Apps of xxxweb camp
Apps of xxxweb camp
The Target Stores division of Target Corporation (“Target”), a licensee of Complainant, has since 1962 operated a chain of TARGET® retail discount department stores, now numbering more than 1,100 stores in 47 states.3. 1,386,318, both for use in connection with, among other things, retail department store sales services.7.Over the years, Target, TARGET® stores, and Target’s other commercial undertakings have developed a national reputation for quality, and value. 845,193, registered February 27, 1968, and for the mark TARGET and the Bullseye design, U. Complainant asserts that as a result of, among other things, Target’s continuous use and extensive advertising promotion, including nationwide television campaigns, the TARGET mark is known, among other places, throughout the United States as identifying Complainant’s exclusive licensee as a source of quality retail services.
9, 2001) (finding no rights or legitimate interests where Respondent generated commercial gain by intentionally and misleadingly diverting users away from Complainant’s site to a competing website); , D2000-1409 (WIPO Dec.
The Panel finds that Complainant will not be prejudiced by accepting this Additional Submission.
Therefore, Respondent’s Additional Submission is accepted into the record.2.
Target asserts that this is a well-deserved and hard-earned reputation and is reflected in a substantial and valuable body of goodwill symbolized by the well-known TARGET mark (or “mark”).4. is identical to Complainant’s TARGET mark and merely adds a top-level indicator ""It has been established that addition of a top-level indicator such as ".com" or ".org" does not defeat a claim of confusing similarity.
The TARGET mark is represented to be a commercial icon that has for many years been extensively used and advertised. , D2000-0429 (WIPO June 25, 2000) (finding that the top level of the domain name such as ".net" or ".com" does not affect the domain name for the purpose of determining whether it is identical or confusingly similar)..
Respondent did not initially use the domain name at all after registration in 1991.
Upon information and belief, when Respondent began using the target.org, D2000-0205 (WIPO May 11, 2000) (finding that it is not a bona fide offering of goods or services to use a domain name for commercial gain by attracting Internet users to sites offering sexually explicit and pornographic material, where such use is calculated to mislead consumers and tarnish the Complainant’s mark).
The disputed domain is composed solely of the common word “target,” which is a common word in the English dictionary meaning, among other things, “an object, such as a padded disk with a marked surface, that is shot at to test accuracy in rifle or archery practice.” and “store,” to eliminate references to Complainant, yielded 14.5 million results.
The word “target” relates to the sport of archery, which involves a bow and arrow and a “target.”The word “target” is also used in the English language to refer to a desired goal or objective.4.
These links include goal, goal setting, personal goal, career goal, hinting equipment, hunting gear and other sports-related and goal related links which are prominently displayed on Respondent’s website.
Respondent maintains that such use of a website to provide generic links can support the Respondent’s legitimate interest.5.
9, 2000) (finding that bad faith registration and use where it is “inconceivable that the respondent could make any active use of the disputed domain names without creating a false impression of association with the Complainant”). 26, 2000) (finding that “this association with a pornographic web site can itself constitute bad faith”).