The Complainant is ESH Strategies Branding, L.L.C. of Charlotte, North Carolina, United States of America ("United States"), represented by Deborah Lee-Serafini of Johnson & Martin, P.A., United States.

The Respondent is Shami Khokar, Integrity Net Solution & Services of Batangas City, Philippines. 2. The Domain Name and Registrar

The disputed domain name is registered with GoD, LLC (the "Registrar"). 3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the "Center") on July 18, 2018. On July 18, 2018, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 18, 2018, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details.

The Center verified that the 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 Respondent of the Complaint, and the proceedings commenced on July 31, 2018. In accordance with the Rules, paragraph 5, the due date for Response was August 20, 2018. The Respondent did not submit any response. Accordingly, the Center notified the Respondent's default on August 21, 2018.

The Center appointed Clive Duncan Thorne as the sole panelist in this matter on August 27, 2018. 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

According to the Complainant it owns and operates over 40,000 hotel rooms in the United States which it operates using the brand "Extended Stay America". It has registered numerous trade marks in the United States and Canada for EXTENDED STAY AMERICA, details of which are set out in Annexes 4 and 5 to the Complaint.

It relies upon specific registrations including, for example, United States Registration No. 2021504 registered on December 3, 1996 for EXTENDED STAY AMERICA. In addition the Complainant has registered and owns numerous domain names including the trade mark EXTENDED STAY AMERICA.

In summary the Complainant with its extensive hotel network has registered and applied worldwide for numerous trade marks incorporating EXTENDED STAY AMERICA so as to protect its brand worldwide. It also invests significant resources to advertise and promote the brand "Extended Stay America" worldwide.

It has fostered and maintained significant and valuable goodwill as well as acquiring an outstanding reputation in EXTENDED STAY AMERICA around the world. As a result the Complainant's brand is associated globally with its hotel product and is a famous trade mark worldwide.

The Respondent registered the disputed domain name on April 24, 2018, 22 years after the Complainant first registered its United States Mark Registration No. 2021504. Twice, on June 27 and July 9, 2018, the Complainant contacted the Respondent regarding the unauthorized use of the disputed domain name and requested a transfer. Copies of the correspondence are set out at Annex 7 to the Complaint. No response was received.

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