National Arbitration Forum

 

DECISION

 

Oregon Freeze Dry, Inc. v. Vertical Axis Inc.

Claim Number: FA1003001316531

 

PARTIES

Complainant is Oregon Freeze Dry, Inc., represented by Ernest G. Bootsma, of Ater Wynne LLP, (“Complainant”), Oregon, USA.  Respondent is Vertical Axis Inc., represented by Ari Goldberger, of ESQwire.com Law Firm, (“Respondent”), New Jersey, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAME 

The domain name at issue is <easymeal.com>, registered with Nameview, Inc.

 

PANEL

The undersigned certify that they have acted independently and impartially and to the best of his or her knowledge has no known conflict in serving as Panelist in this proceeding.

 

Hon. Sir Ian Barker, G. Gervaise Davis III, Esq. and Diane Cabell, Esq. as Panelists.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on March 31, 2010.

 

On April 6, 2010, Nameview, Inc. confirmed by e-mail to the National Arbitration Forum that the <easymeal.com> domain name is registered with Nameview, Inc. and that the Respondent is the current registrant of the name.  Nameview, Inc. has verified that Respondent is bound by the Nameview, 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 14, 2010, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of May 4, 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@easymeal.com by email.  Also on April 14, 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 deficient on May 4, 2010 because the Annexes were not separated from the Response.  Despite the deficiency in the Response, the Panel, in the exercise of its discretion, determined to admit the Response.

 

The Complainant’s Additional Submission was received on May 10, 2010 in compliance with Supplemental Rule 7.

 

The Respondent’s Additional Submission was received in a timely manner on May 17, 2010.

 

On May 19, 2010, pursuant to the Respondent’s request to have the dispute decided by a three-member Panel, the National Arbitration Forum appointed Hon. Sir Ian Barker, G. Gervais Davis III, Esq. and Diane Cabell, Esq. as Panelists.

 

RELIEF SOUGHT

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

 

PARTIES’ CONTENTIONS

A. Complainant

The Complainant has owned a registered United States Trademark for the expression EASY MEAL since September 11, 1984.  It has continually used the mark in interstate commerce since April 5, 1977 for the sale of dry packaged meals consisting primarily of meat, poultry or fish.  The disputed domain name is identical to the Complainant’s trademark. 

 

The Respondent registered the disputed domain name on February 26, 2006.  Since then, the Respondent has maintained a website which contains links to meal planning and recipes.  Its site identifies related searches.  On the website immediately below the heading “Welcome to easymeal.com” there is a link “To purchase this domain click here”.   When the user clicks on that link, the user is taken to <domainbrokers.com>.  The copyright notice located on the website refers to “©2010easymeal.com”.  The copyright notice indicates 2010, but the site has remained the same since 2006.  No goods or services are offered on the site which contains references to meals so as to appear to be a legitimate website but it is merely a placeholder for the sale of the disputed domain name.

 

The Respondent has no legitimate interests in respect of the disputed domain name.  The Complainant contacted <domainbrokers.com> and was advised that the disputed domain name could be acquired for U.S. $10,000.  Consequently, the website is merely a sham to attract buyers. 

 

The Respondent has not made any demonstrable preparations to use the disputed domain name in connection with any bona fide offering of goods and services.  The Complainant attempted to negotiate the purchase of the disputed domain name through <domainbrokers.com> but attempts to negotiate were initially ignored, then followed by a demand for U.S. $10,000. 

 

The Complainant sent a “cease and desist” letter to the Registrar on February 17, 2010, but received no reply.  The Complainant’s letters were sent to the Registrar in Vancouver, Canada and also to the identity shield, Nameview, Inc. in Barbados.

 

B. Respondent

The Respondent has a legitimate interest in the disputed domain name because it incorporates the descriptive term, “Easy Meal”.  The Respondent registered the disputed domain name when it had been deleted and became available for registration.  The Respondent had no knowledge of the Complainant’s trademark when it registered the disputed domain name.

 

“Easy Meal” is a descriptive term using dictionary words denoting a simple way to prepare a serving of food.  The Complainant’s trademark was based on acquired “distinctiveness” under Trade Mark Rule 2(f).  Whilst not arguing that the Complainant’s trademark is invalid, the Respondent says that its registration of the disputed domain name was in good faith because the term “Easy Meal” is descriptive.  Such terms can be registered on a “first come first served” basis as a domain name.

