National Arbitration Forum

 

DECISION

 

OnQ LLC v. Clinton Fein

Claim Number: FA0510000583019

 

PARTIES

Complainant is OnQ LLC (“Complainant”), 243 Lakeview Way, Emerald Hills, CA 94062.  Respondent is Clinton Fein (“Respondent”), Suite 407, 555 Florida Street, San Francisco, CA 94110.

 

REGISTRAR AND DISPUTED DOMAIN NAME 

The domain name at issue is <onq.com>, registered with Network Solutions, 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.

 

Richard Hill as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on October 20, 2005; the National Arbitration Forum received a hard copy of the Complaint on October 31, 2005.

 

On October 25, 2005, Network Solutions, Inc. confirmed by e-mail to the National Arbitration Forum that the <onq.com> domain name is registered with Network Solutions, Inc. and that Respondent is the current registrant of the name.  Network Solutions, Inc. has verified that Respondent is bound by the Network Solutions, 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 November 8, 2005, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of November 28, 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@onq.com by e-mail.

 

A timely Response was received and determined to be complete on November 28, 2005.

 

On December 9, 2005, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Richard Hill as Panelist.

 

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

 

PARTIES’ CONTENTIONS

A. Complainant

 

Complainant, OnQ LLC was established in California in June 2004 to offer promotional and marketing services for a wide range of Fortune 500 retail-sales companies.  It has filed an application for a trademark to be used within the context of retail displays.

 

Complainant alleges that Respondent does not assert ownership of any registered mark for ONQ.

 

When Complainant first looked into registering the disputed domain name, that domain name pointed to a URL with the mention “for sale,” with Respondent requesting upwards of $800,000 for the domain name.  Finding this too high, Complainant instead registered <onqsolutions.com>.

 

For the past two years, according to Complainant, the disputed domain name pointed to a page with the mention “for sale,” but the site recently was changed to say “coming soon.”

 

Complainant alleges that bad faith registration and use is proven by the fact that Respondent, in an e-mail, clearly stated that the domain name is for sale, and, in a telephone conversation, quoted the price as between $80,000 and $100,000.  Respondent has held the domain name for a number of years, yet has made no use of it, thus, alleges Complainant, Respondent’s interest in acquiring the disputed domain name could only have been for the purposes of selling it, a classic case of cyber-squatting.  According to Respondent, this constitutes evidence of bad faith in accordance with 4(b)(i) of the Policy.

 

B. Respondent

Respondent alleges that Complainant is engaging in Reverse Domain Name Hijacking, that confusion is unlikely, and that the disputed domain name has been used to provide bona fide goods and services.

 

Respondent states that it neither registered nor acquired the domain name for the purpose of selling, renting, or otherwise transferring the domain name registration, least of all to Complainant, who did not exist at the time the domain was registered.

 

According to Respondent, Complainant has not established that the disputed domain name is identical or confusingly similar to a trademark or service-mark in which Complainant has rights.

 

According to Respondent, the Panel, in order to determine whether there is a likelihood of confusion, should look at factors such as: (1) the degree of similarity between the marks in appearance and suggestion; (2) the similarity of products or services for which the name is used; (3) the area and manner of concurrent use; (4) the degree of care likely to be exercised by consumers; (5) the strength of Complainant’s mark; (6) actual confusion; and (7) an intent on the part of the alleged infringer to palm-off his products as those of another.  Weighted against these criteria, there is not one factor that would suggest a likelihood of confusion in the present case.

 

Respondent alleges that it registered the disputed domain name in January 1996 to develop and deliver online media content, which was delivered under the OnQ banner through America Online.  At its peak, OnQ was the single most popular forum on America Online, visited over five million times a month.

 

Subsequently, the domain name was no longer used.  Respondent acknowledges that it considered selling the contested domain name after it was evaluated by an independent third party, in July 2004.  However, as no offer was sufficiently high, Respondent chose to retain the domain name for use related to an online service currently in development.

 

Respondent reiterates several times that it could not possibly have acted in bad faith with respect to Complainant because it registered the disputed domain name before Complainant existed.

