NIKE, Inc., Nike Innovate, C.V., and Google Inc. v. Mattia Lumini / Yykk Snc
Claim Number: FA1608001687597
Complainant is NIKE, Inc., Nike Innovate, C.V., represented by David J. Steele of Tucker Ellis, LLP, California, USA. and Google Inc. represented by Monique Liburd, Trademark Counsel, Google Inc., California, USA, ( collectively, “Complainant”), Respondent is Mattia Lumini / Yykk Snc (“Respondent”), Italy.
REGISTRAR AND DISPUTED DOMAIN NAME
The domain name at issue is <nikegoogle.com>, registered with GoDaddy.com, LLC.
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 August 9, 2016; the Forum received payment on August 9, 2016.
On August 10, 2016, GoDaddy.com, LLC confirmed by e-mail to the Forum that the <nikegoogle.com> domain name is registered with GoDaddy.com, LLC and that Respondent is the current registrant of the name. GoDaddy.com, LLC has verified that Respondent is bound by the GoDaddy.com, 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 August 10, 2016, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 30, 2016 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@nikegoogle.com. Also on August 10, 2016, 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 Forum transmitted to the parties a Notification of Respondent Default.
On September 12, 2016, 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.
Preliminary Issue: Multiple Complainants
In the instant proceedings, there are three Complainants: NIKE, Inc., Nike Innovate, C.V., and Google Inc. . The relevant rules governing multiple complainants are UDRP Rule 3(a) and the Forum’s Supplemental Rule 1(e). UDRP Rule 3(a) states, “Any person or entity may initiate an administrative proceeding by submitting a complaint.” The Forum’s Supplemental Rule 1(e) defines “The Party Initiating a Complaint Concerning a Domain Name Registration” as a “single person or entity claiming to have rights in the domain name, or multiple persons or entities who have a sufficient nexus who can each claim to have rights to all domain names listed in the Complaint.”
Previous panels have interpreted the Forum’s Supplemental Rule 1(e) to allow multiple parties to proceed as one party where they can show a sufficient link to each other. For example, in Vancouver Org. Comm. for the 2010 Olympic and Paralymic Games & Int’l Olympic Comm. v. Malik, FA 666119 (Forum May 12, 2006), the panel stated:
“It has been accepted that it is permissible for two complainants to submit a single complaint if they can demonstrate a link between the two entities such as a relationship involving a license, a partnership or an affiliation that would establish the reason for the parties bringing the complaint as one entity.”
In Tasty Baking, Co. & Tastykake Invs., Inc. v. Quality Hosting, FA 208854 (Forum Dec. 28, 2003), the panel treated the two complainants as a single entity where both parties held rights in trademarks contained within the disputed domain names. Likewise, in Am. Family Health Srvs. Group, LLC v. Logan, FA 220049 (Forum Feb. 6, 2004), the panel found a sufficient link between the complainants where there was a license between the parties regarding use of the TOUGHLOVE mark. But see AmeriSource Corp. v. Park, FA 99134 (Forum Nov. 5, 2001) (“This Panel finds it difficult to hold that a domain name that may belong to AmerisourceBergen Corporation (i.e., the subject Domain Names) should belong to AmeriSource Corporation because they are affiliated companies.”).
This Panel adopts the view expressed in Vancouver Org. Comm. for the 2010 Olympic and Paralymic Games & Int’l Olympic Comm. v. Malik, (supra),Tasty Baking, Co. & Tastykake Invs., Inc. v. Quality Hosting, (supra) and Am. Family Health Srvs. Group, LLC v. Logan, (supra).
On the evidence, Complainants NIKE, Inc., and Nike Innovate, C.V., are affiliated companies and are therefore both, for that reason, within the meaning of The Forum’s Supplemental Rule 1(e), “multiple persons or entities who have a sufficient nexus who can each claim to have rights to all domain names listed in the Complaint.” They are therefore both entitled to be a Complainant in this proceeding.
