www.ijcrt.

org © 2018 IJCRT | Volume 6, Issue 2 May 2018 | ISSN: 2320-2882

PROTECTION OF DOMAIN NAME AS A

TRADEMARK

KUMARA. N. H.
Assistant Professor of Law, Vidyodaya Law College, Tumakuru, Karnataka - 572102
Abstract:

In modern era, Intellectual Property (IP) is recognized as a property all over the world and there isa huge scope
and protection for the person’s, who invented or produced any lawfully allowed intellectual outcome from
his/her effort, capital and time. The person’s are allowed to enjoy monopoly right over their invention or for any
work for certain years. Intellectual Property is allowed inventor or author or owner of the work exploit
commercially or allow others to exploit commercially. In the era of evolution of Internet, E-Commerce and
Information Technology there is a scope for domain name under trademarks. Holding and registering a domain
name for a company is as much important as holding and registering the name and logo of the company. So it is
very necessity to know about domain name, its protection and legal issues in this article.

Keywords:Intellectual Property, Domain Name, Trademark, Internet, E-Commerce.

1. Introduction:

The term Intellectual Property has undergone a drastic change with the emergence of new ideas and new
concepts being developed with the passage of time. Evolution of the Internet has increased the scope of
communication and information owing to the development of a number of websites. There are various websites
dealing with different topics, which provide information. Some website provides information with relating to
services, education, shopping, mailing, entertainment, etc through online with the help of domain name and
internet. With the help of domain name there a great scope for E-Commerce. To reach these electronic platform
in the cyber world, World Wide Web, E-mails, Fax, etc. are recognized has an internet tools.

Domain name are a simple form of Internet address, designed to serve the function of enabling users to locate
sites on the Internet in an easy manner. Domain names may be registered in spaces known as generic top level
domains;1 (gTLDS) Such as Com, organ, net, or in the Country Code top-level domains’ 2 (ccTLDS) South
Africa.

As Commercial activities on the Internal have increased, domain names have an acquired significance as
business identifiers and, as such have come into Conflict with the System of business identifiers that Protected

1
A generic top-level domain (gTLD) is one of the categories of top-level domains (TLDs) maintained by the Internet Assigned
Numbers Authority (IANA) for use in the Domain Name System of the Internet.
2
A country code top-level domain (ccTLD) is an Internettop-level domain generally used or reserved for a country (a sovereign state or
a dependent territory).
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by intellectual property rights3 namely, geographical indications and the developing field of personality rights.
The tension between domain names and intellectual property rights has led to numerous problems that raise
challenging policy question. The domain names System is largely privately administered and gives rise to
registrations that result in a global presence, accessible from anywhere in the world.

There are now more than 15.7 million domain names registered worldwide, with over 13.5 million of these
names registered in the gTLDS (. com,. net and . org).Any person may obtain an Internet address (domain name)
for his own web pages. There are certain (gTKDs) Such as ‘.com’, ‘.org’ and ‘.net’ and country code top level
domains (gTLDs) .UK (United Kingdom) .de (Germany) .fr (France). JP (Japan). US. (USA) etc. within country
code domains.

The WIPO4has to be recommended on Internet domain name 28 June 2000. The member states to develop,
through a consultative process, recommendations on means of dealing with the ‘bad faith’ abusive, misleading
@ unfair use’ within the Internet domain name system (DNS) of identifiers that form the basis of certain naming
system used in the real or non –virtual world.5

The identifiers spaced were:

 Personal names.

 International nonproprietary names (INNS) for pharmaceutical substances.

 The names of intellectual intergovernmental organizations.

 Geography indications, Geographical forms, or indications of source and Trade names.

The request was subsequently endorsed by the WIPO general Assembly, the constituent organ of the member
states of WIPO. The request established three process criteria for WIPO’S work.

 It was specified that this activity should take full advantage of WIPO’S prior work.

 The activity should build on existing and ongoing discussions.

