Intercontinental Exchange Holdings, Inc. v. Lord Oxford
Claim Number: FA1810001812100
Complainant is Intercontinental Exchange Holdings, Inc. (“Complainant”), represented by Paul A. Taufer of DLA Piper LLP, Pennsylvania, USA. Respondent is Lord Oxford (“Respondent”), Australia.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue which are registered with NameCheap, Inc. are <theice.blue>, <theice.cash>, <theice.site>, <theice.website>, <theice.fun>, <nyse.fun>, <theice.market>, <theice.ltd>, <theice.news>, <theice.fund>, <theice.fail>, <theice.international>, <theice.money>, <theice.express>, <theice.exchange>, <theice.press>, <theicethieves.site>, and <nodice.website>. The other domain name at issue, <theice.london>, is registered with Uniregistrar Corp.
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.
Steven M. Levy, Esq. as Panelist.
Complainant submitted a Complaint to the Forum electronically on October 16, 2018; the Forum received payment on October 17, 2018.
On October 19, 2018, NameCheap, Inc.; Uniregistrar Corp confirmed by e-mail to the Forum that the <theice.blue>, <theice.cash>, <theice.site>, <theice.website>, <theice.fun>, <nyse.fun>, <theice.market>, <theice.ltd>, <theice.news>, <theice.fund>, <theice.fail>, <theice.international>, <theice.money>, <theice.express>, <theice.exchange>, <theice.press>, <theicethieves.site>, and <nodice.website> domain names are registered with NameCheap, Inc. and that the <theice.london> domain name is registered with Uniregistrar Corp, and that Respondent is the current registrant of the names. NameCheap, Inc. and Uniregistrar Corp have verified that Respondent is bound by the NameCheap, Inc. and Uniregistrar Corp registration agreements 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 October 25, 2018, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of November 14, 2018 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@theice.blue, postmaster@theice.cash, postmaster@theice.site, postmaster@theice.website, postmaster@theice.fun, postmaster@nyse.fun, postmaster@theice.market, postmaster@theice.london, postmaster@theice.ltd, postmaster@theice.news, postmaster@theice.fund, postmaster@theice.fail, postmaster@theice.international, postmaster@theice.money, postmaster@theice.express, postmaster@theice.exchange, postmaster@theice.press, postmaster@theicethieves.site, and postmaster@nodice.website. Also on October 25, 2018, 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 November 17, 2018, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the Forum appointed Steven M. Levy, Esq. 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.
A. Complainant
Complainant operates the leading global electronic marketplace for trading futures, over-the-counter energy contracts and other financial instruments. Complainant offers a wide range of financial products and services, and collects over $3 billion in annual revenues. Complainant has rights in the trademarks ICE (e.g., Reg. No. 2,530,330, registered Jan. 15, 2002) and NYSE (e.g., Reg. No. 909,350, registered Mar. 2, 1971) marks based upon its registration of the marks with the United States Patent and Trademark Office (“USPTO”). Complainant also has rights in the trademark THE ICE based upon its registration of the mark with the European Union Intellectual Property Office (“EUIPO”) (e.g., Reg. No. 909,350, registered Mar. 2, 1971). Each of Respondent’s domain names is confusingly similar to one of the Complainant’s marks as it wholly incorporates the mark and merely adds a generic or descriptive term as a top-level domain (“TLD”).
Respondent has no rights or legitimate interests in the disputed domain names. Respondent is not commonly known by the disputed domain names, nor has Complainant authorized, licensed, or otherwise permitted Respondent to use the trademarks. Respondent also does not use the domain names in connection with a bona fide offering of goods or services or legitimate noncommercial or fair use. Rather, Respondent uses the domain names to post disparaging, vitriolic, and often rambling comments criticizing the Complainant and its legal representatives for not purchasing the domain names from the Respondent, as well as to post other defamatory and anti-Semitic content.