The question remains whether Google Inc. is also a person or entity which can claim, on good grounds, that it has a nexus with NIKE, Inc., and Nike Innovate, C.V. such that it can claim to have rights in the domain name. The domain name is composed solely of two famous trademarks, NIKE and GOOGLE. The evidence tendered to the satisfaction of the Panel is that the NIKE trademark is owned by NIKE, Inc., as it has been assigned to that company. Clearly, Nike Innovate, C.V. also has an interest in the trademark and in whether a domain name has been registered that transgresses on that trademark, as is alleged in this proceeding. The evidence tendered to the satisfaction of the Panel is also that the GOOGLE trademark is owned by Google Inc. and it therefore has an interest in whether the same domain name transgresses on its trademark, as is alleged in the proceeding. Accordingly, Google Inc. has by that means a nexus with both NIKE, Inc., and Nike Innovate, C.V. as it can claim on good grounds to have rights to the same domain name.
In addition, the Panel notes that in Respondent’s email of April 11, 2016 in response to the collective complaint of Complainant and in which it alleged it had registered the domain name for “educational purposes” and demanded $15,000 for the domain name, it addressed that communication to “Dear Google and Nike”. It also proposed that the $15,000 “be divided between NIKE and GOOGLE”. Respondent was therefore well aware that it was addressing parties who had and claimed a common interest in the domain name.
Accordingly, the Panel finds that the evidence establishes a nexus between all three Complainants, and it will therefore treat them as a single entity in this proceeding.
The Complainants will however, for reasons of convenience, be collectively referred to in this decision as “Complainant.”
Complainant requests that the domain name be transferred from Respondent to Complainant Nike Inc.
A. Complainant
Complainant made the following contentions.
Complainants have rights in the NIKE mark (Reg. No. 978,952, Registered Feb. 19, 1974) and the GOOGLE mark (Reg. No. 2,954,071, Registered May 24, 2005) due to registration of the marks with the United States Patent and Trademark Office (“USPTO”). Both marks are world-famous and Respondent’s domain name, <nikegoogle.com>, is confusingly similar because it merely combines the marks and adds the generic top-level domain (“gTLD”) identifier “.com” to the end.
Respondent has no rights or legitimate interests in the disputed domain name. Complainants have not authorized Respondent to use their marks in any fashion, and Respondent is not commonly known by the <nikegoogle.com> domain name. Respondent’s resolving website at the disputed domain name is attempting to impersonate Complainants, and is offering to sell a shoe and advertise a partnership that does not exist. Such use cannot be construed to be a bona fide offering of goods and services or a legitimate noncommercial or fair use of a domain name under Policy ¶ 4(c)(i) or (iii).
Respondent has engaged in bad faith registration and use of the disputed domain name. Respondent offered to sell <nikegoogle.com> to Complainants for $15,000 which far exceeds the out-of-pocket costs associated with registering the domain. Further, Respondent has engaged in a pattern of bad faith registration of domain names that infringe on famous trademarks, and is attempting to take advantage of Internet users’ confusion as to the source, sponsorship, affiliation, or endorsement of the resolving website. Respondent’s use of several of Complainants’ marks on its website, as well as the worldwide fame of both the NIKE and GOOGLE marks is additional evidence that Respondent has engaged in bad faith under Policy ¶ 4(a)(iii).
B. Respondent
Respondent failed to submit a formal Response in this proceeding. However, Respondent sent an email to Complainant’s attorney on April 11, 2016 alleging, for reasons given, that it had registered the disputed domain name for “educational purposes” and offering to sell its “intellectual property” for $15,000.
1. Complainant is engaged respectively in the businesses of the supply of sports shoes and sports apparel and the provision of a highly successful and widely known search engine.
2. Complainant has registered the NIKE mark (Reg. No. 978,952, Registered Feb. 19, 1974) and the GOOGLE mark (Reg. No. 2,954,071, Registered May 24, 2005) with the USPTO.
3. Respondent registered the <nikegoogle.com> domain name on February 21, 2016.
4. Respondent’s resolving website at the disputed domain name is attempting to pass Respondent off as Complainant by impersonating it, and is being used to sell shoes and advertise a partnership that does not exist and to solicit personal information from internet users.
