Westmore · UDRP DecisionSupport-geico.com
The Panel ordered transfer of <support-geico.com>. It found the domain confusingly similar to the GEICO trademark because it incorporated the mark in full, with only the descriptive term “support” and a hyphen added. The Respondent lacked rights or legitimate interests because the domain misleadingly diverted users to a website displaying PPC links, including links associated with the Complainant’s competitors. The Panel also found registration and use in bad faith under paragraph 4(b)(iv), concluding that the Respondent knew or must have known of the distinctive, long-registered GEICO mark and used confusion to attract Internet users for commercial gain.
The timeline behind support-geico.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
This decision illustrates that adding a customer-service-associated term such as “support” to a distinctive trademark may strengthen rather than reduce the appearance of affiliation. It also shows the importance of the content and presentation of a PPC page: PPC use is not inherently illegitimate, but it can defeat rights or legitimate interests and establish bad faith when the page suggests affiliation and channels confused users toward commercial links, including competitor-related links.
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 Government Employees Insurance Company (“GEICO”) v. Registration Private, Domains By Proxy, LLC / Carolina Rodrigues, Fundacion Comercio Electronico, Carolina Rodrigues Case No. D2020-3253 1. The Parties The Complainant is Government Employees Insurance Company (“GEICO”), United States of America, represented by Burns & Levinson LLP, United States of America (“United States”). The Respondent is Registration Private, Domains By Proxy, LLC, United States / Carolina Rodrigues, Fundacion Comercio Electronico, Carolina Rodrigues, Panama. 2. The Domain Name and Registrar The disputed domain name <support-geico.com> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 2, 2020. On December 3, 2020, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 4, 2020, 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 December 16, 2020 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 December 28, 2020. The Center verified that the Complaint together with 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 December 29, 2020. In accordance with the Rules, paragraph 5, the due date for Response was January 18, 2021. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 19, 2021. The Center appointed Alfred Meijboom as the sole panelist in this matter on February 5, 2021. 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 is an insurance company that has provided insurance services since 1936. The Complainant has presently over 17 million policies and insures more than 28 million vehicles, and also has over 40,000 employees. The Complainant has been trading under the trademark GEICO (the “Trademark”) for nearly 80 years and owns several Unites States trademarks, including - United States trademark registration GEICO with registration no. 763,274 of January 14, 1964 for insurance underwriting and related services, and - United States trademark registration GEICO with registration no. 2,601,179 of July 30, 2002, for services in class 36, including providing insurance brokerage and underwriting services for motor vehicles In connection with its insurance products and services, the Complainant has established a website located at “www.geico.com”. The disputed domain name was registered on November 2, 2020. The disputed domain name redirects to an inactive website containing a list of pay-per-click (PPC) links to third-party websites, including to websites of the Complainant’s competitors. 5. Parties’ Contentions A. Complainant The disputed domain name incorporates the Trademark in its entirety and is identical or confusingly similar to the Trademark. The mere addition of the descriptive or generic term “support” and a hyphen is insufficient to prevent similar confusion of the disputed domain name with a registered mark. Furthermore, the Complainant asserts that the Respondent has no rights or legitimate interests in the disputed domain name because the Respondent has no connection or affiliation with the Complainant and has not received any license or consent, express or implied, to use the Trademark in a domain name or in any other manner. The Complainant believes that the Respondent has never been known by the disputed domain name. The disputed domain name currently redirects to an inactive website containing a list of apparent PPC links to unrelated third-party websites, including to websites of the Complainant’s competitors. The Whois page for the disputed domain name indicates that the Registrant has listed it for sale by including hyperlinks in the top promotional banner directing users to “Visit our partner to buy” the disputed domain name. The website to which the “Visit our partner to buy” hyperlink resolves indicates that the disputed domain name is available for purchase for a minimum bid of USD 898. The Complainant believes that the Respondent is using and has used the disputed domain name to intentionally attempt to attract Internet users and consumers looking for legitimate services of the Complainant and/or authorized partners to the Respondent’s own webpage by creating a likelihood of confusion with the Complainant, all for commercial gain. This unauthorized use of the disputed domain name by the Respondent severely harms the Complainant by tarnishing and infringing the Trademark, its reputation and goodwill in the United States and around the world. Therefore, the Complainant claims that the disputed