national arbitration forum

 

DECISION

 

Hot Topic, Inc. v. Navigation Catalyst Systems, Inc

Claim Number: FA1001001302587

 

PARTIES

Complainant is Hot Topic, Inc. (“Complainant”), represented by CitizenHawk, Inc., California, USA.  Respondent is Navigation Catalyst Systems, Inc (“Respondent”), California, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <hottopit.com>, <hottoptic.com>, <hotytopic.com>, <nottopic.com>, <torbid.com>, <torrad.com>, <torraid.com>, <torrib.com>, <torrig.com>, <torriq.com>, <tprrid.com>, <trorrid.com> and <ttorrid.com>, registered with Basic Fusion, 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.

 

Honorable Karl V. Fink (Ret.) as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on January 12, 2010; the National Arbitration Forum received a hard copy of the Complaint on January 13, 2010.

 

On January 21, 2010, Basic Fusion, Inc. confirmed by e-mail to the National Arbitration Forum that the <hottopit.com>, <hottoptic.com>, <hotytopic.com>, <nottopic.com>, <torbid.com>, <torrad.com>, <torraid.com>, <torrib.com>, <torrig.com>, <torriq.com>, <tprrid.com>, <trorrid.com> and <ttorrid.com> domain names are registered with Basic Fusion, Inc. and that Respondent is the current registrant of the names.  Basic Fusion, Inc. has verified that Respondent is bound by the Basic Fusion, 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 January 21, 2010, a Notification of Complaint and Commencement of Administrative Proceeding (the "Commencement Notification"), setting a deadline of February 10, 2010 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@hottopit.com, postmaster@hottoptic.com, postmaster@hotytopic.com, postmaster@nottopic.com, postmaster@torbid.com, postmaster@torrad.com, postmaster@torraid.com, postmaster@torrib.com, postmaster@torrig.com, postmaster@torriq.com, postmaster@tprrid.com, postmaster@trorrid.com and postmaster@ttorrid.com by e-mail.

 

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

 

On February 19, 2010, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Honorable Karl V. Fink (Ret.) 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 <hottopit.com>, <hottoptic.com>, <hotytopic.com>, <nottopic.com> domain names are confusingly similar to Complainant’s HOT TOPIC mark.  Respondent’s <torbid.com>, <torrad.com>, <torraid.com>, <torrib.com>, <torrig.com>, <torriq.com>, <tprrid.com>, <trorrid.com> and <ttorrid.com> domain names are confusingly similar to Complainant’s TORRID mark.

 

2.      Respondent does not have any rights or legitimate interests in the <hottopit.com>, <hottoptic.com>, <hotytopic.com>, <nottopic.com>, <torbid.com>, <torrad.com>, <torraid.com>, <torrib.com>, <torrig.com>, <torriq.com>, <tprrid.com>, <trorrid.com> and <ttorrid.com> domain names.

 

3.      Respondent registered and used the <hottopit.com>, <hottoptic.com>, <hotytopic.com>, <nottopic.com>, <torbid.com>, <torrad.com>, <torraid.com>, <torrib.com>, <torrig.com>, <torriq.com>, <tprrid.com>, <trorrid.com> and <ttorrid.com> domain names in bad faith.

 

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

 

FINDINGS

Complainant, Hot Topic, Inc., holds multiple trademark registrationswith the United States Patent and Trademark Office (“USPTO”) for the HOT TOPIC mark (e.g., Reg. No. 2,771,871 issued October 7, 2003) in connection with clothing and accessories.  Complainant also holds multiple trademark registrations with the USPTO for the TORRID mark (e.g., Reg. No. 2,830,392 issued April 6, 2004) in connection with retail and online clothing and accessories services. 

 

Respondent, Navigation Catalyst Systems, Inc, registered the disputed domain name <hottopit.com> on September 10, 2008, <hottoptic.com> on January 30, 2006, <hotytopic.com> on December 18, 2007, <nottopic.com> on January 27, 2006, <torbid.com> on August 8, 2008, <torrad.com> on October 11, 2004, <torraid.com> on January 30, 2008, <torrib.com> on November 11, 2008, <torrig.com> on December 24, 2006, <torriq.com> on February 2, 2008, <tprrid.com> on January 20, 2006, and <ttorrid.com> on August 12, 2007.  The disputed domain names resolve to websites featuring generic links to third-party websites, some of which directly compete with Complainant’s business.

