national arbitration forum

 

DECISION

 

The PNC Financial Services Group, Inc. v. IDLRG

Claim Number:  FA0506000495473

 

PARTIES

Complainant, The PNC Financial Services Group, Inc. (“Complainant”), is represented by Mark Sommers of Finnegan Henderson Farabow Garrett & Dunner LLP, 901 New York Avenue NW, Washington, DC 20001, USA.  Respondent is IDLRG  (“Respondent”), Kalian, P.O. Bhilowal, Hoshiarpur, Punjab 146104, INDIA.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <pncbankcreditcard.com>, registered with DotRegistrar.

 

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.

 

Honorable Paul A. Dorf (Ret.) as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on June 13, 2005; the National Arbitration Forum received a hard copy of the Complaint on June 14, 2005.

 

On June 15, 2005, DotRegistrar confirmed by e-mail to the National Arbitration Forum that the domain name <pncbankcreditcard.com> is registered with DotRegistrar and that Respondent is the current registrant of the name.  DotRegistrar has verified that Respondent is bound by the DotRegistrar 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@pncbankcreditcard.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 July 11, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Honorable Paul A. Dorf (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 <pncbankcreditcard.com> domain name is confusingly similar to Complainant’s PNC, PNCBANK, and PNCBANK.COM marks.

 

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

 

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

 

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

 

FINDINGS

 

Complainant, PNC Financial Services Group Inc., is one of the largest national diversified financial service organizations in the United States.  Complainant offers a full range of banking and financial services, including the bankcards for individuals and businesses.  Complainant advertises and promotes its PNC, PNCBANK, and PNCBANK.COM marks on the Internet at its main website <pnc.com> and <pncbank.com>.

 

Complainant holds a number of trademark registrations with the United States Patent and Trademark Office (“USPTO”) for its PNC (E.g., Reg. No. 1,416,898 issued Nov. 11, 1986), PNCBANK (E.g., Reg. No. 1,863,311 issued Nov. 15, 1994), and PNCBANK.COM (E.g., Reg. No. 2,188,742 issued Sep. 15, 1998) marks.

 

Respondent registered the <pncbankcreditcard.com> domain name on October 5, 2004.  Respondent uses the domain name for a pay-per-click website, advertising sponsored links for numerous categories, including credit, loans, online banking, and finance.  Some of the advertised links directly compete with Complainant’s business.  Moreover, upon reaching Respondent’s website, a pop-up advertisement appears in a separate window, displaying links to businesses that are 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 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

 

Because Complainant holds several registrations with the USPTO for its marks, Complainant has presented a prima facie case of rights in the mark.  See 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.”); see also Innomed Techs., Inc. v. DRP Servs., FA 221171 (Nat. Arb. Forum Feb. 18, 2004) (“Registration of the NASAL-AIRE mark with the USPTO establishes Complainant's rights in the mark.”).  Without a response from Respondent, the Panel lacks any evidence that would dispute Complainant’s presumption of rights.  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.”).  Thus, the Panel holds that Complainant has established rights for purposes of Policy ¶ 4(a)(i).

 

Respondent’s <pncbankcreditcard.com> domain name incorporates Complainant’s PNCBANK.COM mark and adds generic terms that clearly relate to some of the services Complainant provides.  The Panel finds that such an addition is insufficient to distinguish Respondent’s domain name from Complainant’s mark.  Thus, the disputed domain name is confusingly similar to Complainant’s marks pursuant to Policy ¶ 4(a)(i).  See 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 is 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 is engaged, does not take the disputed domain name out of the realm of confusing similarity).

 

Thus, the Panel finds that Complainant has satisfied Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

 

Complainant’s assertion that Respondent does not have rights or legitimate interests in the <pncbankcreditcard.com> domain name establishes a prima facie case.  Consequently, the burden shifts to Respondent to demonstrate that it does have rights or legitimate interests in the domain name by fitting within one of the examples of Policy ¶ 4(c).  See Compagnie Generale des Matieres Nucleaires v. Greenpeace Int’l, D2001-0376 (WIPO May 14, 2001):

 

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”). 

