Snapchat, Inc. v. PRIVATE REGISTRANT / A HAPPY DREAMHOST CUSTOMER
Claim Number: FA1412001593519
Complainant is Snapchat, Inc. (“Complainant”), represented by Caroline Barbee of Kilpatrick Townsend & Stockton LLP, California, USA. Respondent is PRIVATE REGISTRANT / A HAPPY DREAMHOST CUSTOMER (“Respondent”), California, USA.
REGISTRAR AND DISPUTED DOMAIN NAME
The domain name at issue is <snapchatcheck.com>, registered with DreamHost, LLC.
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 December 4, 2014; the National Arbitration Forum received payment on December 8, 2014.
On December 5, 2014, DreamHost, LLC confirmed by e-mail to the National Arbitration Forum that the <snapchatcheck.com> domain name is registered with DreamHost, LLC and that Respondent is the current registrant of the name. DreamHost, LLC has verified that Respondent is bound by the DreamHost, LLC 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 9, 2014, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of December 29, 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@snapchatcheck.com. Also on December 9, 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 December 31, 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 name be transferred from Respondent to Complainant.
A. Complainant
3. Snapchat, a Delaware corporation located in Venice, California, was created in May 2012.
4. Snapchat provides photo and video sharing services and related products and services through its mobile application software for both the iOS and Android operating systems (the “Snapchat app”). Its website is available at snapchat.com. Since 2011, Snapchat or its predecessor in interest has offered its mobile application software under the SNAPCHAT Mark.
5. The Snapchat app has met with resounding success in the marketplace and has quickly gained a substantial share of the mobile application market. A Pew research study performed in October 2013 found that 9% of all U.S. cell phone owners use the Snapchat app. Another study, released in February 2014, concluded that 77% of U.S. college students use Snapchat at least once per day. According to an article by the publication Business Insider, as of December 2013 Snapchat had 30 million monthly active users and over 60 million total users worldwide. A more recent estimate (specifically, a post on the Wall Street Journal’s “Digits” blog) places the number of monthly users of Snapchat at over 100 million individuals.
6. Data collected by the market analytics company App Annie indicates that from November 2013 to November 2014, the Snapchat app has consistently ranked among the Apple App Store’s top 5 most downloaded photo applications and top 20 most downloaded mobile applications overall. As of April 2014, the app was estimated by Business Insider to be gathering monthly active users at a rate of approximately 10 million per month. More recently, Snapchat was estimated to be the third most popular social app among 18-34 year olds in the United States, trailing only Facebook and Instagram.
7. Due to Snapchat’s exponential growth and immense popularity, the SNAPCHAT brand is frequently, if not daily, referenced in the media and popular culture. In 2014 alone, well-known and widely circulated publications, such as The New York Times and The Washington Post, and widely viewed websites, such as Mashable and the Huffington Post, all featured articles discussing Snapchat’s enormous popularity. In addition, widely circulated international publications, including the German newspaper Bild and the Japanese newspaper The Yomiuri Shimbun, have chronicled Snapchat and its popularity through a number of articles available online.
8. Snapchat has received various awards, including “Fastest Rising Startup” at the 2012 TechCrunch Crunchies Awards, and “Best Mobile Application” at the 2013 TechCrunch Crunchies Awards.
9. Snapchat owns numerous United States and foreign trademark registrations for the SNAPCHAT Mark. Each registration remains valid and in full force and effect.
10. As a result of Snapchat’s widespread use of the SNAPCHAT Mark and the continuous and unsolicited media coverage it has received, as well as the high degree of consumer recognition of the SNAPCHAT Mark and the strong and loyal base of Snapchat users, the SNAPCHAT Mark is well known and broadly recognized among consumers and Internet users generally throughout the world.
B. Respondent and the Domain Name
11. According to the WHOIS database, the Domain Name is registered through the privacy protection service provided by DreamHost, LLC.
12. Respondent registered the Domain Name on January 1, 2014.
13. The Domain Name resolves to a website advertising itself as “Snapchat Check.” The website purports to allow visitors to determine whether a Snapchat username or telephone number has been made public as a result of a January 1, 2014 security leak.
14. In addition, Respondent’s website prominently features an image of Snapchat’s proprietary “ghost logo” (the “Ghost Logo”) at the top of the website’s homepage.
