national arbitration forum

 

DECISION

 

State Farm Mutual Automobile Insurance Company v. PMA Media Group c/o Dewey MacKay

Claim Number: FA0703000942510

 

PARTIES

Complainant is State Farm Mutual Automobile Insurance Company (“Complainant”), represented by Janice K. Forrest, of State Farm Mutual Automobile Insurance Company, One State Farm Plaza, A-3, Bloomington, IL 61710.  Respondent is PMA Media Group c/o Dewey MacKay (“Respondent”), 554 E. Technology Way, Orem, UT 84097.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <insurancestatefarmsaves.info>, registered with RegisterFly.com, 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.

 

Bruce E. Meyerson as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on March 19, 2007; the National Arbitration Forum received a hard copy of the Complaint on March 20, 2007.

 

On March 19, 2007, RegisterFly.com, Inc. confirmed by e-mail to the National Arbitration Forum that the <insurancestatefarmsaves.info> domain name is registered with RegisterFly.com, Inc. and that Respondent is the current registrant of the name.  RegisterFly.com, Inc. has verified that Respondent is bound by the RegisterFly.com, 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 20, 2007, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of April 9, 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@insurancestatefarmsaves.info by e-mail.

 

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

 

On April 14, 2007, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Bruce E. Meyerson 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 <insurancestatefarmsaves.info> domain name is confusingly similar to Complainant’s STATE FARM INSURANCE mark.

 

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

 

3.      Respondent registered and used the <insurancestatefarmsaves.info> domain name in bad faith.

 

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

 

FINDINGS

Complainant, State Farm Mutual Automobile Insurance Company, is a nationally known company conducting business in the insurance and financial services industries.  Complainant holds a registered trademark with the United States Patent and Trademark Office (“USPTO”) for the STATE FARM INSURANCE mark (Reg. No. 1,125,010 issued September 11, 1979).

 

Respondent, PMA Media Group c/o Dewey MacKay, registered the <insurancestatefarmsaves.info> domain name on July 19, 2006.  Respondent is using the disputed domain name to display a list of hyperlinks advertising the insurance services of Complainant’s competitors.

 

On November 14, 2006, a National Arbitration Forum panel issued an order requiring Respondent to transfer registration of the domain name <statefarmcarandhousecare.info> to Complainant.  The panel found that this domain name was confusingly similar to Complainant’s STATE FARM mark and was registered and used in bad faith by Respondent, who did not have any rights or legitimate interests in the mark.  State Farm Mut. Auto. Ins. Co. v. Dewey MacKay d/b/a PMA Media Grp., FA 811699 (Nat. Arb. Forum Nov. 14, 2006). 

 

Respondent has been previously ordered by National Arbitration Forum panels to transfer the domain name registrations of four other domain names that were found to be infringing upon the complainants’ trademarks.  The panels found that each of the domain names were confusingly similar to the complainants’ marks and were registered and used in bad faith by Respondent, who did not have any rights or legitimate interests in the marks.  E.g., Seiko Epson Corp. & Epson America, Inc. v. PMA Media Grp. c/o Dewey MacKay, FA 767167 (Nat. Arb. Forum Sept. 22, 2006) (transferring the <epsoninkcartridgesubstitute.com> and <epsoninkcartridges4less.com> domain names to the complainant); The Neiman Marcus Group, Inc. & NM Nevada Trust v. Dewey MacKay d/b/a PMA Media Grp., FA 813531 (Nat. Arb. Forum Nov. 22, 2006) (transferring the <neimanmarcuswear.info> and <marcusneimanstyle.info> domain names to the 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

 

Complainant’s registration of the STATE FARM INSURANCE mark with the USPTO in 1979 preceded Respondent’s registration of the <insurancestatefarmsaves.info> domain name in 2006.  Under the Policy, registration of a mark with an appropriate governmental authority confers rights in that mark to Complainant.  Thus, the Panel finds that Complainant has established rights in the STATE FARM INSURANCE mark pursuant to Policy ¶ 4(a)(i).  See Expedia, Inc. v. Emmerson, FA 873346 (Nat. Arb. Forum Feb. 9, 2007) (“Complainant’s trademark registrations with the USPTO adequately demonstrate its rights in the [EXPEDIA] mark pursuant to Policy ¶ 4(a)(i)); see also America Online, Inc. v. Thomas P. Culver Enters., D2001-0564 (WIPO June 18, 2000) (finding that successful trademark registration with the USPTO creates a presumption of rights in a mark).

