national arbitration forum

 

DECISION

 

Nike, Inc. v. shopkorea

Claim Number:  FA0506000496892

 

PARTIES

 

Complainant is Nike, Inc. (“Complainant”), represented by Philip Davison, One Bowerman Drive, DF/4, Beaverton, OR 97005.  Respondent is shopkorea (“Respondent”), 114, Yeoksam-dong, Gangnam-gu, Seoul, 135080, KR.

 

REGISTRAR AND DISPUTED DOMAIN NAME

 

The domain name at issue is <nikeplus.com>, registered with Wooho T&C Co., Ltd. d/b/a Rgnames.com.

 

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.

 

Louis E. Condon as Panelist.

 

PROCEDURAL HISTORY

 

Complainant submitted a Complaint to the National Arbitration Forum electronically on June 15, 2005; the National Arbitration Forum received a hard copy of the Complaint on June 15, 2005.

 

On June 29, 2005, Wooho T&C Co., Ltd. d/b/a Rgnames.com confirmed by e-mail to the National Arbitration Forum that the domain name <nikeplus.com> is registered with Wooho T&C Co., Ltd. d/b/a Rgnames.com and that Respondent is the current registrant of the name.  Wooho T&C Co., Ltd. d/b/a Rgnames.com has verified that Respondent is bound by the Wooho T&C Co., Ltd. d/b/a Rgnames.com 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 24, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of July 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@nikeplus.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 20, 2005, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Louis E. Condon 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 <nikeplus.com> domain name is confusingly similar to Complainant’s NIKE mark.

 

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

 

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

 

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

 

FINDINGS

 

Complainant, Nike, Inc., designs, manufactures and markets a broad range of athletic and athleisure footwear, apparel and equipment.  Complainant is the world’s leading sports and fitness company.

 

Complainant holds numerous registrations with the United States Patent and Trademark Office (“USPTO”) for the NIKE mark (including Reg. No. 978,952 issued February 19, 1974; Reg. No. 1,153,938 issued May 12, 1981; and Reg. No. 1,243,248 issued June 21, 1983).  Furthermore, Complainant has registered the mark in many foreign jurisdictions as well.  Complainant first used its NIKE mark in 1971 and has used the mark continuously since that time.

 

Additionally, Complainant has spent millions of dollars to advertise and promote its NIKE mark and has sold billions of dollars in merchandise under its NIKE mark.  Complainant’s NIKE mark has become famous and has acquired extraordinarily valuable goodwill which is associated with and owned by Complainant.

 

Respondent registered the <nikeplus.com> domain name on September 30, 2004.  The domain name resolves to a website that features a generic search engine and displays links to various products and services.  One of the links is to Complainant, while most of the other links are to businesses unrelated to Complainant.  In addition, the Panel presumes that Respondent earns commissions via click-through fees for diverting users to third-party websites via the website at the disputed 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 asserts rights in the NIKE mark due to its registration of the mark with the USPTO and with other trademark authorities worldwide.  It is well-established under the Policy that a complainant’s registration of a mark with a federal authority is prima facie evidence of the complainant’s rights.  See 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.”); 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.”).  Thus, Complainant’s registration of its mark creates a presumption of rights in Complainant’s favor, which shifts the burden of rebuttal to 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.  The respondent has the burden of refuting this assumption.”).  Without a response from Respondent, there is no challenge to Complainant’s prima facie case of rights in the mark.  The Panel, therefore, finds that Complainant has rights in the mark for the purposes of Policy ¶ 4(a)(i).

 

The <nikeplus.com> domain name includes Complainant’s NIKE mark in its entirety, adding only the generic or descriptive word “plus” and the generic top-level domain (gTLD) “.com.”  Prior panels have consistently held that adding a generic or descriptive term to a complainant’s mark will not prevent a domain name from being deemed confusingly similar to the mark.  See Nikon, Inc. v. Technilab, Inc., D2000-1774 (WIPO Feb. 26, 2001) (holding that confusing similarity under the Policy is decided upon the inclusion of a trademark in the domain name rather than upon the likelihood of confusion test under U.S. trademark law); see also Pfizer, Inc. v. Suger, D2002-0187 (WIPO Apr. 24, 2002) (finding that because the subject domain name incorporates the VIAGRA mark in its entirety, and deviates only by the addition of the word “bomb,” the domain name is rendered confusingly similar to the complainant’s mark); see also Sony Kabushiki Kaisha v. Inja, Kil, D2000-1409 (WIPO Dec. 9, 2000) (finding that “[n]either the addition of an ordinary descriptive word . . . nor the suffix ‘.com’ detract from the overall impression of the dominant part of the name in each case, namely the trademark SONY” and thus Policy ¶ 4(a)(i) is satisfied).  The Panel discerns no reason to distinguish this case from established precedent and holds that the disputed domain name is confusingly similar to Complainant’s NIKE mark under Policy ¶ 4(a)(i). 

