WIPO Arbitration and Mediation Center ADMINISTRATIVE PANEL DECISION Inter-Continental Hotels Corporation, Six Continents Hotels, Inc. v. Daniel Kirchhof Case No. D2009-1661 1. The Parties
The Complainants are Inter-Continental Hotels Corporation and Six Continents Hotels, Inc. of Atlanta, Georgia, United States of America, represented by The GigaLaw Firm, United States.
The Respondent is Daniel Kirchhof of Leipzig, Germany. 2. The Domain Names and Registrar
The 1,542 disputed domain names, which are set out in Annex A to this decision, are (or were) registered with PSI-USA, Inc. dba Domain Robot. 3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 7, 2009. On December 7, 2009, the Center transmitted by email to PSI-USA, Inc. dba Domain Robot a request for registrar verification in connection with the disputed domain names. On December 7, 2009, PSI-USA, Inc. dba Domain Robot 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(a) and 4(a), the Center formally notified the Respondent of the Complaint, and the proceedings commenced on December 10, 2009. In accordance with the Rules, paragraph 5(a), the due date for Response was December 30, 2009. The Respondent did not submit any response. Accordingly, the Center notified the Respondent's default on December 31, 2009.
On January 4, 2010, the Complainant requested that 13 disputed domain names which had been included in the original Complaint and which the registrar advised had expired, and which the Complainant apparently was able to subsequently register, be withdrawn from the Complaint. On January 5, 2010, the Center communicated to the Parties that, further to the Complainant's request and subject to any views the Panel may have on appointment regarding the issue, the 13 domain names would be regarded as withdrawn from the Complaint. The Center notes that the registrar of record for these 13 domain names is now MarkMonitor, Inc.
The Center appointed John Swinson as the sole panelist in this matter on January 5, 2010. 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. Communications occurring after Panel appointment
On January 11, 2010, the Respondent contacted the Center and made enquiries regarding the possibility of settlement of these proceedings. The Center, following consultation with the appointed Panel, referred both Parties to paragraphs 10 and 17 of the Rules, and asked that the Center be promptly notified of any settlement.
On January 12, 2010, the Complainant contacted the Center and requested that the Center re-confirm “independently and/or with the Registrar” that all of the disputed domain names remained locked and registered until the outcome of the proceeding.
On January 14, 2010, the Center forwarded a communication received from the registrar which seemingly concerned 782 of the disputed domain names. According to this communication from the registrar, the Respondent had requested deletion of those domain names. The Center requested that the domain names remain locked pending resolution of the matter, notified both Parties of the registrar's communication, and invited the Complainant to comment on the matter prior to January 15, 2010 if it wished to do so.
On January 14, 2010, the Center received from the registrar a clarification of its earlier communication that an error had occurred, that the above-mentioned 782 domain names were not in fact under dispute in the present WIPO proceedings, and confirming that (other than the 13 disputed domain names in Annex A.3 which had been deleted prior to the dispute) the 1,529 disputed domain names in the present WIPO matter “will remain locked and registered until a decision has been reached.” The Center forwarded this communication to the Parties on January 14, 2010, and indicated that accordingly it would no longer be necessary for the Complainant to submit comments on the matters raised in the registrar's earlier communication.
On January 14, 2010, Mr. Witzmann (on behalf of the Respondent) stated that the Respondent “is willing to give his consent to transfer, not to simply delete or release the domains in dispute” (original emphasis). The Center invited the Complainant to comment on Respondent's communication of January 14, 2010. The Complainant did so on the same day advising that it wished to proceed with the Panel decision, but that the Respondent's consent to transfer the disputed domain names should be taken into account in any decision.
The Panel deems it appropriate to consider all of these communications in its decision, as they are relevant to the issues and both Parties were given adequate opportunity to comment on the matters raised. 5. Preliminary issues Withdrawn domain names
As mentioned above, the Complaint filed in this proceeding originally related to 1,542 domain names. See Annex A. On December 7, 2009, in its response to the Center's request for registrar verification, PSI-USA, Inc. dba Domain Robot advised the Center that 13 domain names (see Annex A.3) could not be locked in accordance with normal procedures, because they had been deleted prior to the filing of the dispute. The Center advised both Parties of this fact on December 8, 2009, and invited both Parties to contact the registrar to resolve the issue, should they wish to do so, pursuant to the ICANN Expired Domain Deletion Policy.