 

Respondent’s <insurancestatefarmsaves.info> domain name incorporates Complainant’s STATE FARM INSURANCE mark in its entirety, but with the word “insurance” as the first word and the addition of the word “saves” and the generic top-level domain (“gTLD”) “.info.”  The inversion of the words in Complainant’s mark does not avoid a finding of confusing similarity because the mark retains the same meaning.  The addition of the generic word “saves,” which describes an aspect of Complainant’s business, also does not sufficiently distinguish the disputed domain name from Complainant’s mark.  Finally, the addition of a gTLD is without relevance to this analysis because it is a requirement of every registered domain name.  Therefore, the Panel finds that Respondent’s <insurancestatefarmsaves.info> domain name is confusingly similar to Complainant’s STATE FARM INSURANCE mark pursuant to Policy ¶ 4(a)(i).  See Reed Elsevier Props. Inc. v. Weekly Publishers, FA 151536 (Nat. Arb. Forum May 5, 2003) (“Inverting or transposing words in a trademark is not sufficient to avoid confusing similarity because the two words create the same commercial impression and meaning.”); see also L.L. Bean, Inc. v. ShopStarNetwork, FA 95404 (Nat. Arb. Forum Sept. 14, 2000) (finding that combining the generic word “shop” with the complainant’s registered mark “llbean” does not circumvent the complainant’s rights in the mark nor avoid the confusing similarity aspect of the ICANN Policy).

 

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

 

Rights or Legitimate Interests

 

Complainant has alleged that Respondent does not have rights or legitimate interests in the <insurancestatefarmsaves.info> domain name.  Once Complainant makes a prima facie case in support of its allegations, the burden then shifts to Respondent to show it does have rights or legitimate interests pursuant to Policy ¶ 4(a)(ii).  See G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002) (where the complainant has asserted that respondent does not have rights or legitimate interests with respect to the domain name, it is incumbent on respondent to come forward with concrete evidence rebutting this assertion because this information is “uniquely within the knowledge and control of the respondent”); see also Clerical Med. Inv. Group Ltd. v. Clericalmedical.com, D2000-1228 (WIPO Nov. 28, 2000) (the assertion by the complainant that the respondent does not have rights or legitimate interests is ordinarily sufficient to shift the burden of proof to the respondent to demonstrate that such a right or legitimate interest does exist).  Because Respondent has not responded to the Complaint, the Panel will examine the record to determine if Respondent has rights or legitimate interests pursuant to Policy ¶ 4(c).

 

Complainant has alleged that Respondent is not, nor has ever been, commonly known by the <insurancestatefarmsaves.info> domain name.  The WHOIS information identifies Respondent as “PMA Media Group c/o Dewey MacKay,” and there is no other evidence in the record indicating that Respondent is commonly known by the disputed domain name.  Therefore, the Panel concludes that Respondent is not commonly known by the <insurancestatefarmsaves.info> domain name pursuant to Policy ¶ 4(c)(ii).  See M. Shanken Communications  v. WORLDTRAVELERSONLINE.COM, FA 740335 (Nat. Arb. Forum Aug. 3, 2006) (finding that the respondent was not commonly known by the <cigaraficionada.com> domain name under Policy ¶ 4(c)(ii) based on the WHOIS information and other evidence in the record); 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).

 

Respondent is using the <insurancestatefarmsaves.info> domain name to display a list of hyperlinks advertising the insurance services of Complainant’s competitors.  Such use does not constitute 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 TM Acquisition Corp. v. Sign Guards, FA 132439 (Nat. Arb. Forum Dec. 31, 2002) (finding that the respondent’s diversionary use of the complainant’s marks to send Internet users to a website, which displayed a series of links, some of which linked to the complainant’s competitors, was not a bona fide offering of goods or services); see also Computerized Sec. Sys., Inc. v. Hu, FA 157321 (Nat. Arb. Forum June 23, 2004) (“Respondent’s appropriation of the SAFLOK mark to market products that compete with Complainant’s goods does not constitute a bona fide offering of goods and services”).

