national arbitration forum

 

DECISION

 

Focus on the Family v. NEOG Inc. c/o Domain Admins

Claim Number:  FA0506000493130

 

PARTIES

Complainant is Focus on the Family (“Complainant”), represented by Cynthia A. Casby of Holland & Knight LLP, 633 W. Fifth Street, Suite 2100, Los Angeles, CA 90071.  Respondent is NEOG Inc. c/o Domain Admins (“Respondent”), Sorena Tah. 4167, Istanbul, Turkey 48705.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <fokuspadakeluarga.net>, registered with Onlinenic, 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.

 

John J. Upchurch as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on June 7, 2005; the National Arbitration Forum received a hard copy of the Complaint on June 9, 2005.

 

On June 9, 2005, Onlinenic, Inc. confirmed by e-mail to the National Arbitration Forum that the domain name <fokuspadakeluarga.net> is registered with Onlinenic, Inc. and that Respondent is the current registrant of the name.  Onlinenic, Inc. has verified that Respondent is bound by the Onlinenic, 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 June 16, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of July 6, 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@fokuspadakeluarga.net 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 July 13, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed John J. Upchurch 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 <fokuspadakeluarga.net> domain name is identical to Complainant’s FOKUS PADA KELUARGA mark.

 

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

 

3.      Respondent registered and used the <fokuspadakeluarga.net> domain name in bad faith.

 

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

 

FINDINGS

Complainant, Focus on the Family, is a Christian ministry with its headquarters in Colorado Springs, CO.  Complainant has millions of constituents and seventeen affiliated ministry offices throughout the world.  Complainant’s Indonesian affiliate opened on January 18, 1995 and is well-known locally by its FOKUS PADA KELUARGA mark.  Complainant began using its famous FOCUS ON THE FAMILY mark in 1977 and has used its FOKUS PADA KELUARGA mark since at least April 1996. 

 

Complainant holds numerous registrations throughout the world and with the United States Patent and Trademark Office for its FOCUS ON THE FAMILY mark (Reg. No. 1,104,503 issued October 17, 1978 and Reg. No. 1,130,379 issued February 5, 1980) and corresponding foreign translations.  Complainant’s FOKUS PADA KELUARGA mark (Reg. No. 377990 registered August 4, 1997 and Reg. No. 377989 registered August 4, 1997) is registered in Indonesia with the Department of Justice of the Republic of Indonesia.

 

Respondent registered the <fokuspadakeluarga.net> domain name on September 2, 2004.  The disputed domain name resolves to a website that displays adult-oriented material and charges Internet users who wish to gain access to more adult-oriented material.  Prior to Respondent’s registration of the disputed domain name, Complainant had used the domain name to post information about its ministry for its constituents.  However, in the summer of 2004, Complainant allowed the disputed domain name to expire, at which time Respondent was able to register the domain name.

 

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

 

Complainant has provided evidence that it registered the FOKUS PADA KELUARGA mark with the Department of Justice of the Republic of Indonesia, which establishes a prima facie case of Complainant’s rights in the mark that can be rebutted by Respondent.  See Janus Int’l Holding Co. v. Rademacher, D2002-0201 (WIPO Mar. 5, 2002) (“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.”); see also Vivendi Universal Games v. XBNetVentures Inc., FA 198803 (Nat. Arb. Forum Nov. 11, 2003) (“Complainant's federal trademark registrations establish Complainant's rights in the BLIZZARD mark.”).  Since Respondent has not filed a response, Complainant’s prima facie case of rights in the mark has gone uncontested, and the Panel determines that Complainant has established rights in the FOKUS PADA KELUARGA mark for the purposes of Policy ¶ 4(a)(i).

 

The <fokuspadakeluarga.net> domain name includes Complainant’s FOKUS PADA KELUARGA mark in its entirety and differs from the mark only with the omission of the spaces between the words of the mark and the addition of the generic top-level domain (“gTLD”) “.net.”  Simply adding a gTLD to, and omitting spaces from, a complainant’s mark to form a domain name are not sufficient to create a distinct mark, because domain name registrants are required to add a TLD of some kind and cannot include spaces in domain names.  See 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”).  Therefore, the Panel finds that the disputed domain name is identical to Complainant’s mark under Policy ¶ 4(a)(i).

