National Arbitration Forum

 

DECISION

 

iCall, Inc. v. Reliance Communications Ltd

Claim Number: FA1003001310577

 

PARTIES

Complainant is iCall, Inc. (“Complainant”), represented by Charles Carreon, of Online Media Law, PLLC, Arizona, USA.  Respondent is Reliance Communications Ltd (“Respondent”), represented by Rachel M. Hofstatter, of Steptoe & Johnson LLP, Washington D.C., USA.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <relianceicall.com>, registered with Network Solutions, Inc.

 

PANEL

The undersigned certifies that they have acted independently and impartially and to the best of their knowledge have no known conflict in serving as Panelists in this proceeding.

 

Mr. Calvin A. Hamilton as Chair of the Panel

Ms. Anne Wallace as Panelist

Mr. Judge Tyrus Atkinson as Panelist

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on February 26, 2010.

 

On March 1, 2010, Network Solutions, Inc. confirmed by e-mail to the National Arbitration Forum that the <relianceicall.com> domain name is registered with Network Solutions, Inc. and that the Respondent is the current registrant of the name.  Network Solutions, Inc. has verified that Respondent is bound by the Network Solutions, 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 March 10, 2010, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of March 30, 2010 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent’s registration as technical, administrative, and billing contacts, and to postmaster@relianceicall.com by e-mail.  Also on March 10, 2010, the Written Notice of the Complaint, notifying Respondent of the email addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent’s registration as technical, administrative and billing contacts.

 

A timely Response was received and determined to be complete on March 30, 2010.

 

Complainant filed an Additional Submission with the Forum on April 5, 2010, which was determined to be in compliance with Supplemental Rule #7.

 

Respondent filed an Additional Submission with the Forum on April 12, 2010, which was determined to be in compliance with Supplemental Rule #7.

 

On April 15, 2010, pursuant to Respondent’s request to have the dispute decided by a three-member Panel, the National Arbitration Forum appointed Anne Wallace, Judge Tyrus Atkinson as Panelists and Calvin A. Hamilton as Chair of the Panel.

 

RELIEF SOUGHT

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

 

PARTIES’ CONTENTIONS

A. Complainant

Complainant operates the iCall® Service, a Voice-Over Internet Protocol (“VoIP”) calling platform that operates on desktop computers and on the Apple iPhone and iPod. iCall also offers wholesale VoIP solutions through iCall®Carrier Services. iCall, Inc. offers the iCall® Service in both free and paid versions.

 

<icall.com> domain was first registered on November 26, 1996 and the iCall® Mark was first registered on October 6, 1998 (Reg. No. 2,194,066). In  July 2004 Complainant’s CEO Arlo Gilbert acquired the <icall.com> domain and the trademark rights to the iCall® Mark in order to use both the <icall.com> domain and the iCall® Mark to offer the iCall® Service, and both are now held as corporate assets of Complainant.

 

Complainant contends that it has used the <icall.com> domain and the iCall® Mark exclusively for development, distribution and marketing VoIP services.

 

Complainant states that it has “assiduously” maintained its ownership rights in the iCall® Mark.

 

On October 3, 2008, iCall submitted its “Combined Declaration of Use in Commerce & Application for Renewal of Registration of a Mark under Sections 8 & 9.”

 

On October 11, 2008, the USPTO renewed iCall’s ownership of the iCall® Mark. On December 16, 2009, Complainant submitted its “Declaration of Incontestability of a Mark under Section 15” with the USPTO. On January 26, 2010, the USPTO issued its Notice of Acknowledgment of §15 Declaration, thus establishing the mark’s incontestability.

 

Complainant contends that in March 2009, specialized iCall® software developed specifically for the Apple iPhone was approved for distribution through the iPhone App Store.

 

Complainant asserts that iCall has never had any business relationship with Respondent, and Respondent is not operating <relianceicall.com> under any license granted by iCall.

 

Respondent registered <relianceicall.com> (the “Disputed Domain”) on August 11, 2008.

 

Complainant contends that the Disputed Domain is identical to the <icall.com> domain with the exception of a legally insignificant descriptive prefix “reliance”.