All 13 domain names were later registered by the Complainant Six Continents Hotels, Inc. on or around January 4, 2010. As such, the Complainant requested that these 13 domain names be removed from the Complaint.
From the evidence available on the record, the Respondent did not attempt to contact the registrar in relation to these domain names.
The 13 disputed domain names now owned by the Complainant and accordingly requested to be withdrawn from the Complaint are set out in Annex A.3.
The Panel agrees that it is appropriate in the circumstances for the above-referenced 13 domain names to be removed from these proceedings, and their requested withdrawal is hereby formalized by the Panel as set out in Annex A.3. Multiple complainants
Two companies have brought this Complaint: Six Continents Hotels, Inc and Inter-Continental Hotels Corporation. Six Continents Hotels, Inc. owns certain trade marks related to the dispute, while Inter-Continental Hotels Corporation owns others. The Complainants have requested that the disputed domain names be transferred to Six Continents Hotels, Inc. if they are successful.
The issue of multiple complainants was recently discussed in Fulham Football Club (1987) Limited, Tottenham Hostpur Public Limited, West Ham United Football Club PLC, Manchester United Limited, The Liverpool Football Club And Athletic Grounds Limited v. Domains by Proxy, Inc./ Official Tickets Ltd,WIPO Case No. D2009-0331. Reference was made in that case to the extent the Policy and Rules deal with this issue:
“Paragraph 3(c) of 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. Paragraph 4(f) of the Policy provides that where there are multiple disputes between a complainant and respondent, either party may petition to consolidate the disputes before a single administrative panel. Under paragraph 4(f) of the Policy the consolidation petition is made to the first administrative panel appointed to hear a pending dispute between the Parties, this administrative panel may consolidate before it any or all such disputes in its sole discretion, provided the disputes are governed by the Policy. Under paragraph 10(e) of the Rules it is for the panel to decide a request by a party to consolidate multiple domain name disputes in accordance with the Policy and Rules.
Neither the Policy nor the Rules expressly provides for the consolidation of multiple complainants in a single complaint. While both the Policy and Rules use the term ‘complainant' throughout, the Policy and Rules do not expressly preclude multiple legal persons from falling within the term ‘complainant'.”
Moreover, in Mucos Emulsions, GmbH and Marlyn Nutraceuticals, Inc. v. E and Kim Taeho,WIPO Case No. D2000-1513 it was stated ten years ago:
“In Ken Done, Ken Done & Associates Pty Limited, and Ken Done Down Under Pty Limited v. Ted Gibson, eResolution Case No. AF-0638, the panel concluded that a complaint may be submitted by multiple related parties where there are common interests in a single domain name. In that case, the joint complainants failed to present their claim adequately as they obscured the trademark ownership interests among each of the parties, requested an ambiguous remedy by not stating to which of the Complainants the contested domain name should be transferred to, and avoided the identification of each party's stake in the remedy. That is not the situation here. The panel notes that a number of cases under the ICANN Policy have been decided in favour of the Complainant despite the fact that more than one Complainant instituted the proceeding. (See Bettina Liano and Bettina Liano Pty Limited v. Khanh Kim Huynh,WIPO Case No. D2000-0891; NFL Properties, Inc. et al. v. Rusty Rahe,WIPO Case No. D2000-0128).”
The Complainants submit that this is an appropriate case for multiple complainants, because both Parties have a common legal interest and/or have been the target of common conduct by the Respondent.
Although they are strictly separate entities, both Complainants are members of the same corporate group (InterContinental Hotels Group, “IHG”) and therefore have a common legal interest.
Further, the large number of disputed domain names are all very similar in structure and format, and the websites to which they resolve appear to be derived from the same template, meaning that each Complainant's case against the Respondent is almost identical in nature. The Respondent's conduct in relation to the majority of the disputed domain names has been consistent regardless of the Complainant involved. Additionally, there is only one registrar for all the disputed domain names.