 

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

 

Rights or Legitimate Interests

 

It has been established under the Policy that the complainant has the initial burden of proving that the respondent lacks rights and legitimate interests in the disputed domain name.  In Compagnie Generale des Matieres Nucleaires v. Greenpeace Int’l, D2001-0376 (WIPO May 14, 2001), the panel held:

 

Proving that the Respondent has no rights or legitimate interests in respect of the Domain Name requires the Complainant to prove a negative. For the purposes of this sub paragraph, however, it is sufficient for the Complainant to show a prima facie case and the burden of proof is then shifted on to the shoulders of Respondent.  In those circumstances, the common approach is for respondents to seek to bring themselves within one of the examples of paragraph 4(c) or put forward some other reason why they can fairly be said to have a relevant right or legitimate interests in respect of the domain name in question.

 

Id.; see also Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (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”).  Having found that Complainant has met its initial burden in establishing a prima facie case, the Panel will now conduct an analysis of whether Respondent has met its burden to establish why it should be considered as having rights or legitimate interests in the disputed domain name under Policy ¶ 4(c).

 

Complainant contends that Respondent is not commonly known by the <fokuspadakeluarga.net> domain name and that Respondent is not affiliated in any way with Complainant or its mark.  The Panel has not received a response from Respondent to refute Complainant’s allegations, and the record does not contain any evidence that Respondent is commonly known by the disputed domain name.  Thus, Respondent has failed to establish rights or legitimate interests pursuant to Policy ¶ 4(c)(ii).  See Gallup, Inc. v. Amish Country Store, FA 96209 (Nat. Arb. Forum Jan. 23, 2001) (finding that the respondent does not have rights in a domain name when the respondent is not known by the mark); see also Compagnie de Saint Gobain v. Com-Union Corp., D2000-0020 (WIPO Mar. 14, 2000) (finding no rights or legitimate interest 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); see also Canadian Imperial Bank of Commerce v. D3M Virtual Reality Inc., AF-0336 (eResolution Sept. 23, 2000) (finding no rights or legitimate interests where no such right or interest was immediately apparent to the panel and the respondent did not come forward to suggest any right or interest it may have possessed).

 

Furthermore, Respondent is using the <fokuspadakeluarga.net> domain name to divert Internet users who may be searching for a website affiliated with Complainant’s Christian ministry to an adult-oriented website that charges fees to link users to various forms of adult-oriented material.  Respondent’s use of a domain name that contains Complainant’s mark to host an adult-oriented website does not constitute a bona fide offering of goods or services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii), especially where the material on the website is clearly at odds with Complainant’s use of its FOKUS PADA KELUARGA mark for Christian ministry work.  See Isleworth Land Co. v. Lost In Space, SA, FA 117330 (Nat. Arb. Forum Sept. 27, 2002) (finding that the respondent’s use of its domain name to link unsuspecting Internet traffic to an adult orientated website, containing images of scantily clad women in provocative poses, did not constitute a connection with a bona fide offering of goods or services or a noncommercial or fair use); see also Dipaolo v. Genero, FA 203168 (Nat. Arb. Forum Dec. 6, 2003) (“Diversion to pornography is not a bona fide offering of goods or services or a legitimate noncommercial or fair use of the domain name pursuant to Policy ¶¶ 4(c)(i) and (iii).”).  Additionally, Respondent has not offered any arguments to contest Complainant’s contentions that Responent has not made a bona fide offering of goods or services or a legitimate noncommercial or fair use of the domain name, which leads the Panel to the conclusion that Respondent has not established rights or legitmate interests under Policy ¶ 4(c)(i) or (iii).  See BIC Deutschland GmbH & Co. KG v. Tweed, D2000-0418 (WIPO June 20, 2000) (“By not submitting a response, Respondent has failed to invoke any circumstance which could demonstrate, pursuant to ¶ 4(c) of the Policy, any rights or legitimate interests in the domain name”). 

