national arbitration forum

 

DECISION

 

The Royal Bank of Scotland Group plc v. street c/o street

Claim Number: FA0804001175305

 

PARTIES

Complainant is The Royal Bank of Scotland Group plc (“Complainant”), represented by James A. Thomas, North Carolina, USA.  Respondent is street c/o street (“Respondent”), Germany.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain name at issue are <rbs-online-uk.net>, <rbs-uk.org>, and <rbsuk-online.info>, registered with Estdomains, 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.

 

Louis E. Condon as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on April 4, 2008; the National Arbitration Forum received a hard copy of the Complaint on April 7, 2008.

 

On April 7, 2008, Estdomains, Inc. confirmed by e-mail to the National Arbitration Forum that the <rbs-online-uk.net>, <rbs-uk.org>, and <rbsuk-online.info> domain names are registered with Estdomains, Inc. and that Respondent is the current registrant of the names.  Estdomains, Inc. has verified that Respondent is bound by the Estdomains, 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 April 16, 2008, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of May 6, 2008
 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@rbs-online-uk.net, postmaster@rbs-uk.org, and postmaster@rbsuk-online.info by e-mail.

 

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

 

On May 17, 2008, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Louis E. Condon 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 <rbs-online-uk.net>, <rbs-uk.org>, and <rbsuk-online.info> domain names are confusingly similar to Complainant’s RBS mark.

 

2.      Respondent does not have any rights or legitimate interests in the <rbs-online-uk.net>, <rbs-uk.org>, and <rbsuk-online.info> domain names.

 

3.      Respondent registered and used the <rbs-online-uk.net>, <rbs-uk.org>, and <rbsuk-online.info> domain names in bad faith.

 

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

 

FINDINGS

Complainant, the Royal Bank of Scotland Group plc, is one of the world’s leading financial services groups.  Complainant offers a wide range of financial products and services, including consumer and commercial lending, credit card services, investment and advisory services, and real estate services under its RBS mark.  Complainant registered the RBS mark with the United Kingdom Intellectual Property Office (“UKIPO”) on February 28, 1996 (Reg. No. 2,004,617); with the Office for Harmonization in the Internal Market (“OHIM”) on March 23, 1998 (Reg. No. 97,469); with the United States Patent and Trademark Office (“USPTO”) on December 19, 2006 (Reg. No. 3,185,538); as well as numerous registrations with other governmental trademark authorities. 

 

Respondent registered the <rbs-online-uk.net> domain name on December 3, 2007; the <rbs-uk.org> domain name on December 3, 2007, and the <rbsuk-online.info> domain name on December 4, 2007.  As of December 28, 2007, Respondent had been using the disputed domain names to host a website purporting to be Complainant’s legitimate website, acquiring personal information of Complainant’s current and potental customers.  The disputed domain names do not currently resolve to active websites.

 

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 names registered by Respondent are 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 names; and

(3)   the domain names have been registered and are being used in bad faith.

 

Identical and/or Confusingly Similar

 

Complainant has registered the RBS mark with the UKIPO, the OHIM, and the USPTO, thereby establishing rights to the mark under Policy ¶ 4(a)(i).  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.”).

 