 

The Respondent hosts the disputed domain name with <hitfarm.com>, a service which places pay-per-click (PPC) advertising links on host domains, sharing the advertising revenue with domain name owners.  This is a bona fide offering of goods and services which has been found to establish a legitimate interest in cases under the UDRP, including cases involving the present Respondent.

 

There is no evidence that the Respondent registered the disputed domain name with the Complainant’s trademark in mind or that it had heard of the Complainant at that time.  The Respondent registered the disputed domain name more than 4 years ago. 

 

The Complainant’s long delay in initiating action raises the inference that the Complainant did not believe the Respondent had engaged in bad faith registration or use.  There are no advertisements for products on the Respondent’s website, nor any evidence the Respondent has used the disputed domain name in any way with respect to the Complainant’s trademark. 

 

The Respondent has registered domain names solely because they incorporate common or words of descriptive terms.  It has more than 40 other domain names registered which incorporate the term “easy” in a food context.  Links on the Respondent’s website relate to cooking recipes and meal planning.  There are no links for products associated with the Complainant’s goods and services.  The link on the website which states “To purchase this domain click here” is a standard link appearing on hitfarm.com hosted webpages.

 

The Respondent takes no position regarding the enforceability of the Complainant’s trademark and does not contest that the disputed domain name is identical to the mark in which the Complainant has rights. 

 

However, the Respondent claims legitimate rights and interests in the disputed domain name under Paragraph 4(c)(i) of the Policy.  It cites a number of cases under the Policy where common words and descriptive terms are legitimately subject to registration as domain names on a “first come first served” basis.  The are several decisions under the Policy in which it has been held that the operation of PPC websites can amount to a bona fide offering of goods and services – See C Brewer & Sons Ltd. v. Vertical Axis, Inc.,  D2009-1759 (WIPO Nov. 4, 2010) and Accetta v. Domain Admin et al, FA 826565 (Nat. Arb. Forum Jan. 2, 2007).

 

The Respondent’s business has been held legitimate on more than one occasion – See Le Hara v. Vertical Axis, Inc., FA 1225832 (Nat. Arb. Forum Nov. 24, 2008), and Nursefinders, Inc. v. Vertical Axis, Inc., D2007-0417 (WIPO May 7, 2007).

 

The Complainant has not demonstrated that the disputed domain name was registered and is being used in bad faith.  The Respondent simply registered it when it became available due to deletion.  The Respondent’s record in domain name disputes does not establish that the disputed domain name was registered in bad faith – See the Nursefinders case, supra and Bright Horizons Family Solutions, Inc. et al v. Vertical Axis, Inc., D2007-0795 (WIPO Dec. 10, 2007). 

 

There is no evidence to show that the disputed domain name was registered with the Complainant in mind.  As for the suggestion that the disputed domain name could be acquired for U.S. $10,000, anyone has a right to sell a registered domain name based on its descriptive meaning.  Such a sale does not establish bad faith but can support a respondent’s legitimate interest – See Audiopoint v. eCorp, D2001-0509 (WIPO June 20, 2001) where it was said that speculation in domain names without any intent to profit from other’s trademarks may itself constitute a bona fide activity under Paragraph 4(c)(i) of the Policy.

 

Although it is acknowledged that the doctrine of laches does not apply under the Policy, cases such as Brewer, supra and Vanguard Trademark Holdings USA LLC v. Nett Corp, FA 1262162 (Nat. Arb. Forum July 26, 2009) show that there is merit in the argument that, if a complainant were confident its allegation of bad faith registration, it would not have delayed so long in bringing the Complaint, especially in the absence of an explanation for the delay.

 

The Response was backed by a declaration by one Julie Marshall, Manager and Financial Controller of the Respondent who made a statement “Proffered under penalty of law for making false statements”.  However the Panel notes that there is no statement of where this declaration was made or what the law of what jurisdiction was being suggested as providing a penalty for making false statements.  While many jurisdictions have such laws, a statement such as Ms. Marshall’s can only have the weight to be accorded to such a statement if the deponent states the jurisdiction in which the declaration was being made.  Otherwise, there is no effective sanction for a false statement.

