”  In Broadcom Corp. v. Domain Depot, FA 96854 (Nat. Arb. Forum Apr. 23, 2001), the panel found the <broadcomonline.com> domain name to be confusingly similar to the complainant’s BROADCOM mark.  As the facts of this case are almost indistinguishable, the Panel finds that Respondent has failed to sufficiently distinguish the disputed domain name from the mark pursuant to Policy ¶ 4(a)(i) and therefore finds the <beallsonline.com> domain name to be confusingly similar to the mark.  See Google Inc. v. Xtraplus Corp., D2001-0125 (WIPO Apr. 16, 2001) (finding that the respondent’s domain names were confusingly similar to Complainant’s GOOGLE mark where the respondent merely added common terms such as “buy” or “gear” to the end).

 

The Panel concludes that Complainant has sufficiently satisfied this element of the Policy.

 

Rights or Legitimate Interests

 

Complainant claims that Respondent lacks rights and legitimate interests in the <beallsonline.com> domain name.  Complainant must first make a prima facie case in support of its allegations, and then the burden shifts to Respondent to show it does have rights or legitimate interests pursuant to Policy ¶ 4(a)(ii).  See 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 means that Respondent has not presented any circumstances that would promote its rights or legitimate interests in the subject domain name under Policy ¶ 4(a)(ii).”); 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”). 

 

Respondent’s failure to answer the Complaint raises a presumption that Respondent has no rights or legitimate interests in the <beallsonline.com> domain name.  See Am. Online, Inc. v. AOL Int'l, D2000-0654 (WIPO Aug. 21, 2000) (finding no rights or legitimate interests where the respondent fails to respond); see also BIC Deutschland GmbH & Co. KG v. Tweed, D2000-0418 (WIPO June 20, 2000) (“By not submitting a response, Respondent has failed to invoke any circumstance which could demonstrate, pursuant to ¶ 4(c) of the Policy, any rights or legitimate interests in the domain name”).  However, the Panel will now examine the record to determine if Respondent has rights or legitimate interests under Policy ¶ 4(c).

 

Respondent has registered the domain name under the name “Marketing Total S.A.” and there is no other evidence in the record suggesting that Respondent is commonly known by the domain name in dispute.  As a result, Respondent has not established rights or legitimate interests in the <beallsonline.com> domain name pursuant to Policy ¶ 4(c)(ii).  See Coppertown Drive-Thru Sys., LLC v. Snowden, FA 715089 (Nat. Arb. Forum Jul. 17, 2006) (concluding that the respondent was not commonly known by the <coppertown.com> domain name where there was no evidence in the record, including the WHOIS information, suggesting that the respondent was commonly known by the disputed domain name); see also M. Shanken Commc’ns v. WORLDTRAVELERSONLINE.COM, FA 740335 (Nat. Arb. Forum Aug. 3, 2006) (finding that the respondent was not commonly known by the <cigaraficionada.com> domain name under Policy ¶ 4(c)(ii) based on the WHOIS information and other evidence in the record).

 

Furthermore, Respondent’s <beallsonline.com> domain name resolves to a commercial web directory displaying links to other department store websites that compete with Complainant.  In DLJ Long Term Inv. Corp. v. BargainDomainNames.com, FA 104580 (Nat. Arb. Forum Apr. 9, 2002), the panel determined that the respondent’s use of the <dlj.com> domain name to divert Internet users to the <visual.com> domain name, where services that competed with the complainant were advertised, was 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).  In this case, then, Respondent’s use of the disputed domain name to redirect Internet users to competing websites, presumably for profit by earning “click-through fees” for each consumer it redirects to other financial services websites, is not a bona fide offering of goods or services within Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use within Policy ¶ 4(c)(iii).  See Wal-Mart Stores, Inc. v. Power of Choice Holding Co., FA 621292 (Nat. Arb. Forum Feb. 16, 2006) (finding that the respondent’s use of domain names confusingly similar to the complainant’s WAL-MART mark to divert Internet users seeking the complainant’s goods and services to websites competing with the complainant did not constitute 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)).

 

The Panel concludes that Complainant has sufficiently satisfied this element of the Policy.

 

 

Registration and Use in Bad Faith

 

Respondent is using the <beallsonline.com> domain name, which is confusingly similar to Complainant’s BEALLS mark, to redirect Internet users seeking Complainant’s retail department store services to a search engine displaying links to Complainant’s direct competitors and to other content.  In Associated Newspapers Ltd. v. Domain Manager, FA 201976 (Nat. Arb. Forum Nov. 19, 2003), the respondent registered the <mailonsunday.com> domain name, which included the complainant’s THE MAIL ON SUNDAY mark, and was using the domain name to provide links to competing newspapers and to third-party websites.  The panel held that such use provided evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iv), because Respondent “presumably commercially benefited from the misleading domain name by receiving ‘click-through-fees.’”  In this case, Respondent also likely receives referral fees for each consumer it diverts to other websites and is, therefore, taking advantage of the confusing similarity between the disputed domain name and Complainant’s mark.  Such use of the disputed domain name to profit off of the goodwill associated with Complainant’s mark is indicative of bad faith registration and use under Policy ¶ 4(b)(iv).  See The Univ. of Houston Sys. v. Salvia Corp., FA 637920 (Nat. Arb. Forum Mar. 21, 2006) (“Respondent is using the disputed domain name to operate a website which features links to competing and non-competing commercial websites from which Respondent presumably receives referral fees.   Such use for Respondent’s own commercial gain is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iv).”).

 

The Panel finds that Respondent has registered and is using the disputed domain name in order to disrupt Complainant’s business under the BEALLS mark by providing links on its website to Complainant’s competitors.  Therefore, Respondent has engaged in bad faith pursuant to 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 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).”).

 

The Panel concludes that Complainant has sufficiently satisfied this element of the Policy.

 

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

 

 

 

 

Sandra J. Franklin, Panelist

Dated:  February 21, 2007

 

 

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