 

Complainant argues that Respondent has no legitimate rights or interests with respect to the Domain Name because Respondent is not authorized or licensed to use Complainant’s iCall® mark for any purpose. Nor has Respondent’s business been commonly known as “Reliance I Call” or any variant thereof, but rather has chosen to foment and exploit the confusion arising from incorporating the iCall® Mark into the Disputed Domain. Furthermore, Complainant asserts that Respondent intends to capitalize on the goodwill of Complainant’s ICALL® mark on Respondent’s website by using different typestyles for the descriptive prefix “reliance” and the phrase “icall” and a space between two words, so as to call both visual and search-engine attention to the iCall® Mark, separate from the “reliance” prefix.

 

Complainant asserts that Respondent registered the Disputed Domain in bad faith because the registration was made nine years and eleven months after the issuance of U.S. Trademark No. 2,194,066 for the iCall ® Mark. Consequently, according to Complainant, Respondent’s registration of <relianceicall.com> was certainly made with knowledge that <icall.com> had already been registered and was in active use by iCall to offer competing VoIP services; and Respondent is using the <relianceicall.com> domain to offer services that are essentially identical, and in direct competition with the services offered by iCall through <icall.com>.

 

In its additional submissions Complainant contends that it is undisputed that Respondent is a very large company with 100 Million users in India, and 1 Million in the United States, and that Complainant is a small company whose software has been downloaded 4.5 Million times.

 

Complainant asserts that Respondent has presented no evidence of its corporate intent in registering the domain. According to Complainant, Respondent registered the disputed domain with knowledge of Complainant’s rights since the doctrine of “constructive bad faith” applies.

 

Furthermore, Complainant contends that Respondent’s corporate knowledge can also be inferred from its untimely procurement of registrations for “Reliance iCall” in Germany and France on June 9, 2009, and in the United Kingdom on July 28, 2009, while scrupulously avoiding any effort to register this illegitimate mark in the United States with the USPTO.

 

Claimant asserts that Respondent has never used “RelianceiCall” as its company name, nor has it been known by that name, nor is it registered as RelianceiCall in any country, including Germany, France and the United Kingdom.

 

B. Respondent

Respondent, Reliance Communications Limited, is India’s largest private sector information and telecommunications company. Reliance Industries Limited, the flagship company of the Reliance group, has been a public company in India since 1977, and it and its various affiliates have been operating under the name and mark RELIANCE since that time. By virtue of continuous and extensive use, Reliance’s RELIANCE mark has come to be one of the most famous and recognized marks in India and among Indian expatriates around the world. The Reliance group expanded into the telecommunications services business in the 1990s.

 

Reliance has offered its telecommunications services under a variety of brand names that utilize the RELIANCE mark.

 

As an integral part of its business, Reliance has offered its telecommunications services through its many business websites. It has owned many domain name registrations for its telecommunications services such as <relianceworldcall.com>, <relianceglobalcall.com>, <relianceglobalcom.com>, <relianceindiacall.com> and <relianceicall.com>.

 

The Reliance group began use of the RELIANCE mark in the 1970s when the Indian trademark registration system was not widely employed. The RELIANCE mark subsequently became so well known in India that consumers automatically associated it with the Reliance group companies. As the Reliance group grew and began to expand internationally, it began to register its many RELIANCE trademarks in India (655 registrations) and abroad. It obtained its first registration in India for the mark RELIANCE in 1999.

 

Reliance owns trademark registrations for its mark RELIANCE ICALL in the UK

(Serial Registration No. 2,502,534), France (Registration Nos. 08/3612187 and 08/3612188) and Germany (Registration No. 30 2008 051 957 and 30 2008 051958).

 

Respondent claims that the domain name <relianceicall.com> and Complainant’s ICALL mark are far from identical because iCall consists only of the generic letter “i” combined with the generic word “Call.” Adding, that since the rise of the Internet, many entities have used the letter “i” as a prefix meaning “Internet” followed by a generic or descriptive term to identify Internet-based goods or services.

 

Respondent argues that it has legitimate rights or interests in the <relianceicall.com> domain name for several reasons. First, Reliance owns trademark registrations in the UK, France and Germany for its RELIANCE ICALL mark and registrations of the mark RELIANCE in India, the United States and elsewhere.

 

Respondent asserts that Reliance is commonly known and referred to as “Reliance.” Moreover, on the <relianceicall.com> site, Reliance brands its Internet-based calling service as Reliance iCall.

 

Respondent contends that long before it received notice of this dispute, it has used its <relianceicall.com> domain name to offer its Internet-based calling services under its registered RELIANCE and RELIANCE ICALL trademarks.

