Shoes West, Inc. v. Dang Hong Son / Pham Van Tung
Claim Number: FA2112001977725
Complainant is Shoes West, Inc. (“Complainant”), represented by David A. Plumley and Kurt S. Prange of Lewis Roca Rothgerber Christie LLP, California, USA. Respondent is Dang Hong Son / Pham Van Tung (“Respondent”), Vietnam.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <taoswalk.net>, <taoswalk.xyz>, and <taoswalk.com>, registered with Inet CORPORATION.
The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.
The Honourable Neil Anthony Brown QC as Panelist.
Complainant submitted a Complaint to the Forum electronically on December 20, 2021; the Forum received payment on December 20, 2021.
On December 21, 2021, iNET CORPORATION; confirmed by e-mail to the Forum that the <taoswalk.net>, <taoswalk.xyz>, and <taoswalk.com> domain names are registered with iNET CORPORATION; and that Respondent is the current registrant of the names. iNET CORPORATION; has verified that Respondent is bound by the iNET CORPORATION; registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN’s Uniform Domain Name Dispute Resolution Policy (the “Policy”).
On December 28, 2021, the Forum served the Complaint and all Annexes, including a Vietnamese and English Written Notice of the Complaint, setting a deadline of January 18, 2022 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent’s registration as technical, administrative, and billing contacts, and to postmaster@taoswalk.net, postmaster@taoswalk.xyz, postmaster@taoswalk.com. Also on December 28, 2021, the Vietnamese and English Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent’s registration as technical, administrative and billing contacts.
Having received no official response from Respondent, the Forum transmitted to the parties a Notification of Respondent Default.
On January 24, 2022, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the Forum appointed The Honourable Neil Anthony Brown QC as Panelist.
Having reviewed the communications records, the Administrative Panel (the "Panel") finds that the Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, the Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent.
Complainant requests that the domain names be transferred from Respondent to Complainant.
PRELIMINARY ISSUE: MULTIPLE RESPONDENTS
In this proceeding, an issue arises as to whether the proceeding is consistent with Paragraph 3(c) of the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”) which provides that a “complaint may relate to more than one domain name, provided that the domain names are registered by “the same domain name holder”. In the instant proceedings, there are three domain names and as there is one registrant for one domain name and one registrant for the other two domain names, it could be said that the registrants of the three domain names are not “the same domain name holder”, but two domain name holders.
However, to resolve that issue, Complainant has submitted in effect that there is only one domain name holder because the entities which control the domain names are effectively controlled by the same person and/or entity, operating under several aliases. In the present proceeding and because the person controlling the several domain names is said to be only one person using different aliases, he or she would then be, on the foregoing analysis, “the same domain name holder” and the proceeding would have been validly instituted.
In support of its submission, Complainant contends that the fact that each Respondent registered identical domain names, as all three contain the expression “taoswalk”, and differ only in the generic top-level domain (gTLD) used, suggests that they had been registered by and are now held by the same entity, who would thus be “the same domain name holder”. Additionally, Complainant submits that the fact that the disputed domain names were registered only four months apart and that the WHOIS contact information is the same for each of two of the three registrations, also suggests that the domain names are controlled by the same Respondent. Finally, Complainant submits that the disputed domain names are registered with the same registrar and redirect users to similar resolving websites and that would seem to be the case.
Having regard to the above-mentioned circumstances, the Panel agrees with the Complainant’s submission and finds that the domain names are owned/controlled by a single Respondent who is using multiple aliases and that there is, therefore, only one domain name holder. Accordingly, the proceeding has been formulated correctly and may go forward on that basis.
PRELIMINARY ISSUE: LANGUAGE OF THE PROCEEDINGS
Complainant has submitted that because Respondent is conversant and proficient in the English language, the proceeding should be conducted in English. The Panel notes that the Registration Agreement relating to the domain names is written in the Vietnamese language, thereby making the language of the proceedings in Vietnamese. However, the Panel has a discretion to determine that in all the circumstances, the language should be a language other than the language of the Registration Agreement and that in the present case it should be English. See FilmNet Inc. v. Onetz, FA 96196 (Forum Feb. 12, 2001) (finding it appropriate to conduct the proceeding in English under Rule 11, despite Korean being designated as the required language in the registration agreement because the respondent submitted a response in English after receiving the complaint in Korean and English). Thus, it is open to the Panel to decide to continue the case in English and with the English-language submission of the Complaint. See Rule 11.
