National Arbitration Forum

 

DECISION

 

Diners Club International Ltd. v. Jason McCandlish

Claim Number: FA0810001230033

 

PARTIES

Complainant is Diners Club International Ltd. (“Complainant”), represented by Paul D. McGrady, of Greenberg Traurig, LLP, Illinois, USA.  Respondent is Jason McCandlish (“Respondent”), Ontario, Canada.

 

REGISTRAR AND DISPUTED DOMAIN NAMES 

The domain names at issue are <ecarddiner.info>, <ecarddiner.net>, <carddiner.info>, <carddiner.biz>, <carddiner.org>, <carddiner.net>, <carddiner.com>, <ecarddiner.org>, <ecarddiner.biz> and <ecarddiner.com>, registered with Godaddy.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.

 

James A. Carmody, Esq., as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on October 20, 2008; the National Arbitration Forum received a hard copy of the Complaint on October 21, 2008.

 

On October 20, 2008, Godaddy.com, Inc. confirmed by e-mail to the National Arbitration Forum that the <ecarddiner.info>, <ecarddiner.net>, <carddiner.info>, <carddiner.biz>, <carddiner.org>, <carddiner.net>, <carddiner.com>, <ecarddiner.org>, <ecarddiner.biz> and <ecarddiner.com> domain names are registered with Godaddy.com, Inc. and that Respondent is the current registrant of the names.  Godaddy.com, Inc. has verified that Respondent is bound by the Godaddy.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 October 22, 2008, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of November 12, 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@ecarddiner.info, postmaster@ecarddiner.net, postmaster@carddiner.info, postmaster@carddiner.biz, postmaster@carddiner.org, postmaster@carddiner.net, postmaster@carddiner.com, postmaster@ecarddiner.org, postmaster@ecarddiner.biz and postmaster@ecarddiner.com by e-mail.

 

A Response was received and determined to be complete on November 12, 2008. However, this Response was deficient because it was not received in hard copy pursuant to ICANN Supplemental Rule 5(b).

 

On November 17, 2008, Complainant filed a timely and complete Additional Submission with the National Arbitration Forum in accordance with the National Arbitration Forum’s Supplemental Rule 7.

 

On November 17, 2008, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed James A. Carmody, Esq., as Panelist.

 

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 <ecarddiner.info>, <ecarddiner.net>, <carddiner.info>, <carddiner.biz>, <carddiner.org>, <carddiner.net>, <carddiner.com>, <ecarddiner.org>, <ecarddiner.biz> and <ecarddiner.com> domain names are confusingly similar to Complainant’s DINERS mark.

 

2.      Respondent does not have any rights or legitimate interests in the domain names at issue.

 

3.      Respondent registered and used the domain names at issue in bad faith.

 

B.  Response:

      Respondent failed to submit a proper Response in this proceeding and his email

communications following service of the Complaint do not raise any cognizable defenses to the relief sought by Complainant.

 

 

C.  Additional Submissions:

Complainant filed an Additional Submission which basically pointed out the inadequacy of the email of Respondent to either establish a defense or serve as a proper Response in this proceeding.

 

 

 

FINDINGS

Complainant owns many U.S. and international registrations for its DINERS CLUB and other similar trademarks and has extensively and continuously used these marks in commerce to provide credit cards, traveler’s assistance medical and legal referrals and other services to the public.  Complainant’s marks have become famous under U.S. law and are deemed notorious under the Paris Convention. For example, Complainant has rights in the DINERS mark pursuant to registration of the mark with the United States Patent and Trademark Office (“USPTO”) (Reg. No. 1,462,209 issued Oct. 1987) for credit card services.

 

Each of the disputed domain names contains Complainant’s DINERS mark omitting the letter “s”. Additionally, each of the <ecarddiner.info>, <ecarddiner.net>, <ecarddiner.org>, <ecarddiner.biz> and <ecarddiner.com> domain names precedes Complainant’s mark with the term “ecard,” while each of the <carddiner.info>, <carddiner.biz>, <carddiner.org>, <carddiner.net>, and <carddiner.com> domain names precedes Complainant’s mark with the word “card.” And finally, each of the disputed domain names contains the generic top level domain (“gTLD”) “.info,” “.net,” “.biz,” “.org” or “.com.”

