national arbitration forum

 

DECISION

 

The Antioch Company d/b/a Creative Memories v. In Memory Of

Claim Number:  FA0505000474862

 

PARTIES

Complainant is The Antioch Company d/b/a Creative Memories (“Complainant”), P.O. Box 1839, Saint Cloud, MN 56302.  Respondent is In Memory Of (“Respondent”), P.O. Box 360109, Strongsville, OH 44136.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <ecreativememories.com>, registered with Tucows 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.

 

Judge Harold Kalina (Ret.) as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on May 11, 2005; the National Arbitration Forum received a hard copy of the Complaint on May 23, 2005.

 

On May 12, 2005, Tucows Inc. confirmed by e-mail to the National Arbitration Forum that the domain name <ecreativememories.com> is registered with Tucows Inc. and that Respondent is the current registrant of the name. Tucows Inc. has verified that Respondent is bound by the Tucows 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 May 25, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of June 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@ecreativememories.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 20, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Judge Harold Kalina (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 <ecreativememories.com> domain name is confusingly similar to Complainant’s CREATIVE MEMORIES mark.

 

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

 

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

 

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

 

FINDINGS

Complainant’s Creative Memories business was founded in 1987 as a direct sales company distributing photo album and scrapbook supplies through Creative Memories Consultants.  Creative Memories Consultants are independent distributors who sell CREATIVE MEMORIES brand products. 

 

Since 1987, Creative Memories has grown to include over 65,000 U.S. based Creative Memories Consultants, and nearly 90,000 worldwide.  Complainant has operated a website at the <creativememories.com> domain name since September 1997 to promote its CREATIVE MEMORIES products.

 

Complainant’s predecessor-in-interest registered the CREATIVE MEMORIES mark with the U.S. Patent and Trademark Office on June 11, 1996 (Reg. No. 1,979,739).  The mark was registered for “photograph albums, photograph mounts and plastic refill pages for holding photographs.”  Complainant is the last listed owner of the mark.

 

Complainant’s predecessor-in-interest also registered the CREATIVE MEMORIES mark with the U.S. Patent and Trademark Office on September 23, 1997 (Reg. No. 2,099,073).  The mark was registered for “educational services, namely, home classes for preparing photo albums and scrapbook albums.”  Complainant is the last listed owner of the mark.

 

Respondent registered the disputed domain name, <ecreativememories.com>, on November 16, 2004.  As of January 11, 2005, the domain name resolved to a website that sold “Scrapbook Albums, Embellishments, & More,” and claimed to be the “fastest growing on-line scrapbook supply store.” 

 

Complainant sent a cease and desist letter to Respondent on January 11, 2005.  On or about January 18, 2005, Respondent had removed the former website.  A temporary index page replaced the former website.  On or about April 5, 2005, Respondent commenced using the domain name for a scrapbooking related website.  Now, however, Respondent replaced the references for “eCreativememories.com” with “Forscrapsakes.com.”

 

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.  The Panel is entitled to accept all reasonable allegations and inferences set forth in the Complaint as true unless the evidence is clearly contradictory.  See 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 complaint to be deemed true); see also 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.").

 

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

 

Registering a trademark with a legitimate governing authority establishes a presumption of valid and subsisting trademark rights.  Here, Complainant’s predecessor-in-interest successfully registered the CREATIVE MEMORIES mark with the U.S. Patent and Trademark Office.  Complainant is the last listed owner of those trademark rights.  Since the presumption afforded by registration stands uncontested, Complainant has established rights in the CREATIVE MEMORIES mark pursuant to Policy ¶ 4(a)(i).  See Janus Int’l Holding Co. v. Rademacher, D2002-0201 (WIPO Mar. 5, 2002) (finding that the 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); 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).

 

Additionally, Complainant asserts that the disputed domain name, <ecreativememories.com>, is confusingly similar to the CREATIVE MEMORIES mark.  In making this determination, panels simply compare the second-level domain with the trademark at issue.  See Busy Body, Inc. v. Fitness Outlet Inc., D2000-0127 (WIPO Apr. 22, 2000) (finding that the addition of a top-level domain is without legal significance). 

 

In this case, the only difference between Complainant’s mark and the second-level domain is the addition of the letter “e” to the front-end of Complainant’s mark in the domain name.  Panels have consistently held that domain names are confusingly similar to third-party marks where the only addition is the letter “e” to the third-party’s mark.  Consistent with these prior decisions under the Policy, the Panel finds that the disputed domain name, <ecreativememories.com>, is confusingly similar to the CREATIVE MEMORIES mark pursuant to Policy ¶ 4(a)(i).  See Canadian Tire Corp. v. 849075 Alberta Ltd., D2000-0985 (WIPO Oct. 19, 2000) (finding that the domain names <ecanadiantire.com> and <e-canadiantire.com> are confusingly similar to Canadian Tire’s trademarks); see also Int’l Data Group, Inc. v. Maruyama & Co., Ltd., D2000-0420 (WIPO June 26, 2000) (finding that the domain name <ecomputerworld.com> is confusingly similar to Complainant’s mark, COMPUTERWORLD); see also EBAY, Inc. v. MEOdesigns, D2000-1368 (WIPO Dec. 15, 2000) (finding that Respondent’s domain name <eebay.com> is confusingly similar to Complainant’s registered EBAY trademark).