Complainant submits that because Respondent is conversant and proficient in English, the proceeding should be conducted in English. Complainant contends Respondent’s website available at one of the disputed domain names uses English characters and words therein, suggesting that Respondent is at least proficient in the English language. Additionally, Respondent has communicated via email in English. Further, Complainant is not conversant nor proficient in the Vietnamese language and it would require delay and unnecessary costs to translate the documents.
The Panel therefore determines pursuant to Rule 11 that the language of the proceeding will be English and the matter may go forward on that basis.
A. Complainant
Complainant made the following contentions.
Complainant engages in the sale and marketing of a variety of footwear, known for style and comfort. Complainant submits that it has rights in the TAOS mark through its registration of the mark with multiple trademark agencies around the world, including the United States Patent and Trademark Office (USPTO) (e.g., Reg. No. 3,009,106, registered on October 25, 2005). See Compl. Ex. 6. Respondent’s <taoswalk.net>, <taoswalk.xyz>, and <taoswalk.com> disputed domain names are identical or confusingly similar to Complainant’s TAOS mark as they incorporate the mark in its entirety, only adding the word “walk” and generic top-level domains (gTLDs).
Respondent has no rights or legitimate interests in the <taoswalk.net>, <taoswalk.xyz>, and <taoswalk.com> disputed domain names. Complainant has not authorized or licensed Respondent to use the TAOS mark, nor is Respondent commonly known by the disputed domain name. Further, Respondent is not using the disputed domain name in connection with a bona fide offering of goods and services or legitimate noncommercial or fair use as the resolving websites offer competing goods and attempt to deceive users about the association between Respondent and Complainant.
Respondent registered and uses the <taoswalk.net>, <taoswalk.xyz>, and <taoswalk.com> domain names in bad faith. Respondent disrupts Complainant’s business by offering competing goods. Further, Respondent attempts to attract users for commercial gain by using confusingly similar domain names to redirect users to websites that offer competing goods. Finally, Respondent had actual notice of Complainant’s rights in the TAOS mark.
B. Respondent
Respondent failed to submit a Response in this proceeding. However, the Panel notes that correspondence was received by the Forum via email on December 29, 2021, stating as follows: “For the second time, you've made a mistake in the email address. I'm not supposed to receive this (neither the legal documents), I have no idea what it is and I'm pretty sure I'm not supposed to have access to these documents. Thank you for removing me from this mailing”.
That correspondence purports to have been sent, not by either of the named respondents, but by the person whose name is given in the WHOIS record for the domain name <taoswalk.com> for contact and billing information of that domain name, but not for the other two domain names, <taoswalk.xyz> and <taoswalk.net>. For reasons that will become apparent, the Panel has decided not to disclose the name and/or email address of the person whose name was given for contact and billing information for <taoswalk.com>. That person has said that he or she has no idea what the proceedings are about. It might therefore be said that this raises an issue of identity theft. However, the Panel is of the view that this case does not raise an issue of identity theft and that there should be no redaction of any information that is on record or that would be revealed by the proposed decision of the Panel.
It is true that a panel has the power to order redaction and that this power comes in turn from the power of the Panel to conduct the proceeding as it determines. The power to order redaction has generally been understood to allow the redaction of respondents’ information so that the respondent cannot be identified and associated with any adverse findings made by the Panel when in fact the person involved had nothing to do with the registration or use of the domain name at all. This has been done where the Respondent’s identity seems to have been stolen and usually where the innocent respondent has requested redaction. The Panel as presently constituted has made several orders for redaction. It is obvious that the power to order redaction is a valuable instrument. However, it must be remembered that it should be used sparingly, only where a case is made out for using it and only, so it seems, where it is to be used the protect respondents’ information.
The panel looked at this issue closely and has concluded that no redaction should be made. That is so for the following reasons. First, one of the important features of the UDRP process is that decisions are published in full unless a case is made out for redaction. In the present case, no case for redaction has been made out and it has not been requested. In particular, it should be said that neither party has requested redaction. That being so, the Panel is of the opinion that the principle of full publication should be complied with in the absence of a case for redaction being made out, which has not happened in this case. Secondly, the person who asserts that he or she does not know what the case is about is not a domain name holder / respondent and the capacity in which she or he is involved is not known, except that the person’s name and email address have been given or taken for contact and billing information. But that name and email address will not appear in the decision and will not be made public or, at least, not by the Panel. There is therefore no practical prospect of that person being identified as the subject of adverse rulings having being made against him or her by a panel, because none will have been made. The issue of the consequences of disclosure therefore do not arise. Moreover, the two respondents whose names appear in the heading of the proceeding have not said they have been wrongly drawn into a case they know nothing about or even that they should not be identified as respondents.
