DECISION

 

NYSE Group, Inc. v. Mike Griffit c/o Nyse Brokers

Claim Number: FA0612000862744

 

PARTIES

Complainant is NYSE Group, Inc., New York, NY (“Complainant”) represented by Doreen L. Costa, of Baker Botts L.L.P.  Respondent is Mike Griffit c/o Nyse Brokers, New York (“Respondent”), of Mike Griffit c/o Nyse Brokers.

 

REGISTRAR AND DISPUTED DOMAIN NAME 

The domain name at issue is <nysebrokers.us>, registered with Enom, Inc.

 

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 (the “Forum”) electronically December 6, 2006; the Forum received a hard copy of the Complaint December 7, 2006.

 

On December 6, 2006, Enom, Inc. confirmed by e-mail to the Forum that the <nysebrokers.us> domain name is registered with Enom, Inc. and that Respondent is the current registrant of the name.  Enom, Inc. verified that Respondent is bound by the Enom, Inc. registration agreement and thereby has agreed to resolve domain-name disputes brought by third parties in accordance with the U. S. Department of Commerce’s usTLD Dispute Resolution Policy (the “Policy”).

 

On December 8, 2006, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”) setting a deadline of December 28, 2006, by which Respondent could file a Response to the Complaint, was transmitted to Respondent in compliance with Paragraph 2(a) of the Rules for usTLD Dispute Resolution Policy (the “Rules”).

 

Having received no Response from Respondent, the Forum transmitted to the parties a Notification of Respondent Default.

 

On January 4, 2007, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the Forum appointed Hon. Carolyn Marks Johnson as Panelist.

 

Having reviewed the communications records, the Administrative Panel (the “Panel”) finds that the Forum discharged its responsibility under Paragraph 2(a) of the Rules.  Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the Policy, the Rules, the 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 allegations in this proceeding:

 

1.      The domain name that Respondent registered, <nysebrokers.us>, is confusingly similar to Complainant’s NYSE mark.

 

2.      Respondent has no rights to or legitimate interests in the <nysebrokers.us> domain name.

 

3.      Respondent registered and used the <nysebrokers.us> domain name in bad faith.

 

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

 

FINDINGS

Complainant, NYSE Group, Inc., is the successor-in-interest to the New York Stock Exchange, founded in 1792.  Complainant’s main business activities include the operation of a securities exchange as well as ancillary and educational services provided to traders, investors, and the general public.  Many of the world’s leading corporations list their securities on Complainant’s securities exchange and widely promote and advertise their association with Complainant’s exchange under the NYSE mark.  Complainant maintains a website at the <nyse.com> domain name and holds the domain name registrations for numerous other domain names featuring its NYSE mark.

 

Complainant, through its predecessors in interest, has continuously used the NYSE mark since 1863 and has registered the NYSE mark with the United States Patent and Trademark Office (“USPTO”) (Reg. No. 909,350 issued March 2, 1971; Reg. No. 1,556,093 issued September 12, 1989; Reg. No. 2,665,267 issued December 24, 2002).

 

Respondent registered the <nysebrokers.us> domain name October 23, 2005.  Respondent maintains a website at the disputed domain name offering online securities brokerage services and prominently displaying the NYSE mark.  Complainant alleges that this website is part of a fraudulent phishing scheme aimed at deceiving consumers seeking investment advice.  Respondent’s website contains pictures and biographies of individuals associated with Respondent’s company, but Complainant claims that these employees and their biographies are fictitious and that none are registered brokers within the securities industry.

 

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 the Complainant's undisputed representations pursuant to Paragraphs 5(f), 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 the Respondent is identical or confusingly similar to a trademark or service mark in which the 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 or is being used in bad faith.

 

Given the similarity between the Uniform Domain Name Dispute Resolution Policy (“UDRP”) and the usTLD Policy, the Panel will draw upon UDRP precedent as applicable in rendering its decision.

 

Identical to and/or Confusingly Similar

 

Complainant established with extrinsic evidence in this proceeding that it has rights in the NYSE mark that is contained in its entirety within the disputed domain name.  Through registration of the NYSE mark with the USPTO, Complainant demonstrated its rights in the mark pursuant to Policy ¶ 4(a)(i).  See Thermo Electron Corp. v. Xu, FA 713851 (Nat. Arb. Forum July 12, 2006) (holding that the complainants established rights in marks because the marks were registered with a trademark authority); see also ESPN, Inc. v. MySportCenter.com, FA 95326 (Nat. Arb. Forum Sept. 5, 2000) (concluding that the complainant demonstrated its rights in the SPORTSCENTER mark through its valid trademark registrations with the USPTO and similar offices around the world).