 

Complainant has established Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

 

Complainant asserts Respondent lacks rights and legitimate interests.  The burden then shifts to Respondent to advance concrete evidence rebutting this assertion because this information is “uniquely within the knowledge and control of the respondent.” G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002).  Respondent has failed to meet its burden by failing to respond to the Complaint.  Therefore, the Panel finds that Respondent lacks rights and legitimate interests in the disputed domain name.  See 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).  Nevertheless, the Panel will address the elements of Policy ¶ 4(c).

 

Respondent initially resolved the disputed domain name to a website that sold “Scrapbook Albums, Embellishments, & More.”  Shortly after Complainant sent a cease and desist letter to Respondent, the domain name resolved to a temporary index page.  Months later, Respondent resumed using the domain name for a scrapbook-related website.  Complainant also uses its CREATIVE MEMORIES mark for scrapbook-related services, “namely, home classes for preparing photo albums and scrapbook albums.”  Therefore, the Panel finds that Respondent and Complainant are both operating in the same field of business and, therefore, are competitors.  Under the Policy, there is no right to use a domain name that is identical or confusingly similar to a trademark of one’s competitor.  Therefore, Respondent is not using the disputed domain name in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i).  See Clear Channel Comm’ns, Inc. v. Beaty Enters., FA 135008 (Nat. Arb. Forum Jan. 2, 2003) (finding that Respondent, as a competitor of Complainant, had no rights or legitimate interests in a domain name that utilized Complainant’s mark for its competing website); see also Computerized Sec. Sys., Inc. v. Hu, FA 157321 (Nat. Arb. Forum June 23, 2003) (holding that Respondent’s appropriation of Complainant’s mark to market products that compete with Complainant’s goods does not constitute a bona fide offering of goods and services).

 

There are three bases for the Panel to find that Respondent is not commonly known by the disputed domain name pursuant to Policy ¶ 4(c)(ii).  First, there is no assertion in the record that Respondent is commonly known by the <ecreativememories.com> domain name.  Second, the WHOIS registration information fails to indicate the same.  Third, Respondent has implicitly admitted that it is not commonly known by the disputed domain name when it reattached its scrapbook website.  After receiving the cease and desist letter from Complainant, Respondent changed the references on its website from “eCreativememories.com” to “Forscrapsakes.com.”  This is persuasive evidence that Respondent is not commonly known by 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 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).

 

Moreover, Respondent is using the disputed domain name in a commercial manner and there is no evidence support an argument for fair use.  Therefore, Respondent is not using  the disputed domain name in connection with a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).  See Schering Corp. v. NGS Enters., LTD, FA 198013 (Nat. Arb. Forum Nov. 7, 2003) (“[T]he Panel concludes that Respondent's use is plainly commercial in nature, such that Policy ¶ 4(c)(iii) is in fact inapplicable to this dispute.”); see also Avery Dennison Corp. v. Steele, FA 133626 (Nat. Arb. Forum Jan. 10, 2003) (“Evidence indicates that Respondent is profiting from the use of Complainant's mark, therefore Policy ¶ 4(c)(iii)’s 'noncommercial or fair use' criteria are inapplicable.”).

 

Complainant has established Policy ¶ 4(a)(ii)

 

Registration and Use in Bad Faith

 

As stated prior, Complainant and Respondent are competitors in the scrapbook business.  The fact that Respondent registered a domain name, which is confusingly similar to one of its competitors marks, is sufficient for the Panel find that Respondent registered the domain name primarily to disrupt the business of a competitor.  This is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).  See Surface Protection Indus., Inc. v. Webposters, D2000-1613 (WIPO Feb. 5, 2001) (finding that, given the competitive relationship between Complainant and Respondent, Respondent likely registered the contested domain name with the intent to disrupt Complainant's business and create user confusion); see also 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).

 

In this case, the same facts that establish bad faith pursuant to Policy ¶ 4(b)(iii) also establish bad faith registration and use under Policy ¶ 4(b)(iv).  In particular, Respondent registered a domain name that is confusingly similar to a competitor’s mark and he used that domain name to sell goods and services that compete with those offered by Complainant.  Therefore, the Panel finds that Respondent has intentionally attempted to attract, for commercial gain, Internet users to its web site by creating a likelihood of confusion with Complainant's mark as to the source, sponsorship, affiliation, or endorsement of the resolved website.  See Am. Online, Inc. v. Fu, D2000-1374 (WIPO Dec. 11, 2000) (finding that Respondent intentionally attempted to attract Internet users to his website for commercial gain by creating a likelihood of confusion with Complainant’s mark and offering the same services as Complainant via his website); see also Scholastic Inc. v. Applied Software Solutions, Inc., D2000-1629 (WIPO Mar. 15, 2001) (finding bad faith under Policy ¶ 4(b)(iv) where Respondent initially used the domain name at issue to resolve to a website offering similar services as Complainant into the same market).

 

Complainant has established 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 <ecreativememories.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

 

Judge Harold Kalina (Ret.), Panelist

Dated:  June 30, 2005

 

 

 

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