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 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 (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.”). The Panel will, however, take into account the contents of the email sent by Respondent to Complainant’s attorney referred to above.
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 both the marks being used in Respondent’s domain name. Complainant has registered the NIKE mark (Reg. No. 978,952, Registered Feb. 19, 1974) and the GOOGLE mark (Reg. No. 2,954,071, Registered May 24, 2005) with the USPTO. See Compl., at Attached Ex. D; see also Compl., at Attached Ex. M. Panels have held that a Complainant’s registration of a mark with the USPTO confers rights in such mark per Policy ¶ 4(a)(i). See Trip Network Inc. v. Alviera, FA 914943 (Forum Mar. 27, 2007) (determining that the complainant’s trademark registrations with the USPTO for the CHEAPTICKETS and CHEAPTICKETS.COM marks were adequate to establish its rights in the mark pursuant to Policy ¶ 4(a)(i)); see also BGK Trademark Holdings, LLC & Beyoncé Giselle Knowles-Carter v. Chanphut / Beyonce Shop, FA 1626334 (Forum Aug. 3, 2015) (asserting that Complainant’s registration with the USPTO (or any other governmental authority) adequately proves its rights under Policy ¶ 4(a)(i).). Thus the Panel finds that Complainant has sufficiently demonstrated rights in both the NIKE and GOOGLE marks.
The next question that arises is whether the disputed domain name is identical or confusingly similar to Complainant’s NIKE and GOOGLE marks. Complainant submits that Respondent’s domain name <nikegoogle.com> is confusingly similar to the marks in which Complainant collectively has rights. Complainant contends that Respondent’s domain name merely combines the NIKE and GOOGLE marks while adding the gTLD identifer “.com” at the end. Prior panels have found that a combination of marks plus a gTLD suffix does not sufficiently distinguish a respondent’s domain name from marks to which a complainant has rights. See Textron Innovations Inc. v. Sheng Liang / Sarawina, FA 1622906 (Forum July 20, 2015) (finding confusing similarity under Policy ¶ 4(a)(i) where Respondent’s <greenleetextron.com> domain name merely combined Complainant’s TEXTRON and GREENLEE marks and added the “.com” generic top-level domain suffix.). As well as that general proposition, it is clear that an objective bystander would conclude that the disputed domain name, by referring to both trademarks and nothing else, is invoking both trademarks and the goods and services provided by the owners of those trademarks. Therefore the Panel agrees with Complainant’s submission that Respondent’s domain name is confusingly similar to the NIKE and GOOGLE marks under Policy ¶ 4(a)(i).
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), and then the burden shifts to Respondent to show it does have rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Entm’t Commentaries, FA 741828 (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 (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.”).
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 NIKE and GOOGLE
marks and to use them in their entirety in the disputed domain name;
(b) Respondent registered the disputed domain name on February 21, 2016;
(c) Respondent has used the disputed domain name to resolve to a website that seeks to impersonate Complainant and offers to sell a shoe and advertise a partnership that does not exist;
(d) Complainant specifically argues that Respondent does not have any rights or legitimate interest in the <nikegoogle.com> domain name because it, Complainant, has not licensed or granted any permission for Respondent to use the NIKE and GOOGLE marks, and further that Respondent is not commonly known by the disputed domain name. The Panel notes the WHOIS information for the domain name lists “Mattia Lumini” as the registrant, and Respondent’s organization as “Yykk Snc.” See Compl., at Attached Ex. A. Panels have used WHOIS information to conclude that a respondent is not known by a disputed domain name when there is a lack of evidence to support the contrary. See Instron Corp. v. Kaner, FA 768859 (Forum Sept. 21, 2006) (finding that the respondent was not commonly known by the disputed domain names because the WHOIS information listed “Andrew Kaner c/o Electromatic a/k/a Electromatic Equip't” as the registrant and there was no other evidence in the record to suggest that the respondent was commonly known by the domain names in dispute). In the present case, there is no such evidence. As such, the Panel finds that Respondent is not commonly known by the disputed domain name pursuant to Policy ¶ 4(c)(ii);
