National Arbitration Forum

 

DECISION

 

EducationDynamics, LLC v. Global Access c/o domain admin

Claim Number: FA0905001265489

 

PARTIES

Complainant is EducationDynamics, LLC (“Complainant”), represented by Catherine E. Maxson, of Davis Wright Tremaine LLP, Washington, USA.  Respondent is Global Access c/o domain admin (“Respondent”), represented by Maria Bergsten, of Renova, Ltd., Spain.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <elearner.com>, registered with Fabulous.com Pty Ltd.

 

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., G. Gervaise Davis III,, and Beatrice Onica Jarka as Panelists.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on May 28, 2009; the National Arbitration Forum received a hard copy of the Complaint on May 29, 2009.

 

On June 1, 2009, Fabulous.com Pty Ltd. confirmed by e-mail to the National Arbitration Forum that the <elearner.com> domain name is registered with Fabulous.com Pty Ltd. and that the Respondent is the current registrant of the name.  Fabulous.com Pty Ltd. has verified that Respondent is bound by the Fabulous.com Pty Ltd. 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 June 8, 2009, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of June 29, 2009 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@elearner.com by e-mail.

 

A timely Response was received and determined to be complete on June 29, 2009.

 

An additional Submission was received from the Complainant on July 6, 2009 and from the Respondent  on July 10, 2009.

 

The Panel has considered these additional filings and determined that they are to be considered as they comply with Supplemental Rules 7.

 

On July 8, 2009, pursuant to Complainant’s request to have the dispute decided by a three-member Panel, the National Arbitration Forum appointed Tyrus R. Atkinson, Jr., G. Gervaise Davis III, and Dr. Beatrice Onica Jarka as Panelists.

 

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

 

PARTIES’ CONTENTIONS

A. Complainant

Complainant contends that:

·        It holds United States trademark registrations for Elearners (Reg.No. 2,470,525 registered on July 17, 2001) and ELEARNERS.COM (Reg. No. 2,537, 155 registered on February 5, 2002) for “dissemination of advertising for others via an on-line electronic communications network.”

·        In addition, its  ELEARNERS and ELEARNERS.COM marks have acquired and enjoy substantial goodwill and a valuable reputation through their long-standing use. 

·        The <elearners.com> website averages more than 900,000 unique monthly visitors.  In 2008, the site connected approximately 7 million prospective students to more than 175 higher education and continuing education providers. 

·        The disputed domain name <elearner.com> is confusingly similar to EducationDynamics’s marks ELEARNERS and ELEARNERS.COM, and also to EducationDynamics’s domain name <elearners.com>, as it differs only by one letter “s” from the Complainant’s trademarks and domain name,  

·        Respondent’s registration of the <elearner.com> domain name reflects a common mistyping of EducationDynamics’s marks, and constitutes the deliberate practice known as “typosquatting,”

·        The association between Respondent and EducationDynamics is exacerbated by the way in which Respondent uses the <elearner.com> domain name, specifically, the similarities between the website associated with Respondent’s domain name and EducationDynamics’s <elearners.com> website. 

·        Respondent’s <elearner.com> domain name and contents of the website associated therewith falsely suggest that <elearner.com> is a legitimate website owned or sponsored by EducationDynamics. 

·        Respondent has no rights or legitimate interests in respect of the disputed domain name. 

·        Respondent did not register the domain name until after May 28, 2009, long after EducationDynamics started using its trademarks and registered its trademarks. 

·        Respondent is not known by the name “elearner”;

·        The disputed domain name was registered and is being used in bad faith, as it was registered well after EducationDynamics had started using its marks (ten years) and after it had obtained U.S. trademark registrations (approximately seven years).  Respondent’s domain name utilizes EducationDynamics’s marks, and Respondent uses that domain name in connection with a commercial website that provides links to EducationDynamics’s competitors and to schools that are EducationDynamics’s customers for its advertising services. 

 

B. Respondent

Respondent answers that:

·        Complainant has no exclusive rights to use the term “elearners” or “elearner”in connection with information and advertising relative to elearning, as it is a descriptive and generic term

·        Respondent’s use of the disputed domain name is bona fide and legitimate,

·        Respondent registered the disputed domain name because of its generic/descriptive application and there is no evidence of the actual knowledge of the Respondent in registering and using the disputed domain name.

 

C. Additional Submissions

By the additional submissions, Complainant rejects the reasoning of Respondent by affirming strong trademark rights in ELEARNERS and ELEARNERS.COM, and the proof of all three elements of the Policy. In this sense Complainant invokes the precedent of the decision No. FA0801001139891 (Nat. Arb. Forum March 18, 2008), awarded in the favor of Complainant.

