national arbitration forum

 

DECISION

 

American International Group, Inc. v. The Life Settlement Company a/k/a Timothy Mattek

Claim Number:  FA0501000411716

 

PARTIES

Complainant is American International Group, Inc. (“Complainant”), represented by Caroline L. Stevens, of Leydig, Voit & Mayer Ltd., Two Prudential Plaza, Suite 4900, Chicago, IL 60601-6780.  Respondent is The Life Settlement Company a/k/a Timothy Mattek (“Respondent”), 11476 Sundance Lane, Boca Raton, FL 33428.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <aiglifeassignments.com>, <aiglifesettlements.com> and <americangenerallifesettlements.com>, registered with Go Daddy Software, 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.

 

Sandra Franklin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on January 28, 2005; the National Arbitration Forum received a hard copy of the Complaint on January 31, 2005.

 

On January 31, 2005, Go Daddy Software, Inc. confirmed by e-mail to the National Arbitration Forum that the domain names <aiglifeassignments.com>, <aiglifesettlements.com> and <americangenerallifesettlements.com> are registered with Go Daddy Software, Inc. and that Respondent is the current registrant of the names. Go Daddy Software, Inc. has verified that Respondent is bound by the Go Daddy Software, 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 February 3, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of February 23, 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@aiglifeassignments.com, postmaster@aiglifesettlements.com and postmaster@americangenerallifesettlements.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 3, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Sandra Franklin as Panelist.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that the National Arbitration Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent."  Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, the National Arbitration Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any Response from Respondent.

 

RELIEF SOUGHT

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

 

PARTIES' CONTENTIONS

A.  Complainant makes the following assertions:

 

1.      Respondent’s <aiglifeassignments.com>, <aiglifesettlements.com> and <americangenerallifesettlements.com> domain names are confusingly similar to Complainant’s AIG and AMERICAN GENERAL marks.

 

2.      Respondent does not have any rights or legitimate interests in the <aiglifeassignments.com>, <aiglifesettlements.com> and <americangenerallifesettlements.com> domain names.

 

3.      Respondent registered and used the <aiglifeassignments.com>, <aiglifesettlements.com> and <americangenerallifesettlements.com> domain names in bad faith.

 

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

 

FINDINGS

Complainant, American International Group, Inc., is the world’s leading international insurance and financial services organization with operations in more than 130 countries and jurisdictions worldwide.

 

Complainant has registered the AIG (Reg. Nos. 1,172,557 issued October 6, 1981; 1,273,845 issued April 10, 1984) and AMERICAN GENERAL (Reg. Nos. 803,239 issued February 1, 1966; 2,864,984 issued July 20, 2004) marks with the United States Patent and Trademark Office (“USPTO”) and in jurisdictions throughout the world.

 

Respondent registered the <americangenerallifesettlements.com> domain name on September 11, 2004, the <aiglifesettlements.com> domain name on September 14, 2004 and the <aiglifeassignments.com> domain name on September 27, 2004.  Respondent’s domain names resolve to an “under construction” website.

 

On December 7, 2004, Complainant sent a letter to Respondent requesting that Respondent transfer the disputed domain names immediately.  On December 30, 2004, Respondent replied to Complainant’s letter with e-mail refusing to transfer the domain names but offering to sell the domain name registrations for $2,750 each.  Respondent later reduced this price to $295 each.

 

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 established rights in the AIG and AMERICAN GENERAL marks through registration of the marks with the USPTO and with trademark authorities worldwide.  See Am. Online, Inc. v. Thomas P. Culver Enters., D2001-0564 (WIPO June 18, 2001) finding that successful trademark registration with the United States Patent and Trademark Office creates a presumption of rights in a mark; 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.

 

Respondent’s <aiglifeassignments.com>, <aiglifesettlements.com> and <americangenerallifesettlements.com> domain names are confusingly similar to Complainant’s AIG and AMERICAN GENERAL marks because the domain names incorporate the marks in their entirety and add the terms “life settlement” or “life assignment,” which have a strong association with Complainant’s insurance and financial services business.  Such an addition is not enough to overcome a finding of confusing similarity between Respondent’s domain names and Complainant’s mark pursuant to Policy ¶ 4(a)(i).  See Arthur Guinness Son & Co. (Dublin) Ltd. v. Healy/BOSTH, D2001-0026 (WIPO Mar. 23, 2001) finding confusing similarity where the domain name in dispute contains the identical mark of Complainant combined with a generic word or term; see also Space Imaging LLC v. Brownell, AF-0298 (eResolution Sept. 22, 2000) finding confusing similarity where Respondent’s domain name combines Complainant’s mark with a generic term that has an obvious relationship to Complainant’s business.