(e) Complainant submits that Respondent is not making a bona fide offering of goods and services or making a legitimate noncommercial or fair use of the <nikegoogle.com> domain name. Complainant submits that the resolving website at Respondent’s domain name purports to impersonate it by advertising a shoe and partnership that do not exist. The website offers a high-end NIKE shoe with GOOGLE branding and coloration, and has links that redirect to Complainant’s own websites. See Compl., at Attached Ex. N. When a respondent is using a domain name to sell a complainant’s products, panels have found it is not a bona fide offering of goods or services or a legitimate noncommercial or fair use under Policy ¶ 4(c)(i) or (iii). See Fadal Engineering, LLC v. Strizich, FA 1581942 (Forum Nov. 13, 2014) (finding that Respondent’s use of the disputed domain to sell products related to Complainant without authorization “does not amount to 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).”). Panels have also found that an intention to divert or deceive Internet users by using their marks does not constitute a bona fide offering of goods and services or a legitimate noncommercial or fair use. See Summit Group, LLC v. LSO, Ltd., FA 758981 (Forum Sept. 14, 2006) (finding that the respondent’s use of the complainant’s LIFESTYLE LOUNGE mark to redirect Internet users to respondent’s own website for commercial gain does not constitute either 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)). Thus the Panel agrees with Complainant’s submission that Respondent’s use of the <nikegoogle.com> domain does not fall within the parameters of Policy ¶ 4(c)(i) or (iii).
All of these matters go to make out the prima facie case against Respondent. Respondent has not filed a Response to rebut that prima facie case, but it has sent to Complainant’s attorney an email dated April 11, 2016 that presents its case. It therefore has to be resolved whether the contents of that email rebut the prima facie case.
The email says in substance that Respondent registered the domain name for “educational purposes”, explains how that is manifested and offers Complainant the opportunity to purchase the “intellectual property of my work” for $15,000.
The Panel does not accept this explanation as a justification in any way for using Complainant’s trademarks in its domain name and using the domain name in the way it has. In the first place, as Complainant points out, the assertion that this was done for educational purposes is unsubstantiated. Moreover, there is nothing to suggest that the educational purposes were for profit or otherwise. Respondent’s email has a link to Respondent’s own website at www.luminimattia.com which shows clearly that Respondent is conducting a commercial business. It contains the sentence “I'm now selling with Pay Pal as certified seller with VISA and MASTERCARD circuit, so you won't have any kind of trouble in making payments.” The website also carries buttons for Visa and Mastercard and other information on payment. The website to which the disputed domain name resolves contains, or at least contained when Exhibit N was prepared, illustrations and other information that purport to offer Complainant’s products for sale (although it is not clear if the specified mode of purchase was active) and invites internet users to provide their names and email addresses. The total effect of the website is that it purports to be commercial and there is no indication that the presentation has been prepared for educational purposes alone. Moreover, the offer to sell the “ intellectual property of my work”, which must include the domain name, for $15,000 sits uncomfortably with the claim that the whole process was designed for educational purposes. The Panel concludes from an examination of the resolving website and the email that they do not support Respondent’s contentions. The Panel therefore finds on the balance of probabilities that the intention of Respondent in registering the domain name and using it in the way that Respondent has used it and the intention in creating the website to which it resolved was to give the false impression that they were affiliated in some way with Complainant and its collective businesses, confuse and mislead internet users, sell the domain name to Complainant and extract money from Complainant in doing so.
Respondent has therefore not rebutted the prima facie case against it and the Panel finds that Respondent has no rights or legitimate interests in the disputed domain name.
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 name was registered in bad faith and has 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 name was registered and used in bad faith. That is so for the following reasons. First,
Complainant contends that Respondent has registered and is using the disputed domain name in bad faith. Complainant submits that Respondent offered to sell the <nikegoogle.com> domain name to it for $15,000, and submitted the offer into evidence. See Compl., at Attached Ex. P. When a respondent offers to sell a disputed domain name to a complainant trademark owner in excess of its out-of-pocket costs, panels have found bad faith under Policy ¶ 4(b)(i). See Campmor, Inc. v. GearPro.com, FA 197972 (Forum Nov. 5, 2003) (“Respondent registered the disputed domain name and offered to sell it to Complainant for $10,600. This demonstrates bad faith registration and use pursuant to Policy ¶ 4(b)(i).”). Thus the Panel finds Respondent has acted in bad faith under Policy ¶ 4(b)(i).