 

It invokes the AntiCyberquatting Consumer Protection Act, 15 U.S.C. § 1116, to claim an award of costs and attorney’s fees, on the grounds that Complainant has knowingly made a false representation that the disputed domain name is identical or confusingly similar to a mark.  It does not quantify its claim for a monetary award.

 

FINDINGS

Complainant has been in business under the name ONQ since June 2004.

 

Respondent registered the contested domain name in January 1996 and used it to provide bone fide goods and services, in particular content delivered under the OnQ banner via America Online.

 

Respondent offered to sell the contested domain name for a price well in excess of out-of-pocket costs.

 

DISCUSSION

Paragraph 15(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (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.”

 

Paragraph 4(a) of the Policy requires that the 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 the Respondent is identical or confusingly similar to a trademark or service mark in which the Complainant has rights;

(2)   the 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

 

Respondent argues that, in order to find confusing similarity, this Panel must consider the same factors as would be considered by a national court in a trademark infringement action.  Such is not the case.  It is well established that, under the Policy, a prima-facie comparison of the disputed domain name with the trademark suffices to establish confusing similarity.  As the Panel said in Broadcom Corp. v. Becker, FA 98819 (Nat. Arb. Forum October 22, 2001):

 

Respondent is under the mistaken impression that this Panel is bound by US trademark law when determining the issue of confusing similarity.  Such is not the case.  Indeed Paragraph 15(a) of the Policy requires the Panel to:

 

decide a complaint on the basis of … these Rules and any rules and principles of law that it deems applicable.

 

That is, the Panel has broad latitude to adopt whatever criterion for confusion that it considers appropriate.

 

Panels have consistently held that strict application of the confusion criteria arising out of national trademark laws is not appropriate, and that a broader notion of confusion should be used in these proceedings.

 

This principle is well stated in WIPO case D2000-0047 <eautolamps.com>:

 

When a domain name incorporates, in its entirety, a distinctive mark, that creates sufficient similarity between the mark and the domain name to render it confusingly similar. Accordingly, the Panel holds that Complainant has satisfied the first prong of the ICANN test.

 

Furthermore it is clear the mere addition of letters or words to a trademark does not create a distinct mark and results in a domain name that is confusingly similar to the mark in question.  See for example the Forum’s case FA0095762 <victoriasecret.com>; WIPO case D2001-0026 <guinessguide.com> (finding confusing similarity where the domain name in dispute contains the identical mark of the complainant combined with a generic word or term); and WIPO case D2000-1214 <bodyshopdigital.com> (finding that the domain name <bodyshopdigital.com> is confusingly similar to the complainant’s THE BODY SHOP trademark).

 

Complainant has provided evidence to the effect that it operates a business under the name ONQ.  Thus, it has common law trademark rights.

 

The disputed domain name is clearly identical to Complainant’s common law trademark.

 

The Panel holds that Complainant has met its burden of proving this element of the policy.

 

Rights or Legitimate Interests

 

Respondent has provided ample evidence to show that it registered and used the disputed domain name to provide bona fide goods and services, namely content distributed via American Online.  This establishes a legitimate interest in accordance with ¶¶ 4(c)(i) and (ii) of the Policy.

 

The fact that it subsequently ceased to use the disputed domain name and offered it for sale does not mean that Respondent lost its legitimate interest.  On the contrary, as discussed further below, offering to sell a domain name is, in itself, a bona fide use, absent other circumstances indicating bad faith.

 

The Panel holds that Respondent has a legitimate interest in the disputed domain name.

 

Registration and Use in Bad Faith

 

Complainant invokes 4(b)(i) of the Policy, according to which the following constitutes evidence of bad faith registration and use:

 

Circumstances indicating that you have registered or you have acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of a trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documents out-of-pocket costs directly related to the domain name

 

Respondent could not possibly have registered the disputed domain name for the purposes of selling it to the Complainant, because the Complainant didn’t exist at the time the disputed domain name was registered.  Furthermore, the Complainant didn’t have a trademark (registered or otherwise) at that time, since the Complainant had not yet started its business operations.

