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Posts Tagged ‘Reverse Domain Name Hijacking’

Respondent Has Interesting Arguments For Registering Microsoft’s BING Domains

Monday, January 4th, 2010

       bing-logo

In the recent domain name dispute decision of Microsoft Corporation v. Doug Goodman FA1294422 (Nat. Arb. Forum, December 31, 2009) a single member Panel was faced with a dispute over 21 separate domains containing the mark BING. Microsoft needs no introduction and maintains many web sites for its business, the most relevant in this case being, www.bing.com. The disputed domains were registered during a three day period of June 24, 2009 through June 26, 2009. Respondent provided a response to the dispute, and gave some colorful defenses, which included:

1.    Respondent “created of formulated” the disputed domain names that had been missed by “Microsoft webmasters” until Respondent offered them to Complainant.
2.      The disputed domain names would bring value to the Complainant and the Complainant should pay for them.
3.      Respondent concedes that each of the names has BING in them and that BING is a pending mark
4.      The domain names were not registered in bad faith because Respondent had no intent to harm BING, Inc.
5.      Respondent does not use the disputed domain names to divert users from BING, Inc.
6.      Because of the value the disputed names will bring to Complainant, the case should be viewed as a case of reverse name highjacking

Paragraph 4(a) of the ICANN UDRP Policy requires Complainant to 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) 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 addressing the first element, Microsoft noted that it does not have any registered BING marks yet, but did file for multiple BING related trademarks in March 2009. The Panel noted that Microsoft need not have a trademark registration and can show that it has common law rights to the mark. Microsoft presented evidence that it has continuously used the BING mark since May 28, 2008 and that a previous UDRP Panel found that it had established its rights to the mark. As a result, the Panel reviewed the disputed domains and found that they were confusingly similar to the BING mark. Interestingly, as the Panel explained, Respondent concedes that he intentionally put the BING mark in the domains and was fully aware of Microsoft’s interest in the mark. The Panel found Microsoft satisfied this element.

Moving to the second element, the Panel noted that Microsoft put forth a prima facie case, shifting the burden of argument to Respondent. The Panel noted that Respondent was not commonly known by the disputed domain. Additionally, the Panel found that four (4) of the domains led users to a web site with third party hyperlinks, some of which compete with Microsoft. The Panel found that this was not a bona fide offering of services. Regarding the remaining 17 domains, the Panel noted that they redirected the user to Microsoft’s BING.com web site. The Panel explained that Respondent admitted his primary intention in registering these domains was to sell them to Microsoft. Offering to sell the domains is also not considered a bona fide use. The Panel found that Microsoft satisfied this element.

Moving to the final element, bad faith, the Panel noted that the Respondent attempted to sell the domains for more then his out-of-pocket expenses. This factor is considered bad faith. Additionally, the four domains which landed on parked pages, also were a showing of bad faith, since they likely resulted in click-through fees for Respondent. The Panel found Microsoft satisfied this element as well.

The Panel quickly dispensed with Respondent’s reverse domain name hijacking argument and found that since Microsoft had proved all three elements, it ordered all 21 domains be TRANSFERRED.

Panel Denies Claim For 3 Letter Domain, Finds Reverse Domain Name Hijacking

Monday, November 23rd, 2009

In the recent domain name dispute decision of Bin Shabib & Associates (BSA) LLP v. Hebei IT Shanghai ltd c/o Domain Administrator FA1287164 (Nat. Arb. Forum, November 19, 2009), a three member Panel was faced with a dispute over the domain www.bsa.com. Complainant is a law firm which operates in the United Arab Emirates and maintains a website at www.bsa.ae. Complainant claims rights to the BSA mark since based on two different dates, 2001 and 2007. Complainant filed for a trademark in the UAE, but has not yet received a registration. Respondent provided a Response, including an additional submission. The Panel noted that the Response was deficient for not being timely, but concluded to review the materials regardless.

Paragraph 4(a) of the ICANN UDRP 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.