 

C. Complainant’s Additional Submissions

The Complainant’s mark has acquired a secondary meaning pursuant to s 2(f) of the U.S. Trademark Act.  The USPTO found the mark to be distinctive when used in connection with the Complainant’s goods and commerce.  It has acquired special significance in that the products are produced by the Complainant, a leader in the production of freeze-dried food. 

 

The Complainant is a producer of high quality freeze-dried foods, including the widely recognized “Mountain House” brand of meal packages.  A declaration was attached from a Mr. J.S. Merryman, Senior Vice President of the Complainant.  It was based on his personal knowledge, he having been employed by the Complainant for 36 years. 

 

In the early 1970s, the Complainant was producing and selling the “Mountain House” brand of freeze-dried foods.  In 1977, it established the “Easy Meal” line of products originally designed to provide meals for senior citizens.  The Easy Meal line of products has been strongly identified as a product of the Complainant’s.  It is sold to wholesalers through direct sales channels and product catalogues.  In 2009, the Complainant began preparations for selling the “Easy Meal” product line to consumers through large national and international bulk retailers.  New distribution channel logos and marketing materials were developed. 

 

In connection with developing the new marketing and advertising materials, the Complainant sought to create its first website for a sole product to assist renewed marketing efforts.  It was not until November 2009, that the Complainant became aware of the Respondent’s registration of the disputed domain name.  It promptly attempted to ascertain the owner in order to acquire the domain name.  It was not able to ascertain the true owner and attempted to negotiate the purchase of the disputed domain name through an identity shield. 

 

The declaration was offered by Mr. Merryman under penalty of law for making false statements.  Although one can assume that it had been made in the State of Oregon, there is no reference to the place where the declaration was made and so the same criticisms apply as to the Respondent’s declaration.  The Complainant is the owner of the EASY MEAL mark.  There are only two other trademark registrations in which the words “MEAL” and “EASY” both appear.

 

The Respondent’s use of the disputed domain name does not qualify it under Paragraph 4(c)(i) of the Policy.  There is not a bona fide offering of goods and services since the Respondent’s sole activity is to post advertising links relating to cooking recipes and meal planning. 

 

With regard to the cases where Panels have found that the parking of domain names and offering and collecting PPC advertising revenue can be a bona fide activity, each case must be viewed on its merits.  The operation of a PPC website of a confusingly similar domain name was not a bona fide offering of goods and services in ConsumerInfo.com, Inc. v. Netcorp c/o Netcorp, FA 1283469 (Nat. Arb. Forum Nov. 11, 2009). 

 

The Complainant exhibited a copy of the Respondent’s website wherein copies of each link to which the main page presently directs show links (inter alia) to competitors of the Complainant, selling packaged meals, as well as other links to party buses or Facebook pages.

 

According to paragraph 2 of the Policy, it is the Respondent’s responsibility to determine whether its domain name registration impinges on or violates someone else’s rights.  A sophisticated company in the business of buying and selling domain names should have known and been able to ascertain that the Complainant held a trademark – See mVisible Techs., Inc. v. Navigable Catalyst Sys., Inc., D2007-1141 (WIPO Nov. 30, 2007) where it was said:

 

“A sophisticated domainer who regularly registers domain names for usage as PPC landing pages cannot be willfully blind to whether a particular domain name may violate trademark rights.”

 

Those who register domain names, and particularly those who register domain names in large numbers, may not simply turn a blind eye to the possibility that the names they are registering will infringe or violate the rights of trademark owners.  That responsibility derives from Paragraph 2 of the Policy – See Grundfos A/S v. Tex. Int’l Prop. Assocs., D2007-1448 (WIPO Dec. 14, 2007). 

 

By directing traffic to sites of competitors or confusing customers of the Complainant, the Respondent creates confusion with the intent of driving up the price of the disputed domain name.  The Respondent’s registration and use of the disputed domain name is in bad faith.

 

As to timing, the Complainant traditionally sold products under the mark to wholesalers.  Therefore, it did not have a website for the Easy Meal product line until it recently began preparations for retail sales to consumers through large bulk retailers.  When the Complainant created new packaging and displays, it sought to create its first website for the products and to acquire the disputed domain name.

