National Arbitration Forum

 

DECISION

 

BBY Solutions, Inc. v. Thena Botanicals

Claim Number: FA1007001333656

 

PARTIES

Complainant is BBY Solutions, Inc. (“Complainant”), represented by Christopher J. Schulte, of Merchant & Gould, P.C., Minnesota, USA.  Respondent is Thena Botanicals (“Respondent”), represented by Julie Martin, Colorado, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <geeksquadgirl.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.

 

Honorable Karl V. Fink (Ret.) as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on July 2, 2010.

 

On July 6, 2010, GoDaddy.com, Inc. confirmed by e-mail to the National Arbitration Forum that the <geeksquadgirl.com> domain name is registered with GoDaddy.com, Inc. and that the Respondent is the current registrant of the name.  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 July 14, 2010, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 3, 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@geeksquadgirl.com.  Also on July 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 complete on July 15, 2010.

Complainant submitted an Additional Submission that was received and determined to be compliant with Supplemental Rule 7 on July 20, 2010.

 

Respondent submitted an Additional Submission that was received and determined to be compliant with Supplemental Rule 7 on July 21, 2010.

 

On July 26, 2010, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Honorable Karl V. Fink (Ret.) as Panelist.

 

RELIEF SOUGHT

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

 

PARTIES’ CONTENTIONS

A. Complainant

Complainant owns United States trademark registrations for the various marks which use the term “Geek Squad”.

 

Complainant markets and provides computer and electronics-related products and services under its GEEK SQUAD marks, including wireless networking, computer set-up, technology consultation services, and cables and flash drives.  Since at least as early as 1994, Complainant and its predecessors-in-interest have used the GEEK SQUAD trademark in connection with their products and services.  Complainant’s predecessor-in-interest registered the geeksquad.com domain name on August 18, 1995, and Complainant has continually used the domain in connection with its GEEK SQUAD-branded products and service.  The GEEK SQUAD marks have acquired substantial goodwill and are extremely valuable commercial assets.

 

Respondent registered the domain name geeksquadgirl.com on February 8, 2007.

 

Respondent has no statutory or common law trademark rights or any other right or legitimate interest to the mark GEEK SQUAD or in the infringing domain name <geeksquadgirl.com>.  Respondent uses <geeksquadgirl.com> solely as a domain name.

 

The evidence shows the domain name was registered primarily for the purpose of commercial gain by diverting customers from Complainant’s website  at the <geeksquad.com> domain name and directing such customers to links for what appear to be Respondent’s domain name, website development, and e-marketing services.

 

Menus on the website resolving from the <geeksquadgirl.com> domain name display links to the types of services that consumers would expect to find on Complainant’s <geeksquad.com> website.

 

Respondent’s bad faith registration and use of the domain name is evidenced by Respondent’s requirement that Complainant pay $170,000 for the transfer of the <geeksquadgirl.com> domain name.

 

The domain name <geeksquadgirl.com> is confusingly similar to the GEEK SQUAD marks.  Respondent’s addition of the generic suffix GIRL does not distinguish the <geeksquadgirl.com> domain name from the GEEK SQUAD marks.

 

Respondent does not have any right or legitimate interest in the domain name <geeksquadgirl.com>.  Respondent is not making a legitimate, non-commercial or fair use of the domain name in that its purpose in registering and using the domain name is to divert Complainant’s <geeksquad.com> web traffic to a website containing products and services that are closely related to the types of products and services marketed and provided by Complainant’s GEEK SQUAD marks.

 

The domain name has been registered and used in bad faith.  Bad faith intent can be inferred from Respondent’s choosing to use a designation that it knows to be similar to another’s registered trademark.

 

In a telephone conversation with Complainant, Respondent admitted to having knowledge of the existence of Complainant’s use of the GEEK SQUAD marks, and at least some of the products and services provided by Complainant under its GEEK SQUAD marks.