Complainant contends that the <rbs-online-uk.net>, <rbs-uk.org>, and <rbsuk-online.info> domain names are confusingly similar to Complainant’s RBS mark because the disputed domain names fully incorporate the RBS mark with addition of hyphens, the geographic term “uk,” and in the case of the <rbs-online-uk.net> and <rbsuk-online.info> domain names, the generic term “online.”  Previous panels have concluded that combining a geographic term with a complainant’s mark does not sufficiently distinguish the disputed domain name from the mark.  Here, “uk” is a common abbreviation for the United Kingdom, thus the addition of the letters does not distinguish the disputed domain names.  Moreover, in Broadcom Corp. v. Domain Depot, FA 96854 (Nat. Arb. Forum Apr. 23, 2001), the panel found the <broadcomonline.com> domain name was confusingly similar to the complainant’s BROADCOM mark.  The Panel here also finds that the generic term “online” does not distinguish the disputed domain names from the mark.  Finally, all registered domain names are required to have a generic top-level domain (“gTLD”); Respondent’s addition of the gTLDs “.net,” “.org,” and “.info” are not relevant for assessing the confusing similarity of the disputed domain names, and therefore, are not a distinguishing addition.  The Panel finds that the disputed domain names are confusingly similar to Complainant’s RBS mark pursuant to Policy ¶ 4(a)(i).  See Isleworth Land Co. v. Lost in Space, SA, FA 117330 (Nat. Arb. Forum Sept. 27, 2002) (“[I]t is a well established principle that generic top-level domains are irrelevant when conducting a Policy ¶ 4(a)(i) analysis.”); see also MFI UK Ltd. v. Jones, D2003-0102 (WIPO May 8, 2003) (finding the <mfiuk.com> domain name confusingly similar to the complainant’s MFI mark because the addition of the letters “UK” were merely a common designation for the United Kingdom); see also Health Devices Corp. v. Aspen S T C, FA 158254 (Nat. Arb. Forum July 1, 2003) (“[T]he addition of punctuation marks such as hyphens is irrelevant in the determination of confusing similarity pursuant to Policy ¶ 4(a)(i).”).

 

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

 

Rights or Legitimate Interests

 

Complainant must first demonstrate that Respondent lacks all rights and legitimate interests in the disputed domain names.  The burden shifts to Respondent to show rights and legitimate interests once Complainant has made a prima facie case under Policy ¶ 4(a)(i).  The panel in Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) held 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.”  Complainant has asserted that Respondent lacks all rights and legitimate interests in the disputed domain names; the Panel finds that Complainant has established a prima facie case, thereby shifting the burden to Respondent.  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.”).

 

Respondent has not responded to the Complaint.  Therefore, the Panel may presume that Respondent lacks all rights and legitimate interests in the disputed domain names.  In Geocities v. Geociites.com, D2000-0326 (WIPO June 19, 2000), the panel found that the respondent has no rights or legitimate interests in the domain name because the respondent never submitted a response or provided the panel with evidence to suggest otherwise.  The Panel, however, will consider all evidence in the record to determine if Respondent has any rights or legitimate interests under Policy ¶ 4(c).  See 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”).

 

Complainant maintains that it has never authorized Respondent to use the RBS mark.  In addition, the WHOIS information does not suggest that Respondent is commonly known by the disputed domain names.  Therefore, the Panel finds that Respondent is not commonly known by the disputed domain names under Policy ¶ 4(c)(ii).  See 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); see also 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).

 

Respondent was previously using the disputed domain names to host a website that imitated Complainant’s legitimate website.  The panel in American International Group, Inc. v. Busby, FA 156251 (Nat. Arb. Forum May 30, 2003) found that the respondent attempted to pass itself off as the complainant online, which the panel held to be a blatant unauthorized use of the complainant’s mark and evidence that the respondent had no rights or legitimate interests in the disputed domain name.  This Panel concludes that Respondent’s previous use of the disputed domain names to pass itself off as Complainant was 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 Crow v. LOVEARTH.net, FA 203208 (Nat. Arb. Forum Nov. 28, 2003) (“It is neither a bona fide offerings [sic] of goods or services, nor an example of a legitimate noncommercial or fair use under Policy ¶¶ 4(c)(i) & (iii) when the holder of a domain name, confusingly similar to a registered mark, attempts to profit by passing itself off as Complainant . . . .”).

 

Previously, Respondent was also using the disputed domain names to acquire personal information from Complainant’s current and potential customers.  The Panel finds this behavior is further evidence that Respondent lacks rights and legitimate interests in the disputed domain names under Policy ¶¶ 4(c)(i) and (iii).  See Juno Online Servs., Inc. v. Nelson, FA 241972 (Nat. Arb. Forum Mar. 29, 2004) (finding that using a domain name in a fraudulent scheme to deceive Internet users into providing their credit card and personal information is not a bona fide offering of goods or services nor a legitimate noncommercial or fair use); see also Capital One Fin. Corp. v. Howel, FA 289304 (Nat. Arb. Forum Aug. 11, 2004) (finding that using a domain name to redirect Internet users to a website that imitated the complainant’s credit application website and attempted to fraudulently acquire personal information from the complainant’s clients was not a bona fide offering of goods or services or a legitimate noncommercial or fair use). 

