DECISION

 

Heard Design, LLC v. dfgtyisd aerya / wu jianliu / TADANBANG TADANBANG / Patricia Stryker / Perisolution / millie mike / milliemike

Claim Number: FA2310002065011

PARTIES

Complainant is Heard Design, LLC ("Complainant"), represented by Alison Davis Frey of Law Office of Alison Frey, PC, Texas, USA. Respondent is dfgtyisd aerya / wu jianliu / TADANBANG TADANBANG / Patricia Stryker / Perisolution / millie mike / milliemike ("Respondent"), International.

 

REGISTRAR AND DISPUTED DOMAIN NAMES 

The domain names at issue are <howlerbros.club>, <howlerbross.com>, <howlerbross.top>, <howlerbros.life>, <howlerbrothers.top>, <howlerbros-us.top> and <howlerbrosonline.store>, registered with Namesilo, Llc, Aceville Pte. Ltd., and Hongkong Kouming International Limited.

 

PANEL

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 Honorable Neil Anthony Brown KC as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on October 5, 2023; Forum received payment on October 5, 2023.

 

On October 5, 2023, October 6, 2023 and October 16, 2023, Namesilo, Llc, Aceville Pte. Ltd., and Hongkong Kouming International Limited confirmed by e-mail to Forum that the <howlerbros.club>, <howlerbross.com>, <howlerbross.top>, <howlerbros.life>, <howlerbrothers.top>, <howlerbros-us.top> and <howlerbrosonline.store> domain names are registered with Namesilo, Llc, Aceville Pte. Ltd., and Hongkong Kouming International Limited and that Respondent is the current registrant of the names. Namesilo, Llc, Aceville Pte. Ltd., and Hongkong Kouming International Limited have verified that Respondent is bound by the Namesilo, Llc, Aceville Pte. Ltd., and Hongkong Kouming International Limited 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") and the Rules for Uniform Domain Name Dispute Resolution Policy ( "the Rules".

 

On October 23, 2023, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of November 13, 2023 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@howlerbros.club, postmaster@howlerbross.com, postmaster@howlerbross.top, postmaster@howlerbros.life, postmaster@howlerbrothers.top, postmaster@howlerbros-us.top, postmaster@howlerbrosonline.store. Also on October 23, 2023, 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, Forum transmitted to the parties a Notification of Respondent Default.

 

On November 14, 2023, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed The Honorable Neil Anthony Brown KC as Panelist.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of 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.

 

RELIEF SOUGHT

Complainant requests that the domain names be transferred from Respondent to Complainant.

 

PRELIMINARY ISSUES: MULTIPLE RESPONDENTS

In the instant proceedings, Complainant has submitted that the entities which control the domain names at issue are effectively controlled by the same person and/or entity, which is operating under several aliases. Paragraph 3(c) of the Rules provides that a "complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder." The issue is therefore whether the different nominal registrants of the disputed domain names are in reality the same domain name holder.  The Complainant says that they are the same domain name holder. It supports its contention in the following manner.

 

The Complainant contends that the Respondent is the same in all seven cases. Complainant maintains that all the information provided by the Respondents when registering the Infringing Domain Names is fraudulent as it does not appear to be legitimate contact information. The information provided is said to be nonsensical and/or incomplete for each domain name registration. Even the addresses that appear to be legitimate cannot be verified online or using a mapping application.

 

Also, given that the same content appears at all seven domain names (See Exhibits E, F, G, H, I, I2 and I3) and that the domain names were registered at roughly the same time, they can be presumed to be controlled by the same person or entity even though the respective contact information may differ.

 

Moreover, there are additional overlapping facts about the registrations. Many of them share additional common attributes, such as the registrar, privacy service, and/or server. In most cases, the sites were located on a Cloudflare server, probably hosted by the same service. In five of the cases the registrar is the same, as was the privacy service originally used for the registration. In all cases, the content was copied from Complainant's official website.

 

In addition, the content of the resolving websites is identical or nearly identical to the content found on the websites to which other and related domain names, <howlerbrosshop.com>, <howlerbrosstore.com>, <howlerbrosoutlets.shop>, <outletshowlerbros.shop> and <howlerbros.xyz> resolve. These domain names were transferred to Complainant pursuant to an order in a separate UDRP proceeding .

 

Accordingly, it is said the disputed domain names in the present proceeding fit a pattern whereby the Respondent registers multiple domain names that are confusingly similar to Complainant's trademarks and places the same infringing content on all of them so that they can continue to display the fraudulent content somewhere despite successful takedown notices, abuse complaints and UDRP proceedings.

