optionsXpress Holdings, Inc. v. Peter Smith / Bobs Limited
Claim Number: FA1407001572331
Complainant is optionsXpress Holdings, Inc. (“Complainant”), represented by Laura M. Franco of Winston & Strawn LLP, California, USA. Respondent is Peter Smith / Bobs Limited (“Respondent”), Isle of Man.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <optinosxpress.com>, <optiosnxpress.com>, <optionnxpress.com>, <optinnsxpress.com>, <optinosxpress.com>, <optionnxpress.com>, <optionsppress.com>, <optionsspress.com>, <optiosnxpress.com>, <opttonsxpress.com>, <ooptoinexpress.com>, <optinxpress.com>, <optionnsxpress.com>, and <optionmsxpress.com>, registered with Sibername Internet and Software Technologies Inc.
The undersigned certifies he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.
Houston Putnam Lowry, Chartered Arbitrator, as Panelist.
Complainant submitted a Complaint to the National Arbitration Forum electronically on July 29, 2014; the National Arbitration Forum received payment on July 30, 2014.
On July 30, 2014, Sibername Internet and Software Technologies Inc. confirmed by e-mail to the National Arbitration Forum that the <optinosxpress.com>, <optiosnxpress.com>, <optionnxpress.com>, <optinnsxpress.com>, <optinosxpress.com>, <optionnxpress.com>, <optionsppress.com>, <optionsspress.com>, <optiosnxpress.com>, <opttonsxpress.com>, <ooptoinexpress.com>, <optinxpress.com>, <optionnsxpress.com>, and <optionmsxpress.com> domain names are registered with Sibername Internet and Software Technologies Inc. and that Respondent is the current registrant of the names. Sibername Internet and Software Technologies Inc. has verified that Respondent is bound by the Sibername Internet and Software Technologies Inc. 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 July 31, 2014, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 20, 2014 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@optinosxpress.com, postmaster@optiosnxpress.com, postmaster@optionnxpress.com, postmaster@optinnsxpress.com, postmaster@optinosxpress.com, postmaster@optionnxpress.com, postmaster@optionsppress.com, postmaster@optionsspress.com, postmaster@optiosnxpress.com, postmaster@opttonsxpress.com, postmaster@ooptoinexpress.com, postmaster@optinxpress.com, postmaster@optionnsxpress.com, and postmaster@optionmsxpress.com. Also on July 31, 2014, the 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 response from Respondent, the National Arbitration Forum transmitted to the parties a Notification of Respondent Default.
On August 27, 2014, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the National Arbitration Forum appointed Houston Putnam Lowry, Chartered Arbitrator, as Panelist.
Having reviewed the communications records, the Administrative Panel (the "Panel") finds that the National Arbitration 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 National Arbitration 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.
A. Complainant
a. Complainant and Its Marks.
optionsXpress Holdings, Inc., through its subsidiary optionsXpress, Inc. (together, “optionsXpress”) provides online options and futures brokerage. Since its founding in 2001, optionsXpress’ experienced management team have dedicated themselves to providing investors with an innovative and leading-edge trading environment, making optionsXpress a leader in the industry. optionsXpress is an affiliate of Charles Schwab & Co., Inc., which itself is a leading provider of securities, brokerage, money management and financial advisory services. optionsXpress-branded products and services are advertised and sold to clients in the United States and internationally through optionsXpress and its regional affiliates.
Complainant also operates a website accessible at the URL www.optionsxpress.com, which domain name was registered by Complainant in 1999. On its website, Complainant prominently uses the trademark OPTIONSXPRESS and features information related to the services offered under the mark.
Complainant has used the OPTIONSXPRESS mark since at least as early as 2000, and in 2002, obtained a federal trademark registration for OPTIONSXPRESS (Reg. No. 2,618,175) in Class 36 for “securities trading and investing services via the Internet.” Given its long-standing use, Complainant has achieved significant goodwill in its OPTIONSXPRESS mark, which has become famous.
b. Respondent and Its Actions.
1. Respondent registered the Disputed Domains on April 21 and 22, 2013 and April 13, 2014. The Disputed Domains were registered well after Complainant began extensive marketing of its services under its mark and after the registration of its mark in the U.S. and the registration of the optionsxpress.com domain name. Each of the marks consist of intentional misspellings of Complainants mark.
