The Complainant is Guccio Gucci S.p.A. of Florence, Italy, represented by Studio Barbero, Italy.

The Respondents are Wen Ben Zhou of Xiamen, China and Xiao Feng of Hangzhou, China. 2. The Domain Names and Registrar

The disputed domain names , , , , , , , , , , , , , , , , , , , and (the “Domain Names”) are registered with GoD, LLC (the “Registrar”). 3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 7, 2014. The Center transmitted its request for registrar verification to the Registrar the same day. The Registrar replied on November 10, 2014, confirming that it is the registrar of all of the Domain Names, that the Respondents are the registrants, that the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”) applies, that the Domain Names will remain locked during this proceeding, that the language of the registration agreement is English, and that the Domain Names were registered to the Respondents on March 12, 2014. The Registrar also provided the full contact details held in respect of the Domain Names on its WhoIs database.

The Center verified that the Complaint satisfied the formal requirements of the UDRP, the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”).

In accordance with paragraphs 2(a) and 4(a) of the Rules, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on November 12, 2014. In accordance with paragraph 5(a) of the Rules, the due date for Response was December 2, 2014. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 3, 2014.

The Center appointed Jonathan Turner as the sole panelist in this matter on December 15, 2014. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with paragraph 7 of the Rules. Having reviewed the file, the Panel is satisfied that the Complaint complied with applicable formal requirements, was duly notified to the Respondent and has been submitted to a properly constituted Panel in accordance with the UDRP, the Rules and the Supplemental Rules. 4. Factual Background

The Complainant is part of the Gucci Group, a leading international fashion business founded by Guccio Gucci in 1921. The Complainant owns numerous national and international trademark registrations for the mark GUCCI, including Italian trademark registration no. 801958, International trademark registration no. 429833 and Community trademark registration no. 000121988. The Complainant also has over 1,000 domain names incorporating the word “gucci”, most of which are directed to its website at “”. The mark GUCCI has been extensively used and advertised by the Gucci Group and has been promoted by celebrity figures using its products.

The Domain Names are registered in the name of the first Respondent, Wen Ben Zhou, with the exception of and , which are registered in the name of the second Respondent, Xiao Feng.

The postal addresses of the registrants and other contacts in the WhoIs data for all of the Domain Names contain the same street address, the same postal code and the same country, albeit different cities and provinces. For 18 of the Domain Names the city and province are given as Xiamen and Fu Jian respectively; for the remaining 3 Domain Names, namely , and , these are given as Hangzhou and Zhejiang respectively.

The telephone number of the registrants and other contacts in the WhoIs data for all of the Domain Names is the same.

The email address of the registrant and other contacts in the WhoIs data for 17 of the Domain Names is the same. Three of the remaining Domain Names, namely , and , share a different email address in their WhoIs data. The remaining Domain Name, , has a different email address in its WhoIs data for the registrant and other contacts.

The Domain Names other than , , , , , and are directed to websites containing multiple references to the mark GUCCI and a device mark used by the Gucci Group, together with photographs of GUCCI products and offer to sell them at low prices.

The Domain Names , and are directed to a website on which products bearing the trademarks of companies competing with the Gucci Group are offered for sale.

The Domain Name is directed to a holding web page. The Domain Names , and are not directed to websites.

After learning of the registration and use of some of the Domain Names the Complainant instructed its representative to send a cease and desist letter. The letter was sent to the Respondents at the email addresses identified in the WhoIs data for the Domain Names on April 23, 2014, with reminders on May 8, 2014, June 19, 2014, and September 26, 2014. The second and third reminders included additional Domain Names which the Complainant had by then discovered and were sent to email addresses indicated on some of the Respondents’ websites as well as those in the WhoIs data. No reply was received to any of these communications. 5. Parties’ Contentions A. Complainant

The Complainant first requests consolidation of the claims against the two Respondents in a single proceeding. The Complainant points out that it has been held in previous UDRP decisions that consolidation may be appropriate where the disputed domain names or the websites to which they resolve are under common control and consolidation would be procedurally efficient and fair and equitable to all parties.

The Complainant submits that common control has been found to exist for this purpose where different registrants were alter egos of the same beneficial holder, as indicated by commonality in registration information; or where a single person or entity registered multiple domain names using fictitious names; or where the disputed domain names resolved to common servers; or where the disputed domain names all contained the Complainant’s mark in its entirety together with a descriptive term.

The Complainant then draws attention to the commonalities identified in section 4 above in the WhoIs data for the Domain Names and in the websites to which they resolve. The