Westmore · UDRP DecisionGeicoe.com, Uw2geico.com
The Panel ordered transfer of <geicoe.com> and <uw2geico.com>. It found both domain names confusingly similar to the Complainant’s registered GEICO mark, that the Respondent lacked rights or legitimate interests, and that the domain names were registered and used in bad faith. The bad-faith finding rested cumulatively on the well-known character of GEICO, offers to sell the domain names for USD 500 to USD 898, redirection associated with apparent malware or malicious software, and evidence of the Respondent’s pattern of abusive registrations.
The timeline behind geicoe.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
Westmore reconstructs the full history behind geicoe.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates a cumulative bad-faith analysis where trademark targeting was reinforced by multiple forms of conduct: sale offers, apparent malicious redirection, and a documented pattern of prior abusive registrations. It also shows that adding short, arbitrary character strings to an entire well-known mark will not ordinarily prevent a confusing-similarity finding.
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 v. Registration Private, Domains By Proxy, LLC / Carolina Rodrigues, Fundacion Comercio Electronico Case No. D2020-3280 1. The Parties The Complainant is Government Employees Insurance Company, United States of America (“United States”), represented by Burns & Levinson LLP, United States. The Respondent is Registration Private, Domains By Proxy, LLC, United States / Carolina Rodrigues, Fundacion Comercio Electronico, Panama. 2. The Domain Names and Registrar The disputed domain names <geicoe.com> and <uw2geico.com> are registered with GoDaddy.com, LLC GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 3, 2020 in relation to the domain name <geicoe.com>. On December 4, 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 names, which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to the Complainant on December 7, 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 consolidated Complaint in relation to the domain names <geicoe.com> and <uw2geico.com> as the underlying registrant was the same on December 9, 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 14, 2020. In accordance with the Rules, paragraph 5, the due date for Response was January 3, 2021. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 5, 2021. The Center appointed Emre Kerim Yardimci as the sole panelist in this matter on January 13, 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 providing a full range of insurance services, including automobile, motorcycle, homeowners, rental, condominium, flood, mobile home, personal umbrella, and overseas insurance with more than 40,000 employees. The Complainant has over 17 million insurance policies and insures more than 28 million vehicles. The Complainant has been using the trademark “GEICO” continuously since 1964 and holds many trade and service mark registrations including United States Trademark registrations No. 763,274 for GEICO registered on January 14, 1964, and No. 2,601,179 for GEICO registered on July 30, 2002. It operates a website promoting and selling its insurance services at “www.geico.com”. The disputed domain names were respectively registered on November 5, 2020 and on November 2, 2020. The disputed domain names resolved, via redirection, to unrelated third-party websites, including to a website that serves pop up pages that require Internet users to download suspected malware disguised as security software in order to reach the Complainant’s websites. 5. Parties’ Contentions A. Complainant The Complainant requests the transfer of the disputed domain names. The Complainant asserts that the disputed domain names are identical or in any case confusingly similar to the Complainant’s trademark GEICO and the addition of the random letters and numbers “e” and “uw2”. The Complainant considers that the Respondent has no rights or legitimate interests in respect of the disputed domain names, mainly because the Complainant has neither licensed nor otherwise authorized the Respondent to use its marks or to apply for or use any domain names incorporating the trademark GEICO. Finally, in addressing the question of registration and use of the disputed domain names in bad faith, the Complainant observes that the Respondent could not ignore the Complainant’s well-known trademark. The Complainant claim that the Respondent had the Complainant’s trademark in mind when registering the disputed domain names and that the Respondent is holding the disputed domain names for the purpose of transferring the disputed domain names in excess of its documented out-of-pocket costs. Furthermore, the Complainant claims that the use of the Complainant’s trademark GEICO for a domain name to point to a malicious website or page constitute a bad faith use. Furthermore, the Respondent has a history of abusive registrations, wherein the Complainant and other third-party registered trademarks have been incorporated in the disputed domain names. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Pursuant to paragraph 4(a) of the Policy, the Complainant is required to prove the presence of each of the following three elements to obtain the transfer of the disputed domain names: (i) the disputed domain names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain names; and (iii) the disputed domain names have been registered and is being used in bad faith. A. Identical or Confusingly Similar Paragraph 4(a)(i) of the Policy requires the Complainant to show that the disputed domain names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights. A registered trademark provides a clear indication that the rights in the mark shown on the trademark certificate belong to its respective owner. As indicated above, the Complainant holds several trademark registrations for the GEICO trademark. The disputed domain names <geicoe.com> and <uw2geico.com> integrate the Complainant’s GEICO trademark in its entirety, as its dominant element. The disputed domain names differ from the registered GEICO trademark by the additional letter “e” with respect to <geicoe.com>, and letters and number “uw2” with respect to <uw2geico.com>. The additional letters and numbers do not prevent a finding of confusing similarity between the disputed domain names and the Complainant’s trademark. As regards the generic Top-Lev-Domain (“gTLD”), it is typically disregarded under the confusing similarity test. Consequently, the Panel finds that the Complainant has shown that the disputed domain names are confusingly similar to a trademark in which the Complainant has rights. B. Rights or Legitimate Interests The Panel finds that the Complainant has made a prima facie showing of a lack of the Respondent’s rights or legitimate interests in the mark. The burden of production has therefore shifted to the Respondent to come forward with appropriate allegations demonstrating rights or legitimate interests under the second element of the Paragraph 4(a) of the Policy. Considering that the Respondent did not reply to the Complainant’s claims, the Respondent did no effort to demonstrate any rights or legitimate interests in the disputed domain names. Accordingly, the Panel determines the Complainant has sufficiently demonstrated that the Respondent lacks any rights or legitimate interests in the disputed domain names. C. Registered and Used in Bad Faith The Panel accepts the Complainant’s contention that the trademark GEICO is without any doubt a well-known trademark. The incorporation of a well-known trademark into a domain name by a registrant having no plausible explanation for doing so may be, in and of itself, an indication of bad faith ( Veuve Clicquot Ponsardin, Maison Fondée en 1772 v. The Polygenix Group Co ., WIPO Case No. D2000-0163 ; General Electric Company v. CPIC NET and Hussain Syed , WIPO Case No. D2001-0087 ; Microsoft Corporation v. Montrose Corporation , WIPO Case No. D2000-1568 ). The Respondent has advertised the disputed domain names for sale with a proposed sale value between USD 500 and USD 898 precisely which is unequivocal indication of bad faith registration and use in accordance with paragraph 4(b)(i) of the Policy stating that bad faith can be shown where circumstances indicating that the respondent has registered or has acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of the complainant, for valuable consideration in excess of its documented out-of-pocket costs directly related to the domain name. See WIPO Overview 3.0 , section 3.1 ). Furthermore, it appears from the evidence submitted by the Complainant that the disputed domain names resolve to a website which appears to be spreading malware or malicious software. The Complainant has further submitted evidence that Respondent has engaged in a pattern of registering domain names that have been transferred or cancelled with a finding of bad faith by prior UDRP panels. These include, among others, domain names that incorporate Complainant’s GEICO mark. See, e.g ., Government Employees Insurance Company v. Domains By Proxy, LLC / Carolina Rodrigues, Fundacion Comercio Electronico , WIPO Case No. D2020-1723 . In the circumstances, the Panel is persuaded that the Respondent’s registration and use of the disputed domain names constitute bad faith registration and use of the disputed domain names. The only reason for the registration of the disputed domain names must have been with bad faith intent to use it to exploit, for commercial gain, the Complainant’s reputation. As demonstrated above, the Respondent has used the disputed domain names for precisely that purpose. Therefore, in the view of cumulative circumstances, the Panel finds that the requirement of registration and use in bad faith is satisfied, according to the Policy, paragraph 4(a)(iii). 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 names <geicoe.com> and <uw2geico.com> be transferred to the Complainant. Emre Kerim Yardimci Sole Panelist Date: February 2, 2021
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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