National Arbitration Forum

 

DECISION

 

America Online, Inc. v. Darell Blandshaw

Claim Number: FA0503000444475

 

PARTIES

Complainant is America Online, Inc. (“Complainant”), represented by James R. Davis, of Arent Fox PLLC, 1050 Connecticut Avenue, NW, Washington, DC 20036.  Respondent is Darell Blandshaw (“Respondent”), represented by William L. Warren, of The Marshall Firm, 1065 Avenue of the Americas, New York, NY 10018.

 

REGISTRAR AND DISPUTED DOMAIN NAMES 

The domain names at issue are <aolhiphop.com>, <aolhiphop.net> and <aolhiphop.org>, registered with Go Daddy Software, 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.

 

Judge Irving H. Perluss (Retired) is the Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on March 21, 2005; the National Arbitration Forum received a hard copy of the Complaint on March 24, 2005.

 

On March 21, 2005, Go Daddy Software, Inc. confirmed by e-mail to the National Arbitration Forum that the domain names <aolhiphop.com>, <aolhiphop.net> and <aolhiphop.org> are registered with Go Daddy Software, Inc. and that the Respondent is the current registrant of the name.  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 March 25, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of April 14, 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@aolhiphop.com, postmaster@aolhiphop.net and postmaster@aolhiphop.org by e-mail.

 

A timely Response was received and determined to be complete on April 14, 2005.

 

On April 21, 2005, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Judge Irving H. Perluss (Retired) as Panelist.

 

RELIEF SOUGHT

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

 

PARTIES’ CONTENTIONS

A. Complainant

Identical or Confusingly Similar.  Policy ¶ 4(a)(i)

 

            1.            Complainant America Online, Inc. (“AOL”) is the owner of numerous trademark registrations worldwide for the AOL mark, including U.S. trademark Registration Nos. 1,977,731 and 1,984, 337, which were registered on June 4, 1996, and July 2, 1996, respectively.  AOL registered and uses its AOL mark in connection with, among other things, music and lifestyles.

 

            2.            AOL uses its AOL.COM mark in connection with providing online services.  AOL owns federal trademark Registration Nos. 2,325,291 and 2,325,292 for the AOL.COM mark.  The AOL mark is used extensively at the website.

 

            3.            Long prior to Respondent’s February 19, 2004 registration of the disputed domain names, <aolhiphop.com>, <aolhiphop.net> and <aolhiphop.org>, and at least as early as 1989 for the AOL mark and 1992 for the AOL.COM mark, AOL adopted and began using its marks in connection with computer online services and other Internet-related services.

 

            4.            AOL has invested substantial sums of money in developing and marketing its services and marks. As a result, AOL is one of the most readily recognized and famous marks on the Internet.

 

            5.            AOL operates the most widely-used interactive online service in the world and each year millions of AOL customers worldwide obtain services offered under the AOL and AOL.COM marks.

 

            6.            The disputed domain names, <aolhiphop.com>, <aolhiphop.net> and <aolhiphop.org>, are nearly identical and confusingly similar to the AOL and AOL.COM marks.  Consumer confusion is particularly likely because Respondent is using the very famous and distinctive AOL mark as a prefix to the generic term “hip-hop,” which is a popular style of music.  Consumer confusion is particularly likely because AOL has been providing online music services for many years prior to the date on which Respondent registered the disputed domain names.  Moreover, AOL provides a wide variety of online services related to the hip-hop music style.  Consumers, therefore, are likely to recognize the famous AOL mark in the infringing domains and believe falsely that AOL endorses or is affiliated with Respondent.

 

            Rights and Legitimate Interest. Policy ¶ 4(a)(ii)

 

            1.            Respondent has no rights or legitimate interest in the disputed domain names.  This is because Respondent (Darell Blandshaw) is not commonly known as AOL, nor is he licensed or authorized to use the AOL mark.