 

D.                Respondent’s Additional Submission

The Complainant does not have a monopoly on the descriptive term “Easy Meal”.  There are other third parties that use the description in advertising. 

 

It is well established that the use of a domain name to display links related to the descriptive meaning of the term incorporated in the domain constitutes a bona fide offering of goods and services establishing the Respondent’s legitimate interest.  Therefore, it is no surprise that some of the linked advertisements feature other entities in the prepared food industry.  That is why advertisements for competitors of the Complainant appear in the links on the website. 

 

Even if the Respondent had conducted a trademark search before registering the disputed domain name, a search would not have prohibited the Respondent from registering a descriptive term in a domain name.  A trademark is not a monopoly on a term contained in a trademark and ownership of the trademark does not entitle the registrant to a matching domain name.

 

In Playboy Enters. Int’l Inc. v. Carvalho, D2008-1944 (WIPO Feb. 24, 2009), it was said the fact that the complainant had numerous trademarks for the word “Playboy” did not mean that it had a monopoly over any and all uses of the term.  The Complainant does not have a monopoly on the term “Easy Meal”.  The failure to conduct a trademark search does not support a finding of bad faith registration.

 

FINDINGS

The disputed domain name is identical to the trademark in which the Complainant has rights.

 

The Respondent has no rights or legitimate interest in respect of the disputed domain name.

 

The disputed domain name has been registered and used in bad faith.

 

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

 

The Respondent does not challenge that the disputed domain name is identical to the Complainant’s trademark.  Accordingly, Paragraph 4(a)(1) of the Policy has been established.

 

Rights or Legitimate Interests

 

It is trite jurisprudence under the Policy that, once a Complainant establishes that it gave no rights nor interests to the Respondent, the burden shifts to the Respondent to show, on the balance of probabilities, that it comes within one or other of the exceptions in Paragraph 4(c) of the Policy.  Here, the Complainant gave no rights or interests to the Respondent.

 

On the facts of this case, the only relevant exception is Paragraph 4(c)(i) which requires the Respondent to prove that, before any notice to the Respondent of the dispute, the Respondent used or made demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services. 

 

There is nothing in the evidence to suggest that the Respondent’s use of the disputed domain name occurred only after notice of the dispute.  The question then is whether its prior use has been in connection with a bona fide offering of goods or services.

 

Many panels have held that a respondent can have rights or legitimate interests in domain names that are composed of common descriptive or generic words even if those names correspond to a valid trademark.

 

For example, the Le Hara case, supra and the cases therein referenced.

 

Moreover, according to the circumstances, a PPC revenue from the use of domain names is a legitimate model under the Policy.  As was said in Weathershield Mfg., Inc. v. Phan, D2007-1247 (WIPO Oct. 10, 2007):

 

The Respondent has also made commercial use of the domain name for extended periods in the form of third party marketing, pay-per-click advertising and listing the domain name for resale.  These might according to the circumstances represent use in connection with a bona fide offering of goods and services, particularly with a domain name of a dictionary word and if there is not persuasive evidence that the Respondent was more likely than not aware of the Complainant’s marks.

 

It is proper to note that the Respondent’s modus operandi has been held on at least one occasion not to fall foul of the Policy.  For example, in Jet Marques v. Vertical Axis, Inc., D2006-0250 (WIPO May 26, 2006) the Panel stated:

 

In the English language a domain name is a generic or descriptive expression.  The Respondent says that it is in the business of acquiring such names that have either expired or been deleted and the Panel has no reason to disbelieve that statement.  Indeed, the earlier decisions under the Policy in which the Respondent has been a party appear to confirm that description of the business.

 

The complaint failed in the Le Hara case, supra because the Complainant provided no evidence of reputation for or common law rights in the trademark and there was nothing to give rise to a rebuttable inference that the Respondent had been aware of the Complainant’s trademark at the date of registration of the disputed domain name.  The Complainant there relied purely on constructive knowledge of its trademark rights because of a federal registration.  The Panel rejected that argument because registration of the complainant’s trademark had been merely pending at the time the disputed domain name was registered.

 

Cases where a Respondent has been imputed with knowledge of the complainant’s federally registered mark have often been confined to instances where both parties were located in the United States. 