 

Furthermore, the omission of the spaces between the terms of Complainant’s AMERICAN GENERAL mark as well as the addition of the top-level domain “.com” are insufficient to negate a finding of confusing similarity under Policy ¶ 4(a)(i).  See Nev. State Bank v. Modern Ltd. – Cayman Web Dev., FA 204063 (Nat. Arb. Forum Dec. 6, 2003) (“It has been established that the addition of a generic top-level domain is irrelevant when considering whether a domain name is identical or confusingly similar under the Policy.”); see also Isleworth Land Co. v. Lost in Space, SA, FA 117330 (Nat. Arb. Forum Sept. 27, 2002) finding it is a “well established principle that generic top-level domains are irrelevant when conducting a Policy ¶ 4(a)(i) analysis”; see also Hannover Ruckversicherungs-AG v. Ryu, FA 102724 (Nat. Arb. Forum Jan. 7, 2001) finding <hannoverre.com> to be identical to HANNOVER RE, “as spaces are impermissible in domain names and a generic top-level domain such as ‘.com’ or ‘.net’ is required in domain names”.

 

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

 

Rights or Legitimate Interests

 

Respondent has failed to respond to the Complaint.  Therefore, the Panel may accept all reasonable assertions and allegations set forth by Complainant as true and accurate.  See Do the Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (“Failure of a respondent to come forward to [contest complainant’s allegations] is tantamount to admitting the truth of complainant’s assertion in this regard.”); see also 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.

 

Complainant has asserted that Respondent has no rights or legitimate interests in the disputed domain names, and Respondent, in not submitting a response, has failed to rebut this assertion.  Thus, the Panel may interpret Respondent’s failure to respond as evidence that Respondent lacks rights and legitimate interests in the <aiglifeassignments.com>, <aiglifesettlements.com> and <americangenerallifesettlements.com> domain names pursuant to Policy ¶ 4(a)(ii).  See Parfums Christian Dior v. QTR Corp., D2000-0023 (WIPO Mar. 9, 2000) finding that by not submitting a Response, Respondent has failed to invoke any circumstance which could demonstrate any rights or legitimate interests in the domain name; see also Bank of Am. Corp. v. McCall, FA 135012 (Nat. Arb. Forum Dec. 31, 2002) (“Respondent's failure to respond not only results in its failure to meet its burden, but also will be viewed as evidence itself that Respondent lacks rights and legitimate interests in the disputed domain name.”).

 

Additionally, Respondent’s domain names resolve to an “under construction” website.  In such circumstances, it cannot be said that Respondent is making a bona fide offering of goods or services, nor a legitimate noncommercial or fair use of the domain names.  Thus, the Panel finds that Policy ¶¶ 4(c)(i) and (iii) are inapplicable to Respondent. See Vestel Elektronik Sanayi ve Ticaret AS v. Kahveci, D2000-1244 (WIPO Nov. 11, 2000) (“[M]erely registering the domain name is not sufficient to establish rights or legitimate interests for purposes of paragraph 4(a)(ii) of the Policy.”); see also Pharmacia & Upjohn AB v. Romero, D2000-1273 (WIPO Nov. 13, 2000) finding no rights or legitimate interests where Respondent failed to submit a Response to the Complaint and had made no use of the domain name in question; see also Broadcom Corp. v. Wirth, FA 102713 (Nat. Arb. Forum Jan. 11, 2002) (finding that Respondent’s use of the disputed domain name to display an “under construction” page did not constitute a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).

 

Furthermore, nothing in the record indicates that Respondent is commonly known by the disputed domain names or is authorized to register domain names featuring Complainant’s AIG and AMERICAN GENERAL marks.  Thus, the Panel finds that Respondent lacks rights and legitimate interests in the domain names pursuant to Policy ¶ 4(c)(ii).  See Tercent Inc. v. Lee Yi, FA 139720 (Nat. Arb. Forum Feb. 10, 2003) stating “nothing in Respondent’s WHOIS information implies that Respondent is ‘commonly known by’ the disputed domain name” as one factor in determining that Policy ¶ 4(c)(ii) does not apply; see also Compagnie de Saint Gobain v. Com-Union Corp., D2000-0020 (WIPO Mar. 14, 2000) finding no rights or legitimate interests where Respondent was not commonly known by the mark and never applied for a license or permission from Complainant to use the trademarked name.