 

Complainant argues that Respondent does not fit within Policy ¶ 4(c)(ii) because it is not commonly known by the disputed domain name.  Respondent has not provided any evidence to counter Complainant’s assertions.  Without evidence to indicate that Respondent is commonly known by the disputed domain name, the Panel finds that Respondent failed to meet its burden and has not established rights or legitimate interests 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 the respondent does not have rights in a domain name when the respondent is not known by the mark); see also Bank of Am. Corp. v. McCall, FA 135012 (Nat. Arb. Forum Dec. 31, 2002) (“Respondent's failure to respond not only results in its failure to meet its burden, but also will be viewed as evidence itself that Respondent lacks rights and legitimate interests in the disputed domain name.”). 

 

Furthermore, Complainant argues that Respondent does not have rights or legitimate interests in the domain name because Respondent’s website features pay-per-click links and pop-up windows that advertise services that directly compete with Complainant.  Such diversionary and competing use does not constitute 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 Bank of Am. Corp. v. Nw. Free Cmty. Access, FA 180704 (Nat. Arb. Forum Sept. 30, 2003) (“Respondent's demonstrated intent to divert Internet users seeking Complainant's website to a website of Respondent and for Respondent's benefit is not a bona fide offering of goods or services under Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).”); see also 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 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).  Moreover, Respondent’s failure to submit a response leads this Panel to accept as true Complainant’s allegations.  See Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (“Given Respondent’s failure to submit a substantive answer in a timely fashion, the Panel accepts as true all of the allegations of the complaint.”).  Thus, the Panel concludes that Respondent does not have rights or legitimate interests in the domain name pursuant to Policy ¶ 4(c)(i) or (iii). 

 

Accordingly, the Panel finds that Complainant has satisfied Policy ¶ 4(a)(ii).

 

 

 

 

Registration and Use in Bad Faith

 

Respondent registered and is using the confusingly similar <pncbankcreditcard.com> domain name to operate a website for commercial gain by creating a likelihood of confusion with Complainant’s marks and commercially benefiting from it by means of pay-per-click links.  The Panel concludes that Respondent’s commercial gain constitutes bad faith registration and use pursuant to Policy ¶ 4(b)(iv).  See MathForum.com, LLC v. Weiguang Huang, D2000-0743 (WIPO Aug. 17, 2000) (finding bad faith under Policy ¶ 4(b)(iv) where the respondent registered a domain name confusingly similar to the complainant’s mark and the domain name was used to host a commercial website that offered similar services offered by the complainant under its mark); 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). 

 

Additionally, Respondent registered the <pncbankcreditcard.com> domain name with actual knowledge of Complainant’s rights in the PNC, PNCBANK, and PNCBANK.COM marks.  Respondent wholly incorporates Complainant’s marks and adds a generic term that relates to Complainant’s business.  This Panel infers that Respondent knew of Complainant’s mark due to the obvious link between the mark and the disputed domain name.  See Pfizer, Inc. v. Suger, D2002-0187 (WIPO Apr. 24, 2002) (finding that because the link between the complainant’s mark and the content advertised on the respondent’s website was obvious, the respondent “must have known about the Complainant’s mark when it registered the subject domain name”).  The Panel concludes that actual knowledge of Complainant’s mark constitutes bad faith registration and use under Policy ¶ 4(a)(iii).  See Samsonite Corp. v. Colony Holding, FA 94313 (Nat. Arb. Forum Apr. 17, 2000) (finding that evidence of bad faith includes actual or constructive knowledge of a commonly known mark at the time of registration). 

 

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

 

 

 

 

Honorable Paul A. Dorf (Ret.), Panelist

Dated:  July 26, 2005

 

 

 

 

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