 

            Registration and Use in Bad Faith.  Policy ¶ 4(a)(iii)

 

            1.            Respondent’s bad faith registration of the disputed domain names is evidenced by the fact that the domains were registered many years after the AOL marks were used and registered in the United States.  Moreover, Respondent uses an AOL e-mail address and is an AOL subscriber with actual knowledge of AOL’s rights and the manner in which it uses its AOL brand.  Respondent, therefore, had knowledge of AOL’s superior rights at the time he registered the infringing domains.

 

            2.            Respondent’s bad faith use of the domains is further demonstrated by Respondent’s use of the disputed domain names to route to a commercial website that makes prominent use of the AOL mark and provides and promotes various services, many of which are offered by AOL.  Respondent registered the infringing domains solely to play off the famous AOL name and mark, and to profit from the consumer confusion that is likely to occur when consumers encounter the AOL mark in the disputed domains.

 

            3.            Respondent’s bad faith intent and use of the infringing domains is further demonstrated by several ICANN cases involving nearly identical cybersquatting motives and strategies, what one arbitrator called “pathetic attempts to suggest an unrelated origin for [the] use of AOL.”  See Am. Online, Inc. v. Cucamonga Elec. Corp., FA 103364 (Nat. Arb. Forum Feb. 26, 2002) (“[I]n this age it is not a coincidence when a firm uses the acronym AOL in any new setting.  In the absence of a credible explanation, I will infer that its purpose is to mislead Internet users into thinking that whatever activities are carried on on the site, AOL Inc. has some connection with them.”).

 

B. Respondent

            Identical or Confusingly Similar.  Policy ¶ 4(a)(i)

 

            1.            All Online Hip Hop.com was created as an online source for hip-hop lovers.  All Online Hip Hop is not trying to confuse its customers by using AOL as an acronym for which the Complainant calls a popular style of music (hip-hop).  Music is a just part of hip-hop.  All Online Hip Hop services all aspects of the hip-hop culture, and Complainant is not well known in the hip-hop community as a provider of hip-hop services.

 

            2.            Complainant’s marks are not associated with hip-hop.  All Online Hip Hop.com is establishing a reputation as a source of hip-hop services.

 

            3.            Respondent admits that Complainant has been using its mark since 1992 and contends that America Online has not been servicing hip-hop since that time.

 

            4.            Respondent admits the recognition of Complainant as a famous online provider of goods and services. However, Complainant is not recognized as a provider of hip-hop services on the Internet, neither nationally nor internationally.

 

            5.            All Online Hip Hop.com also reaches a wide customer base and the customers are becoming exposed to the services provided by All Online Hip Hop.com.

 

            Rights and Legitimate Interest.  Policy ¶ 4(a)(ii)

 

            1.            The words “hip-hop” are more widely known than the AOL mark.  Complainant does not service hip-hop.  Hip-hop is more than just rap music; it is a culture, a way of life, one that is covered thoroughly on <aolhiphop.com>.  Merely selling rap CDs is not servicing the hip-hop community as Complainant claims.

 

            2.            Complainant could have easily registered the <aolhiphop.com>, <aolhiphop.net> and <aolhiphop.org> domains since it is implied that it services the hip-hop community.  It could have done so since 1989, the year in which it claims to have adopted the AOL marks.  Respondent registered these names in good faith, understanding that Complainant is not commonly associated with “hip-hop” and that it does not service this culture.  All Online Hip Hop services the hip-hop community, not only with music, but with in-depth articles, videos, magazines and a personal view from someone who has been a part of this hip-hop community for many years, something that Complainant does not do.

 

            Registration and Use in Bad Faith.  Policy ¶ 4(a)(iii)

 

1.            Complainant’s AOL.COM mark may be well known, but the purchasing public does not associate America Online as servicing the hip-hop community, at least to the extent that it would confuse Complainant with All Online Hip Hop, which completely, and exclusively services hip-hop and the hip-hop community.

 

2.            Respondent has no intention to profit in bad faith from Complainant’s AOL marks.  America Online is not commonly associated with the “hip-hop” culture.  There is no bad faith intent, or any confusion because America Online is not known to service the hip-hop area.

 

3.            There is no resemblance to any of the America Online product sites by the disputed domain names.  Respondent uses the AOL prefix since the Respondent is known as “All Online Hip Hop,” and exclusively services the hip-hop community.