 

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 its HOT TOPIC and TORRID marks through its holding of multiple trademark registrations with the USPTO for the HOT TOPIC mark (e.g., Reg. No. 2,771,871 issued October 7, 2003) and the TORRID mark (e.g., Reg. No. 2,830,392 issued April 6, 2004).  The Panel finds that Complainant has established rights in the HOT TOPIC and TORRID marks under Policy ¶ 4(a)(i) through its registration with the USPTO.  See Expedia, Inc. v. Tan, FA 991075 (Nat. Arb. Forum June 29, 2007) (“As the [complainant’s] mark is registered with the USPTO, [the] complainant has met the requirements of Policy ¶ 4(a)(i).”); see also Intel Corp. v. Macare, FA 660685 (Nat. Arb. Forum Apr. 26, 2006) (finding that the complainant had established rights in the PENTIUM, CENTRINO and INTEL INSIDE marks by registering the marks with the USPTO).

 

Complainant argues that Respondent’s <hottopit.com>, <nottopic.com>, <hottoptic.com> and <hotytopic.com> disputed domain names are confusingly similar to Complainant’s HOT TOPIC mark pursuant to Policy ¶ 4(a)(i).  Respondent’s <hottopit.com> and <nottopic.com> disputed domain names merely replace a letter in Complainant’s mark with another and add the generic top-level domain (“gTLD”) “.com.”  Respondent’s <hottoptic.com> and <hotytopic.com> disputed domain names merely add a letter to the entirety of Complainant’s mark and add the gTLD “.com.”  The Panel finds that the replacing a letter in Complainant’s mark creates a confusing similarity between the disputed domain names and Complainant’s mark.  See Victoria’s Secret v. Zuccarini, FA 95762 (Nat. Arb. Forum Nov. 18, 2000) (finding that, by misspelling words and adding letters to words, a respondent does not create a distinct mark but nevertheless renders the domain name confusingly similar to the complainant’s marks); 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”).  The Panel also finds that the addition of a letter to Complainant’s marks creates a confusing similarity between the disputed domain names and the marks.  See Google, Inc. v. DktBot.org, FA 286993 (Nat. Arb. Forum Aug. 4, 2004) (“The mere addition of a single letter to the complainant’s mark does not remove the respondent’s domain names from the realm of confusing similarity in relation to the complainant’s mark pursuant to Policy ¶ 4(a)(i).”); see also Amazon.com, Inc. v. Ikhizamah, D2002-1168 (WIPO Mar. 17, 2003) (holding that the <zamazon.com> domain name was confusingly similar to the complainant’s AMAZON.COM mark).  Additionally, the Panel finds that the addition of a gTLD to a registered mark is irrelevant in distinguishing a disputed domain name and a mark.  See Trip Network Inc. v. Alviera, FA 914943 (Nat. Arb. Forum Mar. 27, 2007) (concluding that the affixation of a gTLD to a domain name is irrelevant to a Policy ¶ 4(a)(i) analysis); see also Jerry Damson, Inc. v. Tex. Int’l Prop. Assocs., FA 916991 (Nat. Arb. Forum Apr. 10, 2007) (“The mere addition of a generic top-level domain (“gTLD”) “.com” does not serve to adequately distinguish the Domain Name from the mark.”).  Therefore, pursuant to Policy ¶ 4(a)(i), the Panel finds that Respondent’s disputed domain names are confusingly similar to Complainant’s HOT TOPIC mark.

 

