Vanguard Trademark Holdings USA LLC v. Carolina Rodrigues / Fundacion Comercio Electronico
Claim Number: FA2203001988708
Complainant is Vanguard Trademark Holdings USA LLC (“Complainant”), represented by Elizabeth K. Brock of Harness, Dickey & Pierce, PLC, Michigan, USA. Respondent is Carolina Rodrigues / Fundacion Comercio Electronico (“Respondent”), Panama.
REGISTRAR AND DISPUTED DOMAIN NAME
The domain name at issue is <natipnalcar.com>, registered with GoDaddy.com, LLC.
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.
James Bridgeman SC as Panelist.
Complainant submitted a Complaint to the Forum electronically on March 17, 2022; the Forum received payment on March 17, 2022.
On March 18, 2022, GoDaddy.com, LLC confirmed by e-mail to the Forum that the <natipnalcar.com> domain name is registered with GoDaddy.com, LLC and that Respondent is the current registrant of the name. GoDaddy.com, LLC has verified that Respondent is bound by the GoDaddy.com, LLC registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN’s Uniform Domain Name Dispute Resolution Policy (the “Policy”).
On March 22, 2022, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of April 11, 2022 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent’s registration as technical, administrative, and billing contacts, and to postmaster@natipnalcar.com. Also on March 22, 2022, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent’s registration as technical, administrative and billing contacts.
Having received no response from Respondent, the Forum transmitted to the Parties a Notification of Respondent Default.
On April 18, 2022, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the Forum appointed James Bridgeman SC as Panelist.
Having reviewed the communications records, the Administrative Panel (the "Panel") finds that the 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" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN 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.
Complainant requests that the disputed domain name be transferred from Respondent to Complainant.
A. Complainant
Complainant claims rights in the NATIONAL and NATIONAL CAR RENTAL service marks based on its ownership of the United States service mark registrations described below which it licenses to providers of car rental services.
Complainant submits that the disputed domain name <natipnalcar.com> is confusingly similar to Complainant’s registered NATIONAL and NATIONAL CAR RENTAL marks as it incorporates each of Complainant’s NATIONAL mark in its entirety, merely swapping the letter “o” in the word “national” with a “p” to mimic a common typographical error, and adding the descriptive term “car,” and dropping the element “national” from NATIONAL CAR RENTAL mark, in combination with the required generic Top-Level Domain identifier <.com>. Complainant notes that the letter “p” is immediately next to the letter “o” on a keyboard, making this a common typing error),
Complainant adds that the incorporation of a trademark in its entirety into a domain name is sufficient to establish that the disputed domain name is identical or confusingly similar to a registered trademark. See Hürriyet Gazetecilik ve Matbaacılık Anonim Şirketi v. Moniker Privacy Services / Kemal Demircioglu, D2010-1941 (WIPO Jan. 28, 2011) (“a domain name that reproduces the trademark in its entirety is confusingly similar to the mark” when the disputed domain names <hürriyet.com>, <hürriyetemlak.com>, and <hürriyetoto.com> fully incorporated the complainant’s HURRIYET mark).
While Respondent has introduced a typographical error by replacing the “o” in “national” with a “p” to mimic a common typographical error, as the “p” key is located immediately next to the “o” key on a keyboard. Complainant submits that these changes do not prevent the disputed domain name from being confusingly similar to Complainant’s marks. See Victoria’s Secret v. Zuccarini, FA 95762 (Forum November 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).
Complainant contends that for the same reasons, the disputed domain name is confusingly similar to Complainant’s domain name <nationalcar.com> which is used by its licensee as the address of its website.
Complainant adds that the generic Top-Level Domain Identifier is also insufficient to distinguish the disputed domain name from Complainant’s NATIONAL and NATIONAL CAR RENTAL marks. See Jerry Damson, Inc. v. Tex. Int’l Prop. Assocs., FA 916991 (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.”).
Complainant next alleges that Respondent has no rights or legitimate interests in the disputed domain name arguing that there is nothing in the WHOIS record for the disputed domain name to indicate that Respondent is commonly known as, is operating a business as, or is advertising herself as Forum.
Complainant submits that previous panels have found that, in the absence of evidence submitted by the respondent, the WHOIS record is the sole piece of relevant evidence when determining how a respondent is commonly known. See Haas Automation, Inc. v. Machine Tools 24-7 / Jon Beal, FA1201001425055 (Forum Feb. 29, 2012) (“Respondent may well be known in the community as a vendor of used Haas equipment, but it has not shown that it is known as such by the name HAAS. The relevant evidence presented consists exclusively of the WHOIS information”).