<table redacted>
15. Snapchat owns numerous United States and foreign trademark registrations for the Ghost Logo. Each registration remains valid and in full force and effect.
16. At the bottom of the website associated with the Domain Name, Respondent provides a link to a website for Bourne Technologies. On information and belief, Respondent is the owner and operator of the Bourne Technologies website.
17. The website associated with the Domain Name does not feature any disclaimer or other indicia that the website or the Domain Name are not provided or endorsed by Snapchat.
18. On information and belief, Respondent uses Snapchat’s SNAPCHAT Mark to pass itself off as Snapchat or to imply that Snapchat sponsors or is associated with Respondent’s website.
Legal Grounds
This Complaint is based on the following legal grounds.
A. Likelihood of Confusion—ICANN Rule 3(b)(ix)(1); ICANN Policy ¶4(a)(i).
19. Snapchat has used the SNAPCHAT Mark continuously since well before January 1, 2014, the registration date for the Domain Name.
20. Indeed, Snapchat owns the U.S. and foreign registrations that issued well before the Domain Name’s registration date. These registrations remain valid and in full force. Thus, Complainant owns rights in the SNAPCHAT Mark that predate the registration date of the Domain Name. See, e.g., Pirelli & C. S.p.A. v. Parisa Tabriz, FA921798 (Nat. Arb. Forum April 12, 2007); FDNY Fire Safety Education Fund, Inc. v. Roger Miller, FA 145235 (Nat. Arb. Forum March 26, 2003) (“[T]he FDNY’s successful registration of its mark on the Principal Register is evidence of its rights in the mark.”).
21. A domain name is “nearly identical or confusingly similar” to a complainant’s mark when it “fully incorporate[s] said mark.” PepsiCo. Inc. v. PEPSI SRL, D2003-0696 (WIPO Oct. 28, 2003) (holding pepsiadventure.net, pepsitennis.com, and others confusingly similar to complainant’s PEPSI mark since they “incorporate[ed the] trademark in its entirety”). Here, the Domain Name incorporates the SNAPCHAT Mark in its entirety and is confusingly similar to the SNAPCHAT Mark.
22. A domain name registrant may not avoid likely confusion by simply adding a descriptive or non-distinctive term to another’s mark. See, e.g., Google Inc. v. Kun Zhang, FA0901001245131 (Nat’l Arb. Forum Mar. 13, 2009) (holding the “addition of generic terms to a famous mark is insufficient to diminish the confusingly similar nature” of the domain name googlevideodownload.com); Google Inc. v. Babaian, FA0708001060992 (Nat’l Arb. Forum Oct. 1, 2007) (finding domain names confusingly similar under Policy ¶4(a)(i) where the registrant merely added “generic words [like] ‘web,’ ‘data,’ ‘drive,’ and ‘storage’ that have an obvious relationship to [Google’s] business”). In this instance, the Domain Name merely adds the descriptive and non-distinctive term “check” after the SNAPCHAT Mark, which serves only to directly explain the nature of Respondent’s purported service.
23. Given Respondent’s prominent use of the SNAPCHAT Mark in the Domain Name and his unauthorized use of the Ghost Logo in connection with a website that allegedly provides information regarding leaked Snapchat usernames and telephone numbers, Respondent appears to be engaged in a concerted effort to attract Snapchat users to its own commercial website by trading on the goodwill embodied by the SNAPCHAT brand. Respondent’s use of the widely recognized and distinctive SNAPCHAT Mark and the non-distinctiveness of the added term “check,” taken with the lack of any disclaimer or other indicia that would minimize the risk of confusion, will cause users encountering the Domain Name to mistakenly believe the Domain Name offers a legitimate service that is associated with or is sponsored by Snapchat.
24. As such, the Domain Name is confusingly similar to the SNAPCHAT Mark.
B. No Rights or Legitimate Interests—ICANN Rule 3(b)(ix)(2); ICANN Policy ¶4(a)(ii).
25. Given the international prominence and growing omnipresence of the SNAPCHAT app, as well as its own activities under the Domain Name, Respondent is undoubtedly familiar with the SNAPCHAT Mark.