In all the circumstances, therefore the Panel finds that there is no case for redaction and the Panel will not order that any redaction should take place.
1. Complainant is a United States company that is engaged in the footwear industry.
2. Complainant has established its trademark rights in the TAOS mark through its registration of the mark with multiple trademark agencies around the world, including the United States Patent and Trademark Office (USPTO) (e.g., Reg. No. 3,009,106, registered on October 25, 2005).
3. Respondent registered the <taoswalk.net> domain name on August 18, 2021, the <taoswalk.xyz> domain name on September 13, 2021 and the <taoswalk.com> domain name on April 20, 2021.
4. Respondent has caused the disputed domain names to resolve to websites that offer competing goods and attempt to deceive internet users about an association between Complainant and Respondent.
Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable."
Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:
(1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and
(2) Respondent has no rights or legitimate interests in respect of the domain name; and
(3) the domain name has been registered and is being used in bad faith.
In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) (“Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint”).
The first question that arises is whether Complainant has rights in a trademark or service mark on which it may rely. Complainant submits that it has rights in the TAOS mark through its registration of the mark with multiple trademark agencies around the world, including the USPTO (e.g., Reg. No. 3,009,106, registered on October 25, 2005). See Compl. Ex. 6. Registering a mark with multiple trademark agencies is sufficient to establish rights in a mark pursuant to Policy ¶ 4(a)(i). See Google LLC v. Bhawana Chandel / Admission Virus, FA 1799694 (Forum Sept. 4, 2018) (“Complainant has rights in the GMAIL mark based upon its registration of the mark with numerous trademark agencies around the world.”); see also Bloomberg Finance L.P. v. Jimmy Yau, FA 1764034 (Forum Jan. 25, 2018) (“The Panel finds that complainant has rights in BLOOMBERG mark under Policy ¶ 4(a)(i) based upon its registration with multiple trademark agencies, including the USPTO.”). Therefore, the Panel finds Complainant has sufficiently established rights in the TAOS mark per Policy ¶ 4(a)(i).
The next question that arises is whether the disputed domain names are identical or confusingly similar to Complainant’s TAOS mark. Complainant argues Respondent’s <taoswalk.net>, <taoswalk.xyz>, and <taoswalk.com> disputed domain names are identical or confusingly similar to Complainant’s TAOS mark, as they incorporate the trademark and the generic word “walk” and different gTLDs in each case. The mere addition of a generic term and a gTLD is not sufficient to differentiate the disputed domain name from a mark. See MTD Products Inc v. J Randall Shank, FA 1783050 (Forum June 27, 2018) (“The disputed domain name is confusingly similar to Complainant’s mark as it wholly incorporates the CUB CADET mark before appending the generic terms ‘genuine’ and ‘parts’ as well as the ‘.com’ gTLD.”); see also Skechers U.S.A., Inc. and Skechers U.S.A., Inc. II v. Svensson Viljae, FA 1784650 (Forum June 1, 2018) (finding confusing similarity where “[t]he disputed domain name <skechers-outlet.com> adds a hyphen and the generic term ‘outlet’ to Complainant's registered SKECHERS mark, and appends the ‘.com’ top-level domain.”). The Panel therefore finds the disputed domain names are confusingly similar to Complainant’s TAOS mark.
Complainant has thus made out the first of the three elements that it must establish.
It is now well established that Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii), then the burden shifts to Respondent to show it does have rights or legitimate interests. See Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011) (finding that a complainant must offer some evidence to make its prima facie case and satisfy Policy ¶ 4(a)(ii)); see also Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014) (“Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests”).
