national arbitration forum

 

DECISION

 

Macy's Inc. v. Dr.MarcoFerro

Claim Number: FA0711001105729

 

PARTIES

Complainant is Macy's Inc. (“Complainant”), represented by Chester Rothstein, of Amster, Rothstein & Ebenstein LLP, 90 Park Avenue, New York, NY 10016.  Respondent is Dr.MarcoFerro (“Respondent”), Box 749, Fribourg CH.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <employeeconnection.org>, registered with Bizcn.com, Inc.

 

PANEL

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.

 

Judge Ralph Yachnin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on October 31, 2007; the National Arbitration Forum received a hard copy of the Complaint on November 1, 2007.

 

On November 1, 2007, Bizcn.com, Inc confirmed by e-mail to the National Arbitration Forum that the <employeeconnection.org> domain name is registered with Bizcn.com, Inc and that Respondent is the current registrant of the name.  Bizcn.com, Inc has verified that Respondent is bound by the Bizcn.com, 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 November 16, 2007, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of December 6, 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@employeeconnection.org by e-mail.

 

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

 

On November 12, 2007, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Judge Ralph Yachnin 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 <employeeconnection.org> domain name is identical to Complainant’s EMPLOYEE CONNECTION mark.

 

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

 

3.      Respondent registered and used the <employeeconnection.org> domain name in bad faith.

 

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

 

FINDINGS

Complainant, Macy's Inc., is one of the largest retail department store companies in the world, owning and operating department store chains under the MACY’S and BLOOMINGDALE’S marks.  Complainant has more than 900 department stores throughout the United States, and currently employees over 200,000 employees worldwide.  In connection with its services provided to its employees, Complainant uses its EMPLOYEE CONNECTION mark, specifically through the use of a website displayed at the <employeeconnection.net> domain name.  Complainant has used its EMPLOYEE CONNECTION mark since at least June 2001, and the <employeeconnection.net> domain name has been in operation since at least December 2001.  Services, benefits and general information is available at this domain name for Complainant’s employees.     

 

Respondent registered the <employeeconnection.org> domain name on July 7, 2004.  Respondent’s disputed domain name resolves to a website displaying numerous hyperlinks that are directly related to the content of Complainant’s <employeeconnection.net> website, including hyperlinks that may induce Internet users to reveal personal and financial information.   Respondent has also been the respondent in several previous UDRP decisions in which the disputed domain names in those cases were transferred from Respondent to the respective complainants in those cases.  See Int’l Olympic Comm. & Comitato Organizzatore XX Giochi Olimpici v. Dr. Marco Ferro, FA 604980 (Nat. Arb. Forum Jan. 20, 2006); see also Sidestep, Inc. v. Anna Valdieri/Marco Ferro, D2007-0212 (WIPO May 1, 2007).  

 

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 does not have a registered trademark with any governmental authority for its EMPLOYEE CONNECTION mark.  However, under Policy ¶ 4(a)(i), if Complainant can establish sufficient secondary meaning in its mark, registration with a trademark authority is unnecessary.  See Artistic Pursuit LLC v. calcuttawebdevelopers.com, FA 894477 (Nat. Arb. Forum Mar. 8, 2007) (finding that Policy ¶ 4(a)(i) does not require a trademark registration if a complainant can establish common law rights in its mark); see also 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).   

 

Complainant has been using its EMPLOYEE CONNECTION mark since at least June 2001, and has been operating a website at the <employeeconnection.net> domain name since at least December 2001.  Complainant has provided evidence of its promotion of its mark and website to its more than 200,000 employees, and to the amount of money it has invested in maintaining and promoting the website that operates under the EMPLOYEE CONNECTION mark.  Complainant provides information on various services for employees under this mark, including payroll and benefit information.  Accordingly, based on its extensive and continuous use of the mark, the Panel finds that Complainant has adequately established common law rights in the EMPLOYEE CONNECTION mark sufficient to satisfy the requirements of Policy ¶ 4(a)(i).  See Kahn Dev. Co. v. RealtyPROshop.com, FA 568350 (Nat. Arb. Forum June 23, 2006) (holding that the complainant’s VILLAGE AT SANDHILL mark acquired secondary meaning among local consumers sufficient to establish common law rights where the complainant had been continuously and extensively promoting a real estate development under the mark for several years); see also Toyota Sunnyvale v. Adfero Publ’g Co., FA 921194 (Nat. Arb. Forum Apr. 10, 2007) (concluding that the complainant’s TOYOTA SUNNYVALE mark had acquired secondary meaning sufficient for it to establish common law rights in the mark through continuous and extensive use of the mark since 2003 in connection with a car dealership under that mark).  

 

The Panel finds that the <employeeconnection.org> domain name is identical to Complainant’s EMPLOYEE CONNECTION mark under Policy ¶ 4(a)(i), as the disputed domain name simply removes the space between the two words in the mark and adds the generic top-level domain (“gTLD”) “.org.”  Neither of these modifications are relevant under Policy ¶ 4(a)(i), due to the nature of domain names, and as such, the Panel holds the disputed domain name identical to Complainant’s mark under Policy ¶ 4(a)(i).  See Hannover Ruckversicherungs-AG v. Ryu, FA 102724 (Nat. Arb. Forum Jan. 7, 2001) (finding <hannoverre.com> to be identical to HANNOVER RE, “as spaces are impermissible in domain names and a generic top-level domain such as ‘.com’ or ‘.net’ is required in domain names”); see also Koninklijke Philips Elecs. NV v. Goktas, D2000-1638 (WIPO Feb. 8, 2001) (finding that the domain name <philips.org> is identical to the complainant’s PHILIPS mark).    

 

The Panel finds that Policy ¶ 4(a)(i) has been satisfied.  