26. On information and belief, Respondent is not commonly known by the Domain Name or any name containing Complainant’s SNAPCHAT Mark. Respondent’s WHOIS information in connection with the Domain Name makes no mention of the Domain Name or the Mark as Respondent’s name or nickname. A registrant may be found to lack any right or legitimate interest in a domain name where there is no indication it is known by that name. See Popular Enterprises, LLC v. Sung-a Jang, FA0610000811921 (Nat. Arb. Forum Nov. 16, 2006) (“Respondent’s WHOIS information does not suggest that [r]espondent is commonly known by the <ntester.com> domain name”).
27. Complainant has not authorized or licensed Respondent to use the SNAPCHAT Mark in any way. Unlicensed, unauthorized use of domains incorporating a complainant’s trademark is strong evidence that Respondent has no rights or legitimate interest in the Domain Name. See, e.g., Time Warner Inc. v. MLM Capital LLC d/b/a Domains, FA0709001076561 (Oct. 26, 2007).
28. Furthermore, by operating a website that prominently features Complainant’s SNAPCHAT Mark and Ghost Logo in conjunction with a link to what appears to be Respondent’s own commercial website, <www.bourne-technologies.com>, Respondent attempts to pass itself off as Snapchat or as affiliated with or sponsored by Complainant. This “is not a bona fide offering of goods or services under Policy ¶4(c)(i) or a legitimate noncommercial or fair use under Policy ¶4(c)(iii).” See Google Inc. v. Private Person / Dmitriy Rekruta, FA1212001473942 (Nat’l Arb. Forum Jan. 14, 2013) (finding no rights or legitimate interests where respondent tried to pass itself off as Google by “imitating Complainant’s GOOGLE PLAY logo in addition to offering similar services as [Google]”); see also Morgan Stanley v. Dominec Williams, FA1201001426319 (Nat’l Arb. Forum Feb. 20, 2012) (finding “that Respondent’s attempt to pass itself off as Complainant is evidence of Respondent’s lack of rights and legitimate interests in the disputed domain name pursuant to Policy ¶4(a)(ii)” where the Respondent “displays on its website Complainant’s logo and information about Complainant”); John J. Wright, D.V.M., P.C., d/b/a Phelps Veterinary Hospital c/o Lynda L. Wright, D.V.M. v. Janelle Yates, FA1209001463770 (Nat’l Arb. Forum Nov. 8, 2012) (finding that, “while Respondent has a right to use a website criticizing Complainant, Respondent does not have the right to criticize Complainant through the inappropriate use of Complainant’s registered service mark and assumed name.”); Bank of Am. Corp. v. Nw. Free Cmty. Access, FA 180704 (Nat. Arb. Forum Sept. 30, 2003) (“Respondent’s demonstrated intent to divert Internet users seeking Complainant’s website to a website of Respondent and for Respondent’s benefit is not a bona fide offering of goods or services under Policy ¶4(c)(i) and it is not a legitimate noncommercial or fair use under Policy ¶4(c)(iii).”).
29. Respondent therefore lacks any right or legitimate interest in the Domain Name.
C. Bad Faith—ICANN Rule 3(b)(ix)(3); ICANN Policy ¶4(a)(iii).
30. The evidence overwhelmingly supports the conclusion that Respondent registered and is using the Domain Name in bad faith.
31. The unique qualities of the SNAPCHAT Mark, which Complainant adopted before the Domain Name was registered, refute any suggestion that Respondent created the Domain Name independently. By including the entire SNAPCHAT Mark in the Domain Name, Respondent willfully violated Snapchat’s intellectual property rights. See, e.g., Yahoo! Inc. v. Butler, FA0607000744444 (Nat’l Arb. Forum Aug. 17, 2006) (finding bad faith registration and use of domain name <yahooanswers.com>, among others, where the respondent “was well-aware of the Complainant’s YAHOO! mark at the time of registration and is taking advantage of the confusing similarity between the Domain Names and Complainant’s YAHOO! Mark”).
32. Likewise, where a domain name is “so obviously connected with such a well-known name and products that its very use by someone with no connection with the products suggests opportunistic bad faith.” Parfums Christian Dior v. Javier Garcia Quintas, D2000-0226 (WIPO May 17, 2000). Indeed, Respondent “could not have chosen or subsequently used . . . its domain names for any reason other than to trade on that name and to confuse Internet users and by that means to attract them to a website with a name which is the same as that of the prominent mark. That is, in itself, evidence of bad faith.” Control Techniques Ltd. v. Lektronix Ltd., D2006-1052 (WIPO Oct. 11, 2006).