 

Respondent claims that it registered the <relianceicall.com> domain name to advertise and sell its own Internet-based calling services under its RELIANCE and RELIANCE ICALL trademarks, fully consistent with its other telecommunications services businesses.

 

Respondent asserts that it has not intentionally attempted to attract for commercial gain Internet users to its site by creating a likelihood of confusion with the ICALL mark.

 

C. Additional Submissions

Complainant filed an Additional Submission with the Forum on April 5, 2010, which was determined to be in compliance with Supplemental Rule #7. Complainant argues in this submission several legal points pursuant to United States trademark law, including the Lanham Act. Since this dispute is governed by the UDRP and not United States legal code, the Panel analyzes this case only under UDRP Policy.

 

Respondent filed an Additional Submission with the Forum on April 12, 2010, which was determined to be in compliance with Supplemental Rule #7.

 

FINDINGS

Complainant, iCall, Inc. operates the iCall® Service, a Voice-Over Internet Protocol (“VoIP”) calling platform that operates on desktop computers and on the Apple iPhone and iPod. iCall also offers wholesale VoIP solutions through iCall®Carrier Services. iCall, Inc. offers the iCall® Service in both free and paid versions.

 

<icall.com> domain was first registered on November 26, 1996 and the iCall® Mark was first registered on October 6, 1998 (Reg. No. 2,194,066).

 

In  July 2004 Complainant’s CEO Arlo Gilbert acquired the <icall.com> domain and the trademark rights to the iCall® Mark in order to use both the <icall.com> domain and the iCall® Mark to offer the iCall® Service, and both are now held as corporate assets of Complainant.

 

On October 3, 2008, iCall submitted its “Combined Declaration of Use in Commerce & Application for Renewal of Registration of a Mark under Sections 8 & 9.”

 

On October 11, 2008, the USPTO renewed iCall’s ownership of the iCall® Mark.

 

On December 16, 2009, Complainant submitted its “Declaration of Incontestability of a Mark under Section 15” with the USPTO.

 

On January 26, 2010, the USPTO issued its Notice of Acknowledgment of §15 Declaration, thus establishing the mark’s incontestability.

 

In March 2009, iCall® developed a software specifically for the Apple iPhone, which was approved for distribution through the iPhone App Store.

 

Respondent, known under company Reliance Communications Limited, is India’s largest private sector information and telecommunications company. Reliance Industries Limited, the flagship company of the Reliance group, has been a public company in India since 1977, and it and its various affiliates have been operating under the name and mark RELIANCE since that time. By virtue of continuous and extensive use, the RELIANCE mark has become one of the most famous and recognized marks in India and among Indian expatriates around the world. The Reliance group expanded into the telecommunications services business in the 1990s.

 

Reliance has offered its telecommunications services under a variety of brand names that utilize the RELIANCE mark.

 

As an integral part of its business, Reliance has offered its telecommunications services through its many business websites. It has owned many domain name registrations for its telecommunications services such as <relianceworldcall.com>, <relianceglobalcall.com>, <relianceglobalcom.com>, <relianceindiacall.com> and <relianceicall.com>.

 

The Reliance group began use of the RELIANCE mark in the 1970s when the Indian trademark registration system was not widely employed. The RELIANCE mark subsequently became so well known in India that consumers automatically associated it with the Reliance group companies. As the Reliance group grew and began to expand internationally, it began to register its many RELIANCE trademarks in India (655 registrations) and abroad. It obtained its first registration in India for the mark RELIANCE in 1999.

 

On April 5, 2005 the mark RELIANCE was registered in USA (Reg. No. 2,937,405).

 

Between 2004 and 2009 the mark RELIANCE was registered in Europe, Asia and Canada.

 

Reliance owns trademark registrations for its mark RELIANCE ICALL in the UK on 17/11/2008 (Serial Registration No. 2,502,534), France on 19/11/2008 (Registration Nos. 08/3612187 and 08/3612188) and Germany on 23/04/2008 (Registration No. 30 2008 051 957 and 30 2008 051958).

 

Reliance registered <relianceicall.com> (the “Disputed Domain”) on August 11, 2008.

 

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;

(1)   the Respondent has no rights or legitimate interests in respect of the domain name; and

(2)   the domain name has been registered and is being used in bad faith.