Even if Respondent were operating a business known as “natipnalcar.com,” Complainant contends that it would not have rights or legitimate interests in the disputed domain name, as previous panels have found that using a trademark term in an unauthorized manner in a domain name, even where a respondent is operating an actual business, causes confusion by illegitimately indicating to consumers that the products offered using the contested domain name are those of the trademark holder. See Seiko Epson Corporation and Epson America, Inc. v. Advantage S & G Inc. c/o John Foley, FA1006001329762 (Forum July 22, 2010) (“[W]here Respondent has erred is in using Complainants’ trademark in its domain names and by that means falsely implying that the bulk and replacement inks being promoted are those of Complainants when they clearly are not,” finding that respondent’s sale of ink products at the <epsonreplacementink.com> and <epsonbulkink.com> domain names was without rights or legitimate interest).
Complainant asserts that it has not licensed or otherwise permitted Respondent to use its NATINAL or NATIONAL CAR RENTAL marks, or any variation thereof, in connection with any goods or services or to apply for any domain name incorporating the marks, or any variation thereof.
In addition, Respondent is clearly not making any legitimate noncommercial or fair use of <natipnalcar.com>. In fact, any claim in that regard is easily dismissed since the disputed domain name is being used in an attempt to install malware on the user’s computer. See Compagnie de Saint Gobain v. Com-Union Corp., D2000-0020 (WIPO Mar. 14, 2000) (finding no rights or legitimate interest where the respondent was not commonly known by the mark and never applied for a license or permission from the complainant to use the trademarked name).
Complainant states that its licensee operates an online car rental website at <nationalcar.com> using the NATIONAL and NATIONAL CAR RENTAL marks and so Respondent has no legitimate rights in the disputed domain name and, by using the confusingly similar domain name, Respondent is attempting to use the <natipnalcar.com> domain name to install malware on the computers of others. Complainant submits that such use constitutes a lack of rights or legitimate interest in the disputed domain name under ICANN Policy ¶¶ 4(c)(i) and (ii). See Big Dog Holdings, Inc. v. Day, FA93554 (Forum Mar. 9, 2000) (finding no legitimate use when respondent was diverting consumers to its own web site by using complainant’s trademark(s)).
Complainant alleges that at various times, the disputed domain name continually redirected Internet traffic, including to the “Last Minute Specials” on the webpage of Complainant’s licensee’s website at <nationalcar.com> on August 3, 2021.
In additional attempts to view the disputed domain name on January 18, 2022 and February 18, 2022, were blocked and redirected. On February 18, 2022, when attempting to view the web site to which the disputed domain name resolved, Complainant’s Representative’s received a McAfee Total Protection security warning – likely for malware – and did not proceed to view the webpage.
Complainant contends that while it is difficult to demonstrate these redirects as they occur and refers to screen captures of the various attempts to access Respondent’s website at the disputed domain name on August 3, 2021, January 18, 2022, and February 18, 2022 which are attached as exhibits in an annex to the Complaint.
Complainant argues that such redirects are likely provide someone, presumably the Respondent, with revenue by automatically diverting Internet users who find their way to the website to which the disputed domain name <natipnalcar.com> resolves. Complainant contends that it is feasible that at least some Internet visitors to Respondent’s <natipnalcar.com> webpage will either not realize that they have been unwittingly directed to a website that has no affiliation with Complainant and/or will believe they have legitimately been redirected to Complainant’s own webpage. Further, some Internet users may believe it is safe to proceed by clicking the McAfee Total Protection security warning before accessing what they believe to be Complainant’s webpage, when in fact it is not.
Previous panels have found that Respondent redirecting users for Attorney Docket No. 5245N-400302 their commercial gain is not a bona fide offering of goods or services or a legitimate noncommercial or fair use under Policy ¶ 4(c)(i) and (iii). See The Royal Bank of Scotland Group plc, Direct Line Insurance plc, and Privilege Insurance Company Limited v. Demand Domains, c/o C.S.C., FA0605000714952 (Forum Aug. 2, 2006) (“The Panel finds that Respondent’s use of the <privelage.com> for commercial gain, presumably by earning “clickthrough” fees for each consumer Respondent redirected to the websites of Complainants’ competitors, does not constitute 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 adds that Respondent’s use of the disputed domain name to pass itself off as Complainant, clearly does not establish legitimate rights when there is deliberate infringement of another's rights, or when the domain name is used to divert users through confusion by using a website that redirected to a trademark owner’s own webpage. See DaVita Inc. v. Cue balls, FA2108001959168 (Forum Sept. 7, 2021) (“Further, Respondent uses the disputed domain name to redirect to Complainant’s own website legitimate website. Under Policy ¶ 4(a)(ii), this does not create any rights or legitimate interests for Respondent.”).