In addressing the first element, the Panel explained:

The Panel finds that Complainant has failed to establish registered trademark rights or common law rights in the BSA mark. Specifically, Complainant’s use of the BSA mark for less than two years has been too short, and Complainant has not shown any evidence of the sort that is usually used to establish that a mark has acquired secondary meaning. In light of Respondent’s arguments, the Panel finds that Complainant has failed to establish common law rights in the BSA mark pursuant to Policy ¶ 4(a)(i)….Having found that Complainant has not satisfied Policy ¶ 4(a)(i) because it has failed to establish rights in the mark, the Panel declines to analyze the other two elements of the Policy.

The Panel was not finished though, since it then addressed the issue of Reverse Domain Name Hijacking.

The panel finds that Complainant has failed to present any evidence to support its claimed rights in the disputed domain name. It only provided an application for trademark registration which does not establish any enforceable rights under the UDRP. It did not offer any evidence to support a finding of common law rights in the disputed mark. Also, the Panel finds that Complainant knew or should have known that it was unable to prove that Respondent lacks rights or legitimate interests in the disputed domain name or that Respondent registered and is using the disputed domain name in bad faith. Based on the foregoing, the panel finds that reverse domain name hijacking has occurred.

In light of the following, the Panel DENIED Complainant’s request to transfer the domain. and made a finding of reverse domain name hijacking.

“Rare Names” Sees Rare Event…Panel Finds Reverse Domain Name Hijacking

Friday, September 11th, 2009

                  lincs

In the recent domain name dispute, Spinsix Strategic Marketing Design, LLC v. RareNames, WebReg FA1273907 (Nat. Arb. Forum, September 3, 2009), a single member Panel was faced with a dispute over the domain www.lincs.com. Complainant appears to be an marketing firm, which sells computer related online marketing tools. Complainant maintains a web site at www.spinsix.com. Complainant owns a trademark registration for the mark LINCS. Respondent appears to be a domainer and registered the disputed domain in September 2003.

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.

In addressing the first element, the Panel found that Complainant had established rights to the mark LINCS through its trademark registration. However, the Panel noted Complainant did not provide sufficient evidence of common law rights dating back to the first use date of January 2004. The Panel recognized that Respondent argued that the disputed domain registration date predated the first use allegations from Complainant, but declined to review the information for this element. The Panel found this element satisfied by Complainant.

Moving to the second element, the Panel found that Complainant failed to establish a prima facie case under the Policy. The Panel noted:

Respondent has offered convincing proof that it is in the business of registering generic domain names and displaying advertising that relates to the generic nature of the terms in the domain names. Respondent asserts that engaging in the sale of generic domain names is a legitimate business.  The Panel finds that Respondent has used the disputed domain name in connection with a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i)….Respondent also argues that the term in the <lincs.com> domain name is generic and of common use and therefore, Complainant does not have an exclusive monopoly on the term on the Internet. Respondent has offered convincing evidence that the contested domain name is comprised of a common term, such that the Panel finds that Respondent has established rights or legitimate interests in the disputed domain name pursuant to Policy ¶ 4(a)(ii).

The Panel then simply stated that the disputed domain was registered before Complainant’s first use of the mark, and then concluded that section finding Respondent had rights or legitimate interests in the domain.

The Panel declined to review the bad faith element in light of this finding and instead moved to Respondent request for a finding of Reverse Domain Name Hijacking. The Panel repeated some of Respondent’s arguments, but did not provide much of its own analysis. Respondent argued:

Complainant has attempted to engage in reverse domain name hijacking by filing the instant UDRP case, with the knowledge both that Respondent had rights or legitimate interests in the disputed domain name, and that Respondent could not have registered  the disputed domain name in bad faith, because its registration of September 01, 2003, pre-dated Complainant’s asserted common law usage of the mark in January of 2004.

In light of these arguments, the Panel found that Complainant engaged in reverse domain name hijacking and DENIED Complainant’s request for transfer.