Accordingly, Complainant concludes that the registrant information should be treated as aliases and that the Respondent should be considered as one and the same for all seven domain name registrations that are the subject of the present Complaint.

 

The Panel agrees with the Complainant's contentions.

 

Having regard to all of those considerations and the whole of the evidence, the Panel therefore finds that the disputed domain names are commonly owned/controlled by a single Respondent who is using multiple aliases. The nominal Respondents are therefore the same domain name holder and the proceeding is clearly one that comes within Paragraph 3(c) of the Rules.

 

The proceeding may therefore go forward on that basis. For reasons of convenience, the Respondents will hereafter be referred to as "Respondent".

 

LANGUAGE OF THE PROCEEDING

Complainant requests that pursuant to UDRP Rule 11(a) this administrative proceeding should be conducted in the English language. Complainant makes this request in light of the fact that one of  the Registration Agreements to which the disputed domain names relate is expressed in the Chinese language which would normally be the language of the proceeding relating to that domain name but that, the Complainant submits, English is a more appropriate language in which to conduct that proceeding. Hence, as the Panel has held that all of the domain names were registered by the one domain name holder, it is appropriate that the proceeding as a whole be conducted in the English language, the language of the other registration agreements.

All relevant considerations should be taken into account in considering this issue. It is also established practice, when such a request is made under Rule 11 (a), to take Rules 10(b) and (c) into consideration to ensure fairness and justice to both parties.

In the present case, Complainant also relies on the ground that the domain names themselves are in English and that they have been used to resolve to website carrying advertisements for which the Respondent is responsible and which are in the English language. Moreover, the domain names are used for a website which purports to sell goods under the Complainant's trademark which is in English and at prices expressed in dollars. Also, the potential customers being targeted by the website would probably be English speakers in view of the English expressions widely used on the websites.

 

Applying those principles, and pursuant to UDRP Rule 11(a), the Panel finds that persuasive evidence has been adduced by Complainant to show that Respondent is conversant and proficient in the English language. The Panel agrees with the Complainant's observation that "If the Respondent can conduct business in English, then the Respondent can participate in a UDRP that is conducted in English." 

Having considering all of the circumstances, the Panel therefore finds that the proceeding should be conducted in the English language and it so orders.

 

PARTIES' CONTENTIONS

A. Complainant

     Complainant made the following contentions.

 

1.       The Complainant ("Howler" and "the Complainant") is a United States company engaged in the manufacture and sale of clothing and related goods and services and operating as Howler Brothers and Howler Bros.

 

2.       The Complainant has rights in the HOWLER BROS trademark registered in the name of the Complainant with the United States Patent and Trademark Office ("USPTO") on December 7, 2010, as Registration No. 3887944,  and other trademarks for HOWLER BROTHERS and similar trademarks registered with the USPTO and in other international jurisdictions, all prior to the registration of the disputed domain names (collectively "the HOWLER BROS trademarks").

 

3.       The Complainant is also the owner of the domain name <howlerbros.com> which it uses in its business as an official domain name and for its website.

 

4.       The Respondent registered the following domain names on the following dates respectively: <howlerbros.club>: September 8, 2023;  <howlerbross.com>: September 27, 2023; <howlerbross.top>: April 9, 2023; <howlerbros.life>: September 26, 2023; <howlerbrothers.top>:  September 26, 2023; <howlerbros-us.top>:  October 7, 2023; and <howlerbrosonline.store>: October 9, 2023 ("the disputed domain names").

 

5.       In so doing, the Respondent incorporated in each the disputed domain names one of the Complainant's constituent HOWLER BROS trademarks as defined without any authority so to do.

 

6.       The Respondent has never had and currently does not have any trademark or other rights entitling it to register or use any of the disputed domain names, is not commonly known by any of the domain names and is not making a legitimate non-commercial or fair use of any of the disputed domain names.

 

7.       Respondent has caused each of the disputed domain names to resolve to an imposter website which is: 

(a)       masquerading as Howler;

(a) in connection with a retail clothing website:

(b)       purporting to sell Howler clothing;

(c)       passing itself off as Howler;

(d)       displaying Howler's goods;

(e)       using Howler trademarks; and/or

(f)       incorporating on its website photographs and graphics copied from Howler's own website.

 

8.       To further its fraudulent and phishing activities, the Respondent has sought to cause confusion with the HOWLER BROS trademarks and siphon off internet traffic from the Complainant.

 

9.       In the course of doing so, the Respondent has obtained by deception customer and credit card information from prospective customers for fraudulent and illegal purposes and has engaged in other deceptive practices to entice internet users to part with that information with the intention of defrauding them.