 

By the additional submissions, Respondent invokes the improperness of the additional submissions of Complainant, as they were unsolicited by the Panel, according to UDRP Rule 12. On the merits, in addition to the already invoked reasoning by Response, Respondent invokes NAF decisions recently decided against the complainant in connection with generic/descriptive terms referring to gradschools.com and  graduateschools.com (FA0903001250509,   Nat. Arb. Forum, May 6, 2009) and earn-your-degree.com.  In connection with decision No. FA0801001139891 (Nat. Arb. Forum March 18, 2008), awarded in the favor of Complainant, Respondent requests that this decision not function as a precedent and this case is to be decided on its own merits.

 

FINDINGS

 

Complainant holds United States trademark registrations for Elearners (Reg.No. 2,470,525, registered on July 17, 2001) and ELERANERS.COM (Reg. No. 2,537,155 registered on February 5, 2002) for “dissemination of advertising for others via an on-line electronic communications network”, which have acquired and enjoy substantial goodwill and a valuable reputation through their long-standing use. 

 

Respondent has been using the disputed domain name since May 28, 2009, in connection with a commercial website that provides links to EducationDynamics’s competitors and to schools that are EducationDynamics’s customers for its advertising services. 

 

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.”

 

Paragraph 4(a) of the Policy requires that the 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 the Respondent is identical or confusingly similar to a trademark or service mark in which the Complainant has rights;

(2)   the 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 contends, and the Panel finds, that it has established rights in the ELEARNERS.COM mark under Policy ¶ 4(a)(i) via its registration of the mark with the United States Patent and Trademark Office (“USPTO”) (Reg. No. 2,537,155 issued Feb. 5, 2002).  See eMusic.com Inc. v. Warren Bird, FA 747940 (Nat. Arb. Forum Sep. 4, 2006) (finding that the complainant’s registration of the EMUSIC mark with the USPTO established the complainant’s rights in the mark under Policy ¶ 4(a)(i)); see also Trip Network Inc. v. Alviera, FA 914943 (Nat. Arb. Forum Mar. 27, 2007) (finding that the complainant’s federal trademark registrations for the CHEAPTICKETS and CHEAPTICKETS.COM marks were adequate to establish its rights in the mark pursuant to Policy ¶ 4(a)(i)).; see also EducationDynamics, LLC v. Texas International Property Associates, (FA0801001139891Nat. Arb. Forum, Mar. 18, 2008), finding that the Complainant has strong trademark rights within its field of on-line educational services in its trademarks ELEARNERS  and ELEARNERS.COM.

 

Respondent’s <elearner.com> domain name differs from Complainant’s ELEARNERS.COM mark by omitting the letter “s.”  The Panel finds that the <elearner.com> domain name is confusingly similar to Complainant’s ELEARNERS.COM mark under Policy ¶ 4(a)(i).  See Victoria's Secret v. Internet Inv. Firm Trust, FA 94344 (Nat. Arb. Forum May 9, 2000) (finding the domain name <victoriasecret.com> to be confusingly similar to the complainant’s trademark, VICTORIA’S SECRET); see also Am. Airlines, Inc. v. Data Art Corp., FA 94908 (Nat. Arb. Forum July 11, 2000) (finding <americanairline.com> "effectively identical and certainly confusingly similar" to the complainant's AMERICAN AIRLINES registered marks).

 

While Respondent contends that the <elearner.com> domain name is comprised of common, descriptive terms and as such cannot be found to be identical to Complainant’s mark, the Panel finds that such a determination is not necessary under Policy ¶ 4(a)(i) as this portion of the Policy considers only whether Complainant has rights in the mark and whether the disputed domain name is identical or confusingly similar to Complainant’s mark.  See Vance Int’l, Inc. v. Abend, FA 970871 (Nat. Arb. Forum June 7, 2007) (finding that because the complainant had received a trademark registration for its VANCE mark, the respondent’s argument that the term was generic failed under Policy ¶ 4(a)(i)); 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.”).

 

Rights or Legitimate Interests

 

Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii), and then the burden shifts to Respondent to show it does have rights or legitimate interests.  See Hanna-Barbera Prods., Inc. v. Entm’t Commentaries, FA 741828 (Nat. Arb. Forum Aug. 18, 2006) (holding that the complainant must first make a prima facie case that the respondent lacks rights and legitimate interests in the disputed domain name under UDRP ¶ 4(a)(ii) before the burden shifts to the respondent to show that it does have rights or legitimate interests in a domain name);

 

In this sense, Complainant asserts it has not granted Respondent any license to use its ELEARNERS.COM mark.  The WHOIS information associated with the disputed domain name lists Respondent as “Global Access c/o domain admin.”  Respondent has not submitted any evidence that it is commonly known by the <elearner.com> domain name. 