33. Moreover, the website associated with the Domain Name prominently displays the SNAPCHAT Mark and references Snapchat’s services, thereby deceiving consumers into believing that the associated website emanates from Snapchat or is sponsored by, affiliated with, or endorsed by Snapchat when that is not in fact the case. See Embarq Management Company v. BizZoo Biz c/o Biz BizZoo.Biz, FA0706001010322 (Nat’l Arb. Forum July 30, 2007) (redirecting users to a “website which imitates Complainant’s website and uses Complainant’s mark prominently on the websites in order to obtain personal information” confuses consumers “as to the source, affiliation, endorsement and sponsorship of the disputed domain names” and therefore is evidence of bad faith); America Online, Inc. v. Miles, FA 105890 (Nat’l Arb. Forum May 31, 2002) (“Respondent is using the domain name at issue to resolve to a website at which Complainant’s trademarks and logos are prominently displayed. Respondent has done this with full knowledge of Complainant’s business and trademarks. The Panel finds that this conduct is that which is prohibited by Paragraph 4(b)(iv) of the Policy.”).
34. Bad faith use and registration is further established by Respondent’s use of the Ghost Logo on the homepage of the website associated with the Domain Name without proper attribution. See, e.g., World Wrestling Fed’n Entm’t, Inc. v. Ringside Collectibles, D2000-1306 (WIPO Jan. 24, 2001) (concluding that the respondent registered and used domain name in bad faith where domain name resolved to a commercial website prominently displaying the complainant’s logo).
35. Finally, the fact that Respondent advertises and provides a link to its own commercial website from the website associated with the Domain Name also evinces Respondent’s bad faith registration and use. See, e.g., Hewlett-Packard Co. and Hewlett-Packard Development Co., L.P. v. Surya Tech. c/o Manoj Kumar Allakattu, FA0708001059665 (Nat’l Arb. Forum Oct. 2, 2007) (“The Panel finds that use of a confusingly similar domain name for Respondent’s own commercial gain is additional evidence of Respondent’s bad faith registration and use pursuant to Policy ¶4(b)(iv).”); Charo Rasten, professionally known as Charo v. URLPro, FA0412000384835 (Nat’l Arb. Forum Feb. 2, 2005) (“[T]he Panel determines that Respondent’s attempts to divert Internet users for commercial gain by attracting Internet users to Respondent’s website through a likelihood of confusion with Complainant’s mark is evidence of bad faith registration and use pursuant to Policy ¶4(b)(iv).”).
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 rights or legitimate interests in respect of the domain name; and
(3) the domain name has not 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 SNAPCHAT mark in connection with its business as a social media platform, where users share photos and videos with other users. Complainant owns the SNAPCHAT mark through its trademark registration with the United States Patent and Trademark Office (“USPTO”) (Reg. No. 4375712, registered July 30, 2013). This registration is sufficient to establish Complainant’s rights in its mark pursuant to Policy ¶4(a)(i) requirements. See Intel Corp. v. Macare, FA 660685 (Nat. Arb. Forum Apr. 26, 2006) (finding that the complainant had established rights in the PENTIUM, CENTRINO and INTEL INSIDE marks by registering the marks with the USPTO). Accordingly, Panel finds Complainant’s USPTO registration satisfies the requirements of Policy ¶4(a)(i).
