A. COMPLAINANT
The Complainant points out that the disputed domain name <amunj.com> is confusingly similar to its trademark AMUNDI as it contains an obvious misspelling of the Complainant’s trademark AMUNDI (i.e. the substitution of the “i” by the “j”).
The Complainant contends that this is a clear case of “typosquatting” and that, as previous panels have found, a slight variation in the spelling does not prevent a disputed domain name from being confusingly similar to the Complainant’s trademark.
With reference to rights or legitimate interests in respect of the disputed domain name, the Complainant states that Respondent has no rights or legitimate interests since it is not commonly known by the disputed domain name.
Moreover, the Complainant underlines that the Respondent is in no way related to the Complainant, is not affiliated or in any way authorized by the Complainant in any way to use the trademark AMUNDI and does not carry out any activity for, or have any business with, the Respondent.
The Complainant also claims that the fact that the disputed domain name is a typosquatted version of the trademark AMUNDI only serves to further prove that the Respondent lacks rights and legitimate interests in the disputed domain name.
Lastly, the Complainant contends that the disputed domain name also points to an “ethical phishing” page, and is used to redirect the Complainant’s clients to the Respondent’s web site with the intent to obtain personal information from such clients, through the use of a registration form.
The Complainant concludes with reference to the issue of the rights or legitimate interest that, the Respondent has in no way any rights or legitimate interests in the disputed domain name.
With reference to the circumstances evidencing bad faith, the Complainant indicates that, considering the renown of its trademark AMUNDI and the distinctiveness of its trademark and reputation, the Respondent knew or should have known the Complainant at the time of registering the disputed domain name.
Moreover, the Complainant emphasizes that the Respondent must also have been well aware of the Complainant at the moment of registering the disputed domain name, since it deliberately chose to include a typo squatted version of the Complainant’s trademark.
The Complainant also asserts that, as the Respondent’s web site redirects to an “ethical phishing” page, by registering the disputed domain name, which is confusingly similar to the Complainant’s trademark AMUNDI, the Respondent’s aim was to attract Internet users to its web site or other online location, for commercial gain, thus creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation or endorsement of its web site, location or product or service on its web site or location.
The Complainant thus concludes that the Respondent registered and is using the disputed domain name in bad faith.
B. RESPONDENT.
NO ADMINISTRATIVELY COMPLIANT RESPONSE HAS BEEN FILED.
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