 

The disputed domain name, <nysebrokers.us>, contains Complainant’s entire registered NYSE mark and simply adds the term “brokers,” a common term in Complainant’s securities exchange business.  In Am. Int’l Group, Inc. v. Ling Shun Shing, FA 206399 (Nat. Arb. Forum Dec. 15, 2003), the panel found that the respondent’s addition of the term “assurance” to the complainant’s AIG mark did not sufficiently differentiate the domain name from the mark because the appended term related directly to the complainant’s business.  Similarly, in Reed Elsevier Inc. v. Christodoulou, FA 97321(Nat. Arb. Forum June 26, 2001), the panel found that the <legallexis.com> and <legallexus.com> domain names were confusingly similar to the complainant’s LEXIS mark because the term “legal” describes the type of services the complainant offers under the LEXIS mark.  In this case, then, Respondent failed to sufficiently distinguish the <nysebrokers.us> domain name from Complainant’s NYSE mark by adding a descriptive term to the end of the mark.  Consequently, the Panel finds the disputed domain name to be confusingly similar to the mark pursuant to Policy ¶ 4(a)(i). 

 

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

 

Rights to or Legitimate Interests

 

Complainant established that it has rights to and legitimate interests in the mark contained in its entirety within the disputed domain name.  Complainant contends that Respondent lacks such rights and legitimate interests in the <nysebrokers.us> domain name.  Complainant must make a prima facie case in support of its allegations, and once Complainant does so, the burden shifts to Respondent to show it does have rights or legitimate interests pursuant to Policy ¶ 4(a)(ii).  See Hanna-Barbera Prods., Inc. v. Entm’t Commentaries, FA 741828 (Nat. Arb. Forum Aug. 18, 2006) (holding that the complainant must first make a prima facie case that the respondent lacks rights and legitimate interests in the disputed domain name under UDRP Policy ¶ 4(a)(ii) before the burden shifts to the respondent to show that it does have rights or legitimate interests in a domain name); see also AOL LLC v. Gerberg, FA 780200 (Nat. Arb. Forum Sept. 25, 2006) (“Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light.  If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names.”).

 

Respondent’s failure to answer the Complaint raises a presumption that Respondent has no rights or legitimate interests in the <nysebrokers.us> domain name.  See Eroski, So. Coop. v. Getdomains Ishowflat Ltd., D2003-0209 (WIPO July 28, 2003) (“It can be inferred that by defaulting Respondent showed nothing else but an absolute lack of interest on the domain name.”); see also Am. Express Co. v. Fang Suhendro, FA 129120 (Nat. Arb. Forum Dec. 30, 2002) (“[B]ased on Respondent's failure to respond, it is presumed that Respondent lacks all rights and legitimate interests in the disputed domain name.”).  However, the Panel examines the record to determine if it shows that Respondent has rights or legitimate interests under Policy ¶ 4(c).

 

Because Complainant established rights to the NYSE mark and Respondent has not come forward with any evidence showing it is the owner or beneficiary of a mark identical to the <nysebrokers.us> domain name, Complainant has satisfied Policy ¶ 4(c)(i).  See Meow Media Inc. v. Basil, FA 113280 (Nat. Arb. Forum Aug. 20, 2002) (finding that there was no evidence that the respondent was the owner or beneficiary of a mark that is identical to the <persiankitty.com> domain name); see also Pepsico, Inc. v. Becky, FA 117014 (Nat. Arb. Forum Sept. 3, 2002) (holding that because the respondent did not own any trademarks or service marks reflecting the <pepsicola.us> domain name, it had no rights or legitimate interests pursuant to Policy ¶ 4(c)(i). 

