national arbitration forum

 

DECISION

 

Hard Rock Cafe International (USA), Inc. v. Luna De Mar Negra I.P.O.N S.A.

Claim Number: FA0907001272460

 

PARTIES

 

Complainant is Hard Rock Cafe Internatinoal (USA), Inc. (“Complainant”), represented by Zachary D. Messa, of Johnson, Pope, Bokor, Ruppel & Burns, LLP, Florida, USA.  Respondent is Luna De Mar Negra I.P.O.N S.A. (“Respondent”), Costa Rica.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

 

The domain names at issue are <costaricahardrock.com>, <costaricahardrockcity.com>, <costaricahardrockbeach.com>, <hardrockcityonline.com>, and <hardrockcityworld.com>, registered with Domaindiscover.

 

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.

 

Bruce E. Meyerson as Panelist.

 

PROCEDURAL HISTORY

 

Complainant submitted a Complaint to the National Arbitration Forum electronically on July 6, 2009; the National Arbitration Forum received a hard copy of the Complaint on July 8, 2009.

 

On July 8, 2009, Domaindiscover confirmed by e-mail to the National Arbitration Forum that the <costaricahardrock.com>, <costaricahardrockcity.com>, <costaricahardrockbeach.com>, <hardrockcityonline.com>, and <hardrockcityworld.com> domain names are registered with Domaindiscover and that Respondent is the current registrant of the names.  Domaindiscover has verified that Respondent is bound by the Domaindiscover 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 July 21, 2009, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of August 10, 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@costaricahardrock.com, postmaster@costaricahardrockcity.com, postmaster@costaricahardrockbeach.com, postmaster@hardrockcityonline.com, and postmaster@hardrockcityworld.com by e-mail.

 

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

 

On August 14, 2009, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Bruce E. Meyerson 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 <costaricahardrock.com>, <costaricahardrockcity.com>, <costaricahardrockbeach.com>, <hardrockcityonline.com>, and <hardrockcityworld.com> domain names are confusingly similar to Complainant’s HARD ROCK mark.

 

2.      Respondent does not have any rights or legitimate interests in the <costaricahardrock.com>, <costaricahardrockcity.com>, <costaricahardrockbeach.com>, <hardrockcityonline.com>, and <hardrockcityworld.com> domain names.

 

3.      Respondent registered and used the <costaricahardrock.com>, <costaricahardrockcity.com>, <costaricahardrockbeach.com>, <hardrockcityonline.com>, and <hardrockcityworld.com> domain names in bad faith.

 

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

 

FINDINGS

 

Complainant, Hard Rock Cafe International (USA), Inc., is a Florida corporation that has been engaged in the business of leisure and entertainment using its HARD ROCK mark since 1978.  Complainant holds numerous registrations of its HARD ROCK mark with many governmental trademark authorities throughout the world, including the United States Patent and Trademark Office (“USPTO”) (i.e., Reg. No. 2,478,328 issued August 14, 2001).

 

Respondent registered the <costaricahardrock.com> and <costaricahardrockcity.com> domain names on November 27, 2008; the <hardrockcityonline.com> and <hardrockcityworld.com> domain names on  December 12, 2008; and the <costaricahardrockbeach.com> domain name on December 17, 2008.  Before Complainant sent Respondent a cease-and-desist letter, the <costaricahardrock.com> and <costaricahardrockcity.com> domain names contained copies Complainant’s websites and the other disputed domain names resolved to blank websites.  Since Respondent received the cease-and-desist letter, all of the disputed domain names resolve to websites with no content.

 

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

 

The Panel finds that Complainant has sufficiently established rights in the HARD ROCK mark through its numerous registrations of this mark held with various governmental trademark authorities throughout the world, including the USPTO (i.e., Reg. No. 2,478,328 issued August 14, 2001).  See Google, Inc. v. DktBot.org, FA 286993 (Nat. Arb. Forum Aug. 4, 2004) (finding that the complainant had established rights in the GOOGLE mark through its holding of numerous trademark registrations around the world); see also Honeywell Int’l Inc. v. r9.net, FA 445594 (Nat. Arb. Forum May 23, 2005) (finding the complainant’s numerous registrations for its HONEYWELL mark throughout the world sufficient to establish the complainant’s rights in the mark under the Policy ¶ 4(a)(i)).

