The Complainant is Bayerische Motoren Werke AG (“BMW”), of Munich, Germany, represented by Kelly IP, LLP, United States of America (“United States”).

The Respondents are Registration Private, Domains By Proxy, LLC of Scottsdale, United States / Armands Piebalgs of Riga, Latvia. 2. The Domain Names and Registrar

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

The Complaint and the amended Complaint were filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 26, 2017 and January 31, 2017. On January 27, 2017 and February 2, 2017, the Center transmitted by email to the Registrar two requests for registrar verification in connection with the Disputed Domain Names. On January 29, 2017 and February 2, 2017, the Registrar transmitted by email to the Center its verification responses confirming that the Respondents are listed as the registrant and providing the contact details.

The Center verified that the Complaint together with the amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “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 the Rules, paragraphs 2 and 4, the Center formally notified the Respondents of the Complaint, and the proceedings commenced on February 7, 2017. In accordance with the Rules, paragraph 5, the due date for Response was February 27, 2017. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on March 1, 2017.

The Center appointed Nick J. Gardner as the sole panelist in this matter on March 7, 2017. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background

The Complainant is one of the leading manufacturers of automobiles and motorcycles in the world. It owns the trademark, service mark, and trade name BMW. It has continuously used BMW as a trademark and service mark since 1917. Under its BMW trademark, the Complainant manufactures, sells, and distributes an array of automobiles and motorcycles, and provides numerous services including maintenance and repair services, financing, leasing, insurance, and warranty services, among others. The Complainant also uses and licenses its BMW trademark on a wide variety of automobile and motorcycle parts and accessories and numerous collateral products.

The Complainant has, and owns numerous registrations for the BMW trademark and variations of it in more than 140 countries around the world. The earliest registration for the BMW trademark is in Germany. Namely, German Trademark registration no. 221388 BMW (figurative mark), registered on December 10, 1917.

The Complainant’s headquarters are located in Germany whilst its products and components are manufactured at 30 sites in 14 countries on four continents. It has more than 122,000 employees worldwide. The Complainant has manufactured, marketed, and sold many millions of vehicles under the BMW trademark. For example, in each year from 2011 through 2015, it produced and sold more than 1,300,000 automobiles, and more than 100,000 motorcycles under the BMW trademark. In 2015, BMW had worldwide sales and revenue in excess of EUR 92 billion. In prior years, BMW’s sales were also in the billions, with revenues of more than EUR 80 billion in 2014, EUR 76 billion in 2013, more than EUR 76 billion in 2012, and more than EUR 68 billion in 2011.

The Complainant like most major car manufacturers utilizes a network of authorized dealers to market its BMW vehicles, vehicle parts and accessories, and other products including apparel, as well as services such as rental, financing, and maintenance services. BMW currently has approximately 3,310 authorized BMW dealers in locations throughout the world. The Complainant over the years has extensively and widely advertised and promoted its products and services under the BMW trademark, spending tens of millions of dollars every year to advertise, market, and promote the BMW name and trademark in connection with its products and services through a variety of media, including television and print advertisements, the Internet, and high-profile sponsorships. The Complainant has also received considerable third-party press, attention, and recognition in connection with the BMW trademark.

In use since 1917, the BMW trademark enjoys unquestionable fame as a result of extensive and long use and advertising, and favorable public acceptance and recognition worldwide. Indeed, the BMW trademark has become one of the most recognized brands in the world. In 2015 Interbrand ranked the BMW trademark eleventh of the “Best Global Brands” with a value of more than USD 37.2 billion.

The Complainant has since 1996 used its BMW trademark in connection with its network of websites dedicated to advertising, promoting, and/or offering its automobiles, motorcycles, and related products and services. The Complainant’s websites are accessible via domain names comprised of the BMW trademark alone and combined with relevant geographic and/or descriptive terms. The domain names it owns include: , and .

The Respondents registered in February 24, 2016. It is used to offer for sale reports that contain (or purport to contain) information about BMW and MINI vehicles including dealer history, service history, and mileage. Respondents are not and have never been an authorized user of BMW’s proprietary data. In addition to containing BMW’s data, Respondents’ reports also contain unauthorized copies of BMW’s copyright-protected publicity images. The Respondents registered on January 27, 2017, immediately after BMW filed this Complaint and after the Respondents were notified of BMW’s Complaint by the Registrar. The Respondents link this domain name to a website offering an unauthorized “BMW VIN Decoder” tool and unauthorized reports for BMW vehicles. A VIN is a Vehicle Identification Number, which is a unique number applicable to a given vehicle. 5. Parties’ Contentions A. Complainant

The Complainant says that the Disputed Domain Names are each confusingly similar to its BMW trademark as each one incorporates Complainant’s well-known and distinctive BMW trademark or an obvious contraction of that trademark, and the combination thereof with generic terminology is insufficient to distinguish the Disputed Domain Names from the Complainant’s BMW trademark.

The Complainant says the Respondents do not have any rights or legitimate interests in the Disputed Domain Names and the Respondents use the Disputed Domain Names in bad faith as the websites to which the Disputed Domain Names resolve make use of the Complainant’s BMW trademark in order to offer for sale reports which the Complainant says are “counterfeit” as the type of data