 

Complainant asserts that Respondent is using the <elearner.com> domain name to resolve to a parking website that display links to third-party websites which are in direct competition to the advertisements and links posted by Complainant. These allegations are not contested by Respondent. Complainant further asserts that Respondent receives click-through fees for the advertisements listed on the resolving websites.  The Panel finds this use is neither a bona fide offering of goods or services under Policy ¶ 4(c)(i) nor a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).  See Fox News Network, LLC v. Reid, D2002-1085 (WIPO Feb. 18, 2003) (finding that the respondent’s use of the disputed domain name to generate revenue via advertisement and affiliate fees is not a bona fide offering of good or services); see also Disney Enters., Inc. v. Kamble, FA 918556 (Nat. Arb. Forum Mar. 27, 2007) (holding that the operation of a pay-per-click website at a confusingly similar domain name was not 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)). 

 

Respondent argues that Complainant does not have an “exclusive right to provide advertising for online courses” as  the disputed domain name is comprised of generic terms and of common use and therefore, Complainant does not have an exclusive monopoly on these terms on the Internet. Complainant holds trademarks for “dissemination of advertising for others via an on-line electronic communications network”, trademarks which have acquired and enjoy substantial goodwill and a valuable reputation through their long-standing use.  Complainant is using these trademarks in order to advertise on line education provided by others. Complainant is not itself a provider of these on-line education services. As found by other Panels, Complainant is well-known within this field of on-line educational services, with incontestable trademark registrations for the ELEARNERS and ELEARNERS.COM marks.  Complainant’s website receives approximately 900,000 visitors per month and allows users to access information and services about on-line education and academic programs.  See also EducationDynamics, LLC v. Texas International Property Associates, (FA0801001139891Nat. Arb. Forum, Mar. 18, 2008).

 

The Panel takes into consideration the request of Respondent to decide this case on its own merits, but it cannot ignore the findings of other Panels in connection with the strong rights of Complainant in the trademarks ELEARNERS and ELEARNERS.COM, especially when Respondent is providing exactly the same kind of services as Complainant – advertising on-line education for others, using Complainant’s trademarks. 

 

Therefore the Panel considers that Respondent has failed to present arguments and evidence to show its rights or legitimate interests in the disputed domain name under Policy ¶ 4(c).

 

 

Registration and Use in Bad Faith

 

Complainant asserts that Respondent is using the disputed domain name to resolve to a website that directly competes with Complainant’s website by advertising third-party eLearning opportunities. As said before these assertions are not contradicted by Respondent.

 

According to Complainant, the website that resolves from the <elearner.com> domain name displays advertisements and links to websites in direct competition with Complainant.  Complainant contends that Respondent receives pay-per-click fees for these links and advertisements. Also these assertions are not contradicted by Respondent.

 

Moreover, the association between Respondent and Complainant is exacerbated, according to Complainant, by the way in which Respondent uses the <elearner.com> domain name, specifically, the similarities between the website associated with Respondent’s domain name and Complainant’s <elearners.com> website. None of these assertions were denied by Respondent, which concentrated its reasoning on the descriptive character of the Complainant’s trademarks.These circumstances require  the Panel to find that Respondent has registered and has been using the disputed domain name in order to take advantage of the inherent confusion between the <elearner.com> domain name and Complainant’s ELEARNERS.COM mark for Respondent’s own financial gain. 

 

Therefore, the Panel concludes that Respondent registered and used the disputed domain name in bad faith under 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 Philip Morris Inc. v. r9.net, D2003-0004 (WIPO Feb. 28, 2003) (finding that the respondent’s registration of an infringing domain name to redirect Internet users to banner advertisements constituted bad faith use of the domain name).

 

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

 

 

 

Dr. Beatrice Onica Jarka, Chair

Tyrus R. Atkinson, Jr., Panelist                                                                                  

        Dated: July 22, 2009

 

DISSENT OF MINORITY PANELIST DAVIS

 

I respectfully disagree with the result of the Majority in this case, while I do not disagree with their finding that Complainant owns several registered trademarks substantially identical to the domain name at issue.  However, I find no evidence whatsoever that the domain was registered in bad faith, since Complainant provided not even a scintilla of evidence to that effect other than that “Respondent must have known of Complainant’s rights” when it acquired the domain in May 2009.  That is not evidence but speculation.  The subject domain has apparently existed for many years in the hands of other owners prior to Respondent acquiring it.  I am not aware of any legal principle under the UDRP which makes it bad faith to register an existing domain name in order to use it, nor did Complainant cite such law.

