As a result, all reasonable inferences asserted in the Complaint will be deemed true. Complainant, VWOA, is a New Jersey Corporation that has a principal place of business at 3800 Hamlin Road, Auburn Hills, MI 48326. VWAG maintains its principal place of business in Wolfsburg, Federal Republic of Germany. Complainant and VWAG, manufacture and sell motor vehicles, parts, and accessories for motor vehicles. Through agreements, over four hundred concerns doing business at the retail level have been licensed to use VWAG's trademarks and service marks, including the VW mark and the VW logo, in connection with the sale, service and repair of Volkswagen Products.
Complainant requires all users of the VW mark to be a licensee of Complainant.
Complainant requires all licensees at the retail level to identify its business as authorized by VWAG to sell, service and repair Volkswagen Products by employing VWAG's trademarks and service marks on its stationary, in its advertising, on its premises and on promotional materials. Respondent is not a licensee of Complainant, and has not been authorized by Complainant to use the VW marks in connection with its business. There are a substantial number of UDRP cases which have found that incorporating a registered trademark entirely into a domain name, regardless of what additional words or letters are added to the domain name, still results in a domain name that is confusingly similar to Complainant s mark. The result should be the same regardless of whether the incorporated mark consists of two, five or ten letters and regardless of whether the additional word is generic or descriptive. Under the UDRP, Respondent has an affirmative duty to come forward with evidence that demonstrates its rights or legitimate interest in the domain name at issue.