 The request indicated that the activity should allow… for a process of consultation with WIPO members
and all interested stakeholders

This article addresses the impact of digital economy on the intellectual property system, namely trade mark and
related rights; each of intellectual property disciplines is confronted with new issues generated by the emergence

3
Intellectual property (IP) is a term referring to a number of distinct types of creations of the mind for which property rights are
recognised--and the corresponding fields of law. Under intellectual property law, owners are granted certain exclusive rights to a
variety of intangible assets, such as musical, literary, and artistic works; discoveries and inventions; and words, phrases, symbols, and
designs. Common types of intellectual property include copyrights, trademarks, patents, industrial design rights and trade secrets in
some jurisdictions.
4
The World Intellectual Property Organization (WIPO) is one of the 16 specialized agencies of the United Nations. WIPO was created
in 1967 "to encourage creative activity, to promote the protection of intellectual property throughout the world."
5
Ibid
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of the internet and electronic commerce. This topic also addresses domain names and their relation to
trademarks, analyzing the intensive work that WIPO has began in-this area.6

The trademark symbolized as the ™ and ®, is the distinctive sign or indication which is used for signifying
some kind of goods or/and services and is distinctively used across the business organization or by an individual
for identifying and uniquely classifying the source or their products and/or services among consumers and
making a distinction of its products or services from the other entities. One of the part of the intellectual property
law, trademark signifies to the name, word, phrase, logo, image, design, symbol or combination of any or all of
these elements.

The trademark grants rights to the owner which in turns may take or can commence legal proceedings in case of
infringement of trademark. However registration is not compulsory in trademark. The owner of common law
trademark can also file the suit but in case of the unregistered mark, the protection granted will only be confined
only to that geographical area within which it has been used or in that area into which it is expected to be
expand.

Informally the term 'trademark' is used for distinguishing those characteristics or attributes which helps in
identifying any individual. When the word 'trademark' is used in context of services rather than products, it may
call Service Mark.7

2. Meaning of Domain Name:

A domain name is primarily used to identify and locate computers on the internet. It can be likened to an address
on the global computer network. Just like every person has a name and telephone number, every computer
connected to the internet has an Internet Protocol (IP address) of its own.8

The Domain Name System (DNS) serves the central function of facilitating users’ ability to navigate the
Internet. It does so with the aid of two components: the domain name and its corresponding Internet Protocol
(IP) number. A domain name is the human-friendly address of a computer that is usually in a form that is easy to
remember or to identify, such as www.wipo.int. An IP number is the unique underlying numeric address, such as
192.91.247.53. Distributed databases contain the list of domain names and their corresponding address and
perform the function of mapping the domain names to their IP numeric addresses for the purpose of directing
requests to connect computers on the Internet. The DNS is structured in a hierarchical manner which allows for
the decentralized administration of name-to-address mapping.9

In the case of Reno v.American Civil Liberties Union, 10 Judge Mokenna has explained the Internet address
system, as follows; each host computer providing Internet services (site) has a unique Internet address. Users

6
Ibid
7
www.legalindia.in/intellectual-property-rights-ipr
8
Pankaj Jan and Pandey Sangeet Rai, “Copyright and Trademark Laws relating to Computer”, p-89
9
http://legalserviceindia.com/articles/cddisp.htm
10
521 U.S.844, 117 S. Ct. 2329 (1997)
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seeking to exchange digital information with a particular internet host require the host’s address in order to
establish a connection. Hosts actually possess two fungible addresses a numeric IP address and alphanumeric
Domain name, with greater mnemonic potential.11

In the case of People Interactive (India) Pvt. Ltd. v. Vivek Pahwa & Ors,12 the Bombay High court gave a proper
definition of the term “domain name” that a “domain name” is the territorial address of a business on the internet
where, it directs a user to a particular part of the web where the particular domain name of the registrant stores
and display all the necessary information, offers and service available on the internet.

As a layman’s term, domain names are user-friendly names that are easily identifiable, remembered and help to
distinguish one website/web address from another’s website/web address. Since they are easily remembered,
they are being used as business identifiers and are being used to attract potential customers to their websites.