Respondent registered and uses the disputed domain names in bad faith. On February 27, 2018 Complainant’s counsel sent a demand letter to the Respondent seeking transfer of those four of the domain names that existed at that time. On March 5, 2018, Respondent replied to this letter asking “Are you authorized to Purchase” and stating, among other things, “Please state clearly which domain you want. the price for a good domain name is $10K”. That same day, Complainant’s counsel, named Richard Cruz, wrote to Respondent again stating that the mentioned domain names infringe upon Complainant’s trademark rights and that “our client is not interested in purchasing any of your domains. Instead, you are being asked to relinquish the subject domains voluntarily, in order to resolve this matter without the need for formal legal proceedings.” On March 19, 2018, Respondent replied to counsel addressing him as “Richard the Crud” and stating, in part, “you need some time in prison”, “complaints have been filed with your boss … and with London Metropolitan Police”, and “YOU DO NOT HAVE free passage to steal from deceive and cheat old age pensioners, the sick, and Children – even though ‘we’re easy meat’ for your predatory practice”, and “Shame shame shame on you and all that employ or deal with you, Nazi…… minded person.” On April 6, 2018, Complainant’s counsel sent a further letter to Respondent noting that fourteen additional domain names had been registered that incorporate the ICE, THE ICE, or NYSE trademarks and demanding transfer of those names as well. In response, on April 18, 2018, Respondent replied referring to the “’Dick’ ‘s Crud Nazi-like letter” and mentioning the registrar for the domain names “who actually pulled the switch to castrate my global operations a sadistic Judas there enjoyed taking down a street peasant who failed to bow low enough, quick enough – vinglorious, uncaring for others.” However, Respondent went on to say “I am not unwilling to sell one or many of the extensive domain collection” and then noted “Please tell me which domain you want to purchase normal Purchase price is $10,000. THEFT PRICE is prison time. plus Pillory and Lampoon…”
Finally, Respondent has engaged in a pattern of bad faith registration and has been involved in many prior UDRP proceedings resulting in adverse decisions. Additionally, Respondent uses the domain names to intentionally attract Internet users to its websites by creating a likelihood of confusion with Complainant's marks as to the source, sponsorship, affiliation, or endorsement of the disparaging comments displayed on the resolving domains. Such use disrupts Complainant’s business and is designed to attract Complainant’s attention for the purpose of selling the domains to Complainant. Finally, Respondent clearly registered the domain names with actual knowledge of Complainant’s rights in the marks given the substantial fame the marks have achieved throughout Complainant’s use of the marks in commerce.
B. Respondent
Respondent failed to submit a Response in this proceeding.
(1) each of the domain names registered by Respondent is confusingly similar to a trademark in which Complainant has rights;
(2) Respondent has no rights to or legitimate interests in respect of the domain names; and
(3) the same domain names were registered and are being used by Respondent 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 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.”).
Complainant claims rights in the trademarks ICE and NYSE based upon its registration of such marks with the USPTO, the EUIPO, and other national trademark registration authorities. Registration of a mark with a governmental authority – regardless of location – sufficiently confers a complainant’s rights in a mark for the purposes of Policy ¶ 4(a)(i). See Viber Media S.à r.l. v. Kristaps Sirmais / SIA "FUN FACTORY", FA 1626671 (Forum Aug. 4, 2015) (“Accordingly, even though Respondent reportedly resides in Latvia, the Panel finds find that Complainant’s USPTO registration is sufficient under Policy ¶ 4(a)(i).”) Accordingly, the Panel finds that Complainant has established rights in the ICE, THE ICE, and NYSE marks for the purposes of Policy ¶ 4(a)(i).
Complainant next argues that Respondent’s disputed domain names are identical or confusingly similar to Complainant’s marks as each of them wholly incorporates one of Complainant’s marks and merely adds a generic or descriptive term as a top-level domain (“TLD”). The Panel notes that the <theicethieves.site> domain name also adds the term “thieves” to THE ICE mark. Similar changes in a registered mark have failed to sufficiently distinguish a domain name for the purposes of Policy ¶ 4(a)(i). See Bloomberg Finance L.P. v. Sunny Bhadauria, FA 1786429 (Forum June 7, 2018) (finding the <bloombergquint.org> domain name to be confusingly similar to the complainant’s BLOOMBERG mark, as the name consists of the mark, the added term “quint” (which refers to the complainant’s Indian business partner “Quintillian Media”) and the gTLD “.org”); see also Microsoft Corporation v. Thong Tran Thanh, FA 1653187 (Forum Jan. 21, 2016) (determining that confusing similarity exists where [a disputed domain name] contains Complainant’s entire mark and differs only by the addition of a generic or descriptive phrase and top-level domain, the differences between the domain name and its contained trademark are insufficient to differentiate one from the other for the purposes of the Policy). With respect to the <nodice.website> domain name, Complainant claims that this merely adds the generic word “nod” to its ICE mark. In the abstract this claim would have seemed odd to this Panel as there does not appear to be a natural relation between the words “nod” and “ice” and the full domain could be viewed as spelling out the common phrase “no dice”. However, as the Respondent clearly appears to be targeting the Complainant’s trademarks, as discussed more fully below in this decision, the Panel concludes that the <nodice.website> domain is confusingly similar to the ICE trademark as such confusion seems to have been the precise intent of the Respondent. This same rationale also applies to the abovementioned <theicethieves.site> domain name.