 

4.            Respondent is also willing to include a disclaimer on the site (for a reasonable and agreed upon period of time) stating that it is not affiliated with Complainant or any of its services.  This disclaimer will be in clear view.

           

FINDINGS AND DETERMINATIONS

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.

 

Preliminarily, it is to be noted that there have been numerous attempts to utilize the principal components of Complainant’s registered AOL mark as a domain name.  These attempts have been extensively arbitrated and in each instance, transfer was ordered.

 

Arbitration decisions which appear to be directly on point, because they involved services, businesses, hobbies, lifestyles, cultures and interests, as here, include Am. Online, Inc. v. RAM, FA 136310 (Nat. Arb. Forum, Jan. 21, 2003) (<aol-india.com>); Am. Online, Inc. v. Tella, FA 101820 (Nat. Arb. Forum, Dec. 28, 2001) (<aolbox.com>); Am. Online, Inc. v. Stop 2 Shop, FA 212629 (Nat. Arb. Forum, Jan. 9, 2004) (<aol-games.com>); Am. Online, Inc. v. Klemons, FA 203127 (Nat. Arb. Forum, Nov. 21, 2003) (<aolsmuts.com>); Am. Online, Inc. v. Phat Nasty Prods., FA 146940 (Nat. Arb. Forum, Apr. 1, 2003) (<aolnasties.com>); Am. Online, Inc. v. AOL Logistics Co., Ltd., FA 166019 (Nat. Arb. Forum, Aug. 20, 2003) (<aologis.com>); Am. Online, Inc. v. AOL Fin. Holdings Group, Inc., FA 362287, (Nat. Arb. Forum, Dec. 20, 2004) (<aolholding.com>); Am. Online, Inc. v. Trapp, FA 268418 (Nat. Arb. Forum, June 28, 2004) (<aol-land.com>); Am. Online, Inc. v. N/A, FA 288982 (Nat. Arb. Forum, Aug. 6, 2004) (<aolhome.com>); Am. Online, Inc. v. World Photo Video & Imaging, Corp., FA 109031 (Nat. Arb. Forum, May 13, 2002) (<aolcamera.com> and <aolcameras.com>); Am. Online, Inc. v. Touch Tone Pictures, LLC, FA 105776, (Nat. Arb. Forum, Mar. 15, 2002) (<aolparty.net>); Am. Online, Inc. v. Action Now Network, FA 104131 (Nat. Arb. Forum, Mar. 15, 2002) (<aolracing.com> and <aolracing.net>); Am. Online, Inc. v. Peppler, FA 103437 (Nat. Arb. Forum, Feb. 22, 2002) (numerous, including <aolpogo.com> and <aolmediaplayer.com>); Am. Online, Inc. v. Anderson, FA 103365 (Nat. Arb. Forum, Feb. 7, 2002) (<aolcollections.com>); Am. Online, Inc. v. Berns, FA 273412, July 8, 2004) (<aolove.com>).

 

Of particular interest is the language of the Panelist in Am. Online, Inc. v. Cucamonga Elec. Corp., FA 103364 (Nat. Arb. Forum, Feb. 26, 2002) (<aolutility.com>).  Therein, it was said:

 

Despite all the verbiage in the submissions, the issues are very simple.  Is there any risk that a user calling the name <aolutility.com> may think he is calling a site about some form of utility that is owned by AOL, Inc. or associated with AOL Inc.?

 

The answer is yes.  Given the ubiquitous nature of AOL Inc., there is no doubt some Internet users when they discover <aolutility.com> will think they have reached a site operated under the aegis of AOL, Inc.  See, for example, America Online, Inc. v. Viper, WIPO Case D2000-1198) (‘it is well past the day when Internet users would not make the assumption that use of AOL as part of a domain name links that site in the mind of the user to Complainant’).

 

And, further:

 

At the same time, the acronym is now so famous that coincidence is incredible.  The result is that one must infer that the name was chosen precisely because it matched that of this large enterprise, AOL, Inc.  To seek to use the goodwill of another enterprise is not to create any rights or legitimate interests.  On the contrary.

