For the purposes of Paragraph 4(a)(iii), the following circumstances, in particular but without limitation, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith:
(i) circumstances indicating that you have registered or you have 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 that complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the domain name; or
(ii) you have registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or
(iii) you have registered the domain name primarily for the purpose of disrupting the business of a competitor; or
(iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your web site or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of your web site or location or of a product or service on your web site or location.
Regarding registration in bad faith, the disputed domain name was registered more than 30 years after the registration of the Complainant’s above-mentioned ZANTAC trademark. Although the trademarks submitted by the Complainant are registered in the United States whereas the Respondent is located in the United Kingdom, several factors tend to show that the Respondent had knowledge of the ZANTAC trademark at the time of registration of the disputed domain name, namely:
- The domain name is identical to the Complainant’s ZANTAC trademark,
- A previous UDRP panel has recognized that the Complainant is “a leading global research-driven pharmaceutical enterprise and has about 140 affiliated companies worldwide” (WIPO Case No. D2016-0055, Boehringer Ingelheim Pharmaceuticals Inc. v. JimmyX),
- The ZANTAC sign has no meaning in English – which is the language of both the Complainant and the Respondent – and is therefore highly distinctive.
In respect to use in bad faith, the Panel notes that the domain name is not being used. Nonetheless, under certain circumstances, passive holding may constitute use in bad faith. Indeed, as discussed in Telstra Corporation Limited v. Nuclear Marshmallows (WIPO Case No. d2000-003, “the relevant issue is not whether the Respondent is undertaking a positive action in bad faith in relation to the domain name, but instead whether, in all the circumstances of the case, it can be said that the Respondent is acting in bad faith. The distinction between undertaking a positive action in bad faith and acting in bad faith may seem a rather fine distinction, but it is an important one. The significance of the distinction is that the concept of a domain name ‘being used in bad faith’ is not limited to positive action; inaction is within the concept. That is to say, it is possible, in certain circumstances, for inactivity by the Respondent to amount to the domain name being used in bad faith”).
Presently, the Respondent has provided a response to the complaint. However, he does not explain for which reasons or intend he registered the domain name.
Thus, based on the evidence presented to the Panel including the lack of rights or legitimate interests of the Respondent in the disputed domain name, it appears that the disputed domain is also being used in bad faith.
Hence, the Complainant has, to the satisfaction of the Panel, shown the disputed domain name has been registered and is being used in bad faith (within the meaning of paragraph 4(a)(iii)of the Policy).
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