Do Trademarks Always Trump Domain Names? Not Always

Online start-ups are faced with the daunting task ofcommon law marks, LITTLE DEALER LITTLE PRICES
selecting a domain name that will withstand legalRV and LITTLE DEALER.
challenges.The respondent argued that it should prevail because
There's a general belief among online start-ups that aits registration of its domain name occurred prior to the
trademark owner will always trump a domain namecomplainant's registration of its trademark.
registrant with the same or confusingly similar domainThe respondent won. The UDRP panelist noted that a
name. That's not always the result... as two recentcomplainant has to show that the respondent's domain
2010 UDRP decisions point out.name is identical or confusingly similar to complainant's
The UDRPmark. "This provision necessarily implies that
What is the UDRP, and why is it important?Complainant's rights must predate the registration of
The UDRP acronym stands for the Uniform DomainRegistrant's domain name", the panelist concluded.
Name Dispute Resolution Policy. The UDRP is a set ofThe take-away - the respondent won because it
procedures and rules that are supposed to helpregistered its domain name before the complainant
determine who should prevail in a dispute over domainregistered its trademark.
name ownership.The University of Texas Case
The UDRP is important because it provides a fasterThe University of Texas at Austin (UT) case involved
and cheaper way to resolve a domain name disputerequirement no. 3 above.
than a full-blown lawsuit in a court of law. Instead ofUT showed that it owned the domain name, as well as
litigation, it's an administrative proceeding where thethe following registered trademarks: TEXAS,
contestants present written arguments to aUNIVERSITY OF TEXAS, TEXAS LONGHORNS,
panelist-arbitrator who issues a binding decision.and LONGHORNS. UT also showed that its TEXAS
In-person hearings (including hearings bymark is registered for "Entertainment services, namely,
teleconference, videoconference, and webproviding college athletic and sporting events."
conference) are permitted only in exceptional cases,UT argued among other things that the use of
and are therefore rare.respondent's texassports.org domain was in bad faith
The UDRP has not been without its critics. Most of thebecause it was used as a "parking" website for
criticism centers on the fact that the UDRP wasinformation related to University of Texas sports and
established to benefit trademark owners in takingsporting events.
non-trademark owners to task in domain nameThe respondent won. The panel found that UT did not
disputes. And UDRP critics often point out the fact theprove "bad faith". The panel reasoned that because
UDRP decisions seem to come out overwhelmingly inthe term "Texas Sports" is geographically descriptive,
favor of trademark owners.the respondent was free to register its domain name
There are three requirements for a trademarkusing the term on a "first-come, first-served basis".
owner-complainant to prevail over a domainThe panel also found that UT did not have a
name-respondent in a UDRP proceeding:registration for the term "Texas Sports", and therefore
1 - the domain name registered by the respondent isthere was no likelihood of consumer confusion.
identical or confusingly similar to a trademark orConclusion
service mark in which the complainant has rights;Selecting a domain name that will withstand legal
2 - the respondent has no rights or legitimate interestschallenges is a strategic undertaking for any online
in respect of the domain name; andstart-up.
3 - the domain name has been registered and is beingThe important lesson is that although the UDRP may
used in bad faith by the respondent.help in deciding in favor of a respondent in a domain
The Arizona State Trailer Sales Casename dispute with a trademark owner, the
This case involved requirement no. 1 above.recommended approach is to avoid the dispute
The complainant, Arizona State Trailer Sales, arguedaltogether by undertaking a thorough search of
that the respondent's domain name was confusinglypre-existing trademarks before selecting a domain
similar to the complainant's registered mark, LITTLEname.
DEALER LITTLE PRICES and the complainant's