National Arbitration Forum

 

DECISION

 

EWM Brand Holdings, LLC v. Don Ross Nabb Productions, LLC c/o Don Nabb

Claim Number: FA0703000952231

 

PARTIES

Complainant is EWM Brand Holdings, LLC (“Complainant”), represented by Nhut Tan Tran, of Godwin Pappas Langley Ronquillo LLP, 1201 Elm Street, Suite 1700, Dallas, TX 75270.  Respondent is Don Ross Nabb Productions, LLC c/o Don Nabb (“Respondent”), 711 S. Carson St., Carson City, NV 78901.

 

REGISTRAR AND DISPUTED DOMAIN NAMES 

The domain names at issue are <thestudiosatlascolinas.com> and <themoviestudiosatlascolinas.com>, registered with Go Daddy Software, 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.

 

David S. Safran, as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to the National Arbitration Forum electronically on March 30, 2007; the National Arbitration Forum received a hard copy of the Complaint on April 2, 2007.

 

On April 2, 2007, Go Daddy Software, Inc. confirmed by e-mail to the National Arbitration Forum that the <thestudiosatlascolinas.com> and <themoviestudiosatlascolinas.com> domain names are registered with Go Daddy Software, Inc. and that Respondent is the current registrant of the name.  Go Daddy Software, Inc. has verified that Respondent is bound by the Go Daddy Software, 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 April 11, 2007, a Notification of Complaint and Commencement of Administrative Proceeding (the “Commencement Notification”), setting a deadline of May 2, 2007 by which Respondent could file a Response to the Complaint, was transmitted to Respondent via e-mail, post and fax, to all entities and persons listed on Respondent’s registration as technical, administrative and billing contacts, and to postmaster@thestudiosatlascolinas.com and postmaster@themoviestudiosatlascolinas.com by e-mail.

 

A timely Response was received in hard copy only on May 2, 2007 and as such was not in compliance with ICANN Rule 5(a).

 

An Additional Submission from Complainant was timely received on May 7, 2007.

 

On May 10, 2007, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed David S. Safran, as Panelist.

 

INITIAL PROCEDURAL ISSUE

While Respondent’s electronic submission was received in a timely manner, Respondent failed to send a hard copy of its Response to either the Forum or Complainant.  In light of this deficiency, the Panel has the sole discretion as to whether to accept the Response as well as the amount of weight given to the Response.  See Six Continents Hotels, Inc. v. Nowak, D2003-0022 (WIPO Mar. 4, 2003) (holding that the respondent’s failure to submit a hard copy of the response and its failure to include any evidence to support a finding in its favor placed the respondent in a de facto default posture, permitting the panel to draw all appropriate inferences stated in the complaint).  However, the Panel has decided to exercise its discretion in favor of considering Respondent’s submission.  See Strum v. Nordic Net Exch. AB, FA 102843 (Nat. Arb. Forum Feb. 21, 2002) (“[R]uling a Response inadmissible because of formal deficiencies would be an extreme remedy not consistent with the basic principles of due process. . . ."); see also J.W. Spear & Sons PLC v. Fun League Mgmt., FA 180628 (Nat. Arb. Forum Oct. 17, 2003) (finding that where the respondent submitted a timely response electronically, but failed to submit a hard copy of the response on time, “[t]he Panel is of the view that given the technical nature of the breach and the need to resolve the real dispute between the parties that this submission should be allowed and given due weight”).

 

RELIEF SOUGHT

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

 

PARTIES’ CONTENTIONS

A. Complainant

Complainant contends that the domain names <thestudiosatlascolinas.com> and <themoviestudiosatlascolinas.com> are identical and confusingly similar to its mark THE STUDIOS AT LAS COLINAS in which it holds rights as the successor through forclosure of the party which had been using the mark since 1981.  Complainant also contends that Respondent has no rights or legitimate interests in the domain names <thestudiosatlascolinas.com> and <themoviestudiosatlascolinas.com> since Respondent does not use them in connection with a bona fide offering of goods or services, that the Respondent is not known by the domain names and is not associated with the Studios at Las Colinas, and that the domain names are not being used for legitimate noncommercial or fair use purposes.  Complainant also asserts that the domain names <thestudiosatlascolinas.com> and <themoviestudiosatlascolinas.com> were registered and are being used in bad faith since they were registered in violation of its agreement with GoDaddy.com and are being used for illegitimate purposes with knowledged of Complainant’s prior rights.

 

B. Respondent

Respondent contends that it registered and is using the domains with the consent of the prior owner whose rights were acquired by Complainant.