A domain name can be categorically divided into two levels:

I. Top-level domain (TLD) – TLD exists at the extreme right of the Universal Resource Locater (URL). In
the case of ‘www.hotmail.com’, ‘com’ is recognized as TLD. TLDs usually come in two types, Generic
TLD (gTLD) and Country Code TLD (ccTLD). Generic TLDs describes the type of organization, which
has the domain name. They are ‘.com’ – commercial organizations, ‘.org’ – non-profit organization, ‘.int’
– international orgainsations, ‘.edu’ – educational institutions, ‘.gov’ – government bodies., ect. Along
with TLDs, there are more than 250 Country code TLDs. They are ‘.in’ – India, ‘.br’- Brazil, ‘.au’ –
Australia, ‘.us’ – USA, etc.
II. Second level domain (SLD) – SLDs exist before TLDs in URL. They are allotted to the parties for
making a brand specific or to differentiate a body from other similar entities or competitors. The
‘hotmail’ becomes the SLD in the URL http://www.hotmail.com. The ‘vidyodayalawcollege’ becomes
the SLD in the URL http://www.vidyodayalawcollege.in
3. Registration of Domain Names:

The Internet Network Information Centre (‘InterNIC’) maintains and administers the central database of all
Internet domain names. In 1993, the InterNIC was established under the sponsorship of the National Science
Foundation as a joint project of AT&T, General Atomics and Network Solutions Inc. (NSI). AT&T was to
manage the InterNIC Directory and Database Services Project; NSI was to manage the Registration services
Project and General Atomics was to manage the Information services project. Thus InterNIC granted Network
Solutions Inc. (NSI) the exclusive authority to register domain names in the .com, net, and org TLDs on behalf
of the U.S. Department of Commerce.13

11
See Supra note 10
12
2016 SCC Online Bom 7351
13
See Supra note 9, p-93
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In November 1998, Internet Corporation for Assigned Names and Numbers (ICANN’s) was formed to assume
responsibility for the IP address space allocation, protocol parameter assignment, domain name system
management, and root server system management functions which were previously performed under U.S.
Government contract by IANA and other entities.14

India’s top-level domain names on the Internet are .IN and .CO.IN. just like .COM, .IN and .CO.IN can be used
for e-mail, Web sites, and other applications. .IN and .CO.IN are unique symbols and are able to inform the
public at large that the website or domain name is INDIA specific.

The top domains so registered in India are ‘.IN’ and ‘.CO.IN’ and these domains were made available to the
general public only after January 01, 2005. In consonance to the UDRP, India has enacted the Indian Domain
Name Dispute Resolution Policy & Domain Name Disputes (INDRP). The activities in the pertaining situation
are monitored by the National Internet Exchange of India (NIXI). INDRP has been successful in eliminating the
issue of the cybersquatting.

Domain name registration of .IN and .CO.IN has been made hassle-free and the procedure for domain name
registration in India is quite simple and everyone has access to it. .IN domain has thus become a relatively simple
process. Registration is available for organizations and individuals in India and outside India. The domain
registration is done by registrars appointed by .IN registry and would happen through a transparent non-biased
process. To register a domain name in India, the registrant has to place a request online and the .IN domain name
is usually registered in his name within 24 hours as per the guidelines established by the Government of India.

4. Domain Name and the Trademark:

A trademark is used to distinguish goods or services of one trader from those of others. Trademark is visual
symbol in the form of a word, a device, or a label applied to articles of commerce with a view to indicate the
purchaser as to the manufacturer of quality of goods. It is a general practice where companies desire to obtain
such domain name which can be easily identified with their established trademarks. This helps the public to
identify the company as there is no physical contact between the two of them.It helps the purchaser satisfactory
assurance of the make and quality of the article he is buying. It also guarantees its unchanged quality. It is an
ancient concept of identifying the source of manufacture. Strictly speaking, this concept of trademark is the
product of a competitive economy where more than one manufacturer is producing similar goods and a particular
product is required to be distinguished in respect of quality of the other similar products.