Complainant further argues that Respondent’s attempt at impersonating Complainant by redirecting Internet traffic is neither a bona fide offering of goods or services nor is it a fair use. Instead, Respondent is impersonating Complainant by holding herself out as Complainant, and likely benefiting financially, by redirecting the disputed domain name to Complainant’s own webpage.
Considering Complainant’s long-standing use and registration of the NATIONAL and NATIONAL CAR RENTAL, Complainant contends that Respondent cannot have, and does not have, any legitimate rights to use the disputed domain name in connection with a website that is set up for continual redirects and attempts to install malware on the user’s computer.
Complainant argues that Respondent’s use of the disputed domain name to distribute malware in a likely illegal scheme is not a legitimate use of the disputed domain name and does not give the Respondent any rights in the disputed domain name. See Dell Inc. v. Whois Manager / Whois Privacy Management Services, FA 1803001778749 (Forum May 9, 2018) (Noting that “Complainant provided screenshots of the <dellservicesales.com> resolving website, which purports to offer a browser extension called “Search Safely Plus Chrome” in concluding that “[u]se of a domain name to distribute malware may not be considered a bona fide offering or fair use pursuant to Policy ¶4(c)(i)& (iii).”).
Additionally, Complainant argues that Respondent’s attempt to divert web traffic by typosquatting is evidence that Respondent lacks any legitimate rights in the domain name. See Vanguard Trademark Holdings USA LLC v. Milan Kovac, FA1106001394073 (Forum July 29, 2011) (“Complainant argues that Respondent’s <ational.com> domain name is merely a misspelled version of Complainant’s NATIONAL mark, intending to capture unknowing Internet users who mistakenly omit the first letter. The Panel finds that this kind of domain name registration is typosquatting, which is evidence of a lack of rights and legitimate interests according to Policy ¶ 4(a)(ii).
Complainant next argues that the facts of record clearly support a finding that Respondent both registered and is using the disputed domain name in bad faith arguing that Respondent’s use of the disputed domain name can lead to no other conclusion than that Respondent was aware of Complainant’s marks, intentionally registered a confusingly similar domain name in which it had no rights and has used that domain name in bad faith to further its scheme of installing malware on others’ computers. See American International Group, Inc. v. Walter Busby d/b/a AIG Mergers and Acquisitions, FA 0304000156251 (Forum May 30, 2003) (“The facts before the Panel clearly demonstrate that Respondent was well aware of Complainant, Complainant’s mark, and the goodwill surrounding that mark when it registered the disputed domain name. Registration of a domain name with actual knowledge of a trademark holder’s rights in a mark is strong evidence that the domain name was registered in bad faith. Following its registration of the disputed domain name, Respondent proceeded to host a website that duplicated Complainant’s mark and logo, giving every appearance of being associated or affiliated with Complainant’s business. Respondent was not authorized to use Complainant’s marks and admitted as much when sent a cease-and-desist letter by Complainant. In a nutshell, Respondent used the disputed domain name to perpetrate a fraud upon individual shareholders who respected the goodwill surrounding the AIG mark. This is evidence that Respondent used the disputed domain name in bad faith.”) [internal citations omitted].
Complainant argues that Respondent is deliberately using a domain name that is confusingly similar to Complainant’s marks to attract, for commercial gain, Internet users to its website, by creating a likelihood of confusion with Complainant’s NATIONAL and NATIONAL CAR RENTAL marks and its official <NationalCar.com> website as to the source, sponsorship, affiliation or endorsement of its website and the services offered at such websites.
Complainant adds that Respondent’s use of the disputed domain name to distribute malware demonstrates that the disputed domain name was registered and is being used in bad faith. See Vanguard Trademark Holdings USA LLC v. Domain Administrator / Fundacion Privacy Services LTD, FA2104001940316 (Forum April 29, 2021) (“Respondent’s aim to distribute malware via the at-issue domain name is evidence of bad faith under Policy ¶ 4(a)(iii)”).
Complainant further contends that Respondent’s business model is based upon use of the disputed domain name to attract users to Respondent’s website is clear evidence that Respondent registered and is using the disputed domain name in bad faith pursuant to Policy ¶ 4(b)(iv). See Kmart v. Kahn, FA 127708 (Forum Nov. 22, 2002) (finding that if a respondent profits from its diversionary use of a complainant’s mark when a domain name resolves to commercial web sites and that respondent fails to contest a complaint, it may be concluded that the respondent is using the domain name in bad faith pursuant to Policy ¶ 4(b)(iv)).