 

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

 

Registration and Use in Bad Faith

 

Complainant has alleged that Respondent has engaged in a bad faith pattern of registering and using trademark-related domain names, including a domain name containing Complainant’s STATE FARM INSURANCE mark.  Complainant cites several UDRP decisions in which Respondent was found to have registered and used various trademark-related domain names in bad faith.  E.g., State Farm Mut. Auto. Ins. Co. v. Dewey MacKay d/b/a PMA Media Grp., FA 811699 (Nat. Arb. Forum Nov. 14, 2006); Seiko Epson Corp. & Epson America, Inc. v. PMA Media Grp. c/o Dewey MacKay, FA 767167 (Nat. Arb. Forum Sept. 22, 2006); The Neiman Marcus Group, Inc. & NM Nevada Trust v. Dewey MacKay d/b/a PMA Media Grp., FA 813531 (Nat. Arb. Forum Nov. 22, 2006).  In light of these previous decisions, the Panel finds that Respondent’s registration and use of the <insurancestatefarmsaves.info> domain name constitutes bad faith pursuant to Policy ¶ 4(b)(ii).  See Stevens v. Modern Ltd.-Cayman Web Dev., FA 250005 (Nat. Arb. Forum May 17, 2004) (“Registration and use of a domain name to prevent Complainant from reflecting its mark in a corresponding domain name through a pattern of such conduct evidences bad faith registration and use of a domain name pursuant to Policy 4(b)(ii).”); see also Sport Supply Group, Inc. v. Lang, D2004-0829 (WIPO Dec. 10, 2004)(“[Respondent] registered the <usgames.com> domain name in order to prevent [Complainant] from reflecting its U.S. GAMES Mark in a corresponding domain name [pursuant to Policy ¶ 4(b)(ii)].  The pattern of such conduct is established, inter alia, by the public decisions of two different UDRP proceedings [against] Respondent.”). 

 

Respondent is using the <insurancestatefarmsaves.info> domain name to display a list of hyperlinks advertising the insurance services of Complainant’s competitors.  This is likely to disrupt Complainant’s business by diverting potential customers to Respondent’s website.  The Panel finds that such registration and use of the <insurancestatefarmsaves.info> domain name constitutes bad faith pursuant to Policy ¶ 4(b)(iii).  See Tesco Pers. Fin. Ltd. v. Domain Mgmt. Svcs., FA 877982 (Nat. Arb. Forum Feb. 13, 2007) (finding that the respondent registered and used the disputed domain name in bad faith pursuant to Policy ¶ 4(b)(iii) when the disputed domain name resolved to a website that displayed commercial links to the websites of the complainant’s competitors); see also Puckett, Individually v. Miller, D2000-0297 (WIPO June 12, 2000) (finding that the respondent has diverted business from the complainant to a competitor’s website in violation of Policy ¶ 4(b)(iii)).

 

Respondent’s <insurancestatefarmsaves.info> domain name, which is confusingly similar to Complainant’s STATE FARM INSURANCE mark, is likely to cause confusion among customers searching for Complainant’s insurance and financial services.  Specifically, customers may become confused as to the affiliation, endorsement, or sponsorship of the competing services advertised by the links on Respondent’s website.  Respondent presumably receives click-through fees for each misdirected Internet user, and is therefore attempting to commercially benefit from this likelihood of confusion between Respondent’s domain name and the goodwill associated with Complainant’s STATE FARM INSURANCE mark.  Therefore, the Panel finds that Respondent’s registration and use of the <insurancestatefarmsaves.info> domain name constitutes bad faith pursuant to Policy ¶ 4(b)(iv).  See Metropolitan  Life Ins. Co. v. Bonds, FA 873143 (Nat. Arb. Forum Feb. 16, 2007) (“The Panel finds such use to constitute bad faith registration and use pursuant to Policy ¶ 4(b)(iv), because [r]espondent is taking advantage of the confusing similarity between the <metropolitanlife.us> domain name and Complainant’s METLIFE mark in order to profit from the goodwill associated with the mark.”); see also Identigene, Inc. v. Genetest Labs., D2000-1100 (WIPO Nov. 30, 2000) (finding bad faith where the respondent's use of the domain name at issue to resolve to a website where similar services are offered to Internet users is likely to confuse the user into believing that the complainant is the source of or is sponsoring the services offered at the site).

 

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 <insurancestatefarmsaves.info> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Bruce E. Meyerson, Panelist

Dated: April 20, 2007

 

 

Click Here to return to the main Domain Decisions Page.

 

Click Here to return to our Home Page

 

National Arbitration Forum