In light of the above, the Panel finds that each of the disputed domain names is either identical or confusingly similar to Complainant’s ICE, THE ICE, or NYSE trademarks under the threshold standard of Policy ¶ 4(a)(i).
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). Should it succeed in that effort, the burden then shifts to Respondent to show that 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”).
Complainant first contends that Respondent has no rights or legitimate interests in the disputed domain names as it is not commonly known by any of such names. Policy ¶ 4(c)(ii). Where, as here, a response is lacking, relevant information such as the WHOIS and any other evidence and assertions submitted by a complainant, including its lack of a relationship with a respondent, may be considered. See Braun Corp. v. Loney, FA 699652 (Forum July 7, 2006) (concluding that the respondent was not commonly known by the disputed domain names where the WHOIS information, as well as all other information in the record, gave no indication that the respondent was commonly known by the domain names, and the complainant had not authorized the respondent to register a domain name containing its registered mark). The relevant WHOIS records identify “Lord Oxford (also known as David Seagle)” as the registrant for all of the disputed domain names. Complainant asserts that no evidence exists to show that Respondent has ever been legitimately known by the ICE, THE ICE, and NYSE marks and that it has never authorized the Respondent to use such marks. Further, in correspondence between the parties the Respondent has identified himself by the name “Lord Oxford” or simply “Oxford”. Accordingly, the Panel agrees that Respondent is not commonly known by the at-issue domain names under Policy ¶ 4(c)(ii).
Next, Complainant avers that Respondent uses the domain names to post disparaging, vitriolic comments criticizing the Complainant and its legal representatives for not purchasing the domain names from the Respondent, as well as to post other defamatory and anti-Semitic content. Complainant provides screenshots of the resolving webpages associated with the disputed domain names, all of which appear to contain rambling, disparaging content associating Complainant with Nazis and criminal activity. It is important, at this point, to note that some of the disputed domain names were created earlier than others. The domains <theice.blue>, <theice.cash>, <theice.site>, and <theice.website> were created between February 5, 2018 and February 6, 2018. The remaining disputed domain names were created between March 6, 2018 and April 1, 2018. This is of particular relevance as the parties engaged in an initial round of correspondence starting with a February 27, 2018 demand letter from Complainant’s counsel seeking transfer of those four of the disputed domain names that existed at that time. In a March 5, 2018 reply from Respondent, he states “Please state clearly which domain you want. the price for a good domain name is $10K”. However, all of Complainant’s screenshots showing the disparaging and defamatory content appear to have been captured either on April 5, 2018 or June 2, 2018 and the Panel’s independent attempt to review earlier images of the disputed domain name websites at the Archive.org (the Wayback Machine) site does not reveal any screenshots prior to that time. Thus, the evidence in this case indicates that the complained-of content only appeared on the disputed domain websites after the initial round of correspondence between the parties. This is a strategy the Respondent has used before. See Travellers Exchange Corporation Limited v. WhoisGuard, Inc. / Lord Oxford, D2018-1523 (WIPO August 24, 2018) (“Prior to the Complainant’s February 2nd letter, neither the original disputed names nor the present disputed domain names resolved to any operational websites. Shortly after the Respondent received that letter … [the domains resolved to] corresponding websites which all provided the same content through a single web page on each site…. Some of that content is directed against the Complainant and bankers in general….”) As such, the Panel will infer that those of the disputed domain names which existed prior to March 6, 2018 contained no content or otherwise were not being used by the Respondent.