 

Finally:

 

Contrary to the submissions of the council for the Respondent ‘AOL’ are not merely three more letters.  That argument assumes that I am a fool.  The three letters together symbolize a large American enterprise.  I simply repeat that in this age it is not a coincidence when a firm uses the acronym AOL in any new setting.  In the absence of a credible explanation, I will infer that its purpose is to mislead Internet users into thinking that whatever activities are carried on on the site, AOL Inc. has some connection with them.  This is fraud within the meaning of the rules, and the law.  See Sony Kabushiki Kaisha v. Inja, Kil, D2000-1409 (WIPO Dec. 9, 2000) (finding that bad faith registration and use where it is ‘inconceivable that the respondent could make any active use of the disputed domain names without creating a false impression of association with the Complainant’).

 

. . . . .

 

I will say only for this Respondent that it has unlike others spared me the pathetic attempts to suggest an unrelated origin for its use of AOL:  America Online, Inc. v. Yeteck Communication, Inc., D2001-0055 (WIPO Apr. 23, 2001) (Respondent held to have acted in bad faith despite claims that <aolcasino.com> was an acronym for ‘Adults On Line Casino’); America Online, Inc. v. East Coast Exotics, D2001-0661 (WIPO July 10, 2001) (bad faith registration and use despite Respondent’s claim that AOL is an acronym for ‘Amateurs On Line’).

 

Identical and/or Confusingly Similar

 

It is found and determined that Complainant has established rights in the AOL mark through its registration of the mark with the United States Patent and Trademark Office (“USPTO”) (Reg. Nos. 1, 977,731 issued June 4, 1996; 1,984,337 issued July 2, 1996) and through continuous use of the mark in commerce since 1989.  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 America Online, Inc. v. Thomas P. Culver Enters., D2001-0564 9WIPO June 18, 2001) (finding that successful trademark registration with the United States Patent and Trademark Office creates a presumption of rights in a mark).

 

It is further found and determined that the disputed domain names, <aolhiphop.com>, <aolhiphop.net> and <aolhiphop.org>, are confusingly similar to Complainant’s AOL mark.  This is because the disputed domain names incorporate the mark in its entirety, merely adding the term “hip hop.”  This 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).  In addition to the arbitration decisions above cited, 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 the complainant combined with a generic work or term); see also Sony Kabushiki Kaisha v. Inja, Kil, D2000-1409 (WIPO Dec. 9, 2000) (finding that “[n]either the addition of an ordinary descriptive word . . . nor the suffix ‘.com’ detract from the overall impression of the dominant part of the name in each case, namely the trademark SONY” and thus Policy ¶ 4(a)(i) is satisfied).

 

Complainant has established the first element required by Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

 

Respondent claims that it is using the disputed domain names in a broader context than the services offered by Complainant.  Nevertheless, it is found and determined that Respondent is using the confusingly similar <aolhiphop.com>, <aolhiphop.net>, and <aolhiphop.org> domain names to offer commercial services that compete directly with the services provided by Complainant.  It is to be noted that the services covered by Complainant’s mark go beyond “music” to include “lifestyles.”  A competing use of the disputed domain names is not a use in connection with 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).  See N. Coast Med., Inc. v. Allegro Med., FA 95541 (Nat. Arb. Forum Oct. 2, 2000) (finding no rights or legitimate interests in a domain name that diverted Internet users to the respondent’s competing website through the use of the complainant’s mark); see also Avery Dennison Corp. v. Steele, FA 133626 (Nat. Arb. Forum Jan. 10, 2003) (finding that the respondent had no rights or legitimate interests in the disputed domain name where it used the complainant’s mark, without authorization, to attract Internet users to its business, which competed with the complainant).