Secondly, Complainant submits that Respondent has engaged in a pattern of bad faith registration under Policy ¶ 4(b)(ii). Complainant submitted WHOIS information for several domain names that Respondent owns as evidence that Respondent has a pattern of cybersquatting on many other famous marks such as BMW, FOX, BRAUN, and CALVIN KLEIN. See Compl., at Attached Ex. O. Previous panels have found a pattern of bad faith registration based on registration of many domain names that include famous third-party marks. See Hachette Filipacchi Presse v. Fortune Int'l Dev., FA 96685 (Forum Apr. 6, 2001) (finding that where the respondent has registered over 50 domain names that correspond to different well-known trademarks, evidence of a pattern exists). Therefore the Panel agrees with Complainant’s submission that Respondent has engaged in a pattern of bad faith registration under Policy ¶ 4(b)(ii).
Thirdly, Complainant argues that Respondent is intentionally trying to create a likelihood of confusion with Complainant’s NIKE and GOOGLE marks as to the source, sponsorship, affiliation, or endorsement of its <nikegoogle.com> domain name. Complainant contends that Respondent is attempting to pass itself off as Complainant by using its registered marks in violation of Policy ¶ 4(b)(iv). Panels have found such passing off to violate the Policy. See Am. Online, Inc. v. Miles, FA 105890 (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.”). Complainant provides evidence of the alleged illegal use of their NIKE and GOOGLE marks on the Respondent’s resolving website of the disputed domain name and that evidence has already been mentioned. Complainant argues that Respondent presumably commercially gains from its offers to sell products and the Panel draws that inference. See Compl., at Attached Ex. N. Panels have also found bad faith where the respondent creates confusion by offering to sell complainant’s products. See Fanuc Ltd v. Mach. Control Servs., FA 93667 (Forum Mar. 13, 2000) (finding that the respondent violated Policy ¶ 4(b)(iv) by creating a likelihood of confusion with the complainant's mark by using a domain name identical to the complainant’s mark to sell the complainant’s products). The Panel thus finds Respondent has registered and used the disputed domain name in bad faith under Policy ¶ 4(b)(iv).
Fourthly, Complainant argues that Respondent had actual notice of Complainants rights in both the NIKE and GOOGLE marks when it registered the disputed <nikegoogle.com> domain name. Complainant submits that the NIKE mark has acquired worldwide fame and that it has been using the mark since 1971. Complainant also asserts that the GOOGLE mark has been used since 1997 and that the mark has reached worldwide fame due to its many affiliates and presence as one of the top websites on the internet for traffic. Although the UDRP does not recognize constructive notice as sufficient grounds for establishing bad faith, panels have found an inference of actual notice when the complainant’s mark is famous. See Google Inc. v. Ahmed Humood, FA1411001591796 (Forum Jan. 7, 2015) (“This Panel makes that inference; Respondent has actual knowledge of Complainant’s mark at the time of domain name registration based on the fame of Complainant’s GOOGLE mark and Respondent’s use of one of the disputed domain names to detail Internet domain name registration and maintenance services related to an in competition with Complainant.”). Therefore the Panel finds Respondent had actual notice of Complainant’s respective rights in the famous NIKE and GOOGLE marks and to be in bad faith under Policy ¶ 4(a)(iii).
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 name using the NIKE and GOOGLE marks and its use of the domain name since registration, Respondent registered and used the disputed domain name 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. In that regard, the Panel notes that Complainant Nike Inc. has, with the consent of Complainant Google Inc., requested that the disputed domain name be transferred to Complainant Nike Inc.
Accordingly, it is Ordered that the <nikegoogle.com> domain name be TRANSFERRED from Respondent to Complainant Nike Inc.
The Honourable Neil Anthony Brown QC
Panelist
Dated: September 20, 2016
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