With respect to the four pre-March 6th domain names (i.e., <theice.blue>, <theice.cash>, <theice.site>, and <theice.website>) Respondent’s non-use of these names may be evidence that it fails to use the disputed domain names in connection with a bona fide offering of goods and services or a noncommercial or fair use per Policy ¶ 4(a)(ii). See Guess? IP Holder L.P. and Guess?, Inc. v. xi long chen, FA 1786533 (Forum June 15, 2018) (“The disputed domain name resolves to a parked page with the message, ‘website coming soon!’ The Panel finds that this use does not amount to a bona fide offering of goods or services or a legitimate noncommercial or fair use per Policy ¶¶ 4(c)(i) & (iii) and Respondent does not have rights or legitimate interests with respect of the domain name.”). Consequently, the Panel finds that Respondent failed to actively use the pre-March 6th domain names before being put on notice of the present dispute and that it has no rights or legitimate interests in the names under Policy ¶ 4(a)(ii).
With respect to the additional disputed domain names, those created between March 6, 2018 and April 1, 2018, the evidence indicates that Respondent created them specifically to antagonize the Complainant and its legal counsel and to gain negotiating leverage in its effort to sell the disputed domains to the Complainant. On April 6, 2018 Complainant’s counsel sent another demand letter to Respondent identifying the additional domain names and, on April 18, 2018, Respondent replied saying “Please tell me which domain name you want to purchase. Normal purchase price is $10,000.” Even given the possibility that the content at these additional websites might otherwise be considered non-commercial content or fair use criticism, the timing of the domain registrations by Respondent – after being placed on notice of a dispute with the Complainant – and their being offered for sale to the Complainant indicates Respondent’s true commercial aspiration for the domain names thus removing them from the sphere of bona fide or fair use under Policy ¶¶ 4(c)(i) and/or (iii). Thus, the critical content of the websites appears to be a contrived pretext for trying to sell the domain names and so it is neither noncommercial nor reflective of fair use. As recognized by prior UDRP Panels, this is not the first time the Respondent has employed the identical strategy of registering domain names that copy a well-known trademark, attempting to sell the domains to the trademark owner after receiving a demand letter, and subsequently posting rambling, contrived content that is disparaging to the brand owner and its legal counsel. For example, in Travellers Exchange Corporation Limited v. WhoisGuard, Inc. / Lord Oxford, supra, the Panel noted that “the overall current content of each of the Respondent’s corresponding websites resolvable through a corresponding [sic] one of the twelve present disputed domain names is merely a pretext contrived to provide a superficial, though mistaken, veneer of legitimacy to disguise the Respondent’s true goal of exploiting the present disputed domain names for its own pecuniary gain…” Respondent’s credibility was also questioned by the Panel in Commonwealth Bank of Australia v. WhoisGuard Protected, WhoisGuard, Inc. / Lord Oxford, D2018-0769 (WIPO, May 29, 2018), who stated “[t]he Panel further finds the Respondent’s assertion that the planned use of the disputed domain names is in respect of a website concerning Israel’s West Bank dispute, an assertion wholly unsupported by any evidence, incredible. The Panel is also, incidentally, unable to discern how the disputed domain names are said to be spoonerisms.”
Upon consideration of all of the evidence presented in this case, the Panel concludes that Respondent has no rights or legitimate interests in the disputed domain names under Policy ¶ 4(a)(ii).
Complainant argues that Respondent had actual knowledge of Complainant’s rights in the ICE, THE ICE, and NYSE trademarks at the time it registered the disputed domain names. Actual knowledge of a complainant's rights in a mark prior to registering a confusingly similar domain name can evince bad faith under Policy ¶ 4(a)(iii). See Univision Comm'cns Inc. v. Norte, FA 1000079 (Forum Aug. 16, 2007) (rejecting the respondent's contention that it did not register the disputed domain name in bad faith since the panel found that the respondent had knowledge of the complainant's rights in the UNIVISION mark when registering the disputed domain name). Complainant contends that Respondent clearly registered the domain names with knowledge of Complainant’s rights in the marks given the substantial fame the marks have enjoyed as a result of Complainant’s longstanding and global use of the marks in commerce. With regard to the NYSE mark, it is used in relation to the world’s largest stock market exchange and prior Panel decisions have recognized that the acronym NYSE has acquired distinctiveness and renown around the world. See, e.g., NYSE Group, Inc. v. Dehai Yu, D2013-1670 (WIPO November 20, 2013) (“There is a risk of association between the Complainant’s well-known trademark NYSE, and the disputed [nyse-asia.com] domain name and site products.”); NYSE Group, Inc. and LIFFE Administration and Management v. Joseph Perry, D2009-0166 (WIPO March 22, 2009) (“The Complainants submitted evidence, which show that the Complainants' trademarks NYSE and LIFFE were registered and are well known in the securities exchange and related stock market services; and that their trademarks are well recognized publicly.”) With respect to the ICE and THE ICE marks, Complainant points out that it is the only exchange operator ranked as a Fortune 500 company and, that in 2017 it was named to the Fortune Future 50 determining the top 50 companies that are best positioned to adapt and deliver growth in a complex environment. Furthermore, as noted below, the Respondent has had a number of prior adverse UDRP decisions against it (some relating to trademarks in the financial services industry) thus indicating that it is familiar with leveraging well-known trademarks to its advantage. On a balance of probabilities, the Panel finds that Respondent did have actual knowledge of Complainant’s marks, which provides a foundation upon which to support a case for bad faith under Policy ¶ 4(a)(iii).
