national arbitration forum

 

DECISION

 

Wachovia Corporation v. Asia Ventures, Inc.

Claim Number:  FA0505000473245

 

PARTIES

Complainant is Wachovia Corporation (“Complainant”), represented by Michael Tobin, of Kennedy, Covington, Lobdell and Hickman, LLP, 214 North Tryon Street, Hearst Tower, 47th Floor, Charlotte, NC 28202.  Respondent is Asia Ventures, Inc. (“Respondent”), GPO 11136, Central, HK.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <wachoviaonlinebanking.com>, registered with The Registry At Info Avenue d/b/a IA Registry.

 

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.

 

Tyrus R. Atkinson, Jr., as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on May 9, 2005; the National Arbitration Forum received a hard copy of the Complaint on May 10, 2005.

 

On May 13, 2005, The Registry At Info Avenue d/b/a IA Registry confirmed by e-mail to the National Arbitration Forum that the domain name <wachoviaonlinebanking.com> is registered with The Registry At Info Avenue d/b/a IA Registry and that Respondent is the current registrant of the name.  The Registry At Info Avenue d/b/a IA Registry has verified that Respondent is bound by the The Registry At Info Avenue d/b/a IA Registry 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 May 13, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of June 2, 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@wachoviaonlinebanking.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 June 13, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Tyrus R. Atkinson, Jr.,  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 <wachoviaonlinebanking.com> domain name is confusingly similar to Complainant’s WACHOVIA mark.

 

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

 

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

 

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

 

FINDINGS

Complainant, Wachovia Corporation, is a holding company that owns numerous subsidiary companies engaged, individually and collectively, in providing a wide variety of banking and financial services throughout the world. 

 

Complainant holds several registrations for the WACHOVIA mark with the United States Patent and Trademark Office (Reg. No. 883,529 issued December 30, 1969; Reg. No. 1,735,242 issued November 24, 1992; Reg. No. 1,729,833 issued November 3, 1992; Reg. No. 2,738,730 issued July 15, 2003; Reg. No. 2,805,546 issued January 13, 2004 and Reg. No. 2,744,626 issued July 29, 2003) in connection with banking and related financial services.  In addition, Complainant owns at least twenty-five other federal trademark registrations for its WACHOVIA family of marks.  Complainant’s WACHOVIA mark is also registered throughout the world (i.e., Japan, Germany, Switzerland, Canada, the United Kingdom and the Cayman Islands).

 

Complainant and its predecessor companies have been using the WACHOVIA mark since Wachovia National Bank was created in 1879.  Since that time, Complainant has expanded its use of the mark to include a wide variety of financial services.  Complainant is a major participant in the international banking community, including branches in Hong Kong, Tokyo, Taipei, Seoul and London.  Additionally, Complainant’s extensive global network includes thirty-three representative offices and over 3,000 correspondent banking relationships in more than 130 countries.

 

Complainant’s main website is operated at <wachovia.com>.

 

Respondent registered the <wachoviaonlinebanking.com> domain name on March 26, 2002.  Respondent is using the domain name to redirect Internet users to a website featuring pop-up advertisements for a variety of services and a search engine linking viewers to a variety of websites, including sites that involve financial services in direct competition with Complainant’s services.

 

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 WACHOVIA mark through registration with the United States Patent and Trademark Office and through continuous use of the mark in commerce.  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 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).

 

Respondent’s <wachoviaonlinebanking.com> domain name is confusingly similar to Complainant’s WACHOVIA mark because Respondent’s domain name incorporates Complainant’s mark in its entirety and adds the generic or descriptive phrase “online banking” to the mark, which describes an aspect of Complainant’s business.  This addition to Complainant’s mark does not negate the confusingly similar aspects of Respondent’s domain name 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 the 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 the respondent’s domain name combines the complainant’s mark with a generic term that has an obvious relationship to the complainant’s business); see also Brown & Bigelow, Inc. v. Rodela, FA 96466 (Nat. Arb. Forum Mar. 5, 2001) (finding that the <hoylecasino.net> domain name was confusingly similar to the complainant’s HOYLE mark, and that the addition of “casino,” a generic word describing the type of business in which the complainant was engaged, did not take the disputed domain name out of the realm of confusing similarity).

 

Additionally, Respondent’s <wachoviaonlinebanking.com> domain name is confusingly similar to Complainant’s WACHOVIA mark because the domain name incorporates Complainant’s mark in its entirety and adds the generic top-level domain “.com.”  The addition of a generic top-level domain name to Complainant’s mark does not negate the confusingly similar aspects of Respondent’s domain name pursuant to Policy ¶ 4(a)(i).  See Fed’n of Gay Games, Inc. v. Hodgson, D2000-0432 (WIPO June 28, 2000) (finding that the domain name <gaygames.com> was identical to the complainant's registered trademark GAY GAMES); see also Little Six, Inc. v. Domain For Sale, FA 96967 (Nat. Arb. Forum Apr. 30, 2001) (finding that <mysticlake.net> was plainly identical to the complainant’s MYSTIC LAKE trademark and service mark).

 

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

 

Rights or Legitimate Interests

 

Complainant has alleged that Respondent does not have rights or legitimate interests in the <wachoviaonlinebanking.com> domain name.  Once Complainant makes a prima facie case in support of its allegations, the burden shifts to Respondent to prove that it does have such rights or legitimate interests pursuant to Policy ¶ 4(a)(ii).  Due to Respondent’s failure to respond to the Complaint, the Panel will infer that Respondent does not have rights or 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 the complainant has asserted that respondent does not have 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 Clerical Med. Inv. Group Ltd. v. Clericalmedical.com, D2000-1228 (WIPO Nov. 28, 2000) (finding that under certain circumstances the mere assertion by the complainant that the respondent does not have rights or legitimate interests is sufficient to shift the burden of proof to the respondent to demonstrate that such rights or legitimate interests do exist).

