UnitedHealth Group Incorporated v.
Claim Number: FA0703000935205
Complainant is UnitedHealth Group Incorporated (“Complainant”), represented by Timothy
M. Kenny, of Fulbright & Jaworski L.L.P., 2100
REGISTRAR
The domain name at issue is <unitedhealthcaronline.com>, registered with Moniker Online Services, Inc.
The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.
James A. Carmody, Esq., as Panelist.
Complainant submitted a Complaint to
the National Arbitration Forum electronically on
On
On
Having received no response from Respondent, the National Arbitration Forum transmitted to the parties a Notification of Respondent Default.
On
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.
Complainant requests that the domain name be transferred from Respondent to Complainant.
A. Complainant makes the following assertions:
1. Respondent’s <unitedhealthcaronline.com> domain name is confusingly similar to Complainant’s UNITEDHEALTHCARE ONLINE mark.
2. Respondent does not have any rights or legitimate interests in the <unitedhealthcaronline.com> domain name.
3. Respondent registered and used the <unitedhealthcaronline.com> domain name in bad faith.
B. Respondent failed to submit a Response in this proceeding.
Complainant, UnitedHealth Group Incorporated, consists of a
highly diversified family of companies offering health and well-being services,
and currently serves over fifty-nine million people in the
Respondent registered the <unitedhealthcaronline.com>
domain name on
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
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.
The Panel finds that Complainant’s federal registration with
the USPTO sufficiently establishes Complainant’s rights in the UNITEDHEALTHCARE
ONLINE mark pursuant to Policy ¶ 4(a)(i). See
Vivendi Universal Games v. XBNetVentures Inc., FA 198803 (Nat. Arb. Forum
The Panel finds that Respondent’s <unitedhealthcaronline.com> domain
name is confusingly similar to Complainant’s UNITEDHEALTHCARE ONLINE mark under
Policy ¶ 4(a)(i), as the disputed domain name contains the dominant features of
Complainant’s mark, omits the letter “e” in the term “care,” and adds the
generic top-level domain “.com.” See
State Farm Mut. Auto. Ins. Co. v. Try Harder &
The Panel finds that Policy ¶ 4(a)(i) has been satisfied.
Complainant initially must establish that Respondent lacks any rights or legitimate interests with respect to the <unitedhealthcaronline.com> domain name. However, once Complainant demonstrates a prima facie case, the burden of proof shifts, and Respondent must prove that it has rights or legitimate interests in the disputed domain name. See Compagnie Generale des Matieres Nucleaires v. Greenpeace Int’l, D2001-0376 (WIPO May 14, 2001) (“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.”); 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 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).”).
Complainant asserts that Respondent is not authorized to use
Complainant’s UNITEDHEALTHCARE ONLINE mark and that Respondent is not
associated with Complainant in any way.
Furthermore, Respondent’s WHOIS information does not suggest that
Respondent is commonly known by the <unitedhealthcaronline.com>
domain name. The Panel thus finds that
Respondent is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii). See Tercent Inc. v. Lee Yi, FA 139720 (Nat. Arb.
Forum
Respondent is using the disputed domain name to redirect
Internet users to a website that features links to Complainant’s
competitors. Respondent’s use of a
domain name that is confusingly similar to Complainant’s UNITEDHEALTHCARE ONLINE
mark to redirect Internet users interested in Complainant’s goods and services
to a website that offers goods and services in competition with Complainant 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 of the domain name pursuant to Policy
¶ 4(c)(iii). See Coryn Group,
Inc. v. Media Insight, FA 198959 (Nat.
Arb. Forum
The Panel finds that Policy ¶ 4(a)(ii) has been satisfied.
Complainant alleged that Respondent acted in bad faith in
registering and using a domain name that is confusingly similar to Complainant’s
protected mark. Respondent is using the <unitedhealthcaronline.com> domain
name to redirect Internet users to
Respondent’s website that features links to competing goods and services. The Panel finds that such use constitutes
disruption and is evidence of bad faith registration and use under Policy ¶ 4(b)(iii). See S. Exposure v. S. Exposure, Inc., FA
94864 (Nat. Arb. Forum
Based on the uncontested evidence presented by Complainant,
the Panel infers that Respondent receives click-through fees for diverting
Internet users to a website offering links to competing goods and
services. Respondent’s domain name
incorporating the dominant features of Complainant’s mark may create confusion
as to Complainant’s affiliation with, or sponsorship of, the disputed domain
name and resulting website. Thus,
Respondent’s use of the <unitedhealthcaronline.com>
domain name amounts to bad faith registration and use pursuant to Policy ¶ 4(b)(iv). See Kmart v. Khan, FA 127708 (Nat. Arb.
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The Panel finds that Policy ¶ 4(a)(iii) has been satisfied.
Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <unitedhealthcaronline.com> domain name be TRANSFERRED from Respondent to Complainant.
James A. Carmody, Esq., Panelist
Dated: April 26, 2007
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