 

Further, it is found and determined that Respondent is neither commonly known by the disputed domain names nor authorized to register domain names featuring Complainant’s AOL mark.  Accordingly, Respondent lacks rights and legitimate interests in the disputed domain names pursuant to Policy ¶ 4(c)(iii).  See Tercent Inc. v. Lee Yi, FA 139720 (Nat. Arb. Forum Feb. 10, 2003( (stating “nothing in the resondent’s WHOIS information implies that the respondent is ‘commonly known by’ the disputed domain name” as one factor in determining that Policy ¶ 4(c)(iii) 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 the respondent was not commonly known by the mark and never applied for a license or permission from the complainant to use the trademarked name).

 

Complainant has established the second element required by Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

 

It is found and determined that Respondent is using the disputed domain names, <aolhiphop.com>, <aolhiphop.net> and <aolhiphop.org>, to operate a website offering services that directly compete with those offered by Complainant.  Such competing use constitutes disruption and is evidence that Respondent registered and used the disputed domain names in bad faith pursuant to Policy ¶ 4(b)(iii).  See S. Exposure v. S. Exposure, Inc., FA 94864 (Nat. Arb. Forum July 18, 2000) (finding the respondent acted in bad faith by attracting Internet users to a website that competes with the complainant’s business); see also Gen. Media Communications, Inc. v. Vine Ent., FA 96554 (Nat. Arb. Forum Mar. 26, 2001) (finding bad faith where a competitor of the complainant registered and used a domain name confusingly similar to the complainant’s PENTHOUSE mark to host a pornographic website).

 

The disputed domain names have been found to be confusingly similar to Complainant’s AOL marks.  It is apparent, accordingly, that consumers accessing the domain names may become confused as to Complainant’s affiliation with the resulting commercial website.  Respondent’s commercial use of the disputed domain names, accordingly, constitutes bad faith registration and use pursuant to Policy ¶ 4(b)(iv).  See Qwest Communications, Int’l Inc. v. Ling Shun Shing, FA 187431 (Nat. Arb. Forum Oct. 6, 2003) (“Respondent’s attempt to commercially benefit from the misleading domain name is evidence of bad faith pursuant to Policy ¶ 4(b)(iv).”); see also Identigene, Inc. v. Genetest Lab., 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 believe that the complainant is the source of or is sponsoring the services offered at the site).  And, of course, see the many arbitration decisions involving the use of acronym “AOL,” above cited.

 

Further, it is evident, and it is found and determined, that Respondent registered the disputed domain names with actual and constructive knowledge of Complainant’s rights in the AOL mark.  The constructive knowledge is because of Complainant’s registration of the mark with the USPTO and because of the international fame that Complainant’s mark has acquired.  The actual knowledge is because Respondent was at one time a registered member of Complainant’s Internet service.  The registration of domain names that are confusingly similar to another’s mark despite actual or constructive knowledge of the mark holder’s rights is tantamount to bad faith registration and use pursuant to Policy ¶ 4(a)(iii).  See Digi Intl’ v. DDI Sys., FA 124506 (Nat. Arb. Forum Oct. 24, 2002) (“[T]here is a legal presumption of bad faith, when Respondent reasonably should have been aware of Complainant’s trademarks, actually or constructively.”); see also Exxon Mobile Corp. v. Fisher, D2000-1412 (WIPO Dec. 18, 2000) (finding that the respondent had actual and constructive knowledge of the complainant’s EXXON mark given the worldwide prominence of the mark); see also Orange Glow Int’l v. Blume, FA 118313 (Nat. Arb. Forum October 4, 2002 (“[T]he complainant’s OXICLEAN mark is listed on the Principal Register of the USPTO, a status that confers constructive notice of those seeking to register or use the mark or any confusingly similar variation thereof.”).

 

Finally, the offered disclaimer by Respondent on his websites does not alleviate his problem.  This is because such disclaimers are not sufficient to prevent initial interest confusion.  See Ciccone v. Parisi (Madonna.com), 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 the respondent’s actions. Such confusion is a basis for finding a violation of the complainant’s rights.”).

 

Complainant has established the third element required by Policy ¶ 4(a)(iii).

 

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 <aolhiphop.com>, <aolhiphop.net> and <aolhiphop.org> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

JUDGE IRVING H. PERLUSS (Retired), Panelist
Dated:  May 4, 2005

 

 

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