national arbitration forum

 

DECISION

 

L.L. Bean, Inc. v. Birgit Klostermann

Claim Number:  FA0501000410328

 

PARTIES

Complainant is L.L. Bean, Inc. (“Complainant”), represented by Kevin R. Haley of Brann and Isaacson, 184 Main Street, PO Box 3070, Lewiston, ME 04243-3070.  Respondent is Birgit Klostermann (“Respondent”), P.O. Box No. 71826, KCPO, Central, 00000, Hong Kong.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <llbeam.com>, registered with Enom, Inc.

 

PANEL

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

 

Honorable Paul A. Dorf (Ret.) as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on January 27, 2005; the National Arbitration Forum received a hard copy of the Complaint on January 31, 2005.

 

On January 28, 2005, Enom, Inc. confirmed by e-mail to the National Arbitration Forum that the domain name <llbeam.com> is registered with Enom, Inc. and that Respondent is the current registrant of the name. Enom, Inc. has verified that Respondent is bound by the Enom, 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 January 31, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of February 21, 2005 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@llbeam.com by e-mail.

 

Having received no Response from Respondent, using the same contact details and methods as were used for the Commencement Notification, the National Arbitration Forum transmitted to the parties a Notification of Respondent Default.

 

On March 2, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Honorable Paul A. Dorf (Ret.) 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 name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A.  Complainant makes the following assertions:

 

1.      Respondent’s <llbeam.com> domain name is confusingly similar to Complainant’s L.L. BEAN and LLBEAN.COM marks.

 

2.      Respondent does not have any rights or legitimate interests in the <llbeam.com> domain name.

 

3.      Respondent registered and used the <llbeam.com> domain name in bad faith.

 

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

 

FINDINGS

Complainant, L.L. Bean, Inc., is a Maine corporation with its headquarters in Freeport, ME.  Complainant markets and sells premium quality sporting goods and outdoor products, apparel, general merchandise and a wide variety of goods via retail outlets, catalogs and its Internet site at the <llbean.com> domain name.

 

Complainant holds trademark registrations with the United States Patent and Trademark Office for the L.L. BEAN (Reg. No. 1,482,799 issued March 29, 1988) and LLBEAN.COM (Reg. No. 2,601,262 issued July 30, 2002) marks.  Complainant has used its LLBEAN.COM mark in commerce since 1996 for mail order services and computerized online retail services and its L.L. BEAN mark since 1912 in association with its retail store and mail order services. 

 

Respondent registered the <llbeam.com> domain name on July 29, 2003.  Respondent is using the disputed domain name to divert Internet users to a website that offers a generic search engine and displays links to various websites, including websites that compete with Complainant.  The website also displays a link for Complainant’s official website. 

 

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.

 

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

 

Complainant has asserted in this proceeding that it has rights in the L.L. BEAN and LLBEAN.COM marks through registration with the United States Patent and Trademark Office.  The Panel finds that registration of Complainant’s marks is prima facie evidence that Complainant has rights in those marks pursuant to Policy ¶ 4(a)(i).  See Men’s Wearhouse, Inc. v. Wick, FA 117861 (Nat. Arb. Forum Sept. 16, 2002) (“Under U.S. trademark law, registered marks hold a presumption that they are inherently distinctive and have acquired secondary meaning.”); see also Janus Int’l Holding Co. v. Rademacher, D2002-0201 (WIPO Mar. 5, 2002) (finding that Panel decisions have held that registration of a mark is prima facie evidence of validity, which creates a rebuttable presumption that the mark is inherently distinctive.  Respondent has the burden of refuting this assumption).

 

The <llbeam.com> domain name registered by Respondent is confusingly similar to Complainant’s L.L. BEAN and LLBEAN.COM marks because the domain name incorporates Complainant’s marks in their entirety, deviating only with the omission of periods and the substitution of the letter “m” for the letter “n” in Complainant’s marks.  Furthermore, the addition of the generic top-level domain “.com” to Complainant’s registered L.L. BEAN mark is irrelevant in determining confusing similarity and does not distinguish the domain name.  See Toronto-Dominion Bank v. Karpachev, D2000-1571 (WIPO Jan. 15, 2001) (finding that the domain names <tdwatergouse.com> and <dwaterhouse.com> are virtually identical to Complainant’s TD WATERHOUSE name and mark); see also Reuters Ltd. v. Global Net 2000, Inc., D2000-0441 (WIPO July 13, 2000) (finding that a domain name which differs by only one letter from a trademark has a greater tendency to be confusingly similar to the trademark where the trademark is highly distinctive); see also Mrs. World Pageants, Inc. v. Crown Promotions, FA 94321 (Nat. Arb. Forum Apr. 24, 2000) (finding that punctuation is not significant in determining the similarity of a domain name and mark); see also Busy Body, Inc. v. Fitness Outlet Inc., D2000-0127 (WIPO Apr. 22, 2000) (finding that "the addition of the generic top-level domain (gTLD) name ‘.com’ is . . . without legal significance since use of a gTLD is required of domain name registrants").

