Complainant is Andrey Ternovskiy, dba Chatroulette, of Sliema, Malta, represented by CSC Digital Brand Services AB, Sweden.

Respondent is Zhichao Yang of Hefei, Anhui, China. 2. The Domain Names and Registrar

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

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 12, 2018. On April 12, 2018, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On April 12, 2018, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named respondent and contact information in the Complaint. The Center sent an email communication to Complainant on April 13, 2018, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on April 17, 2018.

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 Respondent of the Complaint, and the proceedings commenced on April 18, 2018. In accordance with the Rules, paragraph 5, the due date for Response was May 8, 2018. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on May 9, 2018.

The Center appointed Gerardo Saavedra as the sole panelist in this matter on May 28, 2018. This Panel finds that it was properly constituted. This 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

Complainant has rights over the CHATROULETTE trademark for which it holds, among others, registration No. 429957 with the Russian Federal Service for Intellectual Property (ROSPATENT), registered on February 10, 2011, in classes 35, 38 and 42; registration No. 8126890 with the Trademark Office of China, registered on May 7, 2011, in class 42; registration No. 008944076 with the European Union Intellectual Property Office, registered on December 4, 2012, in classes 35, 38 and 42; and registration No. 4445843 with the United States Patent and Trademark Office, registered on December 10, 2013, in classes 38 and 45.

Complainant is the registrant of the domain name which was registered on November 16, 2009.

The disputed domain names were all registered on January 14, 2018. At the time the Complaint was filed, the disputed domain names were redirected to the website “” which showed, among others, the legend “The Top Live Sex Cam Sites In 2018” and featuring pornographic images with apparent hyperlinks. 5. Parties’ Contentions A. Complainant

Complainant’s assertions may be summarized as follows.

Chatroulette, created and owned by Complainant, is an online chat website that pairs random people from around the world together for real-time, webcam-based conversations. Complainant created the Chatroulette service and website in 2009. The idea for Chatroulette stemmed from Complainant’s realization that, at the time of its inception, no website existed which allowed for random video chatting with other Internet users from around the world. The “Chatroulette” name that Complainant chose for his innovative website and business was, in part, selected after Complainant watched a film in which soldiers in played the game of Russian roulette. By combining the term “chat”, which is one of the core purposes of Complainant’s website, and the word “roulette”, which is associated with the thrill of unpredictability, the essence of Chatroulette is captured in such distinctive name.

Very shortly after its launch, the Chatroulette website began to receive 500 visitors per day and only one month later, in January 2010, that figure had increased to 50,000 visitors per day (approximately 1.5 million users per month). In February 2010, that traffic had jumped to approximately 130,000 visitors per day (3.9 million monthly visitors). That exponential growth demonstrates the popularity that Complainant’s Chatroulette website and business were able to achieve within mere months of its launch.

Chatroulette continues to be well-known as one of the most popular video chat sites in the world, and the website has generated significant interest and attention internationally among fans, the media, and competitors. Chatroulette has been featured in and highlighted by numerous publications and media outlets including The New York Times, The New Yorker, and New York Magazine, as well as on television shows. According to A statistics, the Chatroulette website, located at “www.”, received over 270,000 unique monthly visitors in the month of December 2017, earning a global popularity rank of 18,214.

Complainant is the owner of trademark registrations across various jurisdictions, which demonstrate that Complainant has spent a considerable amount of time and money protecting his intellectual property rights.

The disputed domain names are a misspelling of Complainant’s CHATROULETTE trademark and must be considered confusingly similar to Complainant’s trademark. Each of the disputed domain names varies from Complainant’s trademark by only one letter: in the last letter “e” is replaced with the letter “i”; in the letter “a” is added after “chat”; in another letter “e” is added after the first “e”.

Respondent has no rights or legitimate interests in respect of the disputed domain names. Complainant has not given Respondent permission to use Complainant’s trademark in any manner. Respondent is not sponsored by or affiliated with Complainant in any way and is not commonly known by the disputed domain names.

Since the disputed domain names differ from Complainant’s trademark by just one letter, they must be considered prototypical examples of typosquatting, which intentionally takes advantage of Internet users that inadvertently type an incorrect address when seeking to access the trademark owner’s website.

Respondent is using the disputed domain names to occasionally redirect Internet users to a third party website that contains pay-per-click links to competitor websites and adult content. As such, Respondent is not using the disputed domain names to provide a bona fide offering of goods or services, nor a legitimate noncommercial or fair use. Past UDRP decisions have held that use of a domain name that is confusingly similar to a complainant’s trademarks to link to a website featuring pornographic or adult content evidences a lack of legitimate rights or interests.

The disputed domain names were registered and are being used in bad faith.

Complainant and his CHATROULETTE trademark are known internationally, with trademark registrations across numerous countries. Complainant registered in November 2009, and established its Chatroulette service and website very shortly thereafter, before Respondent registered the disputed domain names in January 2018.