national arbitration forum

 

DECISION

 

TM Acquisition Corp. v. Michael Gonzalez a/k/a Mike Gonzalez

Claim Number:  FA0505000477193

 

PARTIES

Complainant is TM Acquisition Corp. (“Complainant”), represented by Tom K. Ara of Lord Bissell & Brook LLP, 300 S. Grand Avenue, Suite 800, Los Angeles, CA, 90071.  Respondent is Michael Gonzalez a/k/a Mike Gonzalez (“Respondent”), 5751 Treaschwig Rd., Spring, TX, 77373.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <mycentury21agent.com> and <21realestate.com>, registered with Spot Domain Llc and Tucows Inc., respectively.

 

PANEL

The undersigned certifies that she has acted independently and impartially and that to the best of her knowledge she has no known conflict in serving as Panelist in this proceeding. Hon. Carolyn Marks Johnson sits as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically May 13, 2005; the National Arbitration Forum received a hard copy of the Complaint May 16, 2005.

 

On May 16, 2005, Spot Domain Llc confirmed by e-mail to the National Arbitration Forum that the domain name <mycentury21agent.com> is registered with Spot Domain Llc and that Respondent is the current registrant of the name.  Spot Domain Llc verified that Respondent is bound by the Spot Domain Llc registration agreement and thereby has 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 18, 2005, Tucows Inc. confirmed by e-mail to the National Arbitration Forum that the domain name <21realestate.com> is registered with Tucows Inc. and that Respondent is the current registrant of the name.  Tucows Inc. verified that Respondent is bound by the Tucows Inc. registration agreement and thereby has 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@mycentury21agent.com and postmaster@21realestate.com by e-mail.

 

A timely Additional Submission was received from Complainant June 20, 2005.

 

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 Hon. Carolyn Marks Johnson as Panelist.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that the National Arbitration Forum 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.      The domain names that Respondent registered, <mycentury21agent.com> and <21realestate.com>, are confusingly similar to Complainant’s CENTURY 21 and C-21 marks.

 

2.      Respondent has no rights to or legitimate interests in the <mycentury21agent.com> and <21realestate.com> domain names.

 

3.      Respondent registered and used the <mycentury21agent.com> and <21realestate.com> domain names in bad faith.

 

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

 

FINDINGS

Complainant, TM Acquisition Corp., is a Delaware corporation that holds a family of CENTURY 21 marks, which it licenses to Century 21 Real Estate LLC.  Both entities are subsidiaries of Cendant Corporation.  Complainant holds numerous registrations with the United States Patent and Trademark Office (“USPTO”) for CENTURY 21-related marks, including the CENTURY 21 (Reg. No. 2,178,970 issued August 4, 1998) and C-21 (Reg. No. 1,268,185 issued February 21, 1984) marks.

 

Respondent registered the <mycentury21agent.com> domain name April 23, 2002 and the <21realestate.com> domain name February 5, 2004.  Respondent is using the <21realestate.com> domain name to resolve to a website that advertises Respondent’s real estate business with Complainant’s competitor, RE/MAX Advantage.  From about June 2004 until about April 2005, Respondent used the <mycentury21agent.com> domain name for the same purpose.  Currently, the <mycentury21agent.com> domain name resolves to a website that states that it is the “Future home of mycentury21agent.com!” and contains advertisements and links to various services, including real estate services.

 

Respondent is a former affiliate of a Century 21 franchisee with which Respondent was associated from about October 24, 2001, through June 15, 2004.  In June 2004, Respondent moved its real estate business to RE/MAX Advantage, a company in direct competition with Complainant. 

 

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 will draw such inferences as the Panel 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 Complainant to 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 to and/or Confusingly Similar

 

Complainant has established by extrinsic proof in this proceeding that it has rights in the CENTURY 21 and C-21 marks through registration of the marks with the USPTO.  In the absence of a response from Respondent, the Panel has before it no evidence to rebut Complainant’s prima facie case of rights.  Therefore, the Panel concludes that Complainant has established rights in the marks under 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.  The respondent has the burden of refuting this assumption).

 

The <mycentury21agent.com> domain name includes Complainant’s CENTURY 21 mark in its entirety and adds the generic or descriptive terms “my” and “agent.”  Under the Policy, addition of generic or descriptive terms to the registered mark of another does not create a distinction between the domain name and the mark.  Therefore, the Panel finds that the <mycentury21agent.com> domain name is confusingly similar to a mark in which Complainant has rights 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 AXA China Region Ltd. v. KANNET Ltd., D2000-1377 (WIPO Nov. 29, 2000) (finding that common geographic qualifiers or generic nouns can rarely be relied upon to differentiate the mark if the other elements of the domain name comprise a mark or marks in which another party has rights).

 

The <21realestate.com> domain name registered by Respondent contains the dominant portion of Complainant’s C-21 mark as well as generic or descriptive terms that bear an obvious relation to Complainant’s business.  Respondent’s attempt to distinguish the domain name from the mark by adding words to a significant term of Complainant’s mark is unsuccessful in this instance and the Panel finds the domain name to be confusingly similar to a mark in which Complainant has rights pursuant to Policy ¶ 4(a)(i).  See Asprey & Garrard Ltd v. Canlan Computing, D2000-1262 (WIPO Nov. 14, 2000) (finding that the <asprey.com> domain name was confusingly similar to the complainant’s ASPREY & GARRARD and MISS ASPREY marks); see also Space Imaging LLC v. Brownell, AF-0298 (eResolution Sept. 22, 2000) (finding confusing similarity where the respondent’s domain name combined the complainant’s mark with a generic term that had an obvious relationship to the complainant’s business).   