2. Respondent redirects all 14 of the Disputed Domains to a website entitled Markets World, at the URL www.marketsworld.com. The MarketsWorld website competes with Complainant as it provides online “binary options trading.” According to the MarketsWorld website, binary options trading is a “simpler, quicker way to earn profit speculating on the financial markets than trading through a stock broker, spread betting, or contracts for difference.” Significantly, nowhere on the MarketsWorld website does it refer to itself as optionsXpress, nor does it otherwise make any reference to optionsXpress. Complainant has sent two cease and desist letters to MarketsWorld and no response from MarketsWorld has been forthcoming. Complainant has also submitted a complaint to Sibername Internet and Software Technologies, Inc. to which no response from the Disputed Domains Registrant has been forthcoming.
3. Complainant has not given Respondent any license, permission, or authorization by which Respondent could make any use of any of its marks.
c. The Disputed Domains are nearly identical and confusingly similarto the OPTIONSXPRESS® mark. (ICANN Rule 3(b)(ix)(1); ICANN Policy ¶4(a)(i)).
The Disputed Domains are each confusingly similar to Complainant’s OPTIONSXPRESS mark due to the intentional misspelling of words, the replacement of one character with another, the juxtaposition of two characters, or the removal of a character from each Disputed Domain. See Victoria’s Secret v. Zuccarini, FA 95762 (Nat. Arb. Forum Nov. 18, 2000) (finding that, by misspelling words and adding letters to words, a respondent does not create a distinct mark but nevertheless renders the domain name confusingly similar to the complainant’s marks); see also Dow Jones & Co., Inc. v. Powerclick, Inc., D2000-1259 (WIPO Dec. 1, 2000) (holding that the deliberate introduction of errors or changes, such as the addition of a fourth “w” or the omission of periods or other such “generic” typos do not change respondent’s infringement on a core trademark held by the complainant); Reuters Ltd. v. Global Net 2000, Inc., D2000-0441 (WIPO July 13, 2000) (finding that a domain name which differs by only one letter from a trademark has a greater tendency to be confusingly similar to the trademark where the trademark is highly distinctive); see also Busy Body, Inc. v. Fitness Outlet Inc., D2000-0127 (WIPO Apr. 22, 2000) ("[T]he addition of the generic top-level domain (gTLD) name ‘.com’ is . . . without legal significance since use of a gTLD is required of domain name registrants . . . .").
d. Respondent has no rights or legitimate interests in the Disputed Domains. (ICANN Rule 3(b)(ix)(2); ICANN Policy ¶4(a)(ii)).
Respondent lacks rights or legitimate interests in the Disputed Domains. Respondent has never been commonly known by any of the following identities: optinosxpress.com; optiosnxpress.com; optionnxpress.com; optinnsxpress.com; optinosxpress.com; optionnxpress.com; optionsppress.com; optionsspress.com; optiosnxpress.com; opttonsxpress.com; ooptoinexpress.com; optinxpress.com; optionnsxpress.com; and optionmsxpress.com. Further, Respondent has never used any trademark or service mark similar to the Disputed Domains by which he or she may have come to be known, other than the infringing use noted herein. See Citigroup Inc. v. Horoshiy, Inc. a/k/a Horoshiy, FA0406000290633 (Aug. 11, 2004) (finding that Respondent had not established rights or legitimate interests in the disputed domain name where there was no evidence that Respondent was commonly known by the domain name); Citigroup Inc. v. Acme Mail, FA 0402000241987 (Nat. Arb. Forum Apr. 12, 2004) (finding that respondent had not established rights or legitimate interests in the disputed domain name where “[r]espondent has no proof and there is no evidence in the record to suggest that [r]espondent is commonly known by <citiban.com>“); McClatchy Management Services, Inc., v. Peter Carrington a/k/a Party Night Inc., FA 0304000155902 (Nat. Arb. Forum June 2, 2003) (finding that respondent failed to establish rights to or legitimate interests in the disputed domain names where respondent was not commonly known as “Startribun” or “Stratribune”); see also GlaxoSmithKline Biologicals S.A. v. David Pfeffer c/o JeMM Productions, FA467340 (Nat. Arb. Forum June 10, 2005) (in which the Panel ordered transfer of <cervarix.us> based in part upon a finding that the respondent lacked rights or legitimate interests in the domain name).