 

C. Additional Submissions

Complainant’s Additional Submission merely amplifies its prior contentions.

 

FINDINGS

The Panel finds that the domain names <thestudiosatlascolinas.com> and <themoviestudiosatlascolinas.com> are confusingly similar to a trademark in which Complainant has rights, that Respondent has no rights or legitimate interests in the domains, and that the domains were registered and are being used in bad faith.

 

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 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;

(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 ownership of the THE STUDIOS AT LAS COLINAS mark through common law rights in the mark further supported by a pending United States Patent and Trademark Office (“USPTO”) registration of the mark (Serial No. 78/888,570 filed May 21, 2006).  Complainant contends that it has used, via its predecessor in interest, the mark exclusively and continuously in connection with services for major motion picture, television, and commercial productions since 1981.  Complainant argues that it has expended substantial sums of money, time and effort in promoting its goods and services under the mark resulting in a widely recognized mark.  The Panel finds that Complainant has established common law rights in the THE STUDIOS AT LAS COLINAS mark sufficient to satisfy Policy ¶ 4(a)(i).  See S.A. Bendheim Co., Inc. v. Hollander Glass, FA 142318 (Nat. Arb. Forum Mar. 13, 2003) (holding that the complainant established rights in the descriptive RESTORATION GLASS mark through proof of secondary meaning associated with the mark); see also Tuxedos By Rose v. Nunez, FA 95248 (Nat. Arb. Forum Aug. 17, 2000) (finding common law rights in a mark where its use was continuous and ongoing, and secondary meaning was established).

 

Complainant argues that the <thestudiosatlascolinas.com> domain name is identical to Complainant’s THE STUDIOS AT LAS COLINAS mark and the <themoviestudiosatlascolinas.com> domain name is confusingly similar to the mark.  Complainant argues that the <thestudiosatlascolinas.com> domain name includes Complainant’s mark in its entirety without any alteration.  Complainant states that the inclusion of the term “movie” in the <themoviestudiosatlascolinas.com> domain name does not distinguish the disputed domain name from Complainant’s mark since the term “movie” is descriptive of Complainant’s business.  The Panel finds that the <thestudiosatlascolinas.com> domain name is identical to Complainant’s mark and the <themoviestudiosatlascolinas.com> domain name is confusingly similar to the mark pursuant to Policy ¶ 4(a)(i).  See Isleworth Land Co. v. Lost in Space, SA, FA 117330 (Nat. Arb. Forum Sept. 27, 2002) (“[I]t is a well established principle that generic top-level domains are irrelevant when conducting a Policy ¶ 4(a)(i) analysis.”); see also Oki Data Ams., Inc. v. ASD, Inc., D2001-0903 (WIPO Nov. 6, 2001) (“[T]he fact that a domain name wholly incorporates a Complainant’s registered mark is sufficient to establish identity [sic] or confusing similarity for purposes of the Policy despite the addition of other words to such marks.”); see also Brown & Bigelow, Inc. v. Rodela, FA 96466 (Nat. Arb. Forum Mar. 5, 2001) (finding that the <hoylecasino.net> domain name is confusingly similar to the complainant’s HOYLE mark, and that the addition of “casino,” a generic word describing the type of business in which the complainant is engaged, does not take the disputed domain name out of the realm of confusing similarity).

 

Rights or Legitimate Interests

 

Complainant asserts that Respondent lacks rights or legitimate interests in the disputed domain name.  In G.D. Searle v. Martin Mktg., FA 118277 (Nat. Arb. Forum Oct. 1, 2002), the panel found that the complainant’s submission of a complaint constituted a prima facie case for purposes of the Policy.  Additionally, in Do The Hustle, LLC v. Tropic Web, D2000-0624 (WIPO Aug. 21, 2000), the panel found that the complainant’s assertion that the respondent lacked rights or legitimate interests in the disputed domain name shifted the burden to the respondent to demonstrate that the respondent did have rights or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(a)(ii).  Thus, the Panel finds that Complainant’s assertion that Respondent lacks rights or legitimate interests in the disputed domain constitutes a prima facie case and shifts the burden to Respondent to demonstrate that it does have rights or legitimate interests as outlined in Policy ¶ 4(c).

