DECISION
Bath & Body Works Brand Management, Inc. v. Hong Zhang / Xiao Fei Li / Ya Feng Liu / Long Chen
Claim Number: FA2401002077491
PARTIES
Complainant is Bath & Body Works Brand Management, Inc. ("Complainant"), represented by Thorne Maginnis of Arent Fox LLP, District of Columbia, USA. Respondent is Hong Zhang / Xiao Fei Li / Ya Feng Liu / Long Chen ("Respondent"), China.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <bathandbodyworksus.com>, <bathandbodyworkus.com>, <bathandbodyworksco.com>, <bathandbodyworkusa.com>, <bathsandbodyworksus.cc>, <bathandbodywork.cc>, <bathandbodyworkusa.cc>, <bathandbodyworksco.cc> and <bathandbodyworksusa.com>, registered with Chengdu West Dimension Digital Technology Co., Ltd. and Jiangsu Bangning Science & technology Co. Ltd..
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 January 3, 2024; Forum received payment on January 3, 2024.
On January 4, 2024, Chengdu West Dimension Digital Technology Co., Ltd. and Jiangsu Bangning Science & technology Co. Ltd. confirmed by e-mail to Forum that the <bathandbodyworksus.com>, <bathandbodyworkus.com>, <bathandbodyworksco.com>, <bathandbodyworkusa.com>, <bathsandbodyworksus.cc>, <bathandbodywork.cc>, <bathandbodyworkusa.cc>, <bathandbodyworksco.cc> and <bathandbodyworksusa.com> domain names are registered with Chengdu West Dimension Digital Technology Co., Ltd. and Jiangsu Bangning Science & technology Co. Ltd. and that Respondent is the current registrant of the names. Chengdu West Dimension Digital Technology Co., Ltd. and Jiangsu Bangning Science & technology Co. Ltd. have verified that Respondent is bound by the Chengdu West Dimension Digital Technology Co., Ltd. and Jiangsu Bangning Science & technology Co. Ltd. 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 January 11, 2024, Forum served the Complaint and all Annexes, including a Chinese and English Written Notice of the Complaint, setting a deadline of January 31, 2024 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@bathandbodyworksus.com, postmaster@bathandbodyworkus.com, postmaster@bathandbodyworksco.com, postmaster@bathandbodyworkusa.com, postmaster@bathsandbodyworksus.cc, postmaster@bathandbodywork.cc, postmaster@bathandbodyworkusa.cc, postmaster@bathandbodyworksco.cc, postmaster@bathandbodyworksusa.com. Also on January 11, 2024, the Chinese and English 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 in Chinese and English.
On February 1, 2024, 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 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, Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent.
RELIEF SOUGHT
Complainant requests that the domain names be transferred from Respondent to Complainant.
PRELIMINARY ISSUES: LANGUAGE OF THE PROCEEDING
According to the Registrar's verification response, the registration agreement for the disputed domain names is written in Chinese. Rule 11(a) provides that the language of the proceedings is the language of the registration agreement, subject to the authority of the Panel to determine otherwise, having regard to the circumstances of the case. Complainant has submitted pursuant to Rule 11(a) that the proceeding should be conducted in English. When considering such submissions it is established practice also to take UDRP Rules 10(b) and (c) into consideration to ensure fairness and justice to both parties. Factors which previous panels have seen as important when determining submissions under Rule 11(a) include evidence showing that the respondent can understand the language of the complaint, the language of the domain name, the content on any web pages resolving from the domain name, prior correspondence between the parties, and potential unfairness or unwarranted delay in ordering translation of the pleadings and the Decision. See Fair Isaac Corporation v. AKPOVO Chidiac, FA 2034648 (Forum Apr. 12, 2023) (finding panel has discretion to conduct proceedings in English contrary to registration agreement given evidence that respondent understands the language).
In the present case, the Complainant relies on the following factors:
(a) The disputed domain names consist of Complainant's English-language mark, with the ampersand correctly replaced by the English word "and", various omissions of the plural "s" as is common in English-language typographical errors, plus common English-language elements ("us", "usa", "co", ".cc" and ".com").
(b) All content on Respondent's websites is exclusively in English, including material that has clearly been copied from Complainant's English-language website.
(c) The sole currency accepted for use of the Respondent's websites is U.S. dollars and all online orders are processed in the English language, which strongly indicates that Complainant is capable of conducting business in English.