 

The <costaricahardrock.com>, <costaricahardrockcity.com>, and <costaricahardrockbeach.com> domain names contain Complainant’s entire HARD ROCK mark, add the geographic term “Costa Rica,” add the generic top-level (“gTLD”) “.com,” and/or add  the generic terms “city” or “beach.”  The Panel finds that none of these additions to Complainant’s mark sufficiently distinguish these disputed domain names from Complainant’s mark.  Therefore, the Panel finds that the <costaricahardrock.com>, <costaricahardrockcity.com>, and <costaricahardrockbeach.com> domain names are confusingly similar to Complainant’s HARD ROCK mark under Policy ¶ 4(a)(i).  See Oki Data Ams., Inc. v. ASD, Inc., D2001-0903 (WIPO Nov. 6, 2001) (“[T]he fact that a domain name wholly incorporates a Complainant’s registered mark is sufficient to establish identity [sic] or confusing similarity for purposes of the Policy despite the addition of other words to such marks”); see also Gannett Co. v. Chan, D2004-0117 (WIPO Apr. 8, 2004) (“it is well established that a domain name consisting of a well-known mark, combined with a geographically descriptive term or phrase, is confusingly similar to the mark.”); Trip Network Inc. v. Alviera, FA 914943 (Nat. Arb. Forum Mar. 27, 2007) (concluding that the affixation of a gTLD to a domain name is irrelevant to a Policy ¶ 4(a)(i) analysis).

    

Respondent’s <hardrockcityonline.com> and <hardrockcityworld.com> domain names both contain Complainant’s HARD ROCK mark in its entirety, add the gTLD “.com,” and add the generic term “city,” and add the generic terms “online” or “world.”  The Panel finds that the <hardrockcityonline.com> and <hardrockcityworld.com> domain names are confusingly similar to Complainant’s HARD ROCK mark under Policy ¶ 4(a)(i) because none of these additions to Complainant’s mark sufficiently distinguish the disputed domain names from Complainant’s mark.  See Warner Bros. Entm’t Inc. v. Sadler, FA 250236 (Nat. Arb. Forum May 19, 2004) (finding the addition of generic terms to Complainant’s HARRY POTTER mark in the respondent’s <shop4harrypotter.com> and <shopforharrypotter.com> domain names failed to alleviate the confusing similarity between the mark and the domain names).

 

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

 

Rights or Legitimate Interests

 

Initially, Complainant must make a prima facie showing that Respondent lacks rights and legitimate interests in the disputed domain names.  The Panel finds that Complainant has sufficiently made its prima facie showing under Policy ¶ 4(a)(ii).  The burden then shifts to Respondent and Respondent must establish that it has rights or legitimate interests in the disputed domain names.  See Intel Corp. v. Macare, FA 660685 (Nat. Arb. Forum Apr. 26, 2006) (finding the “complainant must first make a prima facie case that [the] respondent lacks rights and legitimate interests in the disputed domain names under Policy ¶ 4(a)(ii), and then the burden shifts to [the] respondent to show it does have rights or legitimate interests.”); see also AOL LLC v. Gerberg, FA 780200 (Nat. Arb. Forum Sept. 25, 2006) (finding that if the complainant satisfies its prima facie burden, “then the burden shifts to the respondent to show that it does have rights or legitimate interest in the subject domain names.”).

 

Because Respondent has failed to submit a Response to the Complaint, the Panel may assume Respondent does not have rights or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(a)(ii).  However, the Panel will inspect the record and determine whether there is evidence against Complainant’s allegations under Policy ¶ 4(c). 

 

Complainant contends that prior to sending Respondent a cease-and-desist letter, the <costaricahardrock.com> and <costaricahardrockcity.com> domain names resolved to websites that contained copies of Complainant’s websites.  Complainant submitted screenshots that corroborate its contentions.  The Panel finds that Respondent attempted to pass itself off as Complainant.  Therefore, the Panel finds that such prior use of the <costaricahardrock.com> and <costaricahardrockcity.com> domain names by Respondent 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).  See Kmart of Mich., Inc. v. Cone, FA 655014 (Nat. Arb. Forum April 25, 2006) (The panel found the respondent’s attempt to pass itself of as the complainant was not 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) when the respondent used the disputed domain name to present users with a website that was nearly identical to the complainant’s website); see also MO Media LLC v. NeXt Age Technologies LTD, FA 220031 (Nat. Arb. Forum Feb. 18, 2004) (finding the respondent lacked rights and legitimate interests in the disputed domain name when the respondent copied the complainant’s websites in their entirety at the disputed domain names).