Domain names and trademarks are connected with each other. According to Section 2 (1)(zb) of the Trademarks
Act, 1999, Trademark: “means a mark capable of being represented graphically and which is capable of
distinguishing the goods or services of one person from those of others and may include shape of goods, their
packaging and combination of colors; and

14
Ibid
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 a registered trade mark or a mark used in relation to goods or services for the purpose of indicating or so
as to indicate a connection in the course of trade between the goods or services, as the case may be, and
some person having the right as proposed to use the mark; and

 a mark used or proposed to be used in relation to goods or services for the purpose of indicting or so to
indicate a connection in the course of trade between the goods or services, as the case may be, and some
person having the right, either as proprietor or by way of permitted user, to use the mark whether with or
without any indication of the identity of that person, and includes a certification trade mark or collective
mark.”15

In Cadbury India Limited And Ors. v. Neeraj Food Products,16 the court laid down the purpose of “trademark”
that Trademark is a mark used to protect traders and the consumers against malafide use/adoption of another’s
well-known trademark to deceive the general public to avail unfruitful benefits in the market.

Few Examples of Domain name of Trademark registered Company/Institutions.

SL. NO. TRADEMARKS OF THE COMPANY DOMAIN NAME OF THE COMPANY

01. Eastern Law House https://www.elh.co.in
02. Parle https://www.parleproducts.com
03. MARUTI SUZUKI https://www.mautisuzuki.com
04. GoDaddy https://www.godaddy.com
05. Mercedes-Benz Group https://www.group.mercedes-benz.com
06. Nike https://www.nike.com
07. Google https://www.google.com
08. ITC LIMITED https://www.itcportal.com
09. KARNATAKA STATE LAW UNIVERSITY https://www.kslu.karnataka.gov.in
10. NATIONAL LAW SCHOOL OF INDIA UNIVERSITY https://www.nls.ac.in
11. Godrej https://www.godrej.com
12. The Hindu https://www.thehindu.com
13. Sony IN https://www.sony.co.in
14. Raymond https://www.raymond.in
15. Microsoft https://www.microsoft.com

In Satyam Infoway ltd. v. Sifynet Solutions Pvt. Ltd., 17 the respondent had registered domain names as
www.sifynet.com and www.siffynet .net which were similar to the plaintiff’s domain name of www.sifynet.com
Satyam18 (plantiff) had goodwill in the market and had registered the name sifynet and various other names with
internet Corporation for Assigned Names and Numbers (ICANN) and WIPO. The word Sify was first coined by
the plaintiff using elements from its corporate name Satyam lnfaway, The Supreme Court held that “domain

15
A collective trade mark or collective mark is a trademark owned by an organisation (such as an association), who’s members use
them to identify themselves with a level of quality or accuracy, geographical origin, or other characteristics set by the organization.
Collective trademarks are exceptions to the underlying principle of trademarks in that most trademarks serve as "badges of origin" -
they indicate the individual source of the goods or services. A collective trade mark, however, can be used by a variety of traders, rather
than just one individual concern, provided that the trader belongs to the association. Collective trademarks differ from
certificationmarks. The main difference is that collective trademarks may be used by particular members of the organization.
16
142 (2007) Dlt 724, MIPR 2007 (2) 269, 2007 (35) PTC 95 Del
17
(2004) 6 SCC 145
18
Satyam Infoway (P) Ltd., part of the Satyam Group of Companies, is at the forefront of providing electronic commerce solutions to
Indian businesses. We provide end-to-end solutions that span the entire gamut of the electronic commerce value-chain - from network
solutions to sophisticated Internet-commerce solutions.
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names are business identifiers, serving to identify and distinguish the business itself of its goods and services and
to specify its corresponding on-line location.” The Court also observed that domain name has all the
characteristics of a trademark and an action of passing off con be can where domain names are involved. The
decision was in favor of the plaintiff.