 

Respondent had constructive knowledge of Complainant’s ownership of the GEEK SQUAD marks before it registered the <geeksquadgirl.com> domain name based on the federal registrations for those marks.

 

B. Respondent

Julie Martin d/b/a Thena Botanicals (“Respondent”) registered the domain name <geeksquadgirl.com> on February 8, 2007 after the name had been suggested by a friend.  On December 17, 2007, Julie Martin filed the Articles for Organization for Geek Squad Girl in the State of Colorado.  The business operates in different channels of commerce than the classifications in which the GEEK SQUAD marks are registered.

 

The <geeksquadgirl.com> domain name, Geek Squad Girl, and all iterations of the website have never been in the computer repair and installation business and have neither advertised as such nor solicited advertising from companies who repair and or install computer systems, home entertaining systems, etc.

 

The key phrase “geek squad” has never been utilized by geeksquadgirl.com for either pay per click campaigns or organic search results.

 

There is no evidence that the <geeksquadgirl.com> domain name has “diverted and directed” traffic from the <geeksquad.com> website to the <geeksquadgirl.com> website in order to sell products and services.

 

The products and services currently offered on the <geeksquadgirl.com> website are products related to do-it-yourself websites and products associated with maintaining a website.  Complainant had never been in the business of do-it-yourself websites.

 

There has never been an automatic re-direction connected to the <geeksquadgirl.com> website.

 

Respondent never solicited Complainant at any time.  Complainant demanded the URL be transferred to it and Respondent asked to be compensated.  Complainant asked for a bid, and Respondent sent an amount based on expenses related to the cost of building, maintaining, and optimizing the website for the time it has been on the Web.

 

The domain name <geeksquadgirl.com> is not confusingly similar to the GEEK SQUAD marks.  The addition of girl helps to distinguish the <GeekSquadGirl.com> website as different from the commerce in which Geek Squad is involved.

 

The GEEK SQUAD mark has no acquired secondary meaning in the minds of consumers nationally or globally as of this date such as Kleenex™ or Google™.

 

The <geeksquadgirl.com> website has always clearly stated that it has no affiliation with Geek Squad.

 

Respondent has a legitimate interest in the use of <geeksquadgirl.com>.  The <geeksquadgirl.com> domain name has been on the first page of Google for the search term “website content development” for over a year.  It is reasonable to assume the <geeksquadgirl.com> domain name is associated with the website content development industry and not the computer repair and installation industry.

 

<Geeksquadgirl.com> has been live on the Internet continuously for the past three and a half years, and has always offered products and services related to website development, starting websites, and organic search engine optimization.

 

The <geeksquadgirl.com> domain name is set up to only target products and services of website content development, starting websites, and organic search engine optimization.

 

Respondent has taken great care to avoid confusion in the marketplace.  The only way to find the website utilizing “geek” and “squad” is to utilize the search term, “geeksquadgirl”.  If consumer knows to use the term “geeksquadgirl” as a search term, then the consumer has not been tricked and has also not been confused.

 

The products and services that have been offered and are now offered via the <geeksquadgirl.com> domain name, are not similar to the products and services offered by <Geeksquad.com>.

 

C. Additional Submissions

Complainant

Respondent fails to rebut the central facts of this case which are that the GEEK SQUAD mark is both inherently distinctive as a trademark, the mark was known to Respondent prior to her choosing her domain name <geeksquadgirl.com>, and she offered to sell the domain name for $170,000.

 

Adding the “GIRL” term does not make the domain name distinguishable from the inherently distinctive and well-known GEEK SQUAD mark. 

 

Respondent asserts as a factual matter that she chose the “girl” term precisely for the reason to market to women who seek online content development services.  By Respondent’s own admission the “girl” term is generic, lacks any weight in the confusion analysis and, thus, does not render the <geeksquadgirl.com> domain name distinguishable from Complainant’s marks.