The Panel has examined all of this material and finds that each of the foregoing grounds has been made out and that together they make out a strong case advanced for the Complainant. It is clear that the Respondent's entire operation is aimed at an English-speaking market with which the Respondent must be familiar. In fact, the evidence shows a sophistication in the use of the English language on the part of the Respondent. The Respondent must therefore be assumed to have a good working facility with the English language. It is therefore appropriate that the proceeding be conducted in English.
In any event, if the proceeding were not conducted in English, it would have to be conducted in Chinese and all the documents would have to be translated into Chinese, which would be an expensive and unnecessary process.
The Panel therefore determines that pursuant to Rule 11(a), the proceeding will be conducted in the English language.
MULTIPLE RESPONDENTS
In the instant proceeding, 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 for Uniform Domain Name Dispute Resolution Policy (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 question therefore is whether the named Respondents, because of their use of several alleged aliases, can be said in reality to be "the same domain name holder", which the Complainant submits they are.
The Complainant relies on the grounds that all of the domain names currently resolve to nearly identical websites, they were registered in one of four names, with one of two registrars, and within a four-month period, thus creating a strong inference of common ownership. The Panel agrees with this submission. Moreover, all of the domain names promote the same underhand activity and it would be a remarkable coincidence if the nominal Respondents embarked on that activity independently and at roughly the same time.
Having regard to all of those considerations and the whole of the evidence, the Panel finds that the domain names are commonly owned/controlled by a single Respondent who is using multiple aliases and are therefore "the same domain name holder". The proceeding may therefore go forward on that basis. For reasons of convenience, the nominal Respondents will hereafter be referred to as "Respondent".
PARTIES' CONTENTIONS
A. Complainant
Complainant made the following contentions.
1. Complainant is a United States company engaged in the provision of personal care and home fragrance products and related goods and services and it has been so engaged since at least 1990.
2. Complainant has registered trademark rights in the BATH & BODY WORKS trademark mark by virtue of its registration of the mark with the United States Patent and Trademarks Office ("USPTO"), Registration No. 1742062, registered on December 22, 1992 and other national and international registrations for BATH & BODY WORKS. The Complainant also has common law trademark rights in the BATH & BODY WORKS trademark and has had them since at least 1990 (collectively "the BATH & BODY WORKS trademark").
3. The BATH & BODY WORKS trademark has become prominent, has attracted substantial goodwill and is uniquely associated with the Complainant's goods and services.
4. The Complainant has also registered the domain name <bathandbodyworks.com> which it uses in its business and in particular for a website on which it advertises and markets its legitimate BATH & BODY WORKS products and services.
5. Respondent registered the following domain names on their respective dates, namely:
(a) <bathandbodyworksus.com> : July 31, 2023;
(b) <bathandbodyworkus.com> : July 12, 2023;
(c)<bathandbodyworksco.com>: July 25, 2023;
(d)<bathandbodyworkusa.com>: October 11, 2023;
(e)<bathsandbodyworksus.cc>: November 11, 2023;
(f)<bathandbodywork.cc>: November 11, 2023;
(g)<bathandbodyworkusa.cc>: November 1, 2023;
(h)<bathandbodyworksco.cc>: November 16, 2023; and
(i)<bathandbodyworksusa.com>: October 31, 2023,
("the disputed domain names").
6. In so doing, Respondent has incorporated in the disputed domain names the entirety of Complainant's BATH & BODY WORKS trademark without any authority to do so, and has added a variety of minor additions as follows :
(a) replacing the ampersand with the word "and";
(b) omitting the letter "s" from the term "WORKS";
(c) adding the generic terms "us," "usa,", ".cc", "co"; and/or
(d) adding the generic top-level domain ("gTLD") ".com" or the country code top-level domain ("ccTLD") ".cc" for the Australian territory, the Cocos (Keeling) Islands;
none of which negates a finding of confusing similarity otherwise present as it is in the present case.
7. The disputed domain names are identical and /or confusingly similar to the Complainant's BATH & BODY WORKS trademark.
8. Respondent has caused the disputed domain names to resolve to websites that:
(a) display and offer for sale the Complainant's trademarked products without authority;
(b) impersonate the Complainant;
(c) infringe the Complainant's BATH & BODY WORKS trademark;
(d) use the Complainant's copyright text and images;
(e) imitate the look and feel of the Complainant's website; and
(f) in particular, the Respondent has used the Complainant's mark in stylized font identical to that used by the Complainant, used identical text and images from the Complainant's site; used 900 copyright images of Complainant's products taken from the website, and included under "About Us" material copied from the Complainant's website.