Complainant claims the <snapchatcheck.com> domain name is confusingly similar to Complainant’s SNAPCHAT mark because Respondent has simply added the generic term “check” to the mark. The disputed domain name also differs from the mark because of the addition of the “.com” generic top-level domain (“gTLD”). A domain name differing from a mark by only the addition of a single generic term (check) does not escape the realm of confusing similarity and the addition of a gTLD is irrelevant to a Policy ¶4(a)(i) analysis. See Mead Johnson & Company, LLC v. Chau, FA 1497581 (Nat. Arb. Forum Jun. 18, 2013) (concluding that the addition of the generic term “coupons” and a gTLD did not remove the disputed domain name from the realm of confusing similarity). The <snapchatcheck.com> domain name is confusingly similar to Complainant’s SNAPCHAT mark under 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 lacks rights or legitimate interests in the disputed domain name. Respondent is not commonly known by the <snapchatcheck.com> domain name. The WHOIS information show the domain name was registered by a privacy service. Respondent has not provided any additional information to prove it is commonly known by the disputed domain name. Given the lack of evidence provided by Respondent to infer otherwise, the Panel finds Respondent is not commonly known by the <snapchatcheck.com> domain name pursuant to Policy ¶4(c)(ii). See M. Shanken Commc’ns v. WORLDTRAVELERSONLINE.COM, FA 740335 (Nat. Arb. Forum Aug. 3, 2006) (finding that the respondent was not commonly known by the <cigaraficionada.com> domain name under Policy ¶4(c)(ii) based on the WHOIS information and other evidence in the record).
Complainant claims Respondent has not provided any bona fide offering of goods or services, or made a legitimate noncommercial or fair use of the disputed domain name. Complainant claims Respondent uses the disputed domain to pass itself off as Complainant. This Panel disagrees after doing some research outside the record and reviewing Respondent’s web site. Apparently, Complainant had a security breach. Respondent’s web site allows uses to see if their data was leaked as part of that security breach (taking the web site at face value). Policy ¶4(c)(iii) provides when a respondent is making a legitimate noncommercial or fair use of the domain name (without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue), they have established rights and legitimate rights in the domain name. While there are fairly few Proceedings that fall within this category, there are some; Homer TLC, Inc. v. GreenPeople, Claim Number: FA0508000550345 (October 16, 2005), The Situs Companies LLC v. Paul Cheek, Claim Number: FA1203001436733 (May 10, 2012); Office of Medical & Scientific Justice, Inc. v. J Todd DeShong, Claim Number: FA1302001486064 (May 6, 2013), and ADT US Holdings, Inc. v. Robert Seketa, Claim Number: FA1309001520241 (October 25, 2013). This is one of those few cases.
The Panel finds Policy ¶4(a)(ii) NOT satisfied.
Respondent has rights or legitimate interests in the <snapchatcheck.com> domain name pursuant to Policy ¶4(a)(ii). This generally raises a rebuttable presumption Respondent did not register or use the disputed domain name in bad faith pursuant to Policy ¶4(a)(iii). See Lockheed Martin Corp. v. Skunkworx Custom Cycle, D2004-0824 (WIPO Jan. 18, 2005) (finding that the issue of bad faith registration and use was moot once the panel found the respondent had rights or legitimate interests in the disputed domain name); see also Vanguard Group Inc. v. Investors Fast Track, FA 863257 (Nat. Arb. Forum Jan. 18, 2007) (“Because Respondent has rights and legitimate interests in the disputed domain name, his registration is not in bad faith.”).
Respondent has not violated any of the factors listed in Policy ¶4(b) or engaged in any other conduct that would constitute bad faith registration and use pursuant to Policy ¶4(a)(iii). See Societe des Produits Nestle S.A. v. Pro Fiducia Treuhand AG, D2001-0916 (WIPO Oct. 12, 2001) (finding that where the respondent has not attempted to sell the domain name for profit, has not engaged in a pattern of conduct depriving others of the ability to obtain domain names corresponding to their trademarks, is not a competitor of the complainant seeking to disrupt the complainant's business, and is not using the domain name to divert Internet users for commercial gain, lack of bona fide use on its own is insufficient to establish bad faith); see also Starwood Hotels & Resorts Worldwide, Inc. v. Samjo CellTech.Ltd, FA 406512 (Nat. Arb. Forum Mar. 9, 2005) (finding that the complainant failed to establish that respondent registered and used the disputed domain name in bad faith because mere assertions of bad faith are insufficient for a complainant to establish UDRP ¶4(a)(iii)). Respondent did not register and use the disputed domain name in bad faith, even though it was registered using a privacy service.
The Panel finds Policy ¶4(a)(iii) NOT satisfied.
Having not established all three elements required under the ICANN Policy, the Panel concludes relief shall be DENIED.
Accordingly, it is Ordered the <snapchatcheck.com> domain name REMAIN WITH Respondent.
Houston Putnam Lowry, Chartered Arbitrator, Panelist
Dated: Monday, January 12, 2015
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