The Panel finds that Complainant has made out a prima facie case that arises from the following considerations:
(a) Respondent has chosen to take Complainant’s TAOS mark and to use it in its domain names, adding the generic word “walk”, which does not negate confusing similarity which is otherwise present, as it is in the present case;
(b) Respondent registered the <taoswalk.net> domain name on August 18, 2021, the <taoswalk.xyz> domain name on September 13, 2021 and the <taoswalk.com> domain name on April 20, 2021;
(c) Respondent has caused the disputed domain names to resolve to websites that offer competing goods and attempt to deceive internet users about an association between Complainant and Respondent;
(d) Respondent has engaged in these activities without the consent or approval of Complainant;
(e)Complainant contends Respondent lacks rights and legitimate interests in the <taoswalk.net>, <taoswalk.xyz>, and <taoswalk.com> disputed domain names because Respondent is not authorized to use the TAOS mark, nor is Respondent commonly known by the disputed domain names. To determine whether a respondent is commonly known by a disputed domain name under Policy ¶ 4(c)(ii), the Panel may reference WHOIS information. See Amazon Technologies, Inc. v. Suzen Khan / Nancy Jain / Andrew Stanzy, FA 1741129 (Forum Aug. 16, 2017) (finding that respondent had no rights or legitimate interests in the disputed domain names when the identifying information provided by WHOIS was unrelated to the domain names or respondent’s use of the same). Furthermore, lack of authorization to use a mark serves as further indication that a respondent is not commonly known by the disputed domain name. See Radio Flyer Inc. v. er nong wu, FA 2011001919893 (Forum Dec. 16, 2020) (“Here, the WHOIS information lists “er nong wu” as the registrant and no information suggests Complainant has authorized Respondent to use the RADIO FLYER mark in any way. Therefore, the Panel finds that Respondent is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii).”). In the present case, the available WHOIS information shows Respondent is known as “Dang Hong Son” or “Phan Vam Tung” and there is no evidence to suggest Complainant authorized Respondent to use the TAOS mark in any way. See Amend. Compl. Ex. 2. Therefore, the Panel finds Respondent is not commonly known by the disputed domain names;
(f) Complainant argues Respondent does not use the <taoswalk.net>, <taoswalk.xyz>, and <taoswalk.com> domain names for a bona fide offering of goods and services or legitimate noncommercial or fair use because the resolving websites offer competing goods to those offered by Complainant. Using a disputed domain name to offer competing goods and services to those offered by a complainant is not a bona fide offering of goods and services or legitimate noncommercial or fair use. See General Motors LLC v. MIKE LEE, FA 1659965 (Forum Mar. 10, 2016) (finding that “use of a domain to sell products and/or services that compete directly with a complainant’s business does not constitute a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).”); see also j2 Global Canada, Inc. and Landslide Technologies, Inc. v. VIJAY S KUMAR / STRATEGIC OUTSOURCING SERVICES PVT LTD, FA 1647718 (Forum Jan. 4, 2016) (finding that the disputed domain purports to offer for sale goods and services in the field of electronic marketing, which directly overlap with the services covered by Complainant’s registrations and offered by Complainant online, and therefore Respondent does not have rights or legitimate interests through its competing use). Here, the Panel notes the similarity between the goods offered by Complainant and those offered by Respondent. See Compl. Exs. 3 and 4. As the Panel agrees that Respondent offers competing goods, the Panel finds Respondent is not using the disputed domain names for a bona fide offering of goods and services;
(g) Complainant submits Respondent does not use the disputed domain names for a bona fide offering of goods and services or legitimate noncommercial or fair use because Respondent attempts to deceive users about the association or affiliation between the disputed domain names and resolving websites with Complainant. Past panels have agreed that using a disputed domain name or resolving website to confuse users about the association between the disputed domain name and a complainant is not a bona fide offering of goods and services or legitimate noncommercial or fair use. See Ripple Labs Inc. v. NGYEN NGOC PHUONG THAO, FA 1741737 (Forum Aug. 21, 2017) (“Respondent uses the [disputed] domain name to divert Internet users to Respondent’s website… confusing them into believing that some sort of affiliation exists between it and Complainant… [which] is neither a bona fide offering of goods or services under Policy ¶ 4(c)(i) nor a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).”); see also Invesco Ltd. v. Premanshu Rana, FA 1733167 (Forum July 10, 2017) (“Use of a domain name to divert Internet users to a competing website is not a bona fide offering of goods or services or a legitimate noncommercial or fair use.”). In the present case, the Panel notes the screenshots of the resolving websites to see how Respondent attempts to confuse users by using confusingly similar domain names to redirect to websites that offer competing goods and that seem to be affiliated to Complainant. See Compl. Ex. 4. Therefore the Panel finds Respondent is not using the disputed domain names in connection with a bona fide offering of goods and services or legitimate noncommercial or fair use.
All of these matters go to make out the prima facie case against Respondent.
As Respondent has not filed a Response or attempted by any other means to rebut the prima facie case against it, the Panel finds that Respondent does not have a right or legitimate interest in the disputed domain names.
Complainant has thus made out the second of the three elements that it must establish.