AAA Auto Club Can’t Get AAA.net

Monday, July 27th, 2009

In the recent domain dispute decision of The American Automobile Association, Inc. v. QTK Internet c/o James M. van Johns FA1261364 (Nat. Arb. Forum, July 25, 2009) a three member Panel provided an interesting decision regarding www.aaa.net. Our friends over at Domain Name Wire provided an excellent review of the decision, so we suggest you read their version. (available here). We can already forsee that there will be many future disputes which cite to this decision.

Is SHOE LAND Generic?

Friday, June 12th, 2009

In the recent decision of Shoe Land Group LLC v. Development, Services c/o Telepathy Inc. (Nat. Arb Forum 1255365, June 9, 2009) a three member Panel was faced with a dispute over the domain www.shoeland.com. Complainant, is a footwear retail store and maintains a web site at www.shoeland.net. Complainant claimed use of the mark SHOE LAND since March 1, 1997 and has a Federal registration for the mark since April4, 2006. Respondent replied to the ICANN UDRP complaint noting that they are a business who regularly registers domains with intrinsic value and generates revenue from pay-per-click advertising links. The disputed domain was registered in 1998.

As the Panel noted, 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.

The Panel began with the first prong, whether the domain was identical or confusingly similar to Complainant’s mark. The Panel found that complainant had sufficient rights under the Policy ¶4(a)(i), but noted as follows:

In its Complaint and Additional Submission, Complainant also asserts and provides evidence of its rights in the SHOE LAND mark through its continuous use of the mark in commerce since at least as early as March 1997. Nevertheless this use of the mark remained local, and does not provide the mark with secondary meaning. As a result, the Panel finds that Complainant does not have sufficient common law rights in the SHOE LAND mark under Policy ¶ 4(a)(i), dating back to March 1997. 

Regardless the Panel found Complainant had satisfied the first prong. Moving to the second prong, whether Respondent had any rights or legitimate interests in the domain, the Panel noted that Complainant failed to establish a prima facie case. Respondent argued, and the Panel agreed as follows:

Complainant does not have common law rights dating back as far as September 1998, when Respondent registered the disputed domain name, because Complainant’s SHOE LAND mark had not acquired secondary meaning by that time.  Respondent contends that the evidence put forth by Complainant fails to demonstrate that Complainant was well-known yet outside of the Orlando, Florida area, or that Complainant had spent much money promoting the SHOE LAND mark.    

Respondent also argued that it registered generic domain names as a business practice, which would satisfy the rights or legitimate interests section of the policy. The Panel agreed with this concept as well finding that “registering such a generic domain name is a business practice that confers upon the practitioner rights or legitimate interests in that domain name. As a result, the Panel finds that Respondent established rights in the disputed domain name pursuant to Policy ¶ 4(a)(ii).”

Moving to the last prong, whether the domain was registered and used in bad faith, the Panel explained that since Respondent had proved it had rights or legitimate interests in the domain at the time of registration, then the registration could not have been in bad faith. The Panel explained:

The Panel finds that a respondent is free to register a domain name consisting of common terms, unless he is aware or should have been aware of the secondary meaning those common terms had at the time of the registration. Since the disputed domain name contains such common terms and as there was no secondary meaning at the time of the registration, the Panel is of the opinion that Respondent did not register  the <shoeland.com> domain name in bad faith under Policy ¶ 4(a)(iii).

The Panel also addressed a request by Respondent to find Reverse Domain Name Hijacking. The Panel explained that since Complainant provided evidenced of active promotion of the SHOE LAND mark since 1997 there could not be reverse domain name hijacking. The Panel further explained that reverse domain name hijacking requires bad faith on the part of Complainant and that none was present.

For an interesting counter perspective on the issue of reverse domain name hijacking, read the dissenting opinion by one of the Panelists, who believes this was a clear case of reverse domain name hijacking. He argues that the Complainant had no reasonable basis for arguing bad faith The single dissenting Panelist also chastises the Complainant for revealing emails and facts that the parties engaged in settlement discussions and sale of the domain negotiations prior to the dispute, despite the fact that those communications were labeled “Confidential-For Settlement Purposes Only.”

