Westmore · UDRP DecisionWwwhartfordinsurance.com
The Panel ordered transfer of <wwwhartfordinsurance.com>. It found the domain confusingly similar to the Complainant’s HARTFORD marks, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The bad-faith finding relied principally on the Respondent’s knowledge of the longstanding marks, use of a pay-per-click parking page containing links to competing services, and typosquatting through omission of the period after “www”.
The timeline behind wwwhartfordinsurance.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The decision illustrates the combined significance of a missing-period “www” typo, incorporation of a trademark with an industry-related term, and monetized parking-page use. The Panel did not rely on default alone: it identified longstanding prior rights, actual knowledge and intentional association, competitive pay-per-click links, and the typosquatting structure as grounds for transfer.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
WIPO Arbitration and Mediation Center ADMINISTRATIVE PANEL DECISION Hartford Fire Insurance Company v. Dealwave / Whois Privacy Services c/o Domain Hostmaster, Customer ID: 15391136717642 Case No. D2016-0407 1. The Parties The Complainant is Hartford Fire Insurance Company of Hartford, Connecticut, United States of America, represented by Fross Zelnick Lehrman & Zissu, PC, United States of America. The Respondent is Dealwave of Columbia, Maryland, United States of America / Whois Privacy Services c/o Domain Hostmaster, Customer ID: 15391136717642 of Fortitude Valley, Queensland, Australia. 2. The Domain Name and Registrar The disputed domain name <wwwhartfordinsurance.com> is registered with Fabulous.com (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 29, 2016. On March 1, 2016, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 2, 2016, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to the Complainant on March 4, 2016 providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on March 4, 2016. The Center verified that the amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the ”Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on March 9, 2016. In accordance with the Rules, paragraph 5, the due date for Response was March 29, 2016. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 1, 2016. The Center appointed Andrew Mansfield as the sole panelist in this matter on April 8, 2016. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant and its related entities (hereinafter “The Hartford” and/or “the Complainant”), whose business was founded in 1810, operate one of the largest insurance and financial services businesses in the United States. The Hartford is a leading provider of investment products. The Hartford has provided and continues to provide its products and services under the marks HARTFORD, THE HARTFORD and other HARTFORD-inclusive marks (collectively “the HARTFORD Marks”). The Hartford spends tens of millions of dollars annually on advertising and promoting the HARTFORD Marks and its products and services under the HARTFORD Marks, including via television, radio, print media, and on the Internet. The Complainant holds several domain names including the HARTFORD Marks and amongst these also the domain names <thehartford.com> and <hartfordinvestor.com> which were registered respectively on June 11, 1995 and October 5, 2000. The Complainant’s outside counsel sent a letter to the Respondent, on January 12, 2016 notifying the Respondent of the Complainant’s rights in the HARTFORD Marks and requesting that the Respondent agree to voluntarily transfer the Domain Name to the Complainant. The Respondent did not respond to the letter. The Complainant owns, amongst others, the following trademarks: US trademark THE HARTFORD No. 1155051 registered on May 19, 1981 (first use in 1971) – Insurance underwriting service in Class 36. US trademark HARTFORD No. 2,153891 registered on April 28, 1998 (first use in 1996) – Asset management, investment, retirement planning services in Class 36. The disputed domain name was registered on or around August 23, 2012. Visitors to the URL corresponding to the disputed domain name are currently redirected to the website at: ”www.searchesinteractive.com/?dn=wwwhartfordinsurance.com&pid=9P01F8DZO” This website merely displays a parking page provided by the Searcheslnteractive.com. 5. Parties’ Contentions A. Complainant The Complainant claims that the disputed domain name is confusingly similar to the Complainant’s HARTFORD Marks. This is especially so where the disputed domain name consists of “www” affixed to a trademark. The Complainant asserts that the Respondent has no rights or legitimate interests with respect to the disputed domain name nor is the Respondent a licensee of the Complainant. The Complainant also alleges that the Respondent registered and is using the disputed domain name in bad faith for the following reasons: a) The Complainant’s HARTFORD Marks were registered, used and extensively promoted well before the Respondent registered the disputed domain name <wwwhartfordinsurance.com>. One must conclude, states the Complainant, that the Respondent, when it purportedly registered and acquired the disputed domain