NATIONAL ARBITRATION FORUM

DECISION

Lanquest Corporation v. Media Research Korea
Claim Number: FA0701000896647

PARTIES

Complainant is Lanquest Corporation (“Complainant”), represented by Ari Goldberger, of ESQwire.com Law Firm, 35 Cameo Drive, Cherry Hill, NJ 08003, USA.  Respondent is Media Research Korea (“Respondent”), 2805‑1806Ho Humansia apt, DongBaek‑Dong, GiHeung‑Gu, YongIn‑city KyeongGi‑Do 446728, KR.

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <lanquest.com> (the “Disputed Domain”), registered with Cydentity, Inc. d/b/a Cypack.com.

PANEL

The undersigned certifies that he or she has acted independently and impartially and to the best of his or her knowledge has no known conflict in serving as Panelist in this proceeding.

Robert A. Fashler as Panelist.

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on January 23, 2007; the National Arbitration Forum received a hard copy of the Complaint on February 8, 2007.

On February 8, 2007, Cydentity, Inc. d/b/a Cypack.com confirmed by e‑mail to the National Arbitration Forum that the <lanquest.com> domain name is registered with Cydentity, Inc. d/b/a Cypack.com and that the Respondent is the current registrant of the name.  Cydentity, Inc. d/b/a Cypack.com has verified that Respondent is bound by the Cydentity, Inc. d/b/a Cypack.com 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 February 14, 2007, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of March 6, 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@lanquest.com by e‑mail.

Respondent’s Response, received on March 8, 2007, was untimely as it was received after the deadline for a Response of March 6, 2007.

While the domain name registration agreement was in Korean, both Complainant and Defendant have agreed to conduct this proceeding in English rather than Korean.

On March 13, 2007, pursuant to Complainant’s request to have the dispute decided by a single‑member Panel, the National Arbitration Forum appointed Robert A. Fashler as Panellist.

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

PARTIES’ CONTENTIONS

A.        Complainant

Complainant asserts that:

(a)                Complainant is a network engineering company that designs, installs, and maintains local and wide‑area networks, and sells hardware and software to support its systems.

(b)               Complainant has rights in the LANQUEST mark because:

(i)                  Complainant has common law rights in the LANQUEST mark through continuous and extensive use of the mark in connection with its network engineering services since 1991.

(ii)                Complainant has spent considerable dollars advertising its LANGUEST mark and promoting the services it provides in connection therewith.

(iii)               Complainant is the registrant of the domain name <lanquest.net>, which it registered in September 1996.

(iv)              The LANQUEST mark is composed solely of a term coined by the Complainant.

(c)                Respondent had, at least, constructive knowledge of Complainants common law trademark which it could have learned of by conducting a WHOIS query for <lanquest.net>, which was registered seven years before Respondent registered <lanquest.com>.

(d)               The disputed domain name is identical to the Complainant’s common law trademark LANQUEST.

(e)                Respondent has no rights or legitimate interest in the Dispute Domain because:

(i)                  Respondent registered the disputed domain name after Complainant began using the LANQUEST mark.

(ii)                Respondent is not known as LANQUEST.

(iii)               Respondent is not making a legitimate noncommercial or fair use of the domain name, since it is using LANQUEST to misleadingly divert consumers for commercial gain.

(iv)              Respondent registered the disputed domain name to sell to Complainant for an amount in excess of its out‑of‑pocket expenses as evidenced by statement on its web site in 2005 offering it for sale.

(v)                Respondent clearly intended to sell the disputed domain name to Complainant because Complainant had the rights to the common law trademark LANQUEST and would be the only party interested in purchasing it.

(vi)              Respondent does not appear to use the disputed domain name for an independent website, as evidenced by the redirection of users to a page that appears to have no connection with the disputed domain name, and the page to which the disputed domain name redirects users is neither a bona fide offering of goods or services nor an example of a legitimate noncommercial use.

(vii)             Respondent has never been authorized by Complainant to use the LANQUEST mark, which gives rise to a presumption that Respondent cannot establish that it has rights or any legitimate interests.