 

10.       By reason of the matters aforesaid:

(a)        the disputed domain names are identical and/or confusingly similar to the Complainant's HOWLER BROS trademarks;

(b)        the Respondent has no rights or legitimate interests in the domain names; and

(c)        the domain names have been registered and used in bad faith.

 

11.       Accordingly, the disputed domain names should be transferred to the Complainant.

 

B. Respondent

    Respondent failed to submit a Response in this proceeding.

 

FINDINGS

1.       The Complainant ("Howler" and "the Complainant") is a United States company engaged in the manufacture and sale of clothing and related goods and services and operating as Howler Brothers and Howler Bros.

 

2.       The Complainant has established its rights in the HOWLER BROS trademark registered in the name of the Complainant with the United States Patent and Trademark Office ("USPTO") on December 7, 2010, as Registration No. 3887944, and other trademarks for HOWLER BROTHERS and similar trademarks registered with the USPTO and in other international jurisdictions, all prior to the registration of the disputed domain names ( collectively "the HOWLER BROS trademark").

 

3.       The Respondent registered the following domain names on the following dates respectively: <howlerbros.club>: September 8, 2023;  <howlerbross.com>: September 27, 2023; <howlerbross.top>: April 9, 2023; <howlerbros.life>: September 26, 2023; <howlerbrothers.top>:  September 26, 2023; <howlerbros-us.top>:  October 7, 2023; and <howlerbrosonline.store>: October 9, 2023 ("the disputed domain names").

 

4.       The Complainant acquired its rights in the HOWLER BROS trademark prior to the registration of the disputed domain names.

 

5.       The Respondent has incorporated the Complainant's HOWLER trademark in the disputed domain names without any authority to do so.

 

6.       Respondent has caused the disputed domain names to resolve to imposter websites, passing itself off as the Complainant, copying and duplicating the contents of Complainant's official website at <howlerbros.com> including Complainant's rights in the copyright content of its website copied by the Respondent.

 

7.       Respondent has also used the disputed domain names to engage in a fraudulent phishing scheme.

 

8.       By reason of the matters aforesaid, the Panel finds that disputed domain names are confusingly similar to the Complainant's HOWLER trademark, the Respondent has no rights or legitimate interests in the disputed domain names and the disputed domain names have been registered and used in bad faith.

 

9.       Accordingly, the disputed domain names should be transferred to the Complainant.

 

DISCUSSION

Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted and 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 the Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:

 

(1)       the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and

(2)       Respondent has no rights or legitimate interests in respect of the domain name; and

(3)       the domain name has been registered and is being used in bad faith.

 

In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules.  The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) ("Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint").

 

Identical and/or Confusingly Similar

The first question that arises is whether the Complainant has rights in a

trademark or service mark on which it may rely. The evidence shows that the Complainant has established its rights in the HOWLER BROS trademark registered in the name of the Complainant with the United States Patent and Trademark Office ("USPTO") on December 7, 2010, as Registration No. 3887944, and other trademarks for HOWLER BROTHERS and similar trademarks registered with the USPTO and in other international jurisdictions prior to the registration of the disputed domain names, namely the HOWLER BROS trademark.

 

The Complainant has adduced evidence of the foregoing registrations, which the Panel has examined and which it finds show that each of the trademarks has been validly registered. Registration of a trademark with a recognized authority such as the USPTO is sufficient to demonstrate rights in a mark under Policy ¶ 4(a)(i) and that the Complainant "has" a trademark, which is the element that it must prove and which it has established. Since the Complainant has registered and has established its rights in the HOWLER BROS trademark through its widespread registration and use of the mark, the Panel finds that the Complainant has rights in the HOWLER BROS trademark under Policy ¶ 4(a)(i).

 

The evidence also shows that each of the trademarks going to make up the HOWLER BROS trademarks was registered prior to the registration of the disputed domain names by the Respondent on the respective dates set out above in the Contentions section of this decision.

 

The next question that arises is whether the disputed domain names are identical or confusingly similar to Complainant's registered HOWLER BROS trademark. In that regard, the Complainant argues that:

 

(a)       the domain names <howlerbros.club> and <howlerbros.life> consist only of the term "howlerbros," which is visually and phonetically identical to the HOWLER BROS trademark without the space between "HOWLER" and "BROS";

(b)       the domain names <howlerbross.com> and <howlerbross.top> are also phonetically identical to the HOWLER BROS trademark without the space, are almost identical visually and that the only difference is an additional "s" on the end of the substantive part of the domain names;

(c)        the domain name <howlerbrothers.top> is phonetically and visually identical to the HOWLER BROTHERS trademark mark except for the space;

(d)        each of the domain names also has a Top Level Domain added, either .com, .club, .top, .store or .life. Prior UDRP Panels have routinely held that the addition of such a Top Level Domain to a trademark does not obviate the likelihood of confusion with the trademark in question. That is so because all domain names require a Top Level Domain and in the final analysis the question is whether the relevant domain names are identical or confusingly similar to the relevant trademark which in the present case they are.