It is clear that to establish bad faith for the purposes of the Policy, Complainant must show that the disputed domain names were registered in bad faith and have been used in bad faith. It is also clear that the criteria set out in Policy ¶ 4(b) for establishing bad faith are not exclusive, but that Complainants in UDRP proceedings may also rely on conduct that is bad faith within the generally accepted meaning of that expression.
Having regard to those principles, the Panel finds that the disputed domain names were registered and used in bad faith. That is so for the following reasons.
First, Complainant submits Respondent registered and uses the disputed domain names in bad faith because the confusingly similar domain names and resolving websites disrupt Complainant’s business. When a respondent uses a disputed domain name and resolving website to offer competing products, a panel may find bad faith as the respondent will have been disrupting Complainant’s business. See ZIH Corp. v. ou yang lin q, FA1761403 (Forum Dec. 29, 2017) (Finding bad faith where Respondent used the infringing domain name to disrupt Complainant’s business by diverting Internet users from Complainant’s website to Respondent’s website where it offered competing printer products); see also DatingDirect.com Ltd. v. Aston, FA 593977 (Forum Dec. 28, 2005) (“Respondent is appropriating Complainant’s mark to divert Complainant’s customers to Respondent’s competing business. The Panel finds this diversion is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).”). Here, the Panel notes screenshots of the resolving websites that seem to offer similar goods as Complainant, namely footwear. See Compl. Exs. 3 and 4. As the Panel agrees this disrupts Complainant’s business, the Panel finds Respondent acted in bad faith.
Secondly, Complainant argues Respondent attempts to attract users to its websites for commercial gain, presumably because Respondent financially benefits if users buy its competing products. Using a disputed domain name and resolving website to attract users for commercial gain by offering competing goods may serve as indication of bad faith. See Xylem Inc. and Xylem IP Holdings LLC v. YinSi BaoHu YiKaiQi, FA1504001612750 (Forum May 13, 2015) (“The Panel agrees that Respondent’s use of the website to display products similar to Complainant’s, imputes intent to attract Internet users for commercial gain, and finds bad faith per Policy ¶ 4(b)(iv).”); see also OneWest Bank N.A. v. Matthew Foglia, FA1503001611449 (Forum Apr. 26, 2015) (holding that the respondent’s use of the disputed domain name to direct Internet users to a website which competed with the complainant was evidence of bad faith pursuant to Policy ¶ 4(b)(iv)). Examining the resolving websites, the Panel notes Respondent offers shoes, similar to Complainant. See Compl. Ex. 3. Therefore, the Panel finds Respondent acted in bad faith.
Thirdly, Complainant contends Respondent had actual notice of Complainant’s rights in the TAOS mark, evidenced by the fame of Complainant’s mark, as well as Respondent’s offer of competing goods. Past panels have determined a respondent has actual notice of a mark when the mark is notorious and when the resolving website serves as a competitor to the complainant’s business. See United States Postal Service v. Yongkun Wang, FA 1788170 (Forum July 11, 2018) (finding Respondent had actual knowledge of Complainant’s rights in the USPS mark “given the widespread use of Complainant’s mark and the fact that Respondent registered four separate domain names all of which include Complainant’s USPS mark in its entirety”); see also Norgren GmbH v. Domain Admin / Private Registrations Aktien Gesellschaft, FA1501001599884 (Forum Feb. 25, 2014) (holding that the respondent had actual knowledge of the complainant and its rights in the mark, thus demonstrating bad faith registration under Policy ¶ 4(a)(iii), where the respondent was using the disputed domain name to purposely host links related to the complainant’s field of operation). Here, Complainant provides evidence of the mark’s notoriety, including multiple registrations and articles about the mark, as well as evidence that the Respondent uses the websites to offer competing goods. See Compl. Exs. 4-6 As the Panel finds Respondent had actual notice of Complainant’s rights in the TAOS mark, it finds Respondent acted in bad faith.
Finally, in addition and having regard to the totality of the evidence, the Panel finds that, in view of Respondent’s registration of the disputed domain names using the TAOS mark and in view of the conduct that Respondent has engaged in when using the domain names, Respondent registered and used them in bad faith within the generally accepted meaning of that expression.
Complainant has thus made out the third of the three elements that it must establish.
Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <taoswalk.net>, <taoswalk.xyz>, and <taoswalk.com> domain names be TRANSFERRED from Respondent to Complainant.
The Honourable Neil Anthony Brown QC
Panelist
Dated: January 26, 2022
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