The Indian Courts are of the opinion that internet domain name can be a valuable asset for the company and is
therefore entitled to equal protection as a trademark where molafide intent to cause deception is established any
further enquiry on likelihood of confusion would be unnecessary The attainment of secondary meaning by the
generic domain name is a precondition for granting protection to if as no one can claim monopoly over a generic
word otherwise.

The Bombay High Court in Rediff Communication Ltd v. Cybersbooth & Anr,observed that the value and
importance of a domain name is like a corporate asset of a company in this case the defendant had registered a
domain name radiff.com which was similar to rediff.com. The Court gave a decision in favor of the plaintiff.19

In another case, the defendant registered a number of domain names bearing the name That it was held by the
Court that domain name are not only addresses but trademarks of companies and that they are equally important.

5. Domain Name Disputes:

When the awareness about the domain names of the trademark registered companies aremore popular in the
public domain with the help of internet facilities in the information technology world, it will be a great
opportunities for the business people to increase their electronic commercial transitions. The corporate entities
commenced with new trading activities and marketing their products on the web and have started using domain
names to make others locate them easily on cyberspace. With this drastic change and more scope for domain
names, the disputes over the right to use of domain names have also considerably increased.

There are four types of domain name disputes, they are Cybersqautting, 20 Profit grabbing, Misspelling and
identical domain name and Concurrent claims.

One of the earlier cases pertaining to cybersquatting was Cardservice International Inc. v. McGee, 21 the
American Court held that the domain name serves the same function as a trademark and is not merely to be
construed as an address, as it identifies an Internet site to those who reach it, much like a person’s name
identifies a particular person.

19
AIR 2000 Bom27
20
The term Cybersquatting is coined by two words – Cyber and Squatting. Squatting literally refers to an act of a person who takes
unauthorized possession of unoccupied premises. Thus Cybersquatting is an act of occupying domain name of which he is not
authorized to.
Cybersquatting (also known as domain squatting), according to the United States federal law known as the Anticybersquatting
Consumer Protection Act, is registering, trafficking in, or using a domain name with bad faith intent to profit from the goodwill of a
trademark belonging to someone else. The Cybersquatter then offers to sell the domain to the person or company who owns a
trademark contained within the name at an inflated price.
21
950 F. Supp. 737 (E.D. Va. Jan. 16, 1997)
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In Marks & Spencer v. One-in-a Million,22the UK Court observed that when a person deliberately registers a
domain name on account of its similarity to the name, brand name or trademark of an unconnected commercial
organization, he must expect to find himself at the receiving end of an injunction to restrain the threat of passing-
off.

The first case in India with regard to cybersquatting was Yahoo inc v. Aakash Arara & Anr, 23 Where the
defendant launched a website providing services nearly identical to the plaintiff’s renowned website. Here, the
Court ruled in favor of trademark right of US based Yahoo inc. (the plaintiff) and against the defendant that had
registered itself as Yahooindia.com. The Court observed, “it was an afford to trade on the fame of Yahoo’s
trademark A domain name registrant does not obtain any legal right to use that particular domain name simply
because he has registered the domain name he could still be liable for trademark infringement”.

In a case taken up by the WIPO administrative panel, SBI Card and Payment Services Private Limited (a joint
venture between GE Capital Services the largest issuer of private label credit cards in the world and the State
Bank of India (SBI), the largest Indian bank) filed a case against an Australian entity on cybersquatting Domain
Active Pty Limited, which was incorporated in Australia, had registered a domain name. www.sbicards.com the
administrative panel held that domain name registered by the Australian entity was in bad faith and it could have
attracted attention from the public because of it affiliation to SBI Cards products and services the domain name
www.sbicards.com was transferred to the plaintiff (SBI card and Payment Services Private Limited).