(viii)           Respondent cannot establish rights in the disputed domain name under Paragraph 4(c)(i) of the Policy because Respondent has never made any use of, or demonstrable preparations to use, the disputed domain name or any name corresponding thereto in connection with a bona fide offering of goods or services.

(ix)              Respondent cannot establish rights in the disputed domain name under Paragraph 4(c)(ii) of the Policy because Respondent has never been commonly known by the disputed domain name and has not acquired trademark or service mark rights in the disputed domain name.

(x)                Respondent cannot establish rights in the disputed domain name under Paragraph 4(c)(iii) of the Policy because Respondent is not making a legitimate non-commercial or fair use of the disputed domain name without intent to misleadingly divert consumers for commercial gain.

(f)                 Respondent has registered and is using the disputed domain name in bad faith because:

(i)                  Respondent registered the disputed domain name primarily for the purpose of selling, renting, or otherwise transferring it to the Complainant or to a competitor of Complainant, for valuable consideration in excess of Respondent’s documented out‑of‑pocket costs directly related to the disputed domain name.

(ii)                Respondent is using of the disputed domain name to misdirect potential visitors looking for Complainant’s website to its own site and other third‑party websites demonstrating that Respondent registered the disputed domain name to deceptively attract and then misdirect Internet users for Respondent’s own commercial gain.

B.        Respondent

A Response was filed after the deadline set for submission of a Response.  In these circumstances, the Panel has the sole discretion as to whether to accept the Response as well as to the amount of weight given to the Response: see Talk City, Inc. v. Michael Robertson, WIPO Case No. D2000‑0009 (February 29, 2000).

As the Response was filed two days late and no explanation was given for the late filing, the Panel chooses to exercise its discretion by not considering the Response.

FINDINGS

The Panel finds that Complainant has not proven any of the elements stipulated in Paragraph 4(a) of the Policy.

DISCUSSION

Paragraph 15(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (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 the 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 the Respondent is identical or confusingly similar to a trademark or service mark in which the Complainant has rights;

(2)   the 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

The first element that Complainant must establish is that the disputed domain name “is identical or confusingly similar to a trademark or service mark in which the Complainant has rights.”  Hence, in this case, Complainant must establish that it has rights in the LANQUEST mark.

Although Complainant claims to have been using the trademark LANQUEST continuously and extensively since 1991, Complainant has never acquired a registration for the trademark LANQUEST in any jurisdiction.  Rather Complainant asserts that it has common law rights in the mark.

The Policy recognizes and affords protection to common law trademarks, but it does not establish the existence or legal characteristics of common law trademarks.  Rather, common law trademarks are the creature of the national laws of certain countries.  Common law rights do not exist in every country.  A complainant cannot rely on common law trademark rights in countries whose laws do not recognize such rights.  Even among countries that do recognize common law trademarks, it would be very surprising if the relevant law of each such country was identical to all the others.  Complainant has not specified the legal jurisdiction in which Complainant’s common law trademark rights are supposed to exist and has not provided evidence of the relevant legal principles of that jurisdiction.

As Complainant resides in the United States of America, the Panel assumes that Complainant is relying on U.S. law to establish its common law trademark rights.  Unfortunately, as the Panel is a Canadian intellectual property lawyer, it is not expert in the U.S. law of common law trademarks.  As Complainant has failed to shed any light on the content of the legal rules for establishing common law rights in the United States, the Panel has attempted to ascertain the applicable legal principles on its own. 

McCarthy on Trademarks and Unfair Competition, 4^th ed. (Thomson West: 1992, last updated March 2007) (“McCarthy”) is generally considered to be a leading treatise on trademark law in the United States.  At page 16‑4, McCarthy explains the basis on which common law trademark rights arise under the laws of the United States:

To create trademark or trade dress rights, a designation must be proven to perform the job of identification: to identify one source and distinguish it from other sources.  If it does not do this, then it is not protectable as a trademark, service mark, trade dress or any similar exclusive right.  With each sale of goods or services under such a business symbol, the seller builds up greater and greater legal rights in that symbol.  In the absence of customer recognition of the symbol, the “owner” of the business has no good will, and thus there is nothing for the “trademark” or “trade dress” to symbolize or represent.  [emphasis added; citations omitted].