 

The USPTO has repeatedly determined that the GEEK SQUAD mark is, in fact, inherently distinctive by repeatedly registering the mark on the Principal Register without proof of secondary meaning.

 

Computer repair and website content development are related so as to suggest an affiliation with Complainant.  Both the trademark law and the UDRP recognize that bad faith can be established by use of a mark in a domain name for goods or services that would attract consumers under the wrong impression that the Respondent is acting under some sort of sponsorship affiliation or endorsement of Complainant.

 

Consumers expect to find relation between computer repair and content development services as evidenced in the USPTO records and examples online.

 

Respondent does not dispute the factual core of this case – that she knew of Complainant’s mark and chose to use it anyway as the core element of her virtually identical domain name for related services, and that when confronted about her actions, asked for the astonishing amount of $170,000.

 

Respondent

Respondent never stated that the name was chosen to market to women who seek online content development.

 

Respondent has never attracted consumers by giving a false impression or a hint of affiliation with Complainant.

 

Complainant’s exhibits offer no proof of what consumers would expect to find but rather are examples of what types of products and services are offered by other companies. 

 

FINDINGS

For the reasons set forth below, the Panel finds that Complainant is entitled to the relief requested.

 

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

 

Complainant asserts that it has rights in the GEEK SQUAD mark by virtue of its United States Patent and Trademark Office (“USPTO”) trademark registrations:

 

Reg. No. 1,943,643     issued Dec. 26, 1995;

Reg. No. 2,023,380     issued Dec. 17, 1996;

Reg. No. 2,744,658     issued July 29, 2003;

Reg. No. 2,834,408     issued Apr. 20, 2004;

Reg. No. 3,065,904     issued Mar. 7, 2006;

Reg. No. 3,457,884     issued July 1, 2008; and

Reg. No. 3,462,060     issued July 8, 2008.

 

The Panel finds that USPTO trademark registrations conclusively prove Complainant’s rights in the GEEK SQUAD mark for the purposes of Policy ¶ 4(a)(i).  See AOL LLC v. Interrante, FA 681239 (Nat. Arb. Forum May 23, 2006) (finding that where the complainant had submitted evidence of its registration with the USPTO, “such evidence establishes complainant’s rights in the mark pursuant to 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).

 

Complainant alleges in its Complaint and Additional Submission that Respondent’s <geeksquadgirl.com> domain name is confusingly similar to Complainant’s GEEK SQUAD mark because the disputed domain name merely eliminates the space between the words of Complainant’s mark and appends that generic term “girl” and the generic top-level domain (“gTLD”) “.com.”  The Panel finds that the inclusion of a generic term in the disputed domain name does not alter Complainant’s mark to prevent a finding of confusing similarity.  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 Warner Bros. Entm’t Inc. v. Rana, FA 304696 (Nat. Arb. Forum Sept. 21, 2004) (finding that the addition of the generic term “collection” to Complainant’s HARRY POTTER mark failed to distinguish the domain name from the mark).  The Panel finds that an omitted space and an added gTLD are not considered under a Policy ¶ 4(a)(i) analysis due to the requirements of domain name formation.  See Am. Int’l Group, Inc. v. Domain Admin. Ltd., FA 1106369 (Nat. Arb. Forum Dec. 31, 2007) (finding that “spaces are impermissible and a generic top-level domain, such as ‘.com,’ ‘.net,’ ‘.biz,’ or ‘.org,’ is required in domain names.  Therefore, the panel finds that the disputed domain name [<americangenerallifeinsurance.com>] is confusingly similar to the complainant’s [AMERICAN GENERAL] mark.”); see also Bond & Co. Jewelers, Inc. v. Tex. Int’l Prop. Assocs., FA 937650 (Nat. Arb. Forum Apr. 30, 2007) (finding that the elimination of spaces between terms and the addition of a gTLD do not establish distinctiveness from the complainant’s mark under Policy             ¶ 4(a)(i).  Thus, the Panel finds that Respondent’s <geeksquadgirl.com> domain name is confusingly similar to Complainant’s GEEK SQUAD mark for the purposes of Policy     ¶ 4(a)(i).