 

Similarly, Complainant complains that Respondent’s use of the domain is to attract viewers to a website that directs them to educational institutions, for which it earns a fee.  Contrary to the stated conclusion of the Majority which finds this use improper, this is exactly what Complainant uses its own website and domain for, by its own admission on its web page under its Legal Notices section, http://www.elearners.com/help/legal.asp, where it describes itself as “eLearners.com, a part of the Student Prospecting Division of EducationDynamics, LLC.”  In other words, Complainant uses its domain <elearners.com> to help its institutional advertisers find students who come to the site looking for information.  How this differs legally from what Respondent uses its domain name for is beyond me.  Neither use is contrary to the UDRP and the many, many cases under it, nor does it form a legal basis for ruling here against Respondent.

 

In the final analysis, however, the domain should not be transferred to Complainant, simply because Complainant’s registered trademarks have become so hopelessly generic and descriptive that they no longer serve to uniquely distinguish the services of Complainant.  In fact, it would seem almost incredible that that USPTO ever issued the registrations on these marks which were already generic and descriptive at the time they were issued.  As another Forum panel recently held, in a case involving this same Complainant, “When a trademark is composed of generic terms, or common words phrases, and the disputed domain is being used “because of its attraction as [a] dictionary word[], and not because of [its] value as [a] trade mark[],” the Respondent has legitimate rights in the domain. . . . The use of a common word domain name related to the descriptive meaning of the domain name and its services constitutes use in connection with a bona fide offering of goods or services, pursuant to ¶ 4(c)(i) of the UDRP.” Nat. Arb. Forum, decision FA0903001250509, May 6, 2009.

 

The U.S. Courts of Appeal have ruled similarly in numerous cases, such as a well known decision where the Ninth Circuit held  . . . a holder of a trademark must be denied protection if the  mark becomes generic and is an expression that does not relate exclusively to a trademark owner's property. New Kids on the Block v. News Am. Pub., Inc., 971 F.2d 302, 306 (9th Cir. 1992).  This case has been cited and followed dozens of times since it came down.

 

This principle is so strong that there are legions of U.S. cases of otherwise well established trademarks becoming so descriptive and generic as to result in the unenforceability of the mark, since it no longer, if it ever did, exclusively describes the services or goods of the owner of the mark.  The examples of the terms “cellophane,” “elevator,” “aspirin,” and many other marks illustrate this rule of law which the Majority of this Panel is ignoring by its decision.  See, “An Overview of Trademark Law,” http://cyber.law.harvard.edu/metaschool/fisher/domain/tm.htm#6  where the author explains:

 

Trademark rights can also be lost through genericity. Sometimes, trademarks that are originally distinctive can become generic over time, thereby losing its trademark protection.  Kellogg Co. v. National Biscuit Co., 305 U.S. 111 (1938). A word will be considered generic when, in the minds of a substantial majority of the public, the word denotes a broad genus or type of product and not a specific source or manufacturer. So, for example, the term "thermos" has become a generic term and is no longer entitled to trademark protection. Although it once denoted a specific manufacturer, the term now stands for the general type of product. Similarly, both "aspirin" and "cellophane" have been held to be generic. Bayer Co. v. United Drug Co., 272 F.505 (S.D.N.Y. 1921). In deciding whether a term is generic, courts will often look to dictionary definitions, the use of the term in newspapers and magazines, and any evidence of attempts by the trademark owner to police its mark.”  Section 6.

 

One may also read of numerous other examples in the entry on “Genericized Trademarks” in the well known Wikipedia at http://en.wikipedia.org/wiki/Genericized_trademark, which cites many other examples and cases.

 

Suffice it to say, this Dissenting Panelist feels it is poor public policy as well as contrary to the fundamental purpose of the UDRP to protect generic or descriptive trademarks, which has the effect of taking such terms out of the public use, or at least making it difficult for the public to use the English language from which these words are taken. 

 

An example of the absurdity of this practice, here, is found when one uses the Google® search engine to search for the term “elearner.”  This results in 76,100 hits, only a few of which have anything to do with Complainant or its website, while the tens of thousands of other hits refer to and use the common and generic terms “elearner,” “elearning,” or terms like “elearning methodology,” which illustrates far more effectively than this Panelist can, that the whole concept of “elearning” is a technical English term and description of a new method of learning that belongs to the public at large and not to some domain name owner who seeks to arrogate ownership of a descriptive or generic English word to itself. 

 

EducationDynamics LLC (Complainant here) does not own the word “elearner”or “elearners,” the public does and any decision like that of the Majority here, which so finds, is simply and regrettably wrong.  I have, therefore,  respectfully dissented here in some detail so that other Panels in the future do not make what this Panelist sincerely believes is an error of law.

 

G. Gervaise Davis III, Panelist

 

 

 

 

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