Hence, under U.S. legal principles, common law rights are created by active use of a trademark in association with particular goods and services.  The sale and advertising of such goods and services generates goodwill and reputation among customers and potential customers.  The strength, or distinctiveness, of a common law trademark is a function of the goodwill and reputation generated by those activities.

Accordingly, when one seeks to enforce common law trademarks it is not sufficient merely to assert that one has been “using” the trademark.  One must  provide sufficient evidence from which it can be inferred that common law rights exist and then determine the scope of legal protection that ought to be afforded to the common law trademark.  See Weatherford Int’l, Inc. v. Wells, FA153626 (Nat. Arb. Forum May 19, 2003) (holding that prior UDRP precedent did not support a finding of common law rights in a mark in lieu of any supporting evidence, statements or proof); see also Molecular Nutrition, Inc. v. Network News and Publ’n, FA156715 (Nat. Arb. Forum June 24, 2003) (finding that the complainant failed to establish common law rights in its mark because mere assertions of such rights are insufficient without accompanying evidence to demonstrate that the public identifies the complainant’s mark exclusively or primarily with the complainant’s products); see also Lilian Vachovsky, COO, Aplus.Net Internet Services v. At Hosting Inc., D2006-0703 (WIPO Oct. 26, 2006) (“It is well-established that mere assertions of common law rights in a mark are insufficient without accompanying evidence to demonstrate that the public identifies the Complainant’s mark exclusively or primarily with the Complainant’s products.”). 

Complainant’s only evidence with respect to its use of the LANQUEST mark is at paragraphs 3 and 4 of the Mark Chambers Affidavit, which read:

3.         Lanquest Corporation began operations in September 1991 and we have used the service mark continuously since that date.

4.         I have spent approximately $80,000 to date promoting the LANQUEST service mark.

Even if these statements are accepted at face value, they do not, in and of themselves, establish the existence of any common law trademark rights.  Rather, they beg the question.  Complainant has not provided any evidence of the manner in which the trademark is supposed to have been used since 1991.  Complainant does not provide any indication of the volume of sales that are supposed to have been made in association with the trademark or the revenues that are supposed to have been generated by those sales.  Complainant provides no factual basis from which the Panel can infer that there is any substance to Complainant’s assertions that it has engaged in continuous and extensive use of the trademark LANQUEST in association with any products or services. 

In his Affidavit, Mr. Chambers does assert an expenditure of “approximately $80,000 to date promoting the LANQUEST service mark”.  But the Affidavit does not clarify what Mr. Chambers means by “promoting” or give any examples of those activities.  That statement is unhelpful in demonstrating the existence and strength of Complainant’s common law rights in LANQUEST.

Even if the Panel was to assume that the promotional activities referenced in the Chambers Affidavit were entirely relevant to the issues being determined, an expenditure of $80,000 in the aggregate over 15 years would not allow the Panel to draw any meaningful inferences about the reputation, goodwill or distinctiveness that might have been generated by those activities.  Furthermore, such an expenditure, averaging approximately $5,333.00 per year, is not consistent with assertions in the Complaint that Complainant has spent “considerable dollars” advertising the LANQUEST mark and promoting the services provided in connection with the mark.

Complainant has failed to provide sufficient evidence from which the Panel can infer that Complainant holds common law rights in the trademark LANQUEST.  It is therefore unnecessary to consider whether or not the disputed domain name is identical to or confusingly similar with that trademark.

Rights or Legitimate Interests

The second element that Complainant must prove is that Respondent has no rights or legitimate interests in respect of the disputed domain name.  It is relatively difficult for any complainant to prove that a respondent has no rights or legitimate interests in a domain name, because, for the most part, that evidence is known to and within the control of the respondent.  Accordingly, the burden on a complainant with respect to Paragraph 4(a)(ii) of the Policy must be relatively light.  Nonetheless, a complainant must produce some evidence tending to show that a respondent has no rights or legitimate interests in a domain name: see Richmond Assocs, LLC v. hilltopmall, D2005‑1198 (WIPO Feb. 17, 2006); see also Koninklijke Philips Elecs N.V. v. Manageware, D2001‑0796 (WIPO Oct. 25, 2001).  For example, professionally-conducted searches demonstrating that a respondent does not hold any trademark registrations or registered business names, at least in its home jurisdiction, ought to be sufficient, in most cases, to discharge the complainant’s burden in relation to this element of the Policy. 