Next, Complainant claims that Respondent replied to both of Complainant’s cease and desist letters by offering to sell each domain name for $10,000. Offering a domain name, that is confusingly similar to a well-known trademark, for sale at a very high price can evince bad faith under the Policy. See George Weston Bakeries Inc. v. McBroom, FA 933276 (Forum Apr. 25, 2007) (concluding that the respondent registered and was using the <gwbakeries.mobi> domain name in bad faith according to Policy ¶ 4(b)(i) where it offered it for sale for far more than its estimated out-of-pocket costs it incurred in initially registering the disputed domain name). Complainant provides copies of its correspondence with the Respondent which does show Respondent offering to sell each domain name for “$10k” or “$10,000”. As such, the Panel finds Respondent’s offering of the domain names for sale directly to the Complainant is evidence of bad faith under Policy ¶ 4(b)(i).
Complainant contends that Respondent’s registering the disputed domain names in bad faith is further evidenced by its having engaged in a pattern of cybersquatting conduct. The registration of multiple confusingly similar domain names incorporating a complainants mark, along with evidence of prior adverse UDRP decisions against a respondent, can demonstrate bad faith registration. See Philip Morris USA Inc. v. RapidClic / VAUCLIN Olivier, FA1309001520008 (Forum November 7, 2013) (finding that the respondent’s registration of multiple infringing domain names indicates a pattern of bad faith registration and use under Policy ¶ 4(b)(ii)); see also Fandango, LLC v. 21562719 Ont Ltd, FA1209001464081 (Forum November 2, 2012) (“Respondent’s past conduct and UDRP history establishes a pattern of registered domain names in bad faith under Policy ¶ 4(b)(ii).”) Here, Respondent registered nineteen domain names that incorporate one or more of Complainant’s marks. Further, Respondent, operating under different aliases, has previously been involved as a respondent in at least ten prior UDRP and URS proceedings resulting from abusive registration of domain names that included third-party marks or confusingly similar variants thereof. See, e.g., Deutsche Lufthansa AG v. Lord Oxford, FA 1728149 (Forum May 8, 2017) (domains <lufthansa.click> and <staralliance.link> ordered suspended); Travellers Exchange Corporation Limited v. WhoisGuard, Inc. / Lord Oxford, supra. (twelve domain names that copy the Complainant’s TRAVELEX trademark ordered transferred); Commonwealth Bank of Australia v. WhoisGuard Protected, WhoisGuard, Inc. / Lord Oxford, supra. (<bankwest.site> and <bankwest.website> ordered transferred). The Panel agrees that Respondent’s prior adverse UDPR decisions combined with its registration of nineteen disputed domain names in the present case further evinces bad faith registration under Policy ¶ 4(b)(ii) in that it has engaged in a pattern of conduct to prevent the Complainant from reflecting its ICE, THE ICE, and NYSE trademarks in corresponding domain names of the affected TLDs.
Upon consideration of all of the evidence presented in this case, the Panel concludes that Respondent has registered and used the disputed domain names in bad faith under Policy ¶ 4(a)(iii).
Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <theice.blue>, <theice.cash>, <theice.site>, <theice.website>, <theice.fun>, <nyse.fun>, <theice.market>, <theice.london>, <theice.ltd>, <theice.news>, <theice.fund>, <theice.fail>, <theice.international>, <theice.money>, <theice.express>, <theice.exchange>, <theice.press>, <theicethieves.site>, and <nodice.website> domain names be TRANSFERRED from Respondent to Complainant.
Steven M. Levy, Esq., Panelist
Dated: November 21, 2018
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