national arbitration forum

 

DECISION

 

Takeda Pharmaceutical Company Limited v. Internet Commerce Corp.

Claim Number: FA0703000933916

 

PARTIES

Complainant is Takeda Pharmaceutical Company Limited (“Complainant”), represented by B. Brett Heavner, of Finnegan, Henderson, Farabow, Garrett & Dunner, L.L.P., 901 New York Avenue NW, Washington, DC 20001.  Respondent is Internet Commerce Corp. (“Respondent”), 205 Enterprise Drive, Pekin, IL 61554.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <order-rozerem.com> and <rozerim.org>, registered with Network Solutions, 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.

 

Judge Ralph Yachnin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on March 7, 2007; the National Arbitration Forum received a hard copy of the Complaint on March 8, 2007.

 

On March 7, 2007, Network Solutions, Inc. confirmed by e-mail to the National Arbitration Forum that the <order-rozerem.com> and <rozerim.org> domain names are registered with Network Solutions, Inc. and that Respondent is the current registrant of the names.  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 March 12, 2007, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of April 2, 2007 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@order-rozerem.com and postmaster@rozerim.org by e-mail.

 

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

 

On April 6, 2007, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Judge Ralph Yachnin 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 names be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A.  Complainant makes the following assertions:

 

1.      Respondent’s <order-rozerem.com> and <rozerim.org> domain names are confusingly similar to Complainant’s ROZEREM mark.

 

2.      Respondent does not have any rights or legitimate interests in the <order-rozerem.com> and <rozerim.org> domain names.

 

3.      Respondent registered and used the <order-rozerem.com> and <rozerim.org> domain names in bad faith.

 

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

 

FINDINGS

Complainant, Takeda Pharmaceutical Company Limited, manufacturers and distributes a variety of pharmaceutical products.  In connection with the provision of these products and services, Complainant maintains common law rights in the ROZEREM mark, which identifies Complainant’s medication for insomnia.  Complainant asserts that its rights in the ROZEREM mark date to July 11, 2005.

 

Respondent registered the disputed domain names on August 26, 2005.  The <order-rozerem.com> domain name resolves to a website featuring listings for other websites offering competing products.  The <rozerim.org> domain name resolves to a website displaying advertisements and sponsored listings for various commercial websites.

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

 

Although Complainant does not maintain a federal trademark registration for its ROZEREM mark, previous panels have consistently held that common law rights in a mark are sufficient grounds to file a complaint under the UDRP.  See Great Plains Metromall, LLC v. Creach, FA 97044 (Nat. Arb. Forum May 18, 2001) (“The Policy does not require that a trademark be registered by a governmental authority for such rights to exist.”); see also SeekAmerica Networks Inc. v. Masood, D2000-0131 (WIPO Apr. 13, 2000) (finding that the Rules do not require that the complainant's trademark or service mark be registered by a government authority or agency for such rights to exist).

 

Complainant asserts rights in the ROZEREM mark from July 11, 2005, when Complainant introduced ROZEREM to the press.  Complainant maintains that it is the first user of the ROZEREM mark.  Subsequent to its initial release to the press, Complainant maintains it has generated substantial goodwill in the mark and has marketed the ROZEREM brand of pharmaceuticals.  The Panel, in light of the fact that Complainant’s rights in the mark predate Respondent’s registration of the disputed domain names, finds that Complainant has sufficiently established secondary meaning, and thus common law rights in the ROZEREM mark pursuant to Policy ¶ 4(a)(i).  See Nat’l Ass’n of Prof’l Baseball Leagues v. Zuccarini, D2002-1011 (WIPO Jan. 21, 2003) (finding that the complainant had provided evidence that it had valuable goodwill in the <minorleaguebaseball.com> domain name, establishing common law rights in the MINOR LEAGUE BASEBALL mark); see also Bibbero Sys., Inc. v. Tseu & Assoc., FA 94416 (Nat. Arb. Forum May 9, 2000) (finding, while the complainant had registered the BIBBERO SYSTEMS, INC. mark, it also had common law rights in the BIBBERO mark because it had developed brand name recognition with the word “bibbero”).

 