Ultimately, the Panel DENIED Complainant’s request for transfer and DENIED Respondents request for reverse domain name hijacking.

No Laughing Matter For Improv Comedy Club

Tuesday, June 2nd, 2009

In two different decisions from the National Arbitration Forum, Improv West Associates, d/b/a Improv Comedy Clubs, was not laughing its way to winning some domain names. Improv West Associates maintain web sites at www.improv2.com, www.improv.com and www.improvclubs.com.

The first dispute was Improv West Associates v. Acimasiz Cocuq (Nat. Arb. Forum 1257098, May 12, 2009) where a single member panel was faced with a dispute over the domain www.improvcomedyclubs.com. In the decision, Complainant claims to have used the IMPROV COMEDY CLUB mark since 1963 in connection with live entertainment by stand-up comedians. The Panel noted that 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. Respondent failed to respond to the Complaint. Normally, a Panel will review all three elements in the decision, but this Panel only discussed Complainant’s failure of the third element, bad faith. The Panel explained:

Complainant argues that Respondent has registered and used the disputed domain name in bad faith in that Respondent solely obtained the disputed domain name to sell it to Complainant for value or prevent Complainant from using the disputed domain name.  Noticeably missing from the Complaint, however, is any corroborating or supporting evidence to verify this claim.  The Complaint must provide more than legal assertions and conclusions of bad faith registration and use in order to qualify for its desired remedy under the Policy, and Complainant has failed in this task.  Thus, the Panel cannot, and will not, make a finding of bad faith registration and use on the merits of the case under Policy ¶ 4(a)(iii).

Therefore, the Panel DENIED Complainant’s request for transfer.

The second dispute was Improv West Associates v. Not Applicable a/k/a Kenneth Arnold (Nat. Arb. Forum 1256834, May 13, 2009) where a single member Panel was faced with a dispute over the domain www.improvcomedyclub.com. Unlike the first case above, this Respondent put up a fight and the Panel provided an in-depth analysis of the three UDRP ICANN elements of proof and the parties’ claims.

Although most Panels normally only address the three elements stated above, this Panel created a separate section addressing “rights in a mark” for Complainant.  The Panel noted that Complainant does not have any registered marks for IMPROV COMEDY CLUB, and only recently filed trademark applications for IMPROV. Those applications remain pending, and the Panel explained the under the Policy trademark applications do not give rise to trademark rights. Therefore, the Panel was faced with determining whether Complainant had acquired sufficient common law rights. Interestingly, Complainant’s counsel submitted his own affidavit attesting to 25 years of personal experiences attending the IMPROV COMEDY CLUB. Weighing that “evidence” the Panel explained:

Ignoring those parts of the affidavit [by counsel] expressing opinions about the very issue to be determined, the Panel is prepared to accept, for the purposes of this administrative proceeding and despite the slender evidence which that affidavit provides, that Complainant has, through use, acquired common law rights in the mark IMPROV COMEDY CLUB.  The Panel is not satisfied that the same can be said in relation to the word IMPROV.

The panel next moved into the full three element analysis, where it quickly agreed that the disputed domain was identical or confusingly similar to Complainant’s mark. Moving to the second prong, whether Respondent had any rights or legitimate interests in the domain, the Panel explained as follows:

Respondent has provided no evidence to support his contention that he intends to use the domain name for the improvised comedy club services it describes or at all. He does not even identify the other domain name under which he claims to have operated a business with which the present domain name is claimed to be associated….In the absence of any evidence of use or demonstrable preparations to use the domain name since it was registered in 1999, the Panel finds Respondent has no rights or legitimate interests in the domain name.