 

Here it is not clear where the Respondent is located.  It operates under a privacy shield in Barbados, yet its contact point is a U.S.-based attorney.  Other UDRP cases in which it has been involved indicate that it is based in Korea.  However, wherever it is based, it is clear from its track record that it is a sophisticated player in the domain name arena.  A respondent’s location may be insufficient in an internet context to shield it from a finding of bad faith – see Geopack v. Name Administration, Inc. (BVI), D2006-1590 (WIPO March 15, 2007).

 

A decision under the second limb of the Policy really melds into an investigation into the third limb where the prime enquiry must be whether the registration of the disputed domain had been in bad faith.  In both fields of enquiry, the focus must be on whether there is persuasive evidence that the Respondent was more likely than not to have been aware of the Complainant’s trademark at the time of registration of the disputed domain name.  The ‘wilful blindness’ concept at the time of registration also falls for consideration.

 

Registration and Use in Bad Faith

 

The Complainant has produced evidence that it has a considerable reputation in the preparation of easy meals.  It has been operating extensively under the mark EASY MEALS since 1977, long before registration of its trademark.  This marketing was done mainly through wholesalers with a change in emphasis to retail only occurring in 2009.

The Complainant’s mark has been long-established and it has built up a considerable reputation in the marketplace, so that, unlike in the Le Hara case where there was no evidence of common law rights based on reputation, there is a rebuttable inference that the Respondent should have been aware of the Complainant’s trademark at the time it registered the disputed domain name.

 

A number of Panels have concluded that a Respondent has the right to register and use a domain name to attract Internet traffic based on the use of a commonly-used descriptive phrase, even where the domain name is confusingly similar to a trademark.  Where a Respondent registers a domain name consisting of “dictionary words”, because the Respondent has a good faith belief that the domain name’s value derives from its generic or descriptive qualities, the use of the domain name consistent with such good faith may establish a legitimate interest. 

 

But the domain name must have been registered because of any use consistent with, the attraction as a dictionary word or descriptive term and not because of its attraction as a trademark – See HSBC Fin. Corp. v. Clear Blue Sky, Inc. & Domain Manager, D2007-0062 (WIPO April 6, 2007) and the cases there gathered.  See also Media Gen. Comm’ns, Inc. v. Rarenames, D2006-0964 (WIPO Sept. 23, 2006) where the Respondent, a domain name reseller, did not indicate what steps it has taken in good faith to avoid registering domains which correspond with trademarks.

 

So it follows that, if the Respondent had registered the disputed domain name purely because of its attraction as a generic or dictionary expression and did so in good faith and not because of its attraction as a mark, it will succeed.  The Respondent will in that situation have proved that its offering of goods and services is legitimate under Para. 4(c)(i) of the Policy and the Complainant will have failed to have proved that the registration was made in bad faith.

 

There are many cases under the Policy where a respondent registering a domain name in Country A, is not deemed to be aware of a trademark registered in Country B.  That proposition is somewhat simplistic when applied to a sophisticated domain name operator which makes its living out of acquiring expired domain names as and when they become available.

 

The discussion under this heading calls for consideration of the question whether the Respondent should have conducted a search of the USPTO Register before acquiring the disputed domain name.

 

In mVisible Techs., Inc. v. Navigation Catalyst Sys., Inc., D2007-1141 (WIPO Nov. 20, 2007), a distinguished Panel underscored, as have other Panels, the notion that a sophisticated domainer cannot be “wilfully blind” to whether a particular domain name may violate trademark rights.  The Panel commented that the USPTO website is free and easily searchable for trademark registrations and applications.  That Panel also stated that an assertion that a Respondent was not familiar with the Complainant’s trademark is not enough to avoid a finding of bad faith registration.

 

Similar statements were made in Starwood Hotels & Resorts Worldwide, Inc., Sheraton LLC & Sheraton Int’l v. Porter, D2007-1254 (WIPO Oct. 23, 2007) and Grundfos A/S v Tex. Int’l Prop. Assocs., supra.

 

Whilst there is no general rule that a domain name registrant ought to search the trademark registers of the world before registering its domain name, it is hard to see why a sophisticated operator such as this Respondent would not have checked the readily-available United States trademark register.  The Respondent has obvious and close links with the United States and is in the business of looking for opportunities generated by domain names becoming available for registration.