 

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

 

Registration and Use in Bad Faith

 

Respondent is using the <fokuspadakeluarga.net> domain name, which is identical to Complainant’s FOKUS PADA KELUARGA mark, to resolve to a website that displays adult-oriented material and charges Internet users fees to gain access to various other forms of adult-oriented material.  By using Complainant’s mark in the domain name to create a likelihood of confusion, Respondent is attempting to attract Internet users who are searching for Complainant’s products and services to Respondent’s website for Respondent’s commercial benefit.  Respondent’s activities are evidence of bad faith regisration and use under Policy ¶ 4(b)(iv).  See Bank of Am. Corp. v. Out Island Props., Inc., FA 154531 (Nat. Arb. Forum June 3, 2003) (stating that “[s]ince the disputed domain names contain entire versions of Complainant’s marks and are used for something completely unrelated to their descriptive quality, a consumer searching for Complainant would become confused as to Complainant’s affiliation with the resulting search engine website” in holding that the domain names were registered and used in bad faith pursuant to Policy ¶ 4(b)(iv)); see also G.D. Searle & Co. v. Celebrex Drugstore, FA 123933 (Nat. Arb. Forum Nov. 21, 2002) (finding that the respondent registered and used the domain name in bad faith pursuant to Policy ¶ 4(b)(iv) because the respondent was using the confusingly similar domain name to attract Internet users to its commercial website).

 

The Policy provides that a complainant may satisfy the bad faith registration and use requirement of Policy ¶ 4(a)(iii) by providing evidence of one of the listed circumstances found under Policy ¶ 4(b).  However, the Policy states explicity that a panel is not limited to the provided list in making a determination of bad faith registration and use.  See Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000) (“[T]he examples [of bad faith] in Paragraph 4(b) are intended to be illustrative, rather than exclusive.”); see also Twentieth Century Fox Film Corp. v. Risser, FA 93761 (Nat. Arb. Forum May 18, 2000):

 

The requirement in the ICANN Policy that a complainant prove that domain names are being used in bad faith does not require that it prove in every instance that a respondent is taking positive action. Use in bad faith can be inferred from the totality of the circumstances even when the registrant has done nothing more than register the names.

 

Id.  Thus, the Panel will make findings of bad faith based on the totality of the circumstances.

 

Panels have found that a respondent’s use of an infringing domain name to resolve to an adult-oriented website can alone constitute evidence of bad faith registration and use, especially where a respondent fails to provide any evidence to contradict this contention.  Furthermore, in this instance, where Complainant is a Christian ministry and has used the <fokuspadakeluarga.net> domain name in association with a website that displayed information about Complainant’s ministry for its constituents, the Panel finds that using Complainant’s mark for an adult-oriented website is damaging to the goodwill Complainant has acquired in its mark.  Thus, Respondent’s use of the disputed domain name to divert Internet users who may be searching for information about Complainant to an adult-oriented website is evidence of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).  See Wells Fargo & Co. v. Party Night Inc., FA 144647 (Nat. Arb. Forum Mar. 18, 2003) (finding that the respondent’s tarnishing use of the disputed domain names to redirect Internet users to adult-oriented websites was evidence that the domain names were being used in bad faith); see also Ty, Inc. v. O.Z. Names, D2000-0370 (WIPO June 27, 2000) (finding that absent contrary evidence, linking the domain names in question to graphic, adult-oriented websites is evidence of bad faith); see also CCA Indus., Inc. v. Dailey, D2000-0148 (WIPO Apr. 26, 2000) (finding that where the complainant “has placed substantial emphasis on the damage that it will suffer as a result of the linkage of its own trade mark” to a website that displays adult-oriented material, “this association with a pornographic web site can itself constitute a bad faith”).

 

Furthermore, Complainant contends that it previously held the registration for the <fokuspadakeluarga.net> domain name and operated a website at the domain name, which is further evidence that Respondent registered and used the disputed domain name in bad faith.  Without any response from Respondent to rebut this evidence, the Panel finds that Respondent’s registration of the disputed domain name, which contains Complainant’s mark, after Complainant allowed its registration to lapse is evidence of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).  See InTest Corp. v. Servicepoint, FA 95291 (Nat. Arb. Forum Aug. 30, 2000) (“Where the domain name has been previously used by the Complainant, subsequent registration of the domain name by anyone else indicates bad faith, absent evidence to the contrary.”); see also Aurbach v. Saronski, FA 155133 (Nat. Arb. Forum May 29, 2003) (“Where the domain name registration was previously held, developed and used by Complainant, opportunistic registration of the domain name by another party indicates bad faith, absent any justification that illustrates legitimate use.”).

 

The Panel finds that 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 <fokuspadakeluarga.net> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

 

 

John J. Upchurch, Panelist

Dated:  July 26, 2005

 

 

 

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