 

The Panel agrees with the Complainant's submission in every respect because each domain name is similar to one or the other of the trademarks that constitute the HOWLER BROS trademark as defined and confusingly similar. Taken as a whole, each domain name means and would be interpreted by internet users to mean that it is invoking the Complainant, its HOWLER BROS trademark and its use by the Complainant or with the approval of the Complainant and that the Respondent is using it legitimately. It is therefore clear that the domain names are similar to the trademark and confusingly similar.

 

The Panel therefore finds that the Respondent's domain names are confusingly similar to the Complainant's HOWLER BROS trademark  under Policy ¶ 4(a)(i).

 

The Complainant has thus made out the first of the three elements that it must establish.

 

Rights or Legitimate Interests

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 names under Policy ¶ 4(a)(ii), then the burden shifts to Respondent to show it does have such 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)).

 

The Panel finds that Complainant has made out a prima facie case that arises from the following considerations:

 

        (a) The Respondent has chosen to take Complainant's HOWLER BROS   trademark and to use it in its respective domain names, making only the foregoing slight amendments which do not negate the confusing similarity between the domain names and the mark, and which generate the clear impression that they referring to and legitimately invoking the HOWLER BROS trademark and that the Respondent is authorized to do so, neither of which is true.

(b) The Respondent registered the disputed domain names on the respective dates set out above.

(c) The evidence shows that Respondent has caused the disputed domain names to resolve to imposter websites duplicating and copying the contents of the Complainant's official website at www.howlerbros.com, including the elements of its website copied by the Respondent and in which the Complainant clearly has copyright. This includes repeated used of the expression HOWLER; purporting falsely to assert that the goods and services offered are authentic and affiliated with the Complainant when they are not; and engaging by that means in conduct that is tantamount to misleading customers into believing that the goods are authentic HOWLER goods when they are not. By that means, the Respondent is impersonating and passing itself off as the Complainant and displaying, by means of extensive text and graphics, material of the same type as is displayed on the Complainant's own website and of which the Complainant clearly has copyright. The Complainant has supported its case by extensive references to its own genuine products and comparing them with the contents of the Respondent's website, showing an intention by the Respondent to copy the Complainant and its goods and services and the way in which those products are presented, to give the false impression that they are genuine HOWLER goods and services offered by the Complainant which they clearly are not.

(d) The evidence shows that the Respondent has used the disputed domain names to deceive the public, including the Complainant's customers and potential customers by providing false contact and other information.

(e) Thus, there is no evidence that the Respondent is making a bona fide offering of goods or services within the meaning of Policy ¶ 4(c)(i) and the evidence shows clearly that it is not.

(f) The Complainant has presented a detailed and persuasive evidentiary case that establishes all of the foregoing propositions. Notably, its Exhibits E, F ,G, H, I, 12 and 13 contain very strong evidence to that end. For example, Exhibit E, relating to <howlerbros.club>, depicts images of the Howler ambiance, look and feel, frequent use of the HOWLER trademark and logo, details of shirts, bottoms, hats, caps, outwear, hoodies, jackets, tops and accessories, HOWLER labels on the products, prices, provision for a cart for products purchased, scope for email and shipping addresses, invitations to log-in, logos of credit cards that may be used to purchase the products and a clock with a diminishing time during which a cart is "reserved" for customers. The Panel has examined the other Exhibits and it finds that they are to the same effect as Exhibit E and that there is no need to repeat the details of those Exhibits here. All of this is designed to give the impression that the goods for sale are genuine HOWLER goods being offered for sale by Howler itself when the evidence is that they are not. The evidence is also that the material advertised on the websites is of the same genre as that revealed in the prior UDRP decision Heard Design, LLC v. Rick Wittenbraker/ Howler Brothers/awdda dwadad/awdaadwd, FA2309002060489 (Forum, Sep 28, 2023.

(g) The evidence is also that the Respondent is clearly using its various websites to collect customer information and credit card information for fraudulent purposes. Thus, customers who make purchases are charged, but they do not receive confirmation emails or the goods they thought they had purchased and in that regard the Complainant has received over 300 complaints from customers relating to this scam, many of them being victims of the fraud.