 

The record shows that Respondent registered the domain name under the name “Mike Griffit c/o Nyse Brokers,” but no evidence indicates that Respondent is commonly known the by <nysebrokers.us> domain name.   Complainant claims that it searched for information on the people listed on Respondent’s website at the disputed domain name and did not come up with any information, leading Complainant to believe that Respondent’s company name and its employees are fictitious.  Accordingly, the Panel concludes that Respondent has not established rights or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(c)(iii).  See Yahoo! Inc. v. Dough, FA 245971 (Nat. Arb. Forum May 5, 2004) (finding that although “the WHOIS information for the <yasexhoo.com> domain name states that the registrant is YASEXHOO . . . this alone is insufficient to show that Respondent is commonly known by the domain name.”); see also City News & Video v. Citynewsandvideo, FA 244789 (Nat. Arb. Forum May 5, 2004) (“Although Respondent’s WHOIS information lists its name as ‘citynewsandvideo,’ there is no evidence before the Panel to indicate that Respondent is, in fact, commonly known by the disputed domain name <citynewsandvideo.com> pursuant to Policy ¶ 4(c)(ii).”).

 

Furthermore, the <nysebrokers.us> domain name, which includes Complainant’s NYSE mark, appears to be part of a fraudulent phishing scheme whereby Respondent prominently displays Complainant’s registered NYSE mark and promotes Respondent’s securities brokerage services, deceiving Internet users as to Respondent’s affiliation with Complainant in order to obtain their personal and financial information.  The panel in HOPE worldwide, Ltd. v. Jin, FA 320379 (Nat. Arb. Forum Nov. 11, 2004), defined “phishing” as fooling Internet users into sharing personal financial data so that “identities can be stolen, fraudulent bills … run up, and spam e-mail … sent.”  The panel in that case found that the respondent’s use of the <hope-worldwide.org> domain name to divert Internet users to a website that imitated the complainant’s website in order to fraudulently acquire personal information from the complainant’s customers did not fall within the parameters of UDRP Policy ¶ 4(c)(i) or (iii).  Id.  Similar circumstances exist in the present case and the Panel finds that Respondent’s operation of a website that attempts to acquire personal and financial information from Internet users is a phishing expedition and does not constitute a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(ii) or a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iv).  See Capital One Fin. Corp. v. Howel, FA 289304 (Nat. Arb. Forum Aug. 11, 2004) (defining “phishing” as “a practice that is intended to defraud consumers into revealing personal and proprietary information” and concluding that the respondent’s practice of imitating the complainant’s website in order to fraudulently acquire personal information from Internet users was not a bona fide offering of goods or services under UDRP Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii)).

           

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

 

Registration and Use in Bad Faith

 

Complainant also alleged that Respondent acted in bad faith.  Respondent incorporated Complainant’s NYSE mark in its entirety within the disputed domain name and Respondent prominently displays Complainant’s registered mark when purporting to offer Respondent’s financial services at the website.  This is part of a phishing scheme.  Respondent is no doubt attempting to take advantage of the confusing similarity between the <nysebrokers.us> domain name and Complainant’s mark in order to attempt to profit from the goodwill associated with the mark.  Such use provides evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iv).  See MySpace, Inc. v. Myspace Bot, FA 672161 (Nat. Arb. Forum May 19, 2006) (holding that the respondent registered and used the <myspacebot.com> domain name in bad faith by diverting Internet users seeking the complainant’s website to its own website for commercial gain because the respondent likely profited from this diversion scheme); 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.”).

 

Moreover, the Panel has found that the disputed website is part of a fraudulent phishing scheme whereby Respondent is attempting to acquire personal and financial information from consumers by promoting itself as being affiliated with Complainant and its NYSE mark and purporting to offer investment advice.  The Panel finds that Respondent’s fraudulent conduct provides further evidence of bad faith registration and use under Policy ¶ 4(a)(iii).  See Hess Corp. v. GR, FA 770909 (Nat. Arb. Forum Sept. 19, 2006) (finding that the respondent demonstrated bad faith registration and use because it was attempting to acquire the personal and financial information of Internet users through a confusingly similar domain name); see also Wells Fargo & Co. v. Maniac State, FA 608239 (Nat. Arb. Forum Jan. 19, 2006) (finding bad faith where the respondent registered the <wellsbankupdate.com> domain name in order to fraudulently acquire the personal and financial information of the complainant’s customers).

 

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

 

DECISION

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

 

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

 

 

Hon. Carolyn Marks Johnson, Panelist

Dated: January 18, 2007.

 

Click Here to return to the main Domain Decisions Page.

 

Click Here to return to our Home Page

 


NATIONAL ARBITRATION FORUM