Complainant makes several assertions in its submission regarding Respondent’s alleged lack of rights or legitimate interests in the disputed domain name.  However, Complainant only submits one piece of evidence in support of those allegations, namely, a printout that is supposed to show one page of the website that was accessed via the disputed domain name (“disputed website”) as of March 6, 2005.  Complainant says that it downloaded that screen shot from a free Internet archival service commonly known as “The WayBackMachine”.  That evidence is entirely hearsay and of uncertain reliability.  As well, Complainant does not provide any evidence to show that Respondent owned the disputed domain name or operated the disputed domain name at the time (i.e. 2005).  The Panel is not inclined to give much weight to this evidence, particularly in the absence of additional corroborating evidence. 

Complainant asserts that Respondent is not known as LANQUEST.  However, Complainant does not indicate how it arrived at this conclusion of fact.  Complainant does not provide any copies of Respondent’s current website showing whether or not Respondent was using LANQUEST as its name or trademark before the Complaint issued.  Complainant also failed to provide any search information showing whether or not Respondent has incorporated under a name that includes LANQUEST or owns any LANQUEST trademarks.

Complainant asserts that Respondent is using the disputed domain name to misleadingly divert consumers for commercial gain, but Complainant provides no evidence even suggesting that any consumers are being diverted or that there is a factual basis from which it can be inferred that diversion is likely.  For example, if Complainant had provided evidence demonstrating that its claimed common law trademark has become famous or very well known, that would at least be consistent with a likelihood of diversion or confusion.  To the contrary, Complainant’s evidence does not provide a basis from which it can even be inferred that Complainant’s common law trademark enjoys any reputation at all.  See Kane v. Devine, D2001-1028 (WIPO Oct. 2, 2001) (lack of evidence as to promotion of complainant’s trademark or of its reputation in the market led the panel to find that the complainant had failed to show the respondent had no legitimate rights or interests in the domain name).

The Complaint asserts:

“Respondent registered the Disputed Domain to sell for an amount in excess of its out‑of‑pocket expenses as evidenced by the statement on its website offering it for sale.  Certainly, the intent was to sell it to the Complainant since Complainant had a common law trademark to this coined term and would be the only party logically interested in purchasing it.”

As mentioned earlier, Complainant’s evidence does not shed light on whether Respondent owned the disputed domain name or operated the disputed website at the time that the offer to sell was allegedly displayed.  Further, even if the Panel was to assume that Respondent was responsible for posting the offer to the disputed website, Complainant has not provided any evidence demonstrating why Respondent must have been directing that offer at Complainant.

Complainant has not provided any evidence to indicate why Complainant would be the “only party logically interested in purchasing” the disputed domain name.  By making that assertion, Complainant is representing, by implication, that it and it alone uses and holds proprietary rights to the word LANQUEST as a trademark and trade name and that this trademark is quite well known.  But Complainant provides no evidence to that effect.

Complainant does not assert any trademark registrations for LANQUEST or any applications to register that trademark.  Rather, Complainant asserts that Respondent had “constructive knowledge of Complainant’s common law trademark which it could have learned of by conducting a WHOIS query for <lanquest.net>, which was registered seven years before Respondent registered landquest.com.”  That is a rather surprising assertion.  Domain name registrations are not the legal or practical equivalent of trademark registrations in any sense.  From a legal perspective, domain name registrations do not confer proprietary rights.  From a practical perspective, it is extremely common for people lawfully to register domain names but not use them at all.  This is particularly so where someone has registered a domain name but has not also registered a corresponding trademark.