Complainant argues that Respondent’s <torbid.com>, <torrad.com>, <torrib.com>, <torrig.com>, <torriq.com>, <tprrid.com>, <torraid.com>, <trorrid.com> and <ttorrid.com> domain names are confusingly similar to Complainant’s TORRID mark pursuant to Policy ¶ 4(a)(i).  Respondent’s <torbid.com>, <torrad.com>, <torrib.com>, <torrig.com>, <torriq.com> and <tprrid.com> merely replace a letter in Complainant’s mark with another and add the generic top-level domain (“gTLD”) “.com.”  Respondent’s, <torraid.com>, <trorrid.com> and <ttorrid.com> merely add a letter to the entirety of Complainant’s mark and add the gTLD “.com.”  The Panel finds that the replacing a letter in Complainant’s mark creates a confusing similarity between the disputed domain names and Complainant’s mark.  See Victoria’s Secret v. Zuccarini, FA 95762 (Nat. Arb. Forum Nov. 18, 2000) (finding that, by misspelling words and adding letters to words, a respondent does not create a distinct mark but nevertheless renders the domain name confusingly similar to the complainant’s marks); 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”).  The Panel also finds that the addition of a letter to Complainant’s marks creates a confusing similarity between the disputed domain names and the marks.  See Google, Inc. v. DktBot.org, FA 286993 (Nat. Arb. Forum Aug. 4, 2004) (“The mere addition of a single letter to the complainant’s mark does not remove the respondent’s domain names from the realm of confusing similarity in relation to the complainant’s mark pursuant to Policy ¶ 4(a)(i).”); see also Amazon.com, Inc. v. Ikhizamah, D2002-1168 (WIPO Mar. 17, 2003) (holding that the <zamazon.com> domain name was confusingly similar to the complainant’s AMAZON.COM mark).  Additionally, the Panel finds that the addition of a gTLD to a registered mark is irrelevant in distinguishing a disputed domain name and a mark.  See Trip Network Inc. v. Alviera, FA 914943 (Nat. Arb. Forum Mar. 27, 2007) (concluding that the affixation of a gTLD to a domain name is irrelevant to a Policy ¶ 4(a)(i) analysis); see also Jerry Damson, Inc. v. Tex. Int’l Prop. Assocs., FA 916991 (Nat. Arb. Forum Apr. 10, 2007) (“The mere addition of a generic top-level domain (“gTLD”) “.com” does not serve to adequately distinguish the Domain Name from the mark.”).  Therefore, pursuant to Policy ¶ 4(a)(i), the Panel finds that Respondent’s disputed domain names are confusingly similar to Complainant’s TORRID mark.

 

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

 

Rights or Legitimate Interests

 

Complainant alleges that Respondent has no rights or legitimate interests in the disputed domain names.  Once Complainant makes a prima facie case in support of its allegations, the burden shifts to Respondent to prove it has rights or legitimate interests in the disputed domain names pursuant to Policy ¶ 4(a)(ii).  Based on the arguments made in the Complaint, the Panel finds that Complainant has established a prima facie case in support of its contentions and Respondent has failed to submit a Response to these proceedings.  See Domtar, Inc. v. Theriault., FA 1089426 (Nat. Arb. Forum Jan. 4, 2008) (“It is well established that, once a complainant has made out a prima facie case in support of its allegations, the burden shifts to respondent to show that it does have rights or legitimate interests pursuant to paragraph 4(a)(ii) of the Policy.”); see also Intel Corp. v. Macare, FA 660685 (Nat. Arb. Forum Apr. 26, 2006) (finding the “complainant must first make a prima facie case that [the] respondent lacks rights and legitimate interests in the disputed domain names under Policy ¶ 4(a)(ii), and then the burden shifts to [the] respondent to show it does have rights or legitimate interests.”).  Nevertheless, the Panel will examine the record to determine if Respondent has rights or legitimate interests in the disputed domain names pursuant to Policy ¶ 4(c).

 

The WHOIS information lists the registrant as “Navigation Catalyst Systems, Inc.”  Complainant alleges that Respondent is not sponsored or legitimately affiliated with Complainant in any way and Complainant has not given Respondent permission to use Complainant’s marks in a domain name.  Without evidence to the contrary, the Panel finds that Respondent is not commonly known by the disputed domain names.  See Braun Corp. v. Loney, FA 699652 (Nat. Arb. Forum July 7, 2006) (concluding that the respondent was not commonly known by the disputed domain names where the WHOIS information, as well as all other information in the record, gave no indication that the respondent was commonly known by the disputed domain names, and the complainant had not authorized the respondent to register a domain name containing its registered mark); see also Reese v. Morgan, FA 917029 (Nat. Arb. Forum Apr. 5, 2007) (concluding that the respondent was not commonly known by the <lilpunk.com> domain name as there was no evidence in the record showing that the respondent was commonly known by that domain name, including the WHOIS information as well as the complainant’s assertion that it did not authorize or license the respondent’s use of its mark in a domain name).

 

Respondent’s disputed domain names were registered between October 11, 2004 and November 11, 2008.  The disputed domain names resolve to websites featuring generic links to third-party websites, some of which compete with Complainant’s business.  Respondent presumably receives click-through fees from these linked websites.  The Panel finds that Respondent is not using the disputed domain names in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) or making a legitimate noncommercial or fair use of the disputed domain names pursuant to 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 ALPITOUR S.p.A. v. Albloushi, FA 888651 (Nat. Arb. Forum Feb. 26, 2007) (rejecting the respondent’s contention of rights and legitimate interests in the <bravoclub.com> domain name because the respondent was merely using the domain name to operate a website containing links to various competing commercial websites, which the panel did not find to be a use in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii)). 