 

Moreover, the fact that Respondent offered to sell the domain name registrations to Complainant is evidence that Respondent lacks rights and legitimate interests in the disputed domain names pursuant to Policy ¶ 4(a)(ii).  See Am. Nat’l Red Cross v. Domains, FA 143684 (Nat. Arb. Forum Mar. 4, 2003) stating that “Respondent’s lack of rights and legitimate interests in the domain name is further evidenced by Respondent’s attempt to sell its domain name registration to Complainant, the rightful holder of the RED CROSS mark”; see also Am. Int’l Group, Inc. v. Dobson, FA 146568 (Nat. Arb. Forum Apr. 8, 2003) finding evidence that Respondent lacked rights or legitimate interests in the disputed domain name after it sent several correspondences offering to sell its rights in the domain name in exchange for 1,500 shares of Complainant’s stock to Complainant.

 

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

 

Registration and Use in Bad Faith

 

The fact that Respondent offered to sell the domain name registrations to Complainant is evidence that Respondent registered and used the <aiglifeassignments.com>, <aiglifesettlements.com> and <americangenerallifesettlements.com> domain names in bad faith pursuant to Policy ¶ 4(b)(i).  See Nabisco Brands Co. v. Patron Group, D2000-0032 (WIPO Feb. 23, 2000) finding that Respondent registered and used the domain names to profit where Respondent offered to sell the domain names for $2,300 per name; see also Matmut v. Tweed, D2000-1183 (WIPO Nov. 27, 2000) finding bad faith under Policy paragraph 4(b)(i) where Respondent stated in communication with Complainant, “if you are interested in buying this domain name, we would be ready to sell it for $10,000”.

 

Furthermore, Respondent registered the disputed domain names nearly six months ago, and the domain names resolve to an “under construction” website.  The Panel does not find it necessary to wait for Respondent to actively use the domain names, which contain confusingly similar versions of Complainant’s AIG and AMERICAN GENERAL marks, as any probable use of the domain names would almost certainly be in violation of Complaint’s rights.  Thus, the Panel finds that Respondent registered and used the domain names in bad faith pursuant to Policy ¶ 4(a)(iii).  See Alitalia –Linee Aeree Italiane S.p.A v. Colour Digital, D2000-1260 (WIPO Nov. 23, 2000) finding bad faith where Respondent made no use of the domain name in question and there are no other indications that Respondent could have registered and used the domain name in question for any non-infringing purpose; see also Phat Fashions v. Kruger, FA 96193 (Nat. Arb. Forum Dec. 29, 2000) finding bad faith under Policy ¶ 4(b)(iv) even though Respondent has not used the domain name because “It makes no sense whatever to wait until it actually ‘uses’ the name, when inevitably, when there is such use, it will create the confusion described in the Policy”. 

 

Moreover, Respondent registered the disputed domain names with actual or constructive knowledge of Complainant’s rights in the marks due to Complainant’s registrations of the marks with the USPTO and with trademark authorities worldwide as well as to the immense fame that Complainant’s marks have acquired.  Therefore, the Panel finds that Respondent registered and used the domain names in bad faith pursuant to Policy ¶ 4(a)(iii).  See Orange Glo Int’l v. Blume, FA 118313 (Nat. Arb. Forum Oct. 4, 2002) (“Complainant’s OXICLEAN mark is listed on the Principal Register of the USPTO, a status that confers constructive notice on those seeking to register or use the mark or any confusingly similar variation thereof.”); see also Exxon Mobil Corp. v. Fisher, D2000-1412 (WIPO Dec. 18. 2000) finding that Respondent had actual and constructive knowledge of Complainant’s EXXON mark given the worldwide prominence of the mark and thus Respondent registered the domain name in bad faith.

 

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

 

DECISION

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

 

Accordingly, it is Ordered that the <aiglifeassignments.com>, <aiglifesettlements.com> and <americangenerallifesettlements.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

 

Sandra Franklin, Panelist

Dated:  March 17, 2005

 

 

 

 

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