9. The Respondent also:
(a) has no license or authority to use the Complainant's intellectual property or sell its products;
(b) has sought to pass itself off as the Complainant or as being affiliated with it;
(c ) has not utilized the domain names for any legitimate business purpose or for a bona fide offering of goods or services within the meaning of Policy ¶ 4(c)(i); and
(d) has not made a legitimate noncommercial or fair use of the domain names within the meaning of Policy ¶ 4(c)(iii);
(e) registered the domain names to exploit the goodwill of the Complainant's trademarks.
(f) has no trademark rights in BATH & BODY WORKS; and
(g) is not commonly known by the domain names.
10. By reason of the matters aforesaid, the Respondent has no rights or legitimate interests in the disputed domain names.
11. The Respondent has registered and used the disputed domain names in bad faith. That is so because the Respondent:
(a) registered the confusingly similar domain names with knowledge of the Complainant's trademarks;
(b) clearly had actual knowledge of the Complainant and its BATH & BODY WORKS trademark when it registered and used the domain names;
(c) acted in breach of its registration agreements relating to the disputed domain names;
(d) has intentionally attempted to attract, for commercial gain, internet users to the resolving website by creating confusion with the BATH & BODY WORKS trademark within the meaning of Policy ¶ 4(b)(iv);
(e) has used the Complainant's BATH & BODY WORKS trademark to mislead internet users by passing itself off as Complainant;
(f) has, by virtue of all of the facts, shown that it registered and used the disputed domain names in bad faith.
12. The Complainant has cited numerous prior UDRP decisions to support its contentions.
13. It is therefore submitted by the Complainant that it has shown all of the elements that it must establish and that the domain names should be transferred from the Respondent to the Complainant.
B. Respondent
Respondent failed to submit a Response in this proceeding.
FINDINGS
1. Complainant is a United States company engaged in the provision of personal care and home fragrance products and related goods and services and it has been so engaged since at least 1990.
2. Complainant has established by evidence its registered trademark rights in the BATH & BODY WORKS trademark by virtue of its registration of the mark with the United States Patent and Trademarks Office ("USPTO"), Registration No. 1742062, registered on December 22, 1992 and other national and international registrations for BATH & BODY WORKS. The Complainant also has common law trademark rights in the BATH & BODY WORKS trademark and has had those rights since at least 1990 (collectively "the BATH & BODY WORKS trademark").
3. Respondent registered the following domain names on their respective dates, namely:
(a) <bathandbodyworksus.com> : July 31, 2023;
(b) <bathandbodyworkus.com> : July 12, 2023;
(c)<bathandbodyworksco.com>: July 25, 2023;
(d)<bathandbodyworkusa.com>: October 11, 2023;
(e)<bathsandbodyworksus.cc>: November 11, 2023;
(f)<bathandbodywork.cc>: November 11, 2023;
(g)<bathandbodyworkusa.cc>: November 1, 2023;
(h)<bathandbodyworksco.cc>: November 16, 2023; and
(i)<bathandbodyworksusa.com>: October 31, 2023,
("the disputed domain names").
4. Respondent has caused the disputed domain names to resolve to websites that: (a) display and offer for sale the Complainant's trademarked products without authority; (b) impersonate the Complainant; (c) infringe the Complainant's BATH & BODY WORKS trademark; (d) use Complainant's copyright text and images; (e) imitate the look and feel of the Complainant's website; (e) pass itself off as the Complainant; and (f) exploit the goodwill of the Complainant's trademarks.
5. By reason of the matters aforesaid and as demonstrated by the evidence, the disputed domain names are confusingly similar to the Complainant's BATH & BODY WORKS trademark, the Respondent has no rights or legitimate interests in the domain names and the domain names have been registered and used in bad faith.
6. 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 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: 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 registered trademark rights in the BATH & BODY WORKS trademark by virtue of its registration of the mark with the United States Patent and Trademarks Office ("USPTO"), Registration No. 1742062, registered on December 22, 1992 and other national and international registrations for BATH & BODY WORKS. The evidence also shows that the Complainant has common law trademark rights in the BATH & BODY WORKS trademark and has had those rights since at least 1990 (collectively "the BATH & BODY WORKS trademark").
