Westmore · UDRP DecisionGeicoh.com
The Panel ordered transfer of <geicoh.com>. It found that the domain incorporated the GEICO mark in full with only the addition of the nondistinctive letter “h”; that Respondent had no rights or legitimate interests because the domain was inactive and there was no evidence that Respondent was commonly known by it or making a bona fide, noncommercial, or fair use; and that passive holding constituted bad-faith registration and use in light of the mark’s distinctiveness, Respondent’s default, and the implausibility of any good-faith use.
The timeline behind geicoh.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 geicoh.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how a one-letter typographical variation of a distinctive mark can satisfy confusing similarity and how an inactive domain can still meet the bad-faith requirement. The outcome rested on the combined force of the mark’s distinctiveness and longstanding use, the absence of any legitimate use, Respondent’s default, and the Panel’s finding that no good-faith use was conceivable.
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. Stephen Hadhazi Case No. D2021-3508 1. The Parties Complainant is Government Employees Insurance Company, United States of America (“United States”), represented by Burns & Levinson LLP, United States. Respondent is Stephen Hadhazi, United States. 2. The Domain Name and Registrar The disputed domain name <geicoh.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 October 22, 2021. On October 22, 2021, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 25, 2021, 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 Complainant on October 25, 2021, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on October 25, 2021. The Center verified that the Complaint, together with the amendment to the 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 Respondent of the Complaint, and the proceedings commenced on October 26, 2021. In accordance with the Rules, paragraph 5, the due date for Response was November 15, 2021. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on November 29, 2021. The Center appointed Jeffrey M. Samuels as the sole panelist in this matter on December 2, 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 Complainant Government Employees Insurance Company is an internationally known insurance provider which has provided insurance services throughout the United States under the mark GEICO since at least 1948. Complainant has over 17 million policies and insures more than 28 million vehicles. Complainant’s GEICO trademark is the subject of United States Trademark Registration Nos. 0763274 registered on Janurary 14, 1964, and 2601179 registered on July 30, 2002, as well as European Union Trademark Registration No. 1178718 registered on September 4, 2013. Complainant also owns the domain name, <geico.com>, which it uses to promote and sell its insurance services under its GEICO trademark. At the time of this decision the disputed domain name, <geicoh.com>, resolves to an inactive website. 5. Parties’ Contentions A. Complainant Complainant refers to its trademark registrations for the GEICO mark to satisfy the threshold requirement that it owns trademark rights in the GEICO mark. It then argues that the disputed domain name is identical or confusingly similar to the GEICO mark insofar as it incorporates the GEICO mark, adding only the letter “h” and the generic top-level domain “.com.” Complainant further contends that Respondent has no rights or legitimate interests in the disputed domain name. According to Complainant, the passive holding of a domain name to resolve to an inactive website fails to show use in connection with a bona fide offering of goods or services, nor is there any evidence that Respondent is commonly known by the disputed domain name or that Respondent is making a legitimate noncommercial or fair use of the disputed domain name. With respect to the issue of “bad faith” registration and use, Complainant asserts that “the fact that the Disputed Domain Name is inactive does not prevent a finding of bad faith, particularly where, as here, the GEICO trademark is highly distinctive such that … any good faith use to which the domain name may be put is implausible.” Complainant also alleges that Respondent’s incorporation of Complainant’s “famous, widely-known” GEICO trademark into the disputed domain name, along with a typo, creates a presumption of bad faith. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusing Similarity The Panel finds that the disputed domain name is, for all intents and purposes, identical to the GEICO trademark. As noted above, the disputed domain name incorporates the mark in full, adding only a nondistinctive letter. The Panel further finds that Complainant, through its longstanding use of, and registrations covering, the GEICO mark, has rights in such mark. B. Rights or Legitimate Interests The Panel finds that Complainant has met is burden of proving that Respondent has no rights or legitimate interests in the disputed domain name. The evidence establishes that the disputed domain name resolves to a passive website. Under such circumstances, Respondent, clearly, is not using the disputed domain name in connection with the bona fide offering of goods and services and is not making a legitimate noncommercial or fair use of the disputed domain name. It is not making any use of the disputed domain name. There also is no evidence that Respondent is commonly known by the disputed domain name. C. Registered and Used in Bad Faith The Panel concludes that the disputed domain name was registered and is being used in bad faith. As noted in the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“ WIPO Overview 3.0 ”), section 3.3, UDRP panelists have found that the non-use of a domain would not prevent a finding of bad faith under the doctrine of passive holding. In determining whether to apply the passive holding doctrine, panelists look at: (i) the degree of distinctiveness or reputation of the complainant’s mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent’s concealing its identity or use of false contact details (noted to be in breach of its registration agreement), and (iv) the implausibility of any good faith use to which the domain name may be put. Here, the evidence supports the determination that: (1) the GEICO mark is distinctive; (2) Respondent failed to submit a response to the Complaint; and (3) given the longstanding and widespread use of the GEICO mark, “there is no conceivable contemplated use of the Disputed Domain Name that would not be an infringing use by the Respondent.” See Government Employees Insurance Company v. Jun Yin , WIPO Case No. D2020-0037 (finding the GEICO mark to be “known throughout the world” as a result of extensive use and advertising creating “an exclusive connection between the GEICO mark and the Complainant” such that it should be presumed that respondent knew or should have known about Complainant’s GEICO mark or has exercised the sort of willful blindness that would still support a finding of bad faith). See also Government Employees Insurance Company v. Joel Rosenzweig, RegC , WIPO Case No. D2021-1221 . 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 <geicoh.com> be transferred to Complainant. Jeffrey M. Samuels Sole Panelist Date: December 13, 2021
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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