(h) The evidence is also that the Respondent is clearly passing itself off as the Complainant and doing so for unlawful activities including obtaining money by fraud and phishing. This is particularly seen from the Complainant's evidence of the offending websites to which the disputed domain names resolve and which carry information that has the effect, and is no doubt designed to give the impression that, it is genuine information about the Complainant and that the websites are genuine websites of the Complainant, which they are not.

(i) The evidence shows that the Respondent is not commonly known by the disputed domain names within the meaning of Policy ¶ 4(c)(ii), is not authorized to use Complainant's HOWLER  trademark mark and is not affiliated with Complainant.

`        (j) There is also no evidence that the Respondent is engaged in a legitimate non-commercial or fair use of the domain names within the meaning of Policy ¶ 4(c)(iii) and all the evidence shows that it is not. The evidence shows that the Respondent's conduct is illegitimate in every sense, purely commercial, not a fair use of the domain name and evidence which in any event does not entitle the Respondent to use the domain names at all.

(k) The Respondent has engaged in the foregoing conduct without the consent or approval of the Complainant.

(l) The Respondent had an opportunity to show circumstances to the contrary of the above conclusions if it believed they were warranted, but it has not attempted to do so.

        

All of these matters go to make out the prima facie case against the Respondent.

As the Respondent has not filed a formal Response or attempted by any other means to rebut the prima facie case against it, the Panel finds that the Respondent does not have a right or legitimate interest in the disputed domain names.

 

The Complainant has thus made out the second of the three elements that it must establish.

 

Registration and Use in Bad Faith

It is clear that to establish bad faith for the purposes of the Policy, the Complainant must show that the disputed domain names were registered in bad faith and that they have been used in bad faith. It is also clear that the criteria set out in Policy ¶ 4(b) for establishing bad faith are not exclusive, but that Complainants in UDRP proceedings may also rely on conduct that is bad faith within the generally accepted meaning of that expression.

 

Having regard to those principles, the Panel finds that the disputed domain names were registered and used in bad faith. The evidence in support of that conclusion has already been set out under Rights and Legitimate Interests and there is no need to repeat it here. However, in summary the following may be said.

 

First, all of the evidence shows that the Respondent has been engaged in the improper registration and use of the disputed domain names in bad faith.

 

Secondly, all of the evidence shows that the conduct of the Respondent has been in flagrant breach of and constitutes a substantial infringement of the Complainant's HOWLER trademark. Moreover, the evidence is clear that the Respondent does not have and has never had a trademark or any other intellectual property rights to justify its brazen conduct.

 

Thirdly, the evidence shows that the Respondent registered the disputed domain names to mimic the appearance of legitimate websites operated by the Complainant by displaying the HOWLER trademark and logo, as shown by the evidence in the Complainant's Exhibits E, F ,G, H, I, 12 and 13. The conclusion that must be drawn from that evidence is that Respondent had actual knowledge of the Complainant and its mark when it registered the disputed domain names and therefore that it did so in bad faith.

 

Fourthly, the conclusion must be reached that the Respondent did so with the intention of disrupting the business of the Complainant within the meaning of Policy ¶ 4(b)(iii).

 

Fifthly, the evidence also shows that the Respondent has attempted to  create confusion with the Complainant's HOWLER trademark as to the authenticity of the Respondent's websites and the goods and services offered through them, within the meaning of Policy ¶ 4(b)(iv).

 

Sixthly, the disputed domain names were registered well after the registration of the Complainant's HOWLER trademark.

 

The same conclusion is reached by the evidence to the effect that actual and prospective customers of the Complainant and members of the public would be deceived into believing that the Respondent is or is affiliated with the Complainant and that the Complainant authorized the Respondent's use of the HOWLER  trademark which is not so.

 

Finally, in addition to the specific provisions of the Policy and having regard to the totality of the evidence, the Panel finds that, in view of the Respondent's registration of the disputed domain names using the HOWLER trademark and in view of the conduct that the Respondent has engaged in when using the domain names, the Respondent registered and used them in bad faith within the generally accepted meaning of that expression.

 

The Complainant has thus made out the third of the three elements that it must establish.

 

The Complaint has thus established all of the elements that it must establish under the Policy and is entitled to the relief it seeks.

 

DECISION

Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <howlerbros.club>, <howlerbross.com>, <howlerbross.top>, <howlerbros.life>, <howlerbrothers.top>, <howlerbros-us.top> and <howlerbrosonline.store> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

The Honorable Neil Anthony Brown KC

Panelist

Dated: November 15, 2023