 

Thus, this allegation of bad faith must fail.  Similar reasoning can be found in Ode v. Intership Ltd., D2001-0074 (WIPO May 1, 2001) (“[W]e are of the unanimous view that the trademark must predate the domain name.”); Aspen Grove, Inc. v. Aspen Grove, D2001-0798 (WIPO Oct. 5, 2001) (finding that it is “impossible” for the respondent to register disputed domain name in bad faith if the complainant's company did not exist at the time of registration).

 

Complainant does not argue, much less provide evidence for, any other type of bad faith behavior by Respondent.

 

Complainant makes much of the fact that Respondent offered to sell the disputed domain name for a price well in excess of out-of-pocket costs.  This fact is not disputed.  But, as the Panel stated in Manchester Airport PLC v. Club Club Limited, D 2000-0638 (WIPO August 22, 2000):

 

[S]elling a domain name is not per se prohibited by the ICANN Policy (nor is it illegal or even, in a capitalist system, ethically reprehensible).  Selling of domain names is prohibited by the ICANN Policy only if the other elements of the ICANN Policy are also violated, namely trademark infringement and lack of legitimate interest.

 

Such is clearly not the case here.  Indeed, this case is similar in this respect to Mark Warner 2001 v. Larson, FA 95746 (Nat. Arb. Forum Nov. 15, 2000) (finding that considering or offering to sell a domain name is insufficient to amount to bad faith under the Policy; the domain name must be registered primarily for the purpose of selling it to the owner of a trademark for an amount in excess of out-of-pocket expenses); and LifePlan v. Life Plan, FA 94826 (Nat. Arb. Forum July 13, 2000) (“[T]he mere offering [of the domain name for sale], without more, does not indicate circumstances suggesting that Respondent registered the domain name primarily for the purpose of selling, renting, or transferring the domain name to the complainant as required under [Policy ¶ 4(b)(i)].”)

 

The Panel holds that Complainant has not met its burden of proving bad faith registration and use.

 

Reverse Domain Name Hijacking

 

Paragraph 1 of the Rules defines Reverse Domain Name Hijacking:

 

Reverse Domain Name Hijacking means using the Policy in bad faith to attempt to deprive a registered domain-name holder of a domain name.

 

The general conditions for a finding of bad faith on the part of the complainant are well stated in Smart Design LLC v. Carolyn Hughes D2000-0993 (WIPO, October 18, 2000):

 

Clearly, the launching of an unjustifiable Complaint with malice aforethought qualifies, as would the pursuit of a Complaint after the Complainant knew it to be insupportable.

 

These conditions are confirmed in Goldline International, Inc. v. Gold Line, D2000-1151 (WIPO, January 4, 2001) and Sydney Opera House Trust v. Trilynx Pty. Limited, D2000-1224 (WIPO, October 31, 2000) (where the condition is stated as “the respondent must show knowledge on the part of the complainant of the respondent’s right or legitimate interest in the disputed domain name and evidence of harassment or similar conduct by the complainant in the face of such knowledge”), which in turn cites Plan Express Inc. v. Plan Express D2000-0565 (WIPO, July 17, 2000).

 

Complainant’s only allegation of bad faith registration and use is based on the fact that Respondent offered to sell the disputed domain name for a price well in excess of out-of-pocket costs.  But 4(b)(i) of the Policy clearly states that such behavior is to be considered in bad faith only if the disputed domain name was acquired primarily for the purpose of selling it to Complainant who is the owner of the trademark.

 

Complainant did not exist when Respondent registered the disputed domain name, and Complainant was well aware of this.  Thus, Complainant should have known that its Complaint was groundless and doomed to failure from the start.

 

The Panel holds that filing the Complaint—in the face of clear knowledge that it must fail—amounts to abuse of the administrative proceeding and Reverse Domain Name Hijacking.

 

However, the Panel has no power to award costs or other damages.  Indeed, 4(i) of the Policy explicitly restricts the Panel’s power to ordering, if justified, “the cancellation of your domain name or the transfer of your domain name registration to the complainant”.

 

DECISION

For the reasons set forth above, the Panel concludes that relief shall be DENIED.  The Complaint is dismissed.

 

The Panel concludes that Complainant has engaged in Reverse Domain Name Hijacking.

 

 

 

Richard Hill, Panelist
Dated: December 27, 2005

 

 

 

 

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