Respondent has never operated any bona fide or legitimate business under the Disputed Domains, and is not making a protected non-commercial or fair use of the Disputed Domain. Respondent is using the Disputed Domain to redirect Internet users to <www.marketsworld.com>, a financial trading services website, which is in direct competition with Complainant without authorization and presumably for a nefarious purpose. Notably, the MarketWorld.com website makes no reference to any of the Disputed Domains, either as the common name for the website operator, and alternative for MarketsWorld, or in connection with any of the products or services provided on that site. Such a use is not a bona fide offering of goods or services or a legitimate noncommercial or fair use. Past panels have found that a respondent’s use of a domain name that is confusingly similar to Complainant’s mark to divert Internet users for commercial gain 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 Crow v. LOVEARTH.net, FA 203208 (Nat. Arb. Forum Nov. 28, 2003) (“It is neither a bona fide offerings [sic] of goods or services, nor an example of a legitimate noncommercial or fair use under Policy ¶¶4(c)(i) & (iii) when the holder of a domain name, confusingly similar to a registered mark, attempts to profit by passing itself off as Complainant .. . .”); see also Coryn Group, Inc. v. Media Insight, FA 198959 (Nat. Arb. Forum Dec. 5, 2003) (finding that the respondent was not using the domain names for a bona fide offering of goods or services nor a legitimate noncommercial or fair use because the respondent used the names to divert Internet users to a website that offered services that competed with those offered by the complainant under its marks); American Int’l Group, Inc. v. Busby, FA 156251 (Nat. Arb. Forum May 30, 2003) (finding that the respondent attempts to pass itself off as the complainant online, which is blatant unauthorized use of the complainant’s mark and is evidence that the respondent has no rights or legitimate interests in the disputed domain name).
Complainant has not granted Respondent any license, permission, or authorization by which it could own or use any domain name registrations which are confusingly similar to any of Complainant’s marks. See Amazon.com, Inc. v. Rayaneh Net, FA 0309000196217 (Nat. Arb. Forum October 28, 2003) (finding no legitimate rights in the “amazoniran.com” domain name, in part, because complainant did not grant respondent a license to use the AMAZON.COM mark); see also Nokia Corp. v. Nokiagirls.com, D2000-0102 (WIPO Apr. 18, 2000) (finding absence of license permitting respondent to use complainant’s trademark in domain name evidence of respondent’s illegitimate interests).
e. Respondent registered and uses the Disputed Domains in bad faith. (ICANN Rule 3(b)(ix)(3); ICANN Policy ¶4(a)(iii)).
As the facts set forth above reveal, Respondent registered and uses the Disputed Domains in bad faith. At the time that the Respondent registered the Disputed Domains, Respondent had at least constructive knowledge of the Complainant’s mark because of Complainant’s registration of its mark with the USPTO. See Victoria’s Cyber Secret Ltd. v. V Secret Catalogue, Inc., 161 F.Supp.2d 1339, 1349 (S.D. Fla. 2001) (noting that “a Principal Register registration of a trademark or service mark is constructive notice of a claim of ownership so as to eliminate any defense of good faith adoption” pursuant to 15 U.S.C. § 1072); Orange Glo Int’l v. Blume, FA 118313 (Nat. Arb. Forum Oct. 4, 2002) (“Complainant’s OXICLEAN mark is listed on the Principal Register of the U.S.P.T.O., a status that confers constructive notice on those seeking to register or use the mark or any confusingly similar variation thereof”); see also Grainger, Inc. v. Above.com Domain Privacy, FA 1334458 (Nat. Arb. Forum Aug. 24, 2010) (stating that “the Panel finds that USPTO registration is sufficient to establish these [Policy ¶4(a)(i)] rights even when Respondent lives or operates in a different country.”).
Even if Respondent were able to claim lack of knowledge, bad faith can exist when a search of the trademarks registry would reveal the registration rights of a Complainant. Had the Respondent done a trademark search or domain name search prior to registration of the Disputed Domains, Respondent would have seen Complainant’s mark. See, e.g., Kate Spade, LLC v. Darmstadter Designs, D2001-1384 (WIPO Jan. 3, 2002) (“Had Respondent done a trademark search at the time Respondent registered the domain name at issue, Respondent would have received notice of Complainant's pending application for registration. … It is fair to apply United States principles of constructive notice to this situation.”).