Complainant maintains that Respondent’s disputed domain names are confusingly similar to Complainant’s ROZEREM mark.  In the case of the <order-rozerem.com> domain name, the disputed domain name contains Complainant’s mark in its entirety, adds the generic term “order,” a hyphen, and the generic top-level domain (“gTLD”) “.com.”  In the case of the <rozerim.org> domain name, the disputed domain name is a common misspelling of Complainant’s ROZEREM mark.  Additionally, the disputed domain name contains the gTLD “.org.”  The Panel finds that, in the case of the <order-rozerem.com> domain name, the addition of a generic term, a hyphen, and a gTLD is insufficient to preclude a finding of confusing similarity pursuant to Policy ¶ 4(a)(i).  Additionally, the Panel finds that, in the case of the <rozerim.org> domain name, a common misspelling of a protected mark combined with the addition of a gTLD fails to sufficiently distinguish the disputed domain name from Complainant’s mark pursuant to Policy ¶ 4(a)(i).  See Isleworth Land Co. v. Lost in Space, SA, FA 117330 (Nat. Arb. Forum Sept. 27, 2002) (“[I]t is a well established principle that generic top-level domains are irrelevant when conducting a Policy ¶ 4(a)(i) analysis.”); see also Health Devices Corp. v. Aspen S T C, FA 158254 (Nat. Arb. Forum July 1, 2003) (“[T]he addition of punctuation marks such as hyphens is irrelevant in the determination of confusing similarity pursuant to Policy ¶ 4(a)(i).”); see also Belkin Components v. Gallant, FA 97075 (Nat. Arb. Forum May 29, 2001) (finding the <belken.com> domain name confusingly similar to the complainant's BELKIN mark because the name merely replaced the letter “i” in the complainant's mark with the letter “e”); see also Body Shop Int’l PLC v. CPIC NET, D2000-1214 (WIPO Nov. 26, 2000) (finding that the domain name <bodyshopdigital.com> is confusingly similar to the complainant’s THE BODY SHOP trademark).

 

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

                                                                                                                                                 

Rights or Legitimate Interests

 

In cases where Complainant has made a prima facie case in support of its allegations, the burden shifts to Respondent to set forth concrete evidence indicating that it has rights or legitimate interests in the disputed domain names.  See Clerical Med. Inv. Group Ltd. v. Clericalmedical.com, D2000-1228 (WIPO Nov. 28, 2000) (finding that, under certain circumstances, the mere assertion by the complainant that the respondent has no right or legitimate interest is sufficient to shift the burden of proof to the respondent to demonstrate that such a right or legitimate interest does exist); see also G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002) (“Because Complainant’s Submission constitutes a prima facie case under the Policy, the burden effectively shifts to Respondent.  Respondent’s failure to respond means that Respondent has not presented any circumstances that would promote its rights or legitimate interests in the subject domain name under Policy ¶ 4(a)(ii).”).

 

Respondent’s disputed domain names resolve to sponsored links websites featuring advertisements and lists of other commercial websites.  The Panel finds that such use is neither a bona fide offering of goods or services under Policy ¶ 4(c)(i) nor a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).  See 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); 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).

 

Complainant asserts that Respondent is not commonly known by the disputed domain names.  According to Respondent’s WHOIS registration information, the registrant of the <order-rozerem.com> and <rozerim.org> domain names is “Internet Commerce Corp.”  In light of the lack of countervailing evidence, the Panel finds that Respondent is not commonly known by the disputed domain names pursuant to Policy ¶ 4(c)(ii).  See Am. W. Airlines, Inc. v. Paik, FA 206396 (Nat. Arb. Forum Dec. 22, 2003) (“Respondent has registered the domain name under the name ‘Ilyoup Paik a/k/a David Sanders.’  Given the WHOIS domain name registration information, Respondent is not commonly known by the [<awvacations.com>] domain name.”); see also Wells Fargo & Co. v. Onlyne Corp. Services11, Inc., FA 198969 (Nat. Arb. Forum Nov. 17, 2003) (“Given the WHOIS contact information for the disputed domain [name], one can infer that Respondent, Onlyne Corporate Services11, is not commonly known by the name ‘welsfargo’ in any derivation.”).

 

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

 

Registration and Use in Bad Faith

 

Respondent’s <order-rozerem.com> domain name resolves to a website that features products that directly compete with Complainant’s products.  The Panel finds that Respondent’s use of a confusingly similar domain name to redirect unsuspecting Internet users to a website that offers competing products amounts to a disruption of Complainant’s business, which evinces registration and use in bad faith in accordance with Policy ¶ 4(b)(iii).  See EthnicGrocer.com, Inc. v. Latingrocer.com, FA 94384 (Nat. Arb. Forum July 7, 2000) (finding bad faith where the respondent’s sites pass users through to the respondent’s competing business); see also EBAY, Inc. v. MEOdesigns, D2000-1368 (WIPO Dec. 15, 2000) (finding that the respondent registered and used the domain name <eebay.com> in bad faith where the respondent has used the domain name to promote competing auction sites).

 

Both disputed domain names resolve to websites that display advertisements, from which Respondent presumably receives referral fees.  The Panel finds that such use to attract Internet users for commercial gain amounts to registration and use in bad faith pursuant to Policy ¶ 4(b)(iv).  See State Farm Mut. Auto. Ins. Co. v. Northway, FA 95464 (Nat. Arb. Forum Oct. 11, 2000) (finding that the respondent registered the domain name <statefarmnews.com> in bad faith because the respondent intended to use the complainant’s marks to attract the public to the web site without permission from the complainant); 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).

 

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

 

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 <order-rozerem.com> and <rozerim.org> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

Hon. Ralph Yachnin, Panelist

Justice, Supreme Court, NY (Ret.)

 

Dated:  April 13, 2007

 

 

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