 

Accordingly, the Panel finds that Policy ¶ 4(a)(i) has been satisfied.

 

Rights or Legitimate Interests

 

Complainant alleges that Respondent has no rights or legitimate interests in the <llbeam.com> domain name, containing Complainant’s L.L. BEAN and LLBEAN.COM marks in their entirety.  Once Complainant makes a prima facie case in support of its allegations, the burden shifts to Respondent to show that it does have rights to or legitimate interests in the domain name.  Thus, due to Respondent’s failure to respond to the Complaint, the Panel assumes that Respondent lacks rights and legitimate interests in the disputed domain name.  See G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002) (holding that where Complainant has asserted that Respondent has no rights or legitimate interests with respect to the domain name it is incumbent on Respondent to come forward with concrete evidence rebutting this assertion because this information is “uniquely within the knowledge and control of the respondent”); see also Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (finding that once Complainant asserts that Respondent has no rights or legitimate interests with respect to the domain, the burden shifts to Respondent to provide credible evidence that substantiates its claim of rights and legitimate interests in the domain name); see also Pavillion Agency, Inc. v. Greenhouse Agency Ltd., D2000-1221 (WIPO Dec. 4, 2000) (finding that Respondents’ failure to respond can be construed as an admission that they have no legitimate interest in the domain names).

 

Furthermore, the Panel finds that Complainant has made the prima facie showing.  Therefore, since Respondent has not responded to the Complaint, the Panel is entitled to accept all reasonable allegations and inferences in the Complaint as true.  See Bayerische Motoren Werke AG v. Bavarian AG, FA 110830 (Nat. Arb. Forum June 17, 2002) (finding that in the absence of a Response the Panel is free to make inferences from the very failure to respond and assign greater weight to certain circumstances than it might otherwise do); see also Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (Nat. Arb. Forum July 31, 2000) (holding that Respondent’s failure to respond allows all reasonable inferences of fact in the allegations of the Complaint to be deemed true).

 

Respondent is using the <llbeam.com> domain name to redirect Internet users to a website that features a generic search engine and links to various goods and services which are unrelated to or in competition with Complainant.  The Panel assumes that Respondent earns pay-per-click fees for linking users to the featured websites.  Respondent’s use of a domain name that is confusingly similar to Complainant’s popular L.L. BEAN and LLBEAN.COM marks to divert Internet users interested in Complainant’s products and services to a commercial website that offers a generic search engine and links to Complainant’s competitors is not in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use of the domain name pursuant to Policy ¶ 4(c)(iii).  See eBay Inc. v. Sunho Hong, D2000-1633 (WIPO Jan. 18, 2001) (stating that the "use of complainant’s entire mark in infringing domain names makes it difficult to infer a legitimate use"); see also Disney Enters., Inc. v. Dot Stop, FA 145227 (Nat. Arb. Forum Mar. 17, 2003) (finding that Respondent’s diversionary use of Complainant’s mark to attract Internet users to its own website, which contained a series of hyperlinks to unrelated websites, was neither a bona fide offering of goods or services nor a legitimate noncommercial or fair use of the disputed domain names); see also Black & Decker Corp. v. Clinical Evaluations, FA 112629 (Nat. Arb. Forum June 24, 2002) (holding that Respondent’s use of the disputed domain name to redirect Internet users to commercial websites, unrelated to Complainant and presumably with the purpose of earning a commission or pay-per-click referral fee did not evidence rights or legitimate interests in the domain name).

 

Complainant asserts that Respondent has no relationship with the <llbeam.com> domain name and that Complainant has not authorized Respondent to use Complainant’s well-known L.L. BEAN and LLBEAN.COM marks.  Complainant insists that it has had no connection with Respondent.  Since Respondent has failed to provide any evidence establishing that it is commonly known by the disputed domain name, the Panel finds that Respondent lacks rights and legitimate interests in the disputed domain name pursuant to Policy ¶ 4(c)(ii).  See Gallup Inc. v. Amish Country Store, FA 96209 (Nat. Arb. Forum Jan. 23, 2001) (finding that Respondent does not have rights in a domain name when Respondent is not known by the mark); see also Compagnie de Saint Gobain v. Com-Union Corp., D2000-0020 (WIPO Mar. 14, 2000) (finding no rights or legitimate interest where Respondent was not commonly known by the mark and never applied for a license or permission from Complainant to use the trademarked name).