Complainant makes a number of assertions about the content and function of the Disputed Website, including:

“Respondent does not appear to use the Disputed Domain for an independent website.  Instead, the domain name merely redirects to a page which appears to have no connection to any association with the Disputed Domain.”

“Respondent…has never made any use of, or demonstrable preparations to use, the Domain Name or any name corresponding to the Domain Name in connection with a bona fide offering of goods or services.  Respondent simply has the Domain Name parked at a holding page with links to pages without any discernable commerce appearing on the site.  Even were commerce being conducted there it would not establish a legitimate interest.  Respondent’s use of the Domain Name to misdirect potential visitors to Respondent’s own commercial website and then to third-party commercial websites, for which Respondent presumably receives compensation in the form a “click through” or webpage impression revenues from third party websites where visitors are redirected…”

Complainant provides no documentary evidence to demonstrate the truth of any of those assertions.  If the assertions are, in fact, true, it ought to have been easy to provide some documentary evidence establishing their truth.  See White Pine Software, Inc. v. Desktop Consulting, Inc., D2000-0539 (Aug.31, 2000) (the panel declined to transfer the contested domain name where a full factual record had not been provided so that a conclusive determination could be made regarding the parties' respective claims to the contested domain name). 

Complainant asserts that Respondent has not acquired trademark or service mark rights in the disputed domain name.  However, once again, Complainant provides no evidence in support of that assertion.  It would be completely inappropriate for any complainant to make assertions of this type without first having conducted appropriate searches.  If such searches have been conducted by Complainant, it would have been easy and inexpensive to include them in the Complaint.  Complainant has not provided any such evidence.

Paragraph 10(d) of the Rules gives the Panel the power to determine the admissibility, relevance, materiality and weight of evidence.  For the most part, Complainant’s assertions about Respondent and the Disputed Domain cannot even be considered to be evidence.  The Panel is not prepared to accept as evidence Complainant’s assertions noted above as they are not supported by documentary or sworn evidence.

Complainant represents that it has never authorized Respondent or its predecessors to use the trademark LANQUEST.  Complainant goes on to assert that because Complainant has not authorized Respondent to use the trademark LANQUEST, that gives rise to the presumption that Respondent cannot establish that is has rights or any legitimate interests in the disputed domain name. 

In the Panel’s view, the mere fact that Complainant has not licensed or otherwise authorized Respondent’s use of LANQUEST, in and of itself, cannot satisfy Complainant’s burden in relation to Paragraph 4(a)(ii) of the Policy and thereby shift the burden to Respondent to prove that it does have rights or legitimate interests.  Except in the rare situation in which a complainant and respondent have had a previous business relationship, there will never be a license in place between a complainant and a respondent.  Apart from that kind of situation, there is very little legal significance to the absence of authorization.  Does the lack of a license from the owner of a particular trademark create the presumption that anyone that who uses a similar trademark is an infringer?  On the other hand, proving that a license agreement does exist might constitute a complete defence to a claim for trademark infringement or cybersquatting.  It would be wrong on several levels to equate the absence of a particular defence with proof of culpability. 

Depending on all the circumstances of each particular case, the lack of a license may be a relevant consideration in the assessment of whether or not a respondent has rights and legitimate interests in a domain name.  However, such evidence, standing alone, is neither necessary nor sufficient for satisfying a complainant’s burden in relation to Paragraph 4(a)(ii) of the Policy.

In the circumstances of this particular case, Complainant has not established any facts that demonstrate why Respondent ought to need a license or other form of authorization from Complainant.  Complainant has not established the existence of common law rights.  Even if the Panel was to accept that Complainant holds some common law rights in LANQUEST, Complainant has not established that the common law trademark is so well known that Respondent, who resides in Korea, ought to have known about it.  See Clear!Blue Holdings L.L.C. v. NaviSite, Inc., FA888071 (Nat. Arb. Forum Mar. 5, 2007) (a complainant's contentions that the respondent was using its marks in bad faith were found to be unpersuasive assumptions and conclusions where the complainant could not substantiate with evidence that its marks were famous and widely used). 

The Panel finds that Complainant has failed to satisfy its burden under Paragraph 4(a)(ii) of the Policy.