Respondent’s use of the 14 Disputed Domains to direct consumers to its products and services which are in direct competition with Complainant’s business constitutes bad faith registration and use under Policy ¶4(b)(iii). See Ameritrade Holdings Corp. v. Polanski, FA 102715 (Nat. Arb. Forum Jan. 11, 2002) (finding that the respondent’s use of the disputed domain name to redirect Internet users to a financial services website, which competed with the complainant, was not a bona fide offering of goods or services); Disney Enters., Inc. v. Noel, FA 198805 (Nat. Arb. Forum Nov. 11, 2003) (“Respondent registered a domain name confusingly similar to Complainant's mark to divert Internet users to a competitor's website. Respondent's purpose of registration and use was to either disrupt or create confusion for Complainant's business in bad faith pursuant to Policy ¶¶4(b)(iii) [and] (iv).”); see also S. Exposure v. S. Exposure, Inc., FA 94864 (Nat. Arb. Forum July 18, 2000) (finding the respondent acted in bad faith by attracting Internet users to a website that competes with the complainant’s business). Further, these 14 Disputed Domains have been put to use to intentionally attract, for its own commercial gain, Internet users to Respondent’s web site or other on-line locations, by creating a likelihood of confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement of Respondent’s web site or location or of a product or service on Respondent’s web site. This behavior by Respondent evidences one of the four explicit examples of bad faith set forth in the Policy. See Policy at 4(b)(iv). See TM Acquisition Corp. v. Warren, FA 204147 (Nat. Arb. Forum Dec. 8, 2003) (“Although Complainant’s principal website is <century21.com>, many Internet users are likely to use search engines to find Complainant’s website, only to be misled to Respondent’s website at the <century21realty.biz> domain name. Therefore, it is likely that Internet users seeking Complainant’s website, but who end up at Respondent’s website, will be confused as to the source, sponsorship, affiliation or endorsement of Respondent’s website”).
Finally, Respondent has engaged in typo squatting through its use of the disputed domain names, which are all misspellings of Complainant’s OPTIONSXPRESS mark. Therefore, Respondent’s use of the disputed domain names constitutes bad faith registration and use pursuant to Policy P 4(a)(iii). See The Vanguard Group, Inc. v. IQ Mgmt. Corp., FA 328127 (Nat. Arb. Forum Oct. 28, 2004) (By engaging in typo squatting, [r]espondent has registered and used the <vangard.com> domain name in bad faith pursuant to Policy P 4(a)(iii).); Natl Assn of Profl Baseball League, Inc. v. Zuccarini, D2002-1011 (WIPO Jan. 21, 2003) (Typo squatting is the intentional misspelling of words with [the] intent to intercept and siphon off traffic from its intended destination, by preying on Internauts who make common typing errors. Typo squatting is inherently parasitic and of itself evidence of bad faith.).
B. Respondent
Respondent failed to submit a Response in this proceeding.
(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.
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 Complainant prove the following three elements to obtain an order cancelling or transferring a domain name:
(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(e), 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 and inferences set forth in the Complaint as true unless the evidence is clearly contradictory. See Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (Nat. Arb. Forum July 31, 2000) (holding that the respondent’s failure to respond allows all reasonable inferences of fact in the allegations of the complaint to be deemed true); see also Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (“In the absence of a response, it is appropriate to accept as true all allegations of the Complaint.”).
Complainant uses the OPTIONSXPRESS mark for online securities trading and investing services. Complainant has a federal trademark registration of the OPTIONSXPRESS mark with the United States Patent & Trademark Office (“USPTO”) (Reg. No. 2,618,175 registered September 10, 2002). A USPTO registration satisfies Policy ¶4(a)(i) requirements, despite Respondent’s apparent residence outside USPTO jurisdiction. At this stage, Complainant need only show SOME rights, not that it has superior rights to Respondent. See W.W. Grainger, Inc. v. Above.com Domain Privacy, FA 1334458 (Nat. Arb. Forum Aug. 24, 2010) (stating that “the Panel finds that USPTO registration is sufficient to establish these [Policy ¶4(a)(i)] rights even when Respondent lives or operates in a different country.”).
Complainant claims the disputed domain names are confusingly similar to the OPTIONSXPRESS mark. The disputed domain names consist of 14 different misspellings of the mark. The domain names in dispute differ from the mark by either: (i) the replacement of one character with another; (ii) the juxtaposition of two characters; or, (iii) the removal of a character from the mark. The disputed domain names also include the generic top-level domain (“gTLD”) “.com.” Such relatively minor changes alterations do not sufficiently differentiate the disputed domain names from Complainant’s mark. See, e.g., Belkin Components v. Gallant, FA 97075 (Nat. Arb. Forum May 29, 2001) (finding the <belken.com> domain name confusingly similar to the complainant's BELKIN mark because the name merely replaced the letter “i” in the complainant's mark with the letter “e”); see also Am. Online, Inc. v. Tencent Commc’ns Corp., FA 93668 (Nat. Arb. Forum Mar. 21, 2000) (finding that <oicq.net> and <oicq.com> are confusingly similar to the complainant’s mark, ICQ). Accordingly, the disputed domain names are mere minor misspellings of the OPTIONSXPRESS mark at issue and are confusingly similar to the mark pursuant to Policy ¶4(a)(i).