name on or around August 23, 2012 was aware of the Complainant’s HARTFORD Marks and rights; b) The Respondent is trying to take advantage of the HARTFORD Marks in order to confuse consumers and trade on the Complainant’s rights and reputation and to drive traffic to its own website, all for its own commercial benefit. Therefore, the Complainant submits that the website has been registered to commercially profit from the likelihood of confusion between the trademark and the disputed domain name; c) The website at the disputed domain name displays a parking page provided by the Registrar, where pay-per-click advertisements and hyperlinks, including some that refer to services competing with those of the Complainant, are displayed; d) The Respondent did not respond to the Complainant’s cease and desist letter. e) The fact that the disputed domain name merely adds “www” to the HARTFORD Marks and simply omits a period between “www” and the remainder of words otherwise constituting a HARTFORD mark. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings In order for the Complainant to obtain the transfer of the disputed domain name, paragraphs 4(a)(i)-(iii) of the Policy require that the Complainant demonstrate to the Panel that: i. The disputed domain name 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 in respect of the disputed domain name; and iii. The disputed domain name has been registered and is being used in bad faith. A. Identical or Confusingly Similar The Complainant has established rights in the HARTFORD Marks. The Panel agrees with the Complainant’s assertions that the disputed domain name consists of three letters (“www”) added, without a period, to the HARTFORD trademark, additionally adding the word “insurance” after “HARTFORD” along with the “.com” generic Top-Level Domain (“gTLD”). This finding is in accord with prior UDRP decisions. See , e.g., CSC Holdings, Inc. v. Elbridge Gagne, WIPO Case No. D2003-0273 . The Panel finds the disputed domain name to be confusingly similar to the HARTFORD Marks in which the Complainant has rights. Accordingly, the Panel finds that the Complainant has satisfied paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests The Complainant has made out a prima facie case that the Respondent does not have rights or legitimate interests in the disputed domain name. The Respondent has no connection or affiliation with the Complainant and the Complainant has not licensed or otherwise authorized the Respondent to use or register any domain name incorporating the Complainant’s Marks. The Respondent does not appear to make any legitimate noncommercial or fair use of the disputed domain name, nor any use in connection with a bona fide offering of goods or services for the reasons described in section 6.C below. In addition, the Respondent does not appear to be commonly known by the name “Hartford” or by similar names. Finally, the Respondent has not replied to the Complainant’s contentions, alleging any rights or legitimate interests in the disputed domain name. Accordingly, the Panel finds that the Complainant has satisfied paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith Based on the evidence put forward by the Complainant, the Panel is of the opinion that the Respondent was aware of the Complainant’s trademark registrations and rights to the HARTFORD Marks when it registered the disputed domain name. In fact, the Complainant’s trademark is a fanciful name. It has been utilized for many years and this use came long before the disputed domain name’s registration. Without the provision by the Respondent of any evidence to the contrary, the Panel finds that the Respondent knew of the Complainant’s Marks and intentionally intended to create an association with the Complainant and its business. The Respondent is found to have had actual knowledge of the Complainant’s trademark at the time of the registration of the disputed domain name. The Panel notes that the disputed domain name displays a parking page, where pay-per-click advertisements and hyperlinks including some referring to services competing with those of the Complainant are displayed, and that this falls clearly within the example of bad faith set out in paragraph 4(b)(iv) of the Policy. An inference of bad faith registration and use of the disputed domain name is also available from the fact that the Respondent never replied to the Complainant’s cease and desist letter. No evidence to rebut the facts presented by the Complainant may be found. Further inference of bad faith is given by the fact that the disputed domain name might be entered by an Internet user who forgets to type or omits the period between “www” and the remainder of the disputed domain name. This is a form of typosquatting based on a mistake made by the user searching for the Complainant on the Internet. For these reasons, the Panel finds that the Respondent registered and is using the disputed domain name in bad faith. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <wwwhartfordinsurance.com> be transferred to the Complainant. Andrew Mansfield Sole Panelist Date: April 26, 2016
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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