Referring to copies of search results from a look-up service which have been submitted as evidence in an annex to the Complaint, Complainant further submits that Respondent has taken affirmative steps to set up MX records for the <natipnalcar.com> domain name. Complainant submits that email capability is not needed for parked domains and Respondent’s action leads to an inference of bad faith intent. See The Standard Bank of South Africa Limited v. N/A / mark gersper, FA 1467014 (Forum Dec. 5, 2012) (“The Panel finds Complainant’s allegations about the possibility of Respondent using the disputed domain name for phishing sufficient and finds Respondent has not made a bona fide offering of goods or services or a legitimate noncommercial or fair use of the <stanbicibplc.com> domain name under Policy ¶4(c)(i) and Policy ¶4(c)(iii).”).
Complainant adds that the registration and use of the disputed domain name is considered typosquatting and thus evidence of Respondent’s bad faith in registering and using the disputed domain name. See Vanguard Trademark Holdings USA LLC v. Carolina Rodrigues / Fundacion Comercio Electronico, FA2104001940361 (Forum May 3, 2021) (“Given the nature of the similarities between the disputed domain name and Complainant’s service mark, on the balance of probabilities the disputed domain name was registered in bad faith in an act of typo-squatting by replacing the letter “t” in “national” with the letter “y”, to take advantage typographical errors, as the “y” key is located immediately next to the “t” key on an English-language QWERTY keyboard.”).
B. Respondent
Respondent failed to submit a Response in this proceeding.
Complainant is the owner of the NATIONAL and NATIONAL CAR RENTAL service marks listed below which it licenses to operators of car rental services:
· United States of America registered service mark NATIONAL, registration number 1,537,711, registered on the Principal Register on May 2, 1989 for services in international class 39;
· United States of America registered service mark NATIONAL CAR RENTAL, registration number 1,534,668, registered on the Principal Register on April 11, 1989 in International Class 39;
· United States of America registered service mark NATIONAL CAR RENTAL, registration number 1,540,913 registered on the Principal Register on May 23, 1989 for services in International Class 39;
· United States of America registered service mark NATIONAL CAR RENTAL, registration number 3,663,350, registered on the Principal Register on August 4, 2009 for services in International Class 39 ;
· United States of America registered service mark NATIONAL CAR RENTAL, registration number 4,558,687, registered on the Principal Register on July 1, 2014 for services in International Class 39.
The disputed domain name, <natipnalcar.com> was registered on April 15, 2021 and has been used to attract and redirect Internet traffic to various websites, including the website of Complainant’s licensee and of particular concern it appears that Respondent has taken steps to set up MX records for the disputed domain name which is a step towards creating an email account.
There is no information available about Respondent, except for that provided in the Complaint, the Registrar’s WhoIs and the information provided by the Registrar in response to the Forum’s request for the information related to the registration of the disputed domain name.
In said response to the Forum, the Registrar disclosed the identity of Respondent who had concealed her identity on the published WhoIs, by using a proxy service and confirmed that she is the registrant of the disputed domain name.
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."
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.
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(f), 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 set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) (“Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint”).
Complainant has provided convincing evidence that rights in the NATIONAL and NATIONAL CAR RENTAL marks mark, established by its ownership of the United States trademark registrations described above.
Notwithstanding the replacement of the letter “p” for the letter “o”, Complainant’s NATIONAL is the dominant and only distinctive element in the disputed domain name , <natipnalcar.com>.
Additionally, notwithstanding the substitution of the letters, the first two elements of Complainant’s NATIONAL CAR RENTAL mark is clearly recognizable in the disputed domain name.
The omission of the element “rental” in the disputed domain name does not prevent a finding of confusing similarity as it is descriptive and has no distinctive character.
Neither does the gTLD extension <.com> does not prevent a finding of confusing similarity because on the balance of probabilities it would be considered by Internet users as a necessary technical requirement for a domain name or perhaps an abbreviation of the word “company” or “corporation”.
This Panel finds therefore that the disputed domain name is confusingly similar to both the NATIONAL and NATIONAL CAR RENTAL mark in which Complainant has rights and Complainant has therefore succeeded in the first element of the test in Policy ¶ 4(a)(i).