 

While Respondent contends that the <geeksquadgirl.com> domain name is comprised of common and descriptive terms and as such cannot be found to be confusingly similar to Complainant’s mark, the Panel finds that 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.  See 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)); see also David Hall Rare Coins v. Tex. Int’l Prop. Assocs., FA 915206 (Nat. Arb. Forum Apr. 9, 2007) (“Respondent’s argument that each individual word in the mark is unprotectable and therefore the overall mark is unprotectable is at odds with the anti-dissection principle of trademark law.”).

 

Complainant has proven this element.

 

Rights or Legitimate Interests

 

Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii), and then 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.”).

 

Complainant argues that Respondent is not commonly known by the <geeksquadgirl.com> domain name.  Complainant asserts that the WHOIS information for the disputed domain name identifies the registrant as “Thena Botanicals” and lists an administrative and technical contact name of “Julie Martin.”  Complainant further contends that the wording “Geek Squad Girl” does not appear anywhere on Respondent’s website except for in the domain name.  Respondent has no affiliation with Complainant and is not a licensee of Complainant. The Panel finds that the lack of evidence in the record showing any nominal connection between Respondent and the disputed domain name supports a finding that Respondent is not commonly known by the disputed domain name and therefore lacks rights and legitimate interests in the disputed domain name according to Policy ¶ 4(c)(ii).  See Am. Online, Inc. v. World Photo Video & Imaging Corp., FA 109031 (Nat. Arb. Forum May 13, 2002) (finding that the respondent was not commonly known by <aolcamera.com> or <aolcameras.com> because the respondent was doing business as “Sunset Camera” and “World Photo Video & Imaging Corp.”); see also 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). 

 

Complainant contends that the <geeksquadgirl.com> domain name resolves to a webpage featuring numerous links for Respondent’s website development, domain name, and e-marketing services.  Complainant asserts that these offered services are related to Complainant’s services as both Complainant’s and Respondent’s offered services pertain to the computer industry.  Because of the similarity in products and Respondent’s use of Complainant’s GEEK SQUAD mark, Complainant alleges that Respondent uses the disputed domain name to trick customers into buying her products advertised on the resolving webpage by causing them to believe they are buying Complainant’s products.  Complainant argues that Respondent’s appropriation of Complainant’s mark in the disputed domain name to divert consumers to a website not affiliated with Complainant and advertising competing products is therefore not consistent with a bona fide offering of goods or services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use according to Policy ¶ 4(c)(iii).  The Panel agrees with Complainant.  See Bank of Am. Corp. v. Nw. Free Cmty. Access, FA 180704 (Nat. Arb. Forum Sept. 30, 2003) (“Respondent’s demonstrated intent to divert Internet users seeking Complainant’s website to a website of Respondent and for Respondent’s benefit is not a bona fide offering of goods or services under Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).”); see also Summit Group, LLC v. LSO, Ltd., FA 758981 (Nat. Arb. Forum Sept. 14, 2006) (finding that the respondent’s use of the complainant’s LIFESTYLE LOUNGE mark to redirect Internet users to respondent’s own website for commercial gain does not constitute either 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)). 

 