 

Moreover, after Complainant sent its cease-and-desist letter to Respondent, all of the disputed domain names resolve to websites with no content.  The Panel finds that Respondent’s failure to associate the disputed domain names with active websites is 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).  See George Weston Bakeries Inc. v. McBroom, FA 933276 (Nat. Arb. Forum Apr. 25, 2007) (finding that the respondent had no rights or legitimate interests in a domain name under either Policy ¶ 4(c)(i) or Policy ¶ 4(c)(iii) where it failed to make any active use of the domain name); see also U.S. News & World Report, Inc. v. Zhongqi, FA 917070 (Nat. Arb. Forum Apr. 9, 2007) (“Respondent’s failure to associate content with its disputed domain name evinces a lack of rights and legitimate interests pursuant to Policy ¶ 4(a)(ii).”).

 

The WHOIS information for all of the disputed domain names lists “Luna De Mar Negra I.P.O.N S.A.” as the registrant, which does not indicate that Respondent is commonly known by the any of the disputed domain names.  Furthermore, Respondent has not submitted any evidence to suggest otherwise.  Therefore, the Panel finds that Respondent is not commonly known by any of the disputed domain names under Policy ¶ 4(c)(ii).  See Reese v. Morgan, FA 917029 (Nat. Arb. Forum Apr. 5, 2007) (concluding that the respondent was not commonly known by the <lilpunk.com> domain name as there was no evidence in the record showing that the respondent was commonly known by that domain name, including the WHOIS information as well as the complainant’s assertion that it did not authorize or license the respondent’s use of its mark in a domain name); see also Instron Corp. v. Kaner, FA 768859 (Nat. Arb. Forum Sept. 21, 2006) (finding that the respondent was not commonly known by the <shoredurometer.com> and <shoredurometers.com> domain names because the WHOIS information listed Andrew Kaner c/o Electromatic a/k/a Electromatic Equip't as the registrant of the disputed domain names and there was no other evidence in the record to suggest that the respondent was commonly known by the domain names in dispute).

 

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

 

Registration and Use in Bad Faith

 

Respondent’s prior use of the <costaricahardrock.com> and <costaricahardrockcity.com> domain names to pass itself off as Complainant creates a likelihood of confusion as to Complainant’s affiliation with these disputed domain names.  Therefore, the Panel finds that Respondent’s actions using these disputed domain names constitutes bad faith registration and use under Policy ¶ 4(b)(iv).  See Target Brands, Inc. v. JK Internet Servs., FA 349108 (Nat. Arb. Forum Dec. 14, 2004) (finding bad faith because the respondent not only registered Complainant’s famous TARGET mark, but “reproduced . . . Complainant’s TARGET mark . . . [and] added Complainant’s distinctive red bull’s eye [at the domain name] . . . to a point of being indistinguishable from the original.”); see also America Online, Inc. v. Miles, FA 105890 (Nat. Arb. Forum May 31, 2002) (“Respondent is using the domain name at issue to resolve to a website at which Complainant’s trademarks and logos are prominently displayed.  Respondent has done this with full knowledge of Complainant’s business and trademarks. The Panel finds that this conduct is that which is prohibited by Paragraph 4(b)(iv) of the Policy.”).

 

The Panel finds that a finding of bad faith under Policy ¶ 4(a)(iii) is not limited to those instances enumerated in Policy ¶ 4(b).  See Cellular One Group v. Brien, D2000-0028 (WIPO Mar. 10, 2000) (finding that the criteria specified in 4(b) of the Policy is not an exhaustive list of bad faith evidence); see also Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (“[T]he examples [of bad faith] in Paragraph 4(b) are intended to be illustrative, rather than exclusive.”).

 

Respondent’s subsequent deletion of all content from <costaricahardrock.com> and <costaricahardrockcity.com> domain names, causing all of the disputed domain names to resolve to websites with no content is evidence that Respondent failed to make active use of the disputed domain names.  Therefore, the Panel finds that Respondent’s failure to make active use of the disputed domain names constitutes bad faith registration and use under Policy ¶ 4(a)(iii).  See DCI S.A. v. Link Commercial Corp., D2000-1232 (WIPO Dec. 7, 2000) (concluding that the respondent’s [failure to make an active use] of the domain name satisfies the requirement of ¶ 4(a)(iii) of the Policy); see also Caravan Club v. Mrgsale, FA 95314 (Nat. Arb. Forum Aug. 30, 2000) (finding that the respondent made no use of the domain name or website that connects with the domain name, and that [failure to make an active use] of a domain name permits an inference of registration and use in bad faith).

 

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 <costaricahardrock.com>, <costaricahardrockcity.com>, <costaricahardrockbeach.com>, <hardrockcityonline.com>, and <hardrockcityworld.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

Bruce E. Meyerson, Panelist

Dated:  August 26, 2009

 

 

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