domain name was registered and is being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings The Respondent did not file a response. However, as set out in section 4.3 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), the Respondent’s default does not automatically result in a decision in favor of the Complainant. The Complainant must still establish each of the three elements required by paragraph 4(a) of the Policy. Although the Panel may draw appropriate inferences from the Respondent’s default, paragraph 4 of the Policy requires the Complainant to support its assertions with actual evidence in order to succeed in these proceedings. Paragraph 14(b) of the Rules provides that, in the absence of exceptional circumstances, the Panel shall draw such inferences, as it considers appropriate from a failure of a party to comply with a provision or requirement of the Rules. The Panel finds that in this case there are no such exceptional circumstances. Under the Policy, the Complainant must prove that: - the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and - the Respondent has no rights or legitimate interests in respect of the disputed domain name; and - the disputed domain name has been registered and is being used in bad faith. A. Identical or Confusingly Similar The Panel finds that the disputed domain name is confusingly similar to the Trademark. It is well established that the Top-Level Domain may typically be disregarded in the assessment under paragraph 4(a)(i) of the Policy. The disputed domain name incorporates the Trademark in its entirety in addition to the descriptive word “support” and a hyphen. This does not prevent confusing similarity between the disputed domain name and the Trademark. See, WIPO Overview 3.0 ., section 1.8 : “Where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element. The nature of such additional term(s) may however bear on assessment of the second and third elements”. Consequently, the Panel finds that the Complainant has satisfied the first requirement of paragraph 4(a) of the Policy. B. Rights or Legitimate Interests The Complainant must show a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name, which the Respondent may rebut (e.g., Croatia Airlines d.d. v. Modern Empire Internet Ltd ., WIPO Case No. D2003-0455 ). The Panel takes note of the various allegations of the Complaint and in particular, that no authorization has been given by the Complainant to the Respondent to use the Trademark or to register the disputed domain name and that the Respondent has not been commonly known by the disputed domain name. These allegations of the Complainant remain unchallenged. Furthermore, the Panel finds that the Complainant has demonstrated that the website to which the disputed domain name is redirected shows content suggesting that the Complainant exploits the website, and displays pay-per-click links that redirect Internet users to other websites. Although a website containing PPC links does not per se constitute any illegitimate or illegal activity ( Lardi Ltd v. Belize Domain WHOIS Service Lt, WIPO Case No. D2010-1437 ), the Panel finds that there is no bona fide use of the disputed domain name by the Respondent. The reason for this is that by suggesting that the Complainant exploits the website linked to the disputed domain name, the Respondent misleadingly diverts Internet users to the website in order to direct them towards using the PPC links, some of which display trademarks of the Complainant’s competitors. Such use cannot be considered a bona fide use, nor a fair or noncommercial use. Consequently, the Panel finds that the Complainant has satisfied the requirements of paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith Paragraph 4(a)(iii) of the Policy requires that the Complainant demonstrates that the disputed domain name has been registered and is being used in bad faith. Pursuant to paragraph 4(b)(iv) of the Policy, there is evidence of registration and use of a domain name in bad faith where the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s website or location or of a product or service offered on the Respondent’s website or location. The Complainant undisputedly claimed that the Trademark has been used in the course of a business that offers services to millions of people. The trademark registrations show that they were registered decades before the disputed domain name and the Trademark is distinctive as such. The fact that the Respondent has included the Trademark in its entirety and has added a dictionary term that even may enhance the likelihood of confusion between the Trademark and the disputed domain name leads the Panel to believe that the Respondent was or must have been aware of the Trademark when registering the disputed domain name. The Panel is therefore satisfied that the disputed domain name was registered in bad faith. The evidence submitted by the Complainant demonstrates that the Respondent also uses the disputed domain name in bad faith. As mentioned above under Section B, the Panel finds that the Respondent misleadingly diverts Internet users to the website in order to direct them towards using the PPC links. Thereby, the Respondent intentionally attempts to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Trademark as to the source of the Respondent’s website. The Panel therefore finds that the disputed domain name has been registered and is being used 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 <support-geico.com> be transferred to the Complainant. Alfred Meijboom Sole Panelist Date: February 19, 2021
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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