 

The Respondent cannot say it does not bear responsibility for the sponsored links appearing on its website.  It cannot disclaim responsibility for those links which concern the field of commercial activity in which the Complainant is a major player – See the Grundfos case, supra where, at page 20, several authorities to that effect were quoted with approval. 

 

It follows from this line of authority that the Respondent cannot distance itself from the invitation on the website to interested persons to purchase the disputed domain name.  In the Panel’s view, this notice inclines the balance to holding that the registration was in bad faith because it rather indicates that a major (but not necessarily the only) purpose in registering the disputed domain name was to make it available for sale.  The profitability of PPC links engendered by a well-known name must, over time, increase the saleability, and therefore, the price, of the disputed domain name.  It is no excuse to say that the offer to sell is standard on a particular PPC website.

 

In the Panel’s view, it is this factor of willingness to sell the domain name which distinguishes the present case from those where the Respondent’s activities have been held to be legitimate where it has used a domain name using expressions found in a registered trademark, where the domain was acquired because it had expired and where a legitimate business of PPC advertising was being conducted. 

 

Accordingly, in the Panel’s view, the inference from the evidence is that there was bad faith registration and, accordingly, the Complainant has succeeded in proving the third limb of the Policy and also in showing that the Respondent did not come within Para. 4(c)(i) of the Policy.  Bad faith use is shown by the links to competitors of the Complainant on the website.

 

DECISION

 

A majority of the Panel, having established all three elements required under the ICANN Policy, concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <easymeal.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Hon. Sir Ian Barker, Presiding Panelist

G. Gervaise Davis III, Esq., Panelist

Dated: June 10, 2010

 

 

DISSENT

 

The majority finds bad faith because of the offer to sell the domain, but of course, that is what domain resellers do.  I find that to be a legitimate business (as it is for all of the ICANN-approved registrars) unless there is a clear intent to target a particular mark owner.

 

Here, the Respondent’s business is limited to selling names which have common meaning and can be used in their descriptive sense without infringing a mark.  He is not a cybersquatter who seeks particular trademarks to target.  However, common words also appear in trademarks, so invariably some of Respondent’s domains will be confusingly similar and even identical to someone’s trademark, and in fact may appear in multiple trademarks since common words are commonly used in marks.  To argue that a registrant who chooses descriptive terms and then must be held accountable because it later discovers them to be trademarked by some relatively obscure mark owner is completely the opposite of the UDRP principle.  The UDRP is intended to prevent the intentional targeting of mark owners for commercial advantage and not registrations made solely for fair use purposes whether or not they correspond to a mark. 

 

It is a domain’s descriptive use which both makes it valuable for resale and which also establishes the Reseller’s right and legitimate interest.  Respondent never sought out the Complainant to effect a sale; it simply offered the domain for sale to anyone.  The majority expects Respondents to search the trademark databases of the world before registering a mark.  This seems illogical.  If the Respondent were truly targeting a mark, it would have knowledge of the mark without such a search.  And even if such a search turned up multiple identical or confusingly similar marks (as a USPTO search of this term does), Respondent still has no intent to use the mark other than in a descriptive sense which remains a fair and legitimate use regardless of the number of marks involved.  It is my opinion that the mark owner who chose to adopt a descriptive term (and even had to wait 5 years to develop distinctiveness as is the case here) must accept the consequence of their choice.  The consequence is that the world remains free to use the descriptive term in a descriptive fashion.

 

The Complainant sold its goods primarily to wholesalers until quite recently, so there was little evidence of any consumer recognition at the time the domain was registered. In fact, the domain had been registered for nearly 4 years before the complaint was filed, a filing which corresponds to Complainant’s recent decision to change its marketing strategy and sell directly to the public.  Because the mark had little consumer recognition at the time of registration, I do not believe that there was a valuable flow of mark-related traffic that Respondent was attempting to attract.

 

Nor is there evidence that this mark owner was specifically targeted for abuse.  The .com domain in no longer the only available domain, so Complainant could easily have chosen many other top level domains for its registration rather than purchasing the Respondent’s registration.  It need not have paid Respondent’s price as Respondent surely knows.

Overall I see none of the hallmarks of cybersquatting.  I find for the Respondent.

 

 

 

Diane Cabell, Esq., Panelist