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Passive holding of a domain name can be bad faith


An arbitration panel has ruled that the passive holding of a domain name by a company (i.e. where the name has no web site) in the knowledge that its competitor has legitimate interests in the name, is strong evidence of bad faith. It follows similar decisions by another panel.

Two rival Minneapolis publishers took a dispute over the domain name tctaste.com before a panel of the National Arbitration Forum, a body authorised to resolve domain name disputes under the rules of ICANN, the internet's technical co-ordination body.

Minnesota Monthly Publications (MMP) took action against Key Enterprises. MMP owned a registered trade mark for the phrase TC TASTE, which it used for a supplement to its food and drink magazine. Rival publisher Key Enterprises registered the domain name tctaste.com in 1998, more than one year after MMP’s first use of the mark.

No use was made of the domain name; attempting to visit the site gave a page-not-found error. Lawyers for MMP wrote to the rival company and demanded transfer of the name, but received no response.

The arbitration panellist, James P. Buchele, found that Key Enterprises had no rights or legitimate interests in the domain name, taking its non-use as proof of that fact.

On the question of whether non-use could amount to bad faith use of the domain name, Buchele said: “The passive holding of the domain name by a competitor of [MMP] is a strong indication of bad faith.”

Accordingly, the domain name was transferred to MMP.

Buchele based his finding on two similar decisions made before panels of the World Intellectual Property Organisation (WIPO), also an authorised domain dispute arbitration forum under ICANN’s rules.

Full text of the decision.

The two similar WIPO cases

DCI S.A. of Switzerland took action against Link Commercial Group, a company based in the Bahamas, over the domain name 5asec.com, used for a dry cleaning business. The decision.

Clerical Medical Investment Group Limited took action against another Bahamas-based company over the domain name Clericalmedical.com. The decision.

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