 

Moreover, where Complainant makes the prima facie showing and Respondent does not respond, the Panel may accept all reasonable allegations and inferences in the Complaint as true.  See Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (“In the absence of a response, it is appropriate to accept as true all allegations of the Complaint.”); see also Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (Nat. Arb. Forum July 31, 2000) (holding that the respondent’s failure to respond allows all reasonable inferences of fact in the allegations of the complainant to be deemed true).

 

Respondent is using the <wachoviaonlinebanking.com> domain name to redirect Internet users to a website featuring pop-up advertisements for a variety of services and a search engine linking viewers to a variety of websites, including sites that involve financial services in direct competition with Complainant’s services.  Respondent’s use of a domain name, which is confusingly similar to Complainant’s WACHOVIA mark, to redirect Internet users interested in Complainant’s products and services to a commercial website that links to financial-related websites and pop-up advertisements 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 of the domain name pursuant to Policy ¶ 4(c)(iii).  See Wells Fargo & Co. v. Party Night Inc., FA 144647 (Nat. Arb. Forum Mar. 18, 2003) (holding that the respondent’s use of confusingly similar derivatives of the complainant’s WELLS FARGO mark to divert Internet users to websites featuring pop-up advertisements was not a bona fide offering of goods or services); see also Toronto-Dominion Bank v. Karpachev, 188 F.Supp.2d 110, 114 (D. Mass. 2002) (finding that, because the respondent's sole purpose in selecting the domain names was to cause confusion with the complainant's website and marks, its use of the names was not in connection with the offering of goods or services or any other fair use); see also Geoffrey, Inc. v. Toyrus.com, FA 150406 (Nat. Arb. Forum Apr. 5, 2003) (holding that the respondent’s use of the disputed domain name, a simple misspelling of the complainant’s mark, to divert Internet users to a website that featured pop-up advertisements and an Internet directory, was neither a bona fide offering of goods or services nor a legitimate noncommercial or fair use of the domain name).

 

Moreover, Respondent has offered no evidence and, nothing in the record suggests, that Respondent is commonly known by the <wachoviaonlinebanking.com> domain name.  Thus, Respondent has not established rights or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(c)(ii).  See Tercent Inc. v. 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 RMO, Inc. v. Burbridge, FA 96949 (Nat. Arb. Forum May 16, 2001) (interpreting Policy ¶ 4(c)(ii) "to require a showing that one has been commonly known by the domain name prior to registration of the domain name to prevail"); see also Am. Airlines, Inc. v. Zuccarini, FA 95695 (Nat. Arb. Forum Nov. 6, 2000) (finding no rights or legitimate interests in the misspelled domain name <amaricanairlines.com> because the respondent was not authorized to use the complainant's mark).

 

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

 

Registration and Use in Bad Faith

 

Respondent registered the <wachoviaonlinebanking.com> domain name consisting of Complainant’s well-known mark with the addition of a generic or descriptive term, and did so for Respondent’s commercial gain.  Respondent’s domain name redirects Internet users seeking Complainant’s goods or services to Respondent’s commercial website through the use of a domain name that is confusingly similar to Complainant’s mark.  Furthermore, Respondent is unfairly and opportunistically benefiting from the goodwill associated with Complainant’s WACHOVIA mark.  Respondent’s practice of diversion, motivated by commercial gain, constitutes bad faith registration and use pursuant to Policy ¶ 4(b)(iv).  See Kmart v. Khan, FA 127708 (Nat. Arb. Forum Nov. 22, 2002) (finding that if the respondent profits from its diversionary use of the complainant's mark when the domain name resolves to commercial websites and the respondent fails to contest the complaint, it may be concluded that the 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 the respondent directed Internet users seeking the complainant’s site to its own website for commercial gain); see also Reuters Ltd. v. Global Net 2000, Inc., D2000-0441 (WIPO July 13, 2000) (finding bad faith where the respondent attracted users to a website sponsored by the respondent and created confusion with the complainant’s mark as to the source, sponsorship, or affiliation of that website).

 

Respondent is using the disputed domain name to redirect Internet users to a website featuring a search engine and links to financial-related websites.  Complainant’s business provides banking and financial services to individuals and businesses throughout the world.  The Panel finds that, by creating confusion around Complainant’s WACHOVIA mark, Respondent is attempting to disrupt the business of a competitor.  Respondent’s use of a domain name confusingly similar to Complainant’s mark to sell services similar to Complainant’s goods and services 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 the respondent acted in bad faith by attracting Internet users to a website that competes with the complainant’s business); see also EBAY, Inc. v. MEOdesigns, D2000-1368 (Dec. 15, 2000) (finding that the respondent registered and used the domain name <eebay.com> in bad faith where the respondent has used the domain name to promote competing auction sites); see also Hewlett Packard Co. v. Full Sys., FA 94637 (Nat. Arb. Forum May 22, 2000) (finding that the respondent registered and used the domain name primarily for the purpose of disrupting the business of the complainant by offering personal e-mail accounts under the domain name <openmail.com> which is identical to the complainant’s services under the OPENMAIL mark).

 

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

 

 

 

Tyrus R. Atkinson, Jr., Panelist

Dated:  June 27, 2005

 

 

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