The Panel then moved to the last element, whether the Respondent registered and used the domain in bad faith. Complainant sought an inference from the Panel that bad faith occurred as a result of a finding of no rights or legitimate interests. The Panel rejected this proposition. The Complainant also alleged that Respondent’s lack of use of the domain for 10 years also inferred bad faith in line with the famous “passive holding” case of Telstra Corp. Limited v. Nuclear Marshmallows (D2000-00003 WIPO Feb. 18, 2000). The Panel disagreed with this proposition and stated as follows:

The present case, however, is on all fours with Alberto-Culver Co. v. Pritpal Singh Channa, D2002-0757 (WIPO Oct. 7, 2002), in which the domain names were <staticguard.com> and <staticguards.com>.  The learned panelist said:
 
…Complainant relies on the idea of “passive holding” as established in Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003. This case established the proposition that doing nothing with a domain name may amount to bad faith registration and use. However the Panelist in that case was extremely careful to note that this principle does not apply to every example of passive holding. The specific circumstances in that case included false name information in the WHOIS record, false address information, failing to respond to the Complaint, an extremely famous mark within the geographical region of both Complainant and Respondent, and a mark that was entirely invented. This case has none of those features: Respondent has provided his name, and his address, and has responded within time to the Complaint. Complainant has provided no evidence that its mark is so well known that any registration (without use) of a domain name cannot help but lead to the conclusion that Respondent registered with male fides. And, unlike the mark in Telstra, the mark and the domain names here are the concatenation of two generic English words. I conclude therefore that the Telstra passive holding principle does not apply to the facts in this case.

The same words apply here with equal force, the only exception being that the name under which the domain name was registered was “Not Applicable.” The name and address of Respondent, Kenneth Arnold, were disclosed as the Administrative Contact and Technical Contact. Accordingly, registration in the name “Not Applicable” is insufficient to distinguish this case from Alberto-Culver Co., supra and insufficient to attract the “passive use” doctrine of Telstra Corp. Ltd., supra.

Ultimately, the Panel found that Complainant failed to establish the third element and DENIED the request for transfer. The Respondent also made a request for a finding of reverse domain hijacking, which the Panel rejected.

John Berryhill Wins Another Based on Complainant’s Failure to Establish Trademark Rights

Tuesday, March 17th, 2009

In the recent decision of Oystar USA, Inc. v. Domain Administrator info@heavylifting.com HeavyLifting, LLC (WIPO D2009-0025, March 6, 2009)(available here), a single member Panel was faced with a dispute over www.oystar.com. Complainant, Oystar USA is the subsidiary of Oystar Holding GmbH, based in Germany. Oystar operates a website at www.oystar.de. Oystar USA is involved in the packaging and processing industry and operates a website at www.oystarusa.com. Oystar claims to be the owner of the mark OYSTAR used in commerce in the U.S. since June 2007. Respondent, Heavy Lifting LLC, claims that it was not the original registrant of the domain, which was first registered in 2000. Respondent acquired the domain on April 19, 2006.

Respondent’s attorney, John Berryhill, provided some important arguments in favor of a denial. The Panel summarized the arguments as follows:

The Respondent contends that the Complainant has not demonstrated that it has rights in the OYSTAR marks. According to the Respondent, the Complainant is not the owner of the German national registrations for the OYSTAR marks, which the Respondent argues in any event, are of no legal effect in the United States. Even assuming that the Complainant’s German parent has granted its subsidiary the right to use the OYSTAR marks in the United States, the Respondent points out that there are no United States registrations for the marks, and that the USPTO has provisionally refused to extend protection to the OYSTAR marks. Nor, according to the Respondent, has the Complainant demonstrated enforceable rights based on use of the OYSTAR marks in the United States.

The Respondent’s arguments went further to explain:

According to the Respondent, the earliest date of any registration for the OYSTAR marks is a German registration in June 2008 obtained by the Complainant’s German parent, based on an application not filed until late 2007. The Respondent maintains that it acquired the disputed domain name in the spring of 2006. Even assuming arguendo that the Complainant had used the OYSTAR marks in commerce in the United States since June 2007, the Respondent asserts there is no conceivable basis to conclude that the Respondent registered the disputed domain name with the aim of exploiting the Complainant’s then non-existent rights in the marks.