 

Complainant alleges that Respondent is using a typographical error in the confusingly similar disputed domain names to redirect Internet users to Respondent’s websites and profiting through the collection of click-through fees.  The Panel agrees and finds that Respondent has no rights or legitimate interests pursuant to Policy ¶ 4(a)(ii).  See Microsoft Corp. v. Domain Registration Philippines, FA 877979 (Nat. Arb. Forum Feb. 20, 2007) (concluding that by registering the <microssoft.com> domain name, the respondent had “engaged in typosquatting, which provides additional evidence that [the] respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii).”); see also IndyMac Bank F.S.B. v. Ebeyer, FA 175292 (Nat. Arb. Forum Sept. 19, 2003) (finding that the respondent lacked rights and legitimate interests in the disputed domain names because it “engaged in the practice of typosquatting by taking advantage of Internet users who attempt to access Complainant's <indymac.com> website but mistakenly misspell Complainant's mark by typing the letter ‘x’ instead of the letter ‘c’”).

 

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

 

Registration and Use in Bad Faith

 

The Panel finds that Respondent’s registration and use of the disputed domain names to link Internet users to websites featuring third-party links which are in competition with Complainant constitutes a disruption of Complainant’s business and is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).  See Tesco Pers. Fin. Ltd. v. Domain Mgmt. Servs., FA 877982 (Nat. Arb. Forum Feb. 13, 2007) (concluding that the use of a confusingly similar domain name to attract Internet users to a directory website containing commercial links to the websites of a complainant’s competitors represents bad faith registration and use under Policy ¶ 4(b)(iii)); see also Persohn v. Lim, FA 874447 (Nat. Arb. Forum Feb. 19, 2007) (finding bad faith registration and use pursuant to Policy ¶ 4(b)(iii) where a respondent used the disputed domain name to operate a commercial search engine with links to the complainant’s competitors). 

 

The Panel finds that Respondent is using the disputed domain names to intentionally attract Internet users and profit through the receipt of click-through fees.  Respondent’s use of the disputed domain names attempts to capitalize on the confusing similarity between Respondent’s disputed domain names and Complainant’s marks, which is evidence of bad faith pursuant to Policy ¶ 4(b)(iv).  See Univ. of Houston Sys. v. Salvia Corp., FA 637920 (Nat. Arb. Forum Mar. 21, 2006) (“Respondent is using the disputed domain name to operate a website which features links to competing and non-competing commercial websites from which Respondent presumably receives referral fees.   Such use for Respondent’s own commercial gain is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iv).”); see also Zee TV USA, Inc. v. Siddiqi, FA 721969 (Nat. Arb. Forum July 18, 2006) (finding that the respondent engaged in bad faith registration and use by using a domain name that was confusingly similar to the complainant’s mark to offer links to third-party websites that offered services similar to those offered by the complainant).

 

As established previously, Respondent has engaged in the practice of typosquatting by intentionally misspelling Complainant’s HOT TOPIC and TORRID marks to take advantage of Internet users seeking Complainant’s goods and services.  The Panel finds that typosquatting is evidence of bad faith registration and use under Policy ¶ 4(a)(iii).  See Nextel Commc’ns Inc. v. Geer, FA 477183 (Nat. Arb. Forum July 15, 2005) (finding that the respondent’s registration and use of the <nextell.com> domain name was in bad faith because the domain name epitomized typosquatting in its purest form); see also Internet Movie Database, Inc. v. Temme, FA 449837 (Nat. Arb. Forum May 24, 2005) (“Respondent's registration of the domain names in dispute constitutes bad faith because the domain names are merely typosquatted versions of the [complainant’s] IMDB mark.).

 

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 <hottopit.com>, <hottoptic.com>, <hotytopic.com>, <nottopic.com>, <torbid.com>, <torrad.com>, <torraid.com>, <torrib.com>, <torrig.com>, <torriq.com>, <tprrid.com>, <trorrid.com> and <ttorrid.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

Honorable Karl V. Fink (Ret.), Panelist

Dated:  March 4, 2010

 

 

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