The Panel finds Policy ¶4(a)(i) satisfied.
Complainant must first make a prima facie case 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 has rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Entm’t Commentaries, FA 741828 (Nat. Arb. Forum Aug. 18, 2006) (holding that the complainant must first make a prima facie case that the respondent lacks rights and legitimate interests in the disputed domain name under UDRP ¶4(a)(ii) before the burden shifts to the respondent to show that it does have rights or legitimate interests in a domain name); see also AOL LLC v. Gerberg, FA 780200 (Nat. Arb. Forum Sept. 25, 2006) (“Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light. If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names.”).
Complainant claims Respondent has no rights or legitimate interests in the disputed domain names. Complainant did not authorize Respondent to use the OPTIONSXPRESS mark, a fact Respondent apparently does not dispute. In IndyMac Bank F.S.B. v. Eshback, FA 830934 (Nat. Arb. Forum Dec. 7, 2006) the panel held that the respondent failed to establish rights and legitimate interests in the <emitmortgage.com> domain name as the respondent was not authorized to register domain names featuring the complainant’s mark and failed to submit evidence that it is commonly known by the domain name. Neither the privacy WHOIS nor the subsequently revealed registrant’s names bear any relationship to the disputed domain names. It is clear Respondent is not commonly known by the disputed domain names pursuant to Policy ¶4(c)(ii).
Complainant claims Respondent has never operated any bona fide business under the disputed domain name. Respondent is not making a protected noncommercial or fair use. The disputed domain names redirect to a competitor’s financial trading services website, <marketworld.com>. In Coryn Group, Inc. v. Media Insight, FA 198959 (Nat. Arb. Forum Dec. 5, 2003), the panel found the respondent was not using the domain names for a bona fide offering of goods or services nor a legitimate noncommercial or fair use because the respondent used the names to divert Internet users to a website that offered services that competed with those offered by the complainant under its marks. This Panel would agree and finds Respondent is not providing a bona fide offering of goods or services, or a legitimate noncommercial or fair use, within the meaning of Policy ¶¶4(c)(i) or (iii).
Furthermore, Respondent is using a privacy service, which means title to the disputed domain names is held by a nominee. Since Respondent is not publicly associating itself with the disputed domain names in any way, Respondent cannot acquire any rights to the disputed domain names.
The Panel finds Policy ¶4(a)(ii) satisfied.
Complainant claims Respondent’s use of the disputed domain names to redirect users to a competing site demonstrates bad faith disruption. The disputed domain names resolve to <marketworld.com>, a competing financial trading services website. In Instron Corp. v. Kaner, FA 768859 (Nat. Arb. Forum Sept. 21, 2006), the panel found the respondent registered and used the disputed domain names in bad faith pursuant to Policy ¶4(b)(iii) by using the disputed domain names to operate competing websites. That is what is happening here. Respondent registered and uses the disputed domain names in bad faith under Policy ¶4(b)(iii) because they resolve to a website offering competing products and services.
Complainant claims the disputed domain names are used to intentionally attract and mislead internet users about Complainant’s relationship with the resolving pages, and Respondent likely benefits from the confusion. In Nokia Corp. v. Private, D2000-1271 (WIPO Nov. 3, 2000), the panel found bad faith registration and use pursuant to Policy ¶4(b)(iv) where the domain name resolved to a website offering similar products as those sold under the complainant’s famous mark. The fact Respondent registered 14 similar domain names suggests Respondent had actual knowledge of Complainant’s mark. Respondent registered and uses the disputed domain names in bad faith pursuant to Policy ¶4(b)(iv).
Finally, Respondent registered the disputed domain names with a privacy service. In the commercial context, this raises the rebuttable presumption of bad faith registration and use of the domain names. Respondent has done nothing to rebut the presumption. That alone justifies a finding of bad faith registration and use.
The Panel finds Policy ¶4(a)(iii) satisfied.
Having established all three elements required under the ICANN Policy, the Panel concludes relief shall be GRANTED.
Accordingly, it is Ordered the <optinosxpress.com>, <optiosnxpress.com>, <optionnxpress.com>, <optinnsxpress.com>, <optinosxpress.com>, <optionnxpress.com>, <optionsppress.com>, <optionsspress.com>, <optiosnxpress.com>, <opttonsxpress.com>, <ooptoinexpress.com>, <optinxpress.com>, <optionnsxpress.com>, and <optionmsxpress.com> domain names be TRANSFERRED from Respondent to Complainant.
Houston Putnam Lowry, Chartered Arbitrator, Panelist
Dated: Wednesday, September 3, 2014
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