 

Complainant has not licensed or otherwise authorized Respondent to use any of its trademarks, nor does Respondent so allege in his email to the National Arbitration following the commencement of this proceeding.  Respondent registered each of the domain names at issue on or about April 24, 2008, with actual or constructive knowledge of Complainant’s rights in the DINERS CLUB marks.

 

Respondent did not file a Response which complied with the Policy but sent email to the National Arbitration Forum following the commencement of this proceeding which did not set up any cognizable defenses to the Complaint.  Accordingly, the Panel determined that it would disregard the email of Respondent for the purposes of this proceeding.

 

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

As noted above, the Complainant has numerous registrations of long standing with respect to the DINERS CLUB family of marks which substantially predate registration of the domain name at issue.  See Mothers Against Drunk Driving v. phix, FA 174052 (Nat. Arb. Forum Sept. 25, 2003) (finding that the complainant’s registration of the MADD mark with the United States Patent and Trademark Office establishes the complainant’s rights in the mark for purposes of Policy ¶ 4(a)(i)); see also Bloomberg L.P. v. Johnston, FA 760084 (Nat. Arb. Forum Oct. 25, 2006) (finding that the complainant had established rights in the BLOOMBERG mark through registration with the United States Patent and Trademark Office).

 

The omission of the letter “s” in the domain names at issue does not preclude a finding of confusing similarity with the Complainant’s family of marks. See Universal City Studios, Inc. v. HarperStephens, D2000-0716 (WIPO Sept. 5, 2000) (finding that deleting the letter “s” from the complainant’s UNIVERSAL STUDIOS STORE mark did not change the overall impression of the mark and thus made the disputed domain name confusingly similar to it); see also Barnesandnoble.com LLC v. Your One Stop Web Shop, FA 670171 (Nat. Arb. Forum May 3, 2006) (finding that the <barnesandnobles.info> and <barnesandnobles.biz> domain names are confusingly similar to the complainant’s BARNESANDNOBLE.COM mark because the additions of the letter “s” and generic top-level domains to the dominant features of the complainant’s mark do not negate the confusingly similar aspects of the domain names pursuant to Policy ¶ 4(a)(i)).

 

Further, the presence of the word “card” in each of the domain names at issue does not insulate against a finding of confusing similarity.  The Panel finds that the addition of one word or term to Complainant’s mark, especially one that has a close relation to the credit card services provided under Complainant’s mark, fails to differentiate the disputed domain names. See Am. Express Co. v. MustNeed.com, FA 257901 (Nat. Arb. Forum June 7, 2004) (finding the respondent’s <amextravel.com> domain name confusingly similar to Complainant’s AMEX mark because the “mere addition of a generic or descriptive word to a registered mark does not negate” a finding of confusing similarity under Policy ¶ 4(a)(i)); see also Am. Online, Inc. v. Miller, FA 180625 (Nat. Arb. Forum Sept. 15, 2003) (finding confusing similarity where “[t]he domain name includes Complainant’s mark with the addition of the descriptive word “hot,” which does not dispel any confusion arising from the inclusion of Complainant’s mark in the domain name.”).

 

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

 

Rights or Legitimate Interests

Complainant has made a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain names under Policy ¶ 4(a)(ii) by having alleged without contravention that it has not licensed or otherwise authorized Respondent to use any form of the DINERS CLUB marks and that Respondent is not commonly known by the domain names at issue.  Accordingly, 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); see also AOL LLC v. Gerberg, FA 780200 (Nat. Arb. Forum Sept. 25, 2006) (“Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light.  If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names.”).