 

Complainant contends that Respondent is using the <thestudiosatlascolinas.com> and <themoviestudiosatlascolinas.com> domain names to redirect Internet users to Respondent’s website located at the <drnshowbusiness.com> domain name.  Complainant argues that Respondent operates a website that deceives consumers and misappropriates public goodwill in Complainant’s mark.  In its Additional Submission Complainant states that Respondent has failed to provide any evidence of prior permissive use of the disputed domain names.  Complainant further states that Respondent does not have any contract or relationship with Complainant.  Complainant asserts that such use is neither a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i), as Respondent is misappropriating Complainant’s mark in order to promote its goods and services, nor a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii), as Respondent is operating a commercial website.  In its Additional Submission, Complainant emphasizes that Respondent has failed to meet any of the requirements for a bona fide offering of goods or services and has failed to provide any concrete evidence in support of its alleged legitimate interests.  The Panel finds that Respondent lacks rights or legitimate interests in the disputed domain name pursuant to Policy ¶¶ 4(c)(i) and (iii).  See Bank of Am. Corp. v. Nw. Free Cmty. Access, FA 180704 (Nat. Arb. Forum Sept. 30, 2003) (“Respondent's demonstrated intent to divert Internet users seeking Complainant's website to a website of Respondent and for Respondent's benefit is not a bona fide offering of goods or services under Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).”); see also Am. Online, Inc. v. Tencent Commc’ns Corp., FA 93668 (Nat. Arb. Forum Mar. 21, 2000) (finding that use of the complainant’s mark “as a portal to suck surfers into a site sponsored by [the respondent] hardly seems legitimate.”). 

 

Complainant further asserts that Respondent is not commonly known by the <thestudiosatlascolinas.com> and <themoviestudiosatlascolinas.com> domain names.  Complainant cites as evidence the fact that Respondent’s WHOIS information identifies Respondent as “Don Ross Nabb Productions, LLC.”  Complainant also asserts that Respondent is not sponsored by or affiliated with Complainant, and Complainant has not given Respondent permission to use Complainant’s mark in a domain name.  The Panel finds that Respondent lacks rights or legitimate interests in the disputed domain names pursuant to Policy ¶ 4(c)(ii).  See Tercent Inc. v. Lee Yi, FA 139720 (Nat. Arb. Forum Feb. 10, 2003) (stating “nothing in Respondent’s WHOIS information implies that Respondent is ‘commonly known by’ the disputed domain name” as one factor in determining that Policy ¶ 4(c)(ii) does not apply); see also Am. W. Airlines, Inc. v. Paik, FA 206396 (Nat. Arb. Forum Dec. 22, 2003) (“Respondent has registered the domain name under the name ‘Ilyoup Paik a/k/a David Sanders.’  Given the WHOIS domain name registration information, Respondent is not commonly known by the [<awvacations.com>] domain name.”).

 

            Registration and Use in Bad Faith

 

Complainant contends that Respondent is using the disputed domain names to redirect Internet users to its own website.  Complainant argues that because the disputed domain names are identical and confusingly similar to Complainant’s mark, Internet users seeking Complainant may instead find themselves redirected to Respondent’s website and may mistakenly believe that Respondent is somehow sponsored by Complainant.  Complainant asserts that Respondent is profiting from this confusion.  Such action has been found to evidence bad faith registration and use pursuant to Policy ¶ 4(b)(iv).  See Am. Univ. v. Cook, FA 208629 (Nat. Arb. Forum Dec. 22, 2003) (“Registration and use of a domain name that incorporates another's mark with the intent to deceive Internet users in regard to the source or affiliation of the domain name is evidence of bad faith.”); see also G.D. Searle & Co. v. Celebrex Drugstore, FA 123933 (Nat. Arb. Forum Nov. 21, 2002) (finding that the respondent registered and used the domain name in bad faith pursuant to Policy ¶ 4(b)(iv) because the respondent was using the confusingly similar domain name to attract Internet users to its commercial website).

 

While Respondent has asserted that it has registered and is using the domain names pursuant to consent received from Complainant’s predecessor and has provided a copy of a letter dated July 20, 2003, to that effect, the Panel has noted that the domains were not registered until more than two years later and after Complainant acquired ownership of the Studios at Las Colinas mark and the underlying business.  Given the close working relationship that Respondent contended existed between it and Complainant’s predecessor in interest, it is reasonable for the Panel to attribute knowledge of the transfer of ownership to Respondent and belated filing of the domain names to a change in Respondent’s relationship with the Studios at Las Colinas after Complainant acquired the Studios at Las Colinas mark and the underlying business.

 

As a result, the Panel finds Respondent has registered and is using the domains in bad faith pursuant to Policy ¶ 4(b)(iv). 

 

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 <thestudiosatlascolinas.com> and <themoviestudiosatlascolinas.com> domain names be TRANSFERRED from Respondent to Complainant.

                                               

 

David S. Safran, Panelist
Dated: May 24, 2007

 

 

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