Complainant alleges in its Complaint and Additional Submission that Respondent attempted to sell the <geeksquadgirl.com> to Complainant for $170,000.  Complainant argues that Respondent provided no evidence supporting her assertion that the price was based on Respondent’s incurred expenses in connection with the domain name.  Complainant asserts in its Additional Submission that if the disputed domain name is worth that amount, its value is a result of the goodwill of Complainant that Respondent appropriated.  Such an offer to sell the disputed domain name supports a conclusion by the Panel that Respondent has no rights and legitimate interests in the disputed domain name pursuant to Policy ¶ 4(a)(ii).  See Drown Corp. v. Premier Wine & Spirits, FA 616805 (Nat. Arb. Forum Feb. 13, 2006) (“Moreover, the Panel interprets Respondent’s offer to sell the domain name registration for $100,000 as evidence that Respondent lacks rights and legitimate interests in the disputed domain name pursuant to Policy                  ¶ 4(a)(ii).”); see also Vance Int’l, Inc. v. Abend, FA 970871 (Nat. Arb. Forum June 8, 2007) (“An attempt by a respondent to sell a domain name to a complainant who owns a trademark with which the domain name is confusingly similar for an amount in excess of out-of-pocket costs has been held to demonstrate a lack of legitimate rights or interests.”). 

 

Respondent argues that she has included a disclaimer on the website resolving from the <geeksquadgirl.com> domain name specifically disavowing any connection or affiliation between Geek Squad Girl and Complainant.  The Panel finds, however, that the presence of a disclaimer is not sufficient to mitigate confusion or prove Respondent’s rights and legitimate interests in the disputed domain name.  See AltaVista Co. v. AltaVisa, FA 95480 (Nat. Arb. Forum Oct. 31, 2000) (finding that since a disclaimer does not, and could not, accompany the domain name, then the “domain name attracts the consumer’s initial interest and the consumer is misdirected long before he/she has the opportunity to see the disclaimer”); see also DaimlerChrysler Corp. v. Bargman, D2000-0222 (WIPO May 29, 2000) (finding that addition of a disclaimer, when the domain name consists of the complainant’s well-known trademark, does not counter the expectation of Internet users that the domain name is sponsored by the complainant).

 

Complainant has proven this element.

 

Registration and Use in Bad Faith

 

Complainant asserts in its Complaint and Additional Submission that Respondent offered to sell the <geeksquadgirl.com> domain name to Complainant after being contacted by Complainant before the initiation of this proceeding.  Complainant argues that Respondent’s offered price of $170,000 is well outside a reasonable range and thus is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(i).  In its Additional Submission, Complainant alleges that Respondent provides no evidence supporting Respondent’s argument that the price is consistent with the expenses incurred in connection with the disputed domain name.  The Panel finds that, in line with prior UDRP decisions, Complainant’s allegation is correct. See Kabushiki Kaisha Hitachi Seisakusho (Japan Corp.) v. Fortune Int’l Dev. Ent. Co., D2000-0412 (WIPO July 2, 2000) (finding the respondent’s offer to sell the domain name for $100,000 constitutes bad faith); see also Am. Online, Inc. v. Prijic, FA 112639 (Nat. Arb. Forum June 27, 2002) (“[I]n determining whether Respondent has sought consideration in excess of its out-of-pocket costs, the Policy makes clear that only costs related to the domain name are to be considered, and not those related to the creation or maintenance of the connected website”). 

 

Complainant contends that Respondent’s services advertised and offered at the <geeksquadgirl.com> domain name compete with Complainant’s services because both Respondent and Complainant operate within the computer industry.  In its Additional Submission, Complainant denies Respondent’s argument that the UDRP requires the exact services to be offered by both Complainant and Respondent for competition or confusion to exist.  Complainant argues that Respondent therefore registered the disputed domain name appropriating Complainant’s GEEK SQUAD mark in order to take advantage of Complainant’s mark and goodwill to increase Respondent’s business profits.  The Panel finds that Respondent’s registration of the disputed domain name shows an intent to disrupt Complainant’s business through competition and evidences bad faith registration and use under Policy ¶ 4(b)(iii).  See DatingDirect.com Ltd. v. Aston, FA 593977 (Nat. Arb. Forum Dec. 28, 2005) (“Respondent is appropriating Complainant’s mark to divert Complainant’s customers to Respondent’s competing business.  The Panel finds this diversion is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).”); see also SR Motorsports v. Rotary Performance, FA 95859 (Nat. Arb. Forum Jan. 4, 2001) (finding it "obvious" that the domain names were registered for the primary purpose of disrupting the competitor's business when the parties are part of the same, highly specialized field). 