Registration and Use in Bad Faith

The final element that Complainant must establish under the Policy is that the disputed domain name has been registered and is being used in bad faith.

Complainant makes the following allegations in relation to this element:

(a)                Respondent registered the disputed domain name primarily for the purpose of selling, renting, or otherwise transferring it to the Complainant or to a competitor of Complainant, for valuable consideration in excess of Respondent’s documented out‑of‑pocket costs directly related to the disputed domain name.

(b)               Respondent’s use of the disputed domain name to misdirect potential visitors looking for Complainant’s website to its own site and other third‑party websites is evidence that Respondent registered the disputed domain name to deceptively attract and then misdirect Internet users for Respondent’s own commercial gain.

In support of the first allegation, Complainant tenders a page printed from the WayBackMachine archives showing a page that is supposed to have been posted at the Disputed Website on March 6, 2005.  That screen shot does, in fact, contain the following statement:

“You visiting this URL is available, if you are interested in buying this domain name please contact quoman@dreamwiz.com”.

However, Complainant says that the disputed domain name was registered on July 24, 2003.  Hence, even if this evidence from 2005 was considered to be reliable and relevant, the conduct of Respondent, or its predecessor in title, in March of 2005 does not prove Respondent’s intention in 2003, or, for that matter, in 2007, which is when the Complaint issued.

In any event, trading in domain names does not, in and of itself, constitute cybersquatting or any other form of illegal or improper activity.  The offer to sell that appears to have been displayed at the disputed website in 2005 was not specifically directed to Complainant.  Complainant has not provided any evidence that Respondent has approached Complainant or one of its competitors attempting to sell the disputed domain name.  Rather, Complainant merely asserts that Respondent must have been acting in bad faith because “Complainant had a common law trademark to this coined term and would be the only party logically interested in purchasing it”  As noted earlier, Complainant has also failed to provide sufficient evidence to establish that it actually has acquired common law trademark rights in LANQUEST.  Even if the Panel was prepared to find that Complainant did own the a common law trademark LANQUEST, the minimal evidence provided by Complainant does not support the inference that the trademark had acquired a reputation of such magnitude at the relevant time that Respondent would necessarily have intended to capitalize on that reputation.

As well, the Panel notes that Complainant has not provided any objective evidence that actually shows the content, appearance, or function of Respondent’s website around the time that the Complaint issued.  If Respondent’s current website supports all of the allegations of bad faith conduct asserted by Complainant, why would Complainant not have included a copy of the website with the Complaint?  Accordingly, the Panel assumes that, at the time that the Complaint issued, Respondent’s current use of the disputed website did not offer the domain name for sale and does not otherwise suggest any bad faith on the part of Respondent.

Complainant also alleges that Respondent is using the disputed domain name for the purpose of misdirecting potential visitors looking for Complainant’s website to its own site and other third-party websites.  Once again, Complainant has not provided any objective evidence indicating that any misdirection is actually taking place.  More important, Complainant has not provided any evidence, beyond mere assertions, that there exists a factual basis from which the Panel ought to infer that Respondent is intentionally attempting to create a likelihood of confusion and thereby attract for its own commercial gain Internet users looking for Complainant’s website.  See QAS Systems Ltd. v. Hopewiser Ltd., D2001-0273 (WIPO Apr. 29, 2001) (bare assertion by the complainant that the respondent is a direct competitor and therefore must know that disputed mark is used by the complainant, when unsupported by evidence, is insufficient to establish that the respondent was acting in bad faith).  In fact, Complainant has not provided any objective evidence showing the content, (appearance) or function of the disputed website since 2005.

The Panel finds that Complainant has failed to satisfy its burden under Paragraph 4(a)(ii) of the Policy.

DECISION

Having failed to establish any of the three elements required under the ICANN Policy, the Panel concludes that relief shall be DENIED.

Accordingly, it is the decision of this Panel that the domain name at issue, <lanquest.com>, not be transferred from Respondent to Complainant.

Robert A. Fashler, Panelist
Dated: March 27, 2007

 

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