The Panel then addressed the elements of paragraph 4(a)of the Policy which require a finding that (i) the domain name registered by the respondent is identical or confusingly similar to a trademark or service mark in which the complainant has rights; and (ii) the respondent has no rights or legitimate interests with respect to the domain name; and (iii) the domain name has been registered and is being used in bad faith.

The Panel began to address the first prong, where Respondent’s assertions regarding ownership of the mark proved to be fatal to Complainant. The Panel explained:

There is no dispositive basis in the provided record, however, upon which the Panel can conclude that the Complainant is the owner or exclusive licensee of the German registrations, and the United States applications for the OYSTAR marks (also held by the German parent company) are still in examination, and have not achieved the status of registered marks. Hence, the Complainant’s assertion of rights in the OYSTAR marks cannot on the present record be based on registration rights….While the Complainant asserts that is has continuously used the OYSTAR marks in the United States since June 2007, the Complainant has not submitted any evidence to substantiate this claim. The marketing brochures submitted by the Complainant upon examination appear to have been prepared by the German parent for general use by its various subsidiaries. Portions of the materials reflect a creation date of February 2008.

In addressing the nature and amount of evidence presented by Oystar, the Panel stated: “The Complainant has offered no evidence of the length and amount of sales under the marks, the nature and extent of advertising, or other relevant information such as consumer surveys or media recognition.”

Based upon the above stated reasons the Panel found that Oystar USA failed to establish it had any rights to the OYSTAR marks. The Panel elected to skip the remaining UDRP 4(a) prongs in light that finding. The Panel was also tasked with a determination of possible reverse domain hijacking. Based upon other presented evidence of Respondent’s use of the domain, the Panel found that a reverse domain hijacking claim was not merited. Ultimately the Panel DENIED Complainant’s request for transfer.

DefendMyDomain Commentary: We tip our hat to Mr. Berryhill for his insightful arguments in this dispute. The lesson to be learned herein is to make sure the proper Complainant brings the case, or at least to provide sufficient evidence of ownership of the trademark(s).

Porta-John vs. Porta-Jon: They care where you go!

Thursday, September 4th, 2008

In the case of Toilets.com, Inc. v. Porta-Jon of the Piedmont (WIPO D2008-1043, August 22, 2008), the Panel was faced with two long standing companies using nearly identical marks and web sites. Complainant first used the phrase “porta-john” for rented portable toilets in 1962. And owns registered mark for PORTA-JOHN since 1972. Complainant’s principal website is “www.porta-john.com”, which it has used continuously since 1997. Respondent conducted a similar business in the state of North Carolina since May 1969, and incorporated its business under the name Porta-Jon of the Piedmont, Inc. in North Carolina in 1973. Respondent holds state trademark registrations for PORTA-JON in North Carolina and South Carolina. Respondent registered the disputed domain name “porta-jon.com” in 1998 and used it to promote its business.

                 

The Complainant sent many cease and desist letters to Respondent over the years. The panel acknowledged, that the only fathomable argument in favor of finding a lack of legitimate purpose was that the cease and desist letters may have served as notice of the dispute. However, the panel quickly dismissed any validity or support thereto.

Instead the panel focused on the evidence presented in favor of legitimate use by the Respondent, noting:

This Panel cannot conceive circumstances in which decades of use of a business name, without interruption, can fail to give a registrant a right or legitimate interest under the Policy to incorporate the principal word in that name into a domain name used for purposes of that business. Such circumstances are exactly the reason for the safe harbor in paragraph 4(c)(ii) of the Policy.

The Panel observed further that:

To the extent Complainant believes its business has been adversely affected by Respondent’s long-time conduct, an action in court for trademark infringement or unfair competition is the appropriate means for seeking redress. A court action, not a Policy proceeding, similarly is the place to determine “priority” and other rights under national trademark laws. With its abbreviated proceedings and considerably lower costs, the Policy may appear to be a quick-and-dirty alternative to an infringement action or, as appears to be true in this case, to a further cease-and-desist letter.

Ulitimately, the Panel denied the transfer of the domain and found that the complaint was “nothing more than harassment” and was Reverse Domain Name Hijacking.

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