 

Identical and/or Confusingly Similar

 

Complainant, iCall, Inc., claims that it offers Voice-Over Internet Protocol (“VoIP”) that allows Internet users to make voice communications through computers or Apple’s iPhone and iPod. Complainant contends and provided evidence that it holds a trademark registration with the United States Patent and Trademark Office ("USPTO") for its ICALL mark (Reg. No. 2,194,066 issued October 6, 1998).

 

Per this registration, Complainant has established rights in the marks pursuant to Policy ¶ 4(a)(i). As the panel in Morgan Stanley v. Fitz-James (CT2341-RSC) Cititrust Grp. Ltd., FA 571918 (Nat. Arb. Forum Nov. 29, 2005) stated, “The Panel finds from a preponderance of the evidence that Complainant has registered its mark with national trademark authorities. The Panel has determined that such registrations present a prima facie case of Complainant’s rights in the mark for purposes of Policy ¶ 4(a)(i).” In the same sense, Paisley Park Enters. v. Lawson, FA 384834 (Nat. Arb. Forum Feb. 1, 2005) also held that rights under a mark were established under Policy ¶ 4(a)(i) through registration of the mark with the USPTO.

 

The Panel agrees that the registration of a mark with the USPTO sufficiently meets the prima facie requirements under Policy ¶ 4(a)(i). The issuance of a Registration certificate by the empowered authority on trademark matters is a scheme to regulate trade and commerce in relation to trademarks, and unless registration is shown invalid, it gives its owner the exclusive right to the use of said trademarks in respect to those wares or services for which it is registered.

 

Complainant alleges that Respondent’s <relianceicall.com> domain name is confusingly similar to Complainant’s ICALL mark.  Complainant argues that the disputed domain name adds the generic term “reliance” and the generic top-level domain (“gTLD”) “.com” to Complainant’s mark. The addition of a generic term and gTLD does not adequately distinguish the disputed domain name from Complainant’s mark under Policy ¶ 4(a)(i).

 

Respondent alleges that its <relianceicall.com> domain name is not confusingly similar to Claimant’s ICALL trade mark.  Respondent claims that the term “reliance” reflects Respondent’s RELIANCE mark.  Respondent argues that the addition of Respondent’s mark to Complainant’s alleged mark ensures that the disputed domain name is not confusingly similar to Complainant’s mark and concludes that the <relianceicall.com> domain name is not confusingly similar to Complainant’s ICALL mark under Policy ¶ 4(a)(i).

 

Respondent contends that the <relianceicall.com> domain name is comprised of common and generic terms and as such cannot be found to be confusingly similar to Complainant’s mark, however, 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. A parties’ trademark registration of a mark overcomes the argument that the mark is generic. 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)).

 

On the one hand, and as was stated by previous panels, the incorporation of a trademark in its entirety within a domain name is sufficient to establish that said domain name is identical or confusingly similar to the complainant’s registered mark. Revlon Consumer Prods. Corp. v. Farris, D2003-0291 (WIPO June, 4 2003) (finding the respondent’s <iloverevlon.com> and <iloverevlon.com>  domain names confusingly similar to Complainant’s REVLON mark because the “addition of a generic terms “I” and “love” did not distinguish the domain names so as to avoid confusion).

 

However, our case is different. In the case before us “Reliance” is not a descriptive/generic word, since a parties’ trademark registration overcomes the genericness. Moreover, Complainant has submitted no evidence to establish either fame or strong secondary meaning in its mark such that consumers are likely to associate <relianceicall.com> only with ICALL mark (as it in the case of REVLON mark). On the contrary, Respondent has demonstrated, the term "icall" is in widespread use in a descriptive sense.

 

The Panel finds therefore, that the domain name registered by the Respondent is not confusingly similar to a trademark or service mark in which the Complaint has rights. Thus, the panel finds that Respondent’s <relianceicall.com> domain name is not confusingly similar to Complainant’s ICALL mark pursuant to Policy ¶ 4(a)(i).

 

The Panel declines to analyze the other elements of the Policy because Complainant must prove all three elements under Paragraph 4(a) of the Policy to prevail in this proceeding, and it failed to prove the element listed in Paragraph 4(a)(i).

 

DECISION

Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be DENIED.

 

 

Calvin A. Hamilton, Chair of the Panel

Anne Wallace, Panelist

Judge Tyrus Atkinson, Panelist

 

Dated: April 29, 2010

 

 

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