Complainant has made out a prima facie case that Respondent has no rights legitimate interests in the disputed domain name arguing that
· there is nothing in the WHOIS record for the disputed domain name to indicate that Respondent is commonly known as, operating a business as, or advertising as <natipnalcar.com>;
· even if Respondent were operating a business known as “natipnalcar.com,” it would not have rights or legitimate interests in the disputed domain name because use of Complainant’s marks in the disputed domain name would confusion by illegitimately indicating to consumers that the products offered by Respondent are those of the trademark holder;
· considering the long-standing use and registration of the NATIONAL and NATIONAL CAR RENTAL marks by Complainant, Respondent cannot have and does not have any legitimate rights in the disputed domain name which is being used in connection with a website that is set up to redirect Internet traffic and in attempts to install malware on the user’s computer;
· Complainant has not licensed or otherwise permitted Respondent to use its NATIONAL or NATIONAL CAR RENTAL marks, or any variation thereof, in connection with any goods or services or to apply for any domain name incorporating Complainant’s marks, or any variation thereof;
· Complainant’s licensee operates an online car rental website at <nationalcar.com> and Respondent is attempting to use the <natipnalcar.com> domain name to install malware on the computers of others;
· screen captures of the websites to which the disputed domain name resolves show that at various times, the disputed domain name continually redirected Internet traffic, including to the “Last Minute Specials” on the webpage of Complainant’s licensee’s website at <nationalcar.com> on August 3, 2021; on January 18, 2022 and February 18, 2022, were blocked and redirected; and on February 18, 2022, when attempting to view the web site to which the disputed domain name resolved, Complainant’s Representative’s received a McAfee Total Protection security warning – likely for malware – and did not proceed to view the webpage;
· presumably Respondent, is receiving revenue by using the disputed domain name to automatically divert Internet users who find their way to the website to which the disputed domain name <natipnalcar.com> resolves;
· it is feasible that at least some Internet visitors to the webpage to which the disputed domain name resolves will either not realize that they have been unwittingly directed to a website that has no affiliation with Complainant and/or will believe they have legitimately been redirected to Complainant’s own webpage;
· further, some Internet users may believe it is safe to proceed by clicking the McAfee Total Protection security warning before accessing what they believe to be Complainant’s webpage, when in fact it is not;
· Respondent’s use of the disputed domain name to pass itself off as Complainant, clearly does not establish legitimate rights when there is deliberate infringement of another's rights, or when the domain name is used to divert users through confusion by using a website that redirected to a trademark owner’s own webpage;
· use of the disputed domain name by Respondent to distribute malware in what is likely to be an illegal scheme is not a legitimate use of the disputed domain name and does not create rights in the disputed domain name;
· Respondent’s attempt to divert web traffic to <natipnalcar.com> by use of typosquatting is evidence that Respondent lacks any legitimate rights in the domain name;
· Respondent’s use of the disputed domain name does not constitute 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).
It is well established that once a complainant makes out a prima facie case that a complainant has no rights or legitimate interests in the domain name at issue, the burden of production shifts to the respondent to prove its rights or legitimate interests.
Respondent has failed to discharge that burden and therefore this Panel must find that Respondent has no rights or legitimate interests in the disputed domain name. Complainant has therefore succeeded in the second element of the test in Policy ¶ 4(a)(ii).
Complainant’s service mark rights predate the registration of the disputed domain name and Complainant’s licensee has an established Internet presence using the similar domain name <nationalcar.com>. The disputed domain name <natipnalcar.com> is on the balance of probabilities a misspelling of Complainant’s licensee’s domain name and, in particular, because of the proximity of the letters “p” and “o” on an English-language QWERTY keyboard, on the balance of probabilities the disputed domain name was registered in an act of typosquatting to target and take predatory advantage of Complainant’s rights and goodwill.
On the balance of probabilities therefore, it is most improbable that the registrant of the disputed domain name was unaware of Complainant, its service marks, business, and reputation when the disputed domain name was chosen and registered.
This Panel finds that the disputed domain name was bad faith,
There is not sufficient evidence to prove that the disputed domain name is being used to distribute malware as alleged.
However, given that Respondent is using the disputed domain name in an exercise of typosquatting and that Respondent has taken affirmative steps to set up MX records for the disputed domain name which demonstrates an intention to use the disputed domain name as an email account, the evidence allows a finding that on the balance of probabilities the disputed domain name is being used in bad faith to confuse and misdirect Internet users and with the intention of creating confusion among Internet users.
As this Panel has found that the disputed domain names were registered and are being used in bad faith, Complainant has succeeded in the third element of the test in Policy ¶ 4(a)(iii).
Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <natipnalcar.com> domain name be TRANSFERRED from Respondent to Complainant.
James Bridgeman SC
Panelist
Dated: April 20, 2022
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