 

The disputed domain names do not currently resolve to active websites.  Previous panels have maintained that holding disputed domain names without actively using them does not demonstrate any rights or legitimate interests.  The Panel finds that Respondent’s failure to actively use the disputed domain names is evidence of lack of rights and legitimate interests under Policy ¶ 4(a)(ii).  See TMP Int’l, Inc. v. Baker Enters., FA 204112 (Nat. Arb. Forum Dec. 6, 2003) (“[T]he Panel concludes that Respondent's [inactive use] of the domain name does not establish rights or legitimate interests pursuant to Policy ¶ 4(a)(ii).”); see also Am. Home Prods. Corp. v. Malgioglio, D2000-1602 (WIPO Feb. 19, 2001) (finding no rights or legitimate interests in the domain name <solgarvitamins.com> where the respondent did not actively use the domain name).

 

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

 

Registration and Use in Bad Faith

 

Respondent was previously using the <rbs-online-uk.net>, <rbs-uk.org>, and <rbsuk-online.info> domain names to operate a website imitating Complainant’s website; Complainant contends that this use evidences registration and use in bad faith.  The Panel finds that Respondent’s use of the disputed domain names was capable of creating confusion as to the source or affiliation of the website that resolved from the disputed domain names.  Moreover, Respondent was commercially benefiting from the goodwill associated with the RBS mark.  In H-D Michigan, Inc. v. Petersons Auto., FA 135608 (Nat. Arb. Forum Jan. 8, 2003), the panel found that the disputed domain name was registered and used in bad faith pursuant to Policy ¶ 4(b)(iv) through the respondent’s registration and use of the infringing domain name to intentionally attempt to attract Internet users to its fraudulent website by using the complainant’s famous marks and likeness.  Here, the Panel finds that Respondent’s use demonstrates registration and use 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.”).

Furthermore, by using the disputed domain names to acquire personal information, Respondent’s use further evidences registration and use in bad faith under Policy ¶ 4(a)(iii).  See HOPE worldwide, Ltd. v. Jin, FA 320379 (Nat. Arb. Forum Nov. 11, 2004) (finding that the respondent registered and used the domain name in bad faith because it redirected Internet users to a website that imitated the complainant’s website and was used to fraudulently acquire personal information from the complainant’s potential associates); see also Juno Online Servs., Inc. v. Iza, FA 245960 (Nat. Arb. Forum May 3, 2004) (finding that using a domain name that “is confusingly similar to Complainant’s mark, redirects Internet users to a website that imitates Complainant’s billing website, and is used to fraudulently acquire personal information from Complainant’s clients” is evidence of bad faith registration and use).   

 

Respondent’s previous use of the disputed domain names also evidence registration and use in bad faith under Policy ¶ 4(b)(iii) because it was capable of disrupting Complainant’s business.  See 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).”); see also S. Exposure v. S. Exposure, Inc., FA 94864 (Nat. Arb. Forum July 18, 2000) (finding the respondent acted in bad faith by attracting Internet users to a website that competes with the complainant’s business.

 

Finally, Respondent’s current inactive use of the disputed domain names demonstrates bad faith registration and use.  In Clerical Medical Investment Group Ltd. v. Clericalmedical.com, D2000-1228 (WIPO Nov. 28, 2000), the panel found that merely holding an infringing domain name without active use can constitute use in bad faith.  The Panel concludes that Respondent’s use shows registration and use in bad faith under Policy ¶ 4(a)(iii).  See DCI S.A. v. Link Commercial Corp., D2000-1232 (WIPO Dec. 7, 2000) (concluding that the respondent’s inactive use of the domain name satisfies the requirement of ¶ 4(a)(iii) of the Policy).

 

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

 

DECISION

Complainant having established all three elements required under the ICANN Policy, the Panel concludes that relief should be GRANTED.

 

Accordingly, it is Ordered that the <rbs-online-uk.net>, <rbs-uk.org>, and <rbsuk-online.info> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

Louis E. Condon, Panelist

Dated:  May 23, 2008

 

 

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