 

Complainant alleges that Respondent’s <geeksquadgirl.com> domain name was intentionally registered to attract consumers seeking out Complainant’s computer-related services.  Complainant contends that since Respondent operates within the same computer-oriented field as Complainant, Internet users are likely to be confused upon arriving at the disputed domain name’s resolving website and may fail to realize that Respondent is not affiliated with Complainant.  In contrast to Respondent’s argument that Complainant and Respondent operate in different channels of commerce, Complainant asserts in its Additional Submission that exact similarity of services is not required for there to be the likelihood of confusion at the disputed domain name under Policy               ¶ 4(b)(iv).  Because Respondent operates a business via the disputed domain name, Respondent is likely to profit from this attraction and subsequent confusion, which the Panel finds reveals Respondent’s bad faith registration and use for the purposes of Policy ¶ 4(b)(iv).  See Nokia Corp. v. Private, D2000-1271 (WIPO Nov. 3, 2000) (finding bad faith registration and use pursuant to Policy ¶ 4(b)(iv) where the domain name resolved to a website that offered similar products as those sold under the complainant’s famous mark); see also Identigene, Inc. v. Genetest Labs., D2000-1100 (WIPO Nov. 30, 2000) (finding bad faith where the respondent's use of the domain name at issue to resolve to a website where similar services are offered to Internet users is likely to confuse the user into believing that the complainant is the source of or is sponsoring the services offered at the site).

 

Respondent alleges that she has intentionally included a disclaimer on the resolving website at the <geeksquadgirl.com> domain name in order to dispel confusion and prevent Internet users from assuming a connection between Complainant and Respondent.  The Panel finds, however, that a disclaimer on the resolving website does not mitigate a finding of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).  See Continental Airlines, Inc. v. Vartanian, FA 1106528 (Nat. Arb. Forum Dec. 26, 2007) (“Respondent’s use of a disclaimer does note mitigate a finding of bad faith under Policy ¶ 4(a)(iii) “); see also Ciccone v. Parisi, D2000-0847 (WIPO Oct. 12, 2000) (“Respondent’s use of a disclaimer on its website is insufficient to avoid a finding of bad faith.  First, the disclaimer may be ignored or misunderstood by Internet users.  Second, a disclaimer does nothing to dispel initial interest confusion that is inevitable from Respondent’s actions.  Such confusion is a basis for finding a violation of Complainant’s rights.”). 

 

Complainant argues that Respondent had actual and constructive notice of Complainant and its rights in the GEEK SQUAD mark prior to the registration of the <geeksquadgirl.com> domain name.  Complainant asserts that in telephone conversations between Complainant and Respondent prior to the initiation of these proceedings, Respondent admitted to having knowledge of the existence of Complainant’s use of the GEEK SQUAD mark and of at least some of Complainant’s offered products and services.  Although constructive knowledge has not generally been held sufficient to support a finding of bad faith, the Panel finds Respondent had actual knowledge of Complainant’s mark, and the Panel finds Respondent registered and used the disputed domain name in bad faith pursuant to Policy ¶ 4(a)(iii).  See Bluegreen Corp. v. eGo, FA 128793 (Nat. Arb. Forum Dec. 16, 2002) (finding bad faith where the method by which the respondent acquired the disputed domain names indicated that the respondent was well aware that the domain names incorporated marks in which the complainant had rights); see also Yahoo! Inc. v. Butler, FA 744444 (Nat. Arb. Forum Aug. 17, 2006) (finding bad faith where the respondent was “well-aware” of the complainant’s YAHOO! Mark at the time of registration).

 

Complainant has proven this element.

 

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 <geeksquadgirl.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Honorable Karl V. Fink (Ret.), Panelist
Dated: August 8, 2010

 

 

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