 

Rights or Legitimate Interests

 

Under Policy ¶ 4(a)(ii), Complainant must present a prima facie case that Respondent lacks rights and legitimate interests in the <employeeconnection.org> domain name.  Once Complainant has established such a case, as the Panel finds it has done here, the burden shifts to Respondent to show that it has rights or legitimate interests with regard to the disputed domain name.  See Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (holding that once the complainant asserts that the respondent has no rights or legitimate interests with respect to the domain, the burden shifts to the respondent to provide “concrete evidence that it has rights to or legitimate interests in the domain name at issue”); 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).”).

 

Respondent’s WHOIS information lists Respondent as “Dr.MarcoFerro,” and there is no other evidence that Respondent is or ever has been commonly known by the disputed domain name or authorized to use Complainant’s mark.  Thus, the Panel finds no evidence that Respondent is commonly known by the <employeeconnection.org> domain name under Policy ¶ 4(c)(ii).  See Coppertown Drive-Thru Sys., LLC v. Snowden, FA 715089 (Nat. Arb. Forum July 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 Compagnie de Saint Gobain v. Com-Union Corp., D2000-0020 (WIPO Mar. 14, 2000) (finding no rights or legitimate interest where the respondent was not commonly known by the mark and never applied for a license or permission from the complainant to use the trademarked name).       

 

Respondent is using the <employeeconnection.org> domain name to operate a website that displays hyperlinks to various third-party websites.  These hyperlinks are displayed on Respondent’s website under terms directly relating to services offered by Complainant under its EMPLOYEE CONNECTION mark, including payroll services.  Thus, there is a possibility that Internet users attempting to locate Complainant’s website may unknowingly give personal information to Respondent.  The Panel finds that Respondent’s use of the <employeeconnection.org> domain name 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 Computer Doctor Franchise Sys., Inc. v. Computer Doctor, FA 95396 (Nat. Arb. Forum Sept. 8, 2000) (finding that the respondent’s website, which is blank but for links to other websites, is not a legitimate use of the domain names); see also HOPE worldwide, Ltd. v. Jin, FA 320379 (Nat. Arb. Forum Nov. 11, 2004) (finding that a domain name that “is confusingly similar to Complainant’s mark, redirects Internet users to a website that imitates Complainant’s website, and is used to acquire personal information from Complainant’s potential associates fraudulently” does not fall within the parameters of Policy ¶¶ 4(c)(i) or (iii)).     

 

The Panel finds that Policy ¶ 4(a)(ii) has been satisfied.

 

Registration and Use in Bad Faith

 

The Panel finds that Respondent is commercially benefiting through the use of the <employeeconnection.org> domain name, either through the accrual of click-through fees, or through the gaining of personal information from Complainant’s employees, or both.  Such use of the disputed domain name is capable of creating a likelihood of confusion as to Complainant’s source, sponsorship, affiliation or endorsement with the <employeeconnection.org> domain name and corresponding website, particularly due to the content displayed on the website that resolves from the disputed domain name.  The Panel therefore finds evidence of bad faith registration and use under Policy ¶ 4(b)(iv).  See Am. Online, Inc. v. Tencent Commc’ns Corp., FA 93668 (Nat. Arb. Forum Mar. 21, 2000) (finding bad faith where the respondent registered and used a domain name confusingly similar to the complainant’s mark to attract users to a website sponsored by the respondent); 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)).

 

Respondent has also been the respondent in several previous UDRP decisions in which the disputed domain names in those cases were transferred from Respondent to the respective complainants in those cases.  See Int’l Olympic Comm. & Comitato Organizzatore XX Giochi Olimpici v. Dr. Marco Ferro, FA 604980 (Nat. Arb. Forum Jan. 20, 2006); see also Sidestep, Inc. v. Anna Valdieri/Marco Ferro, D2007-0212 (WIPO May 1, 2007).  The Panel thus finds a pattern of bad faith registration and use under Policy ¶ 4(b)(ii).  See Nat’l Abortion Fed’n v. Dom 4 Sale, Inc., FA 170643 (Nat. Arb. Forum Sept. 9, 2003) (finding bad faith pursuant to Policy ¶ 4(b)(ii) because the domain name prevented the complainant from reflecting its mark in a domain name and the respondent had several adverse decisions against it in previous UDRP proceedings, which established a pattern of cybersquatting); see also Arai Helmet Americas, Inc. v. Goldmark, D2004-1028 (WIPO Jan. 22, 2005 ((finding that “Respondent has registered the disputed domain name, <aria.com>, to prevent Complainant from registering it” and taking notice of another UDRP proceeding against the respondent to find that “this is part of a pattern of such registrations”).      

 

Moreover, as the website that resolves from the <employeeconnection.org> domain name displays hyperlinks to websites that may be used to gain personal information from Internet users, the Panel finds further evidence of bad faith registration and use under Policy ¶ 4(a)(iii).  See Juno Online Servs., Inc. v. Nelson, FA 241972 (Nat. Arb. Forum Mar. 29, 2004) (“The domain name <billing-juno.com> was registered and used in bad faith by using the name for fraudulent purposes.”); see also Capital One Fin. Corp. v. Howel, FA 289304 (Nat. Arb. Forum Aug. 11, 2004) (finding bad faith registration and use because the respondent used the domain name to redirect Internet users to a website that imitated the complainant’s website and to fraudulently acquire personal information from the complainant’s clients).    

 

The Panel finds that Policy ¶ 4(a)(iii) has been satisfied.

 

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 <employeeconnection.org> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Hon. Ralph Yachnin, Panelist

Justice, Supreme Court, NY (Ret.)

 

Dated:  December 18, 2007

 

 

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