 

The Panel finds that Complainant has satisfied the requirements of 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 by establishing a prima facie case, the Panel will now conduct an analysis of whether Respondent has met its burden to establish rights or legitimate interests in the disputed domain name under Policy ¶ 4(c).

 

Complainant asserts that Respondent is not commonly known by the NIKE mark or the <nikeplus.com> domain name and that Complainant has not licensed or otherwise permitted Respondent to use Complainant’s mark or any variation thereof.  Since the Panel has not received a response from Respondent, the Panel is left with no evidence to rebut Complainant’s contentions.  Therefore, the Panel finds that Respondent has not established rights or legitimate interests in the disputed domain name under Policy ¶ 4(c)(ii).  See 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 Ian Schrager Hotels, L.L.C. v. Taylor, FA 173369 (Nat. Arb. Forum Sept. 25, 2003) (finding that without demonstrable evidence to support the assertion that a respondent is commonly known by a domain name, the assertion must be rejected); see also Pavillion Agency, Inc. v. Greenhouse Agency Ltd., D2000-1221 (WIPO Dec. 4, 2000) (finding that the respondents’ failure to respond can be construed as an admission that they have no legitimate interest in the domain names).

 

It has been widely held under the Policy that a respondent’s use of a domain name that contains a complainant’s mark to attract Internet users to a website that displays links through which the respondent presumably earns click-through fees is not 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).  See Black & Decker Corp. v. Clinical Evaluations, FA 112629 (Nat. Arb. Forum June 24, 2002) (holding that the respondent’s use of the disputed domain name to redirect Internet users to commercial websites, unrelated to the complainant and presumably with the purpose of earning a commission or pay-per-click referral fee did not evidence rights or legitimate interests in the domain name); see also Computer Doctor Franchise Sys., Inc. v. Computer Doctor, FA 95396 (Nat. Arb. Forum Sept. 8, 2000) (finding that the respondent’s website, which is blank but for links to other websites, is not a legitimate use of the domain names).  Respondent is using the <nikeplus.com> domain name to divert Internet users to a generic search engine website that displays a variety of commercial links to various products and services.  Some of the links are to Complainant or Complainant’s competitors, while some are to sites unrelated to Complainant’s business.  In addition, Respondent has not offered any arguments to contest Complainant’s contentions that Respondent 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 legitimate interests under Policy ¶ 4(c)(i) or (iii).  See 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.”).

 

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

 

Registration and Use in Bad Faith

 

The <nikeplus.com> domain name resolves to a website that displays links to a variety of products and services as well as a generic search engine.  The Panel infers that Respondent receives a commission for diverting Internet users to third-party websites via the search engine and links at Respondent’s website.  Furthermore, by using Complainant’s famous NIKE mark in the domain name, Respondent is creating a likelihood of confusion and attempting to attract Internet users to Respondent’s website for Respondent’s commercial gain.  The Panel finds that Respondent’s activities are evidence of bad faith registration and use under Policy ¶ 4(b)(iv).  See 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 Am. Online, Inc. v. Tencent Commc’ns Corp., FA 93668 (Nat. Arb. Forum Mar. 21, 2000) (finding bad faith where the respondent registered and used a domain name confusingly similar to the complainant’s mark to attract users to a website sponsored by the respondent); see also Am. Univ. v. Cook, FA 208629 (Nat. Arb. Forum Dec. 22, 2003) (“Registration and use of a domain name that incorporates another's mark with the intent to deceive Internet users in regard to the source or affiliation of the domain name is evidence of bad faith.”).

 

Furthermore, Complainant’s registration of the <nikeplus.com> domain name, which contains Complainant’s famous NIKE mark in its entirety, suggests that Respondent knew of Complainant’s rights in the mark.  Complainant has spent millions of dollars to advertise and promote its mark throughout the world and has acquired substantial goodwill in its mark, causing the public to associate the NIKE mark with Complainant’s goods and services.  In light of these circumstances, the Panel finds that Respondent chose the disputed domain name due to the fame of Complainant’s NIKE mark.  Respondent’s registration of a domain name that contains Complainant’s mark despite Respondent’s knowledge of Complainant’s rights in the mark is evidence of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).  See Digi Int’l v. DDI Sys., FA 124506 (Nat. Arb. Forum Oct. 24, 2002) (holding that “there is a legal presumption of bad faith, when Respondent reasonably should have been aware of Complainant’s trademarks, actually or constructively”); see also 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); see also Exxon Mobil Corp. v. Fisher, D2000-1412 (WIPO Dec. 18, 2000) (finding that the respondent had actual and constructive knowledge of the complainant’s EXXON mark given the worldwide prominence of the mark and thus the respondent registered the domain name in bad faith).

 

The Panel finds that Complainant has satisfied the requirements of Policy ¶ 4(a)(iii).

 

DECISION

 

Complainant having established all three elements required under the ICANN Policy, the Panel concludes that relief should be GRANTED.

 

Accordingly, it is Ordered that the <nikeplus.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

 

 

Louis E. Condon, Panelist

Dated:  August 2, 2005

 

 


 

 

 

 

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