In Acqua Minerals Ltd. V. Promod Borse, 24 case popularly known as ‘Bisleri case’, the Delhi high court
restrained an it company from using <bisleri.com>25 as a domain name for their website a suit filed by aqua
minerals ltd the makers of the bisleri brand of mineral water the plaintiffs had filed a suit and pleaded for an
injunction on use or transfer of the domain name by the defendants and also for an order from the court
transferring the domain name to the plaintiffs the plaintiffs had already registered<bislerimineralwater.com> but
argued that bisleri is a well-established brand name and that the defendants were resorting to cybersquatting “
and that their registration of <bisleri.com> was a “ bad faith registration “passing the injunction in favor of the
plaintiffs the court observed bisleri is a very rare name defendants do not intend to do any business they have
asked for money for the transfer of domain name they have got the domain name registered only to obtains
monetary settlement with the increase of e commerce, the disputes of this nature are bound to increase once
again the court seems to have taken the approach of protecting bisleri as famous marks are in the US .

22
[1997] EWHC PATENTS 357
23
1999 (19) PTC 210 (Del)
24
2001 PTC 619 (Del)
25
Bisleri is a brand of bottled water in India. Bisleri has 60% market share in packaged drinking water in India. It is available in 8 pack
sizes: 250ml cups, 250ml bottles, 500ml, 1 litre, 1.5 litre, 2 litre, 5 litre, and 20 litre. Its operations run throughout the subcontinent of
India and is one of the leading bottled water supplying companies in India. As of 2007, Bisleri has 8 plants & 11 franchisees all over
India.

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6. Conclusion:

In conclusion, it may be said that protection of domain name as a trademark gets its focus from International to
National level. As domain names are popularized, there was a number of disputed cases emerged and resolution
by the authority/courts. Dispute resolution is still in its infancy in India however, one does foresee many more
disputes as e-commerce becomes bigger and bigger in the country.

The concept of a domain name is an extended version of Trademark and has all the similar things of being seen
as a Trademark. The case of Arun Jaitley, v. Network Solutions Private Ltd.,26 laid out a few important points
regarding domain names as Trademark by the following points –

1. That the domain name is not just an address but is used for a known person or the prospective customer
to visit the webpage and immediately connect with that particular individual’s services.

2. Domain names are the personality goodwill of the company in the virtual world which is similar to
goodwill in the physical world.

3. It is important to have protection for domain names to protect them from cybersquatting or trafficking
like Trademark law.

Finally we may say that, domain names are having their own reputation in a virtual world, there is a more chance
of it being misrepresented by somebody else to harm the reputation and goodwill. Therefore, it should be seen as
a Trademark and should be protected as a Trademark.

REFERENCES

BOOKS:

1) Acharya N.K, Text Book on Intellectual Property Rights, 3rd Edition, Asia Law House Publications,
Hyderabad.
2) Alikhan Shahid and Mashalkar Raghanath, Intellectual Property and Competitive Stretergies in the 21st
Century, 2006 edition, Aditya Books Private Limited, New Delhi
3) Bainbridge David, Intellectual Property, 5th Edition, Aditya Book Private Limited, New Delhi.
4) Bently Lionel and Sherman Brad, Intellectual Property Law, 3rd Edition, Oxford University Press
Incorporation, New Delhi.
5) Cornish and Llewelyn, Intellectual Property, 5th Edition, Sweet and Maxwell Limited, London
6) Jain Pankaj and Pandey Sangeet Rai, Copyright and Trademark Laws relating to Computers, First
Edition, 2005, Eastern Book Company, Lucknow.
7) Ryder D Rodney, Intellectual Property and the Internet, 2002 Edition, Lexis Nexis, Butterworth’s New
Delhi.

26
2011 (47) PTC 1 (Del)
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JOURNALS:

 The Icfai University Journal of Intellectual Property Right, Volume-VIII, No.2, May 2009

 Corporate Law Cases, Volume 11, Part 2, February 2010

WEBSITES:

 https://www.ntchosting.com/domines/in.html

 https://www.indiaip.com

 https;//www.iprlawindia.org

 https://www.icfapress.org/203/IjIPR203.htm

 https://www.legalindia.in/intellectual-property-rights-ipr

 http://www.legalserviceindia.com/articles/cddisp.htm

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