 

Thus, the Panel finds that Policy ¶ 4(a)(ii) has been satisfied.

 

Registration and Use in Bad Faith

 

Respondent is using the <llbeam.com> domain name to intentionally attempt to attract Internet users interested in reaching Complainant’s <llbean.com> website who inadvertently type in the letter “m” instead of the letter “n.”  Additionally, Respondent presumably reaps commercial benefit from these diversions through referral fees from links to other commercial websites, some of which are in competition with Complainant.  Therefore, the Panel determines that Respondent’s attempts to divert Internet users for commercial gain by attracting Internet users to Respondent’s website through a likelihood of confusion with Complainant’s mark is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iv).  See G.D. Searle & Co. v. Celebrex Drugstore, FA 123933 (Nat. Arb. Forum Nov. 21, 2002) (finding that Respondent registered and used the domain name in bad faith pursuant to Policy ¶ 4(b)(iv) because Respondent was using the confusingly similar domain name to attract Internet users to its commercial website); see also Kmart v. Khan, FA 127708 (Nat. Arb. Forum Nov. 22, 2002) (finding that if Respondent profits from its diversionary use of Complainant's mark when the domain name resolves to commercial websites and Respondent fails to contest the Complaint, it may be concluded that Respondent is using the domain name in bad faith pursuant to Policy ¶ 4(b)(iv)); see also Drs. Foster & Smith, Inc. v. Lalli, FA 95284 (Nat. Arb. Forum Aug. 21, 2000) (finding bad faith where Respondent directed Internet users seeking Complainant’s site to its own website for commercial gain).

 

Complainant uses its L.L. BEAN and LLBEAN.COM marks to market and sell a wide variety of goods and services, including apparel, outerwear, footwear, sporting goods, house wares, home furnishings, gifts.  Respondent is using the <llbeam.com> domain name to link to websites that offer competing products.  Thus, the Panel finds that Respondent’s use of a domain name confusingly similar to Complainant’s registered marks to offer, inter alia, products and services in direct competition with Complainant is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).  See S. Exposure v. S. Exposure, Inc., FA 94864 (Nat. Arb. Forum July 18, 2000) (finding Respondent acted in bad faith by attracting Internet users to a website that competes with Complainant’s business); see also EthnicGrocer.com, Inc. v. Unlimited Latin Flavors, Inc., FA 94385 (Nat. Arb. Forum July 7, 2000)  (finding that the minor degree of variation from Complainant's marks suggests that Respondent, Complainant’s competitor, registered the names primarily for the purpose of disrupting Complainant's business).

 

Furthermore while each of the four circumstances listed under Policy ¶ 4(b), if proven, evidences bad faith use and registration of a domain name, this list is not intended to be exhaustive.  The Panel has chosen to consider additional factors which support its finding of bad faith registration and use.  See Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (“the examples [of bad faith] in Paragraph 4(b) are intended to be illustrative, rather than exclusive”); see also Twentieth Century Fox Film Corp. v. Risser, FA 93761 (Nat. Arb. Forum May 18, 2000) (finding that in determining if a domain name has been registered in bad faith, the Panel must look at the “totality of circumstances”).

 

Respondent is engaging in the practice of “typosquatting” by taking advantage of a common typographical error made by Internauts intending to reach Complainant’s website at the <llbean.com> domain name who mistakenly type the letter “m” instead of the letter “n.”  The Panel determines that Respondent’s use of typosquatting to attract Internet users to its website is evidence of bad fait registration and use pursuant to Policy ¶ 4(a)(iii).  See Nat’l Ass’n of Prof’l Baseball Leagues v. Zuccarini, D2002-1011 (WIPO Jan. 21, 2003) (“Typosquatting is the intentional misspelling of words with intent to intercept and siphon off traffic from its intended destination, by preying on Internauts who make common typing errors.  Typosquatting is inherently parasitic and of itself evidence of bad faith”); see also Zone Labs, Inc. v. Zuccarini, FA 190613 (Nat. Arb. Forum Oct. 15, 2003) (finding that Respondent registered and used the <zonelarm.com> domain name in bad faith pursuant to Policy ¶ 4(a)(iii) because the name was merely a typosquatted version of Complainant’s ZONEALARM mark); see also Dermalogica, Inc. v. Domains to Develop, FA 175201 (Nat. Arb. Forum Sept. 22, 2003) (finding that the <dermatalogica.com> domain name was a typosquatted version of complainant’s DERMALOGICA mark and stating that “[t]yposquatting itself is evidence of bad faith registration and use pursuant to Policy ¶ 4(a)(iii)”).

 

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

 

 

Honorable Paul A. Dorf (Ret.), Panelist

Dated:  March 15, 2005

 

 

 

 

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