The Complainant has adduced evidence of the foregoing registrations and of its common law rights, which the Panel has examined and which it finds to be in order. Registration of a trademark with a recognized authority such as the USPTO and evidence of common law rights are 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 Complainant has registered and established its rights in the BATH & BODY WORKS trademark through its widespread registration and use of the mark, the Panel finds that the Complainant has rights in the BATH & BODY WORKS trademark under Policy ¶ 4(a)(i).
In that regard, the Panel finds that the registered trademark was registered and the common law trademark rights were acquired well prior to the Respondent's registration of the disputed domain names on the dates set out above.
The next question that arises is whether the disputed domain names are identical or confusingly similar to the Complainant's BATH & BODY WORKS trademark. The Panel finds that the disputed domain names are confusingly similar to the BATH & BODY WORKS trademark. Several minor alterations were made by the Respondent to the Complainant's trademark before incorporating it into the domain names. But they are minor and cannot negate a finding of confusing similarity that is otherwise present as it is in the present case. If anything, they strengthen it because they show that the Respondent was trying to cast a very wide net and ensure that as many specific groups of internet users as possible would be enticed into its wrongful and misleading use of the Complainant's trademark, even, so it seems, such a specific group as the 593 residents of the Cocas Keeling Islands. Taken as a whole, the domain names mean and would be interpreted by internet users to mean that they are invoking the Complainant and its BATH & BODY WORKS trademark and its use by the Respondent with the implied approval of the Complainant. It is therefore clear that the domain names are similar to the trademark and confusingly so.
The Panel therefore finds that the disputed domain names are confusingly similar to Complainant's BATH & BODY WORKS 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
The Panel finds on the evidence that the Complainant has made out a prima facie case that arises from the following considerations:
(a) the Respondent has chosen to take the Complainant's BATH & BODY WORKS trademark and to use it in its domain names, making only the minor additions and alterations to the trademark mentioned above, generating the clear impression that it is referring to and invoking the Complainant's BATH & BODY WORKS trademark in its domain names and that the Respondent is authorized to do so. The Respondent had no right to do any of this, meaning that there is no foundation at all for finding that it had the right to do so or that it gave the Respondent any legitimate interest in the domain names so created;
(d) having registered the disputed domain names, the Respondent then set about causing them to resolve to respective websites that copied the Complainant's own website, sought to pass itself off as the Complainant, and purported to sell the Complainant's trademarked products, none of which the Respondent was authorised to do;
(e) this conduct was a clear infringement of the Complainant's trademark, a clear breach of the Respondent's registration agreement, and an equally clear breach of the copyright laws;
(f) the evidence of these matters is contained in the Complainant's Attachment E. The Complainant in that exhibit drew a valuable and helpful comparison between the Complainant's website and the Respondent's websites, showing that the latter are brazen copies of the former, going as far as carrying a false endorsement by the Complainant's CEO of the Respondent and its website. It is not necessary to repeat the details set out above, but they constitute an attempted fraud on internet by the Respondent, with prices, a wide range of products for sale under the brand BATH & BODY WORKS, and all the other accoutrements that a buyer would expect to see on a website of this sort. All of this evidence shows an intention to use the Complainant's trademark to pretend that the Respondent is the Complainant, to conduct business allegedly with the permission of the Complainant and of course to sell goods under the imprimatur of the Complainant's name and trademark.
(g) In all, the only conclusion that can be reached on the evidence is that the Respondent is using the Complainant's trademark and business to make money by offering the same or counterfeit products to those of the Complainant. It is clearly deceptive because the whole thrust of the offer is that they are legitimate BATH & BODY WORKS service that are being offered, which is an entirely false assertion;
(h) the evidence shows that the Respondent is not commonly known by the domain names;
(i) the evidence also shows that the Respondent is not using the disputed domain names in connection with a bona fide offering of goods or services. Indeed, the opposite is the case, as the evidence shows that the Respondent is not using them for a bona fide offering of goods or services but to resolve to websites and thus falsely assert that it can offer legitimate BATH & BODY WORKS goods and services promoted on the websites. This conduct cannot give rise to a right or legitimate interest in the domain names;
(j) the evidence also shows that the domain names are not being used for a legitimate non-commercial or fair use; the use of the domain names has been demonstrated to be illegitimate; it also cannot be said to be non-commercial in any sense as it clearly is intended to be used by the Respondent for a financial purpose, namely to make money; nor is it fair, as it is clearly unfair to use a trademark without permission and to pretend that it is being used with the approval of the Complainant as trademark owner;
(k) the evidence shows that there is no relationship between the Complainant and the Respondent and that the Complainant has not authorized or licensed the Respondent to register the domain names or to use its BATH & BODY WORKS trademark in any way;
(l) the Complainant and the Respondent are not affiliated, connected, or associated with each other;
(m) all of the above considerations disprove any suggestion that the Respondent has a right or legitimate interest in the domain names.