 

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

 

Rights to or Legitimate Interests

 

Complainant established that it has rights to and legitimate interests in the marks contained in their entirety in the disputed domain names.  Complainant also has the initial burden of establishing that Respondent lacks such rights and legitimate interests.  Once Complainant has established a prima facie case, the burden shifts to Respondent to establish a claim of rights or legitimate interests in the disputed domain names, which may be done in accordance with one of the three safe harbor provisions under Policy ¶ 4(c).  In this instance, Complainant met its initial burden and Respondent failed to contest Complainant’s allegations.  Therefore, the Panel determines that Respondent has not established rights or legitimate interests in the disputed domain names.  See G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002) (holding that, where the complainant has asserted that the respondent has no rights or legitimate interests with respect to the domain name, it is incumbent on the 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 the complainant asserts that the respondent has no rights or legitimate interests with respect to the domain, the burden shifts to the respondent to provide credible evidence that substantiates its claim of rights and legitimate interests in the domain name); see also Parfums Christian Dior v. QTR Corp., D2000-0023 (WIPO Mar. 9, 2000) (finding that by not submitting a response, the respondent has failed to invoke any circumstance which could demonstrate any rights or legitimate interests in the domain name).

 

Complainant contends that Respondent is using the <21realestate.com> domain name to advertise Respondent’s real estate business, which he conducts through RE/MAX, a direct competitor of Complainant.  Complainant further claims that Respondent used the <mycentury21agent.com> domain name for the same purpose until approximately April 2005.  Under the Policy, clear precedent allows the inference that Respondent’s use of domain names that are confusingly similar to Complainant’s registered mark to divert Internet users to Respondent’s website is not sufficient to satisfy Respondent’s burden pursuant to Policy ¶¶ 4(c)(i) or (iii), especially where Respondent’s website advertises services that compete with Complainant.  See 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); see also Clear Channel Commc’ns, Inc. v. Beaty Enters., FA 135008 (Nat. Arb. Forum Jan. 2, 2003) (finding that the respondent, as a competitor of the complainant, had no rights or legitimate interests in a domain name that utilized the complainant’s mark for its competing website); see also MSNBC Cable, LLC v. Tysys.com, D2000-1204 (WIPO Dec. 8, 2000) (finding no rights or legitimate interests in the famous MSNBC mark where the respondent attempted to profit using the complainant’s mark by redirecting Internet traffic to its own website).  Additionally, the fact that Respondent was employed by a licensee of Complainant does not bestow upon Respondent the right to use variations of Complainant’s marks as an individual.  See TM Acquisition Corp. v. Schneider, FA 96272 (Nat. Arb. Forum Feb. 2, 2001) (holding that respondent, an employee of one of complainant’s licensees, had no rights or legitimate interests in a domain name that contained a variation of complainant’s mark, because a respondent can “gain no greater right to the use of an unlicensed variation of the mark than can her employer”).

 

Complainant claims that no evidence suggests that Respondent has been commonly known by the <mycentury21agent.com> or <21realestate.com> domain name.  The only evidence of Respondent’s identity is the WHOIS information, which indicates that Respondent is known as “Michael Gonzalez.”  Thus, since Respondent has defaulted and provided no evidence to challenge Complainant’s assertions in this regard, the Panel determines that Respondent has not established rights or legitimate interests in the disputed domain names pursuant to Policy ¶ 4(c)(ii).  See 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 Gallup Inc. v. Amish Country Store, FA 96209 (Nat. Arb. Forum Jan. 23, 2001) (finding that respondent has no rights in a domain name when the respondent is not known by the mark).

 

Complainant has satisfied Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

 

Complainant alleges that Respondent acted in bad faith in registering and using the domain names.  Complainant uses its CENTURY 21 and C-21 marks in association with its real estate business and Respondent works in the same field.  In fact, Respondent is a former affiliate of one of Complainant’s licensees and subsequently moved its real estate business to Complainant’s competitor, RE/MAX Advantage.  Furthermore, Respondent is using or has used the <mycentury21agent.com> and <21realestate.com> domain names to advertise Respondent’s competing services.  These circumstances indicate that Respondent registered the disputed domain names primarily to disrupt Complainant’s competing business, which is evidence of bad faith registration and use under Policy ¶ 4(b)(iii).  See Surface Prot. Indus., Inc. v. Webposters, D2000-1613 (WIPO Feb. 5, 2001) (finding that, given the competitive relationship between the complainant and the respondent, the respondent likely registered the contested domain name with the intent to disrupt the complainant's business and create user confusion); see also VeriSign, Inc. v. Tandon, D2000-1216 (WIPO Nov. 16, 2000) (finding bad faith where the respondent has connections with a competitor of the complainant’s digital security business and the respondent indicated that she intended to enter the same business); see also 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).

 

Complainant argues that Respondent’s use of the <mycentury21agent.com> and <21realestate.com> domain names to resolve to Respondent’s competing website is an attempt to attract Internet users to Respondent’s commercial website by rendering it likely that users will become confused as to Complainant’s affiliation with the resulting website.  The Panel finds that by using portions of Complainant’s marks that have become distinctive in the real estate business to resolve to a website advertising Respondent’s real estate business with Complainant’s competitor, Respondent has created a likelihood of confusion for Respondent’s commercial gain, which is evidence of bad faith registration and use under Policy ¶ 4(b)(iv).  See Am. Online, Inc. v. Fu, D2000-1374 (WIPO Dec. 11, 2000) (finding that the respondent intentionally attempted to attract Internet users to his website for commercial gain by creating a likelihood of confusion with the complainant’s mark and offering the same chat services via his website as the complainant); 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 believing that the complainant is the source of or is sponsoring the services offered at the site).

 

Complainant has satisfied 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 <mycentury21agent.com> and <21realestate.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

Hon. Carolyn Marks Johnson, Panelist

Dated: July 5, 2005.

 

 

 

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