 

Respondent is not commonly known by the disputed domain names and Respondent does not contest this. The WHOIS information for each of the disputed domain names identifies Respondent as “Jason McCandish.” Complainant also states that it has not granted Respondent any license, permission or authorization to use the DINERS mark in anyway. Consequently, Respondent is not commonly known by any of the disputed domain names pursuant to Policy ¶ 4(c)(ii). See IndyMac Bank F.S.B. v. Eshback, FA 830934 (Nat. Arb. Forum Dec. 7, 2006) (finding that the respondent failed to establish rights and legitimate interests in the <emitmortgage.com> domain name as the respondent was not authorized to register domain names featuring the complainant’s mark and failed to submit evidence of that it is commonly known by the disputed domain name); see also Educ. Broad. Corp. v. DomainWorks Inc., FA 882172 (Nat. Arb. Forum Apr. 18, 2007) (concluding that the respondent was not commonly known by the <thirteen.com> domain name based on all evidence in the record, and the respondent did not counter this argument in its response).

 

The disputed domain names each either resolve to a website that advertises goods or services that directly compete with Complainant or redirect Internet users to the websites of third-parties who compete with Complainant. These websites promote various competing financial services. This does not constitute 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). See Constellation Wines U.S., Inc. v. Tex. Int’l Prop. Assocs., FA 948436 (Nat. Arb. Forum May 8, 2007) (finding that the respondent had no rights or legitimate interests under Policy ¶¶ 4(c)(i) or 4(c)(iii) by using the disputed domain name to operate a website featuring links to goods and services unrelated to the complainant); see also ALPITOUR S.p.A. v. Albloushi, FA 888651 (Nat. Arb. Forum Feb. 26, 2007) (rejecting the respondent’s contention of rights and legitimate interests in the <bravoclub.com> domain name because the respondent was merely using the domain name to operate a website containing links to various competing commercial websites, which the panel did not find to be 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 pursuant to Policy ¶ 4(c)(iii)).

 

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

 

Registration and Use in Bad Faith

The disputed domain names each resolve to a website featuring various links to direct competitors of Complainant. This competitive use is sufficient to establish that Respondent registered and is using the disputed domain names in bad faith pursuant to Policy ¶ 4(b)(iii). See Tesco Pers. Fin. Ltd. v. Domain Mgmt. Servs., FA 877982 (Nat. Arb. Forum Feb. 13, 2007) (concluding that the use of a confusingly similar domain name to attract Internet users to a directory website containing commercial links to the websites of a complainant’s competitors represents bad faith registration and use under Policy ¶ 4(b)(iii)); see also David Hall Rare Coins v. Tex. Int’l Prop. Assocs., FA 915206 (Nat. Arb. Forum Apr. 9, 2007) (finding that the respondent registered and used the disputed domain name in bad faith pursuant to Policy ¶ 4(b)(iii) because respondent used the disputed domain name to advertise goods and services of complainant’s competitors, thereby disrupting the complainant’s business).

 

Respondent had actual or at least constructive knowledge of Complainant’s rights in the DINERS mark because of Complainant’s federal registrations of the mark with the USPTO. This is further evidence of Respondent’s bad faith registration and use pursuant to Policy ¶ 4(a)(iii). See Samsonite Corp. v. Colony Holding, FA 94313 (Nat. Arb. Forum Apr. 17, 2000) (finding that evidence of bad faith includes actual or constructive knowledge of a commonly known mark at the time of registration); see also Digi Int’l v. DDI Sys., FA 124506 (Nat. Arb. Forum Oct. 24, 2002) (“[T]here is a legal presumption of bad faith, when Respondent reasonably should have been aware of Complainant’s trademarks, actually or constructively.”).

 

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 <ecarddiner.info>, <ecarddiner.net>, <carddiner.info>, <carddiner.biz>, <carddiner.org>, <carddiner.net>, <carddiner.com>, <ecarddiner.org>, <ecarddiner.biz> and <ecarddiner.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

James A. Carmody, Esq., Panelist
Dated: November 28, 2008

 

 

 

 

 

 

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