All of these matters go to make out the prima facie case against Respondent.
As Respondent has not filed a Response and did not reply to the Complainant's additional submission or attempt by any other means to rebut the prima facie case against it, the Panel finds that Respondent does not have a right or legitimate interest in the disputed domain names.
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 and used in bad faith. It is also clear that the criteria set out in Policy ¶ 4(b) are not exclusive but that UDRP proceedings may also rely on conduct that is bad faith within the generally accepted meaning of that expression.
The Complainant has submitted that the Respondent has registered and used the disputed domain names in bad faith on several grounds, namely that the Respondent:
(a) registered the confusingly similar domain names with knowledge of the Complainant's trademarks;
(b) clearly had actual knowledge of the Complainant and its BATH & BODY WORKS trademark when it registered and used the domain names;
(c) acted in breach of its registration agreements relating to the disputed domain names;
(d) has intentionally attempted to attract, for commercial gain, internet users to the resolving website by creating confusion with the BATH & BODY WORKS trademark within the meaning of Policy ¶4(b)(iv);
(e) has used the Complainant's BATH & BODY WORKS trademark to mislead internet users by passing itself off as the Complainant;
(f) has, by virtue of all of the facts, shown that it registered and used the disputed domain names in bad faith.
The Panel finds that each of the grounds relied on by the Complainant has been made out by the detailed case presented by the Complainant and it is not necessary to repeat all of the evidence that points unequivocally to that conclusion.
The Panel will add, however, that the Respondent has registered and used the domain names in bad faith because the evidence shows that the Respondent:
(a) clearly had actual knowledge of the Complainant and its BATH & BODY WORKS trademark when it registered and used the domain names; that is because the BATH & BODY WORKS trademark is obviously well known and the Respondent must have had actually knowledge of it, because it took the mark, made some specific alterations and additions to it to cast a wide net of unsuspecting internet users and used it in its domain names and websites to pass itself off as the Complainant; none of that could have been perpetrated without actual knowledge of the trademark;
(b) created a website that claimed to be an online store where buyers could purchase the Complainant's branded goods and which was calculated to give the appearance of an association with the Complainant and to earn money for the Respondent but which in reality was a fraud and probably a thinly disguised framework for running a phishing scheme;
(c) used the offending websites to display and offer for sale the Complainant's trademarked products without authority;
(d) intentionally attempted to attract, for commercial gain, internet users to the resolving website by creating confusion with the BATH & BODY WORKS trademark within the meaning of Policy ¶ 4(b)(iv), again to make money; the Respondent obviously tried to pretend that it was the Complainant or was authorized by it and set about confusing and misleading internet users; in particular, the Respondent has used the domain names and their resolving websites to display and offer for sale the Complainant's trademarked products without authority;
(e) moreover, it set about engaging in conduct that showed it was intending to disrupt the Complainant's business within the Policy ¶ 4(b)(iii);
(f) acted in breach of its registration agreements relating to the disputed domain names;
(g) all of the other grounds relied on by the Complainant have been well and truly proven by the evidence.
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 BATH & BODY WORKS trademark and in view of the conduct that the Respondent has engaged in when using them, the Respondent registered and used them in bad faith within the generally accepted meaning of that expression.
The Complainant has correctly cited several prior UDRP decisions that support its contentions.
Complainant has thus made out the third of the three elements that it must establish.
Complainant has established all of the elements that it must show under the Policy and is therefore 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 <bathandbodyworksus.com>, <bathandbodyworkus.com>, <bathandbodyworksco.com>, <bathandbodyworkusa.com>, <bathsandbodyworksus.cc>, <bathandbodywork.cc>, <bathandbodyworkusa.cc>, <bathandbodyworksco.cc> and <bathandbodyworksusa.com>, domain names be TRANSFERRED from Respondent to Complainant.
The Honorable Neil Anthony Brown KC
Panelist
Dated: February 5, 2024
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