The Panel therefore concludes that the inclusion of multiple complainants in this case is acceptable. There is clearly a common grievance on the part of both Complainants, and despite the extremely large and unprecedented number of disputed domain names, it would be procedurally efficient to deal with all matters in the one proceeding given the almost identical facts among them.
The present case presents a text book example of the type of bulk registration strategy to which UDRP process and jurisprudence is having to adapt in order to keep pace with the broader developments and registration trends within the domain name system.
The Panel also notes that a prior UDRP decision (Six Continents Hotels, Inc., Inter-Continental Hotels Corporation v. South East Asia Tours,WIPO Case No. D2004-0388) was commenced by the same two Complainants, and no issues were raised with the joinder in that case.
For the purposes of this decision, “Complainant” will refer to both Complainants, unless a specific Complainant is named. 6. Factual Background
Both Complainant companies (Six Continents Hotels, Inc and Inter-Continental Hotels Corporation) are members of the IHG.
The IHG is an international organisation which manages and operates hotels in the Americas, Asia, Australasia, Europe, China, the Middle East and Africa. The IHG operates hotels either as a franchisor under franchise agreements (which comprises the majority of its business), or as a manager or owner of the property.
IHG currently operates a large number of hotels under seven brands, being “InterContinental”, “Crowne Plaza”, “Holiday Inn”, “Holiday Inn Express”, “Candlewood Suites”, “Staybridge Suites” and “Hotel Indigo”. The Complainant owns registered trade marks covering these brands, in many geographic regions around the world.
The Respondent appears to be an individual resident in Germany. According to the website “”, the Respondent (via the email address “daniel.kirchhof@”) is the contact in WhoIs records for over 70,000 domain names.
The Respondent (or the company he is associated with, Unister GmbH) does not seem to have been involved as a party in prior UDRP decisions.
The 1,529 disputed domain names the subject of this dispute were registered over the period spanning December 9, 2008 to July 21, 2009 however the vast majority were registered over a period of five days (between July 17 to 21, 2009).
The websites operating from disputed domain names follow a similar layout and format. The following description is specific to “”, but the description is equally applicable to websites operating from other disputed domain names (save for the name of the hotel):
The headline of the website is “Hotel InterContinental Amstel” following by an image of five stars. There are tabs for “Homepage”, “Hotel offers”, “Hotel pictures” and “Surrounding pictures”.
The homepage provides some limited information on the location and features of the property, with a link titled “Hotelinfos” which opens a separate pop-up window that is titled “InterContinental Amstel” and sets out more information about this hotel. This separate window notes that the website at the disputed domain name is “powered by ”. The window also contains advertising links, typically including to the Complainant's websites (for example, “”) as well as third party websites (for example, “/b&b”). These appear to be Google-sourced advertisements. The information provided in this window also includes a hotel description, list of facilities, information on check-in and check-out and nearby attractions, and makes the following statement:
“Note: It is the responsibility of the hotel chain and/or the individual property to ensure the accuracy of the photos displayed. is not responsible for any inaccuracies in the photos.”
The homepage allows a user to post a review or check rates and availability. When a search for rates or availability is entered, a message appear:
“Please Wait. We are searching for the best deals from over 220.000 hotels”
and then the site diverts to the “www.” booking engine, at the relevant listing for that specific property.
The “Hotel offers” page contains availability and rates for the property which are similar to those appearing on the “www.” website. The page also contains advertisements sponsored by Google including the Complainant's websites (“” and “”), other hotel booking engine websites (“”), and websites relating to hotels not affiliated or associated with the Complainant.
The “Hotel pictures” page contains a large number of professional looking photos of a hotel and its surroundings. At least some of these photos are extremely similar to the photographs appearing on the Complainant's website (see “/impressions/photo_tour.cfm”). Sponsored advertising links (of the same nature referred to in the paragraph above) also appear on this page.
The “Surrounding pictures” page contains a large number of photos of Amsterdam, which are noted to have been provided by Google's Panoramio service. Sponsored advertising links (of the same nature referred to above) also appear on this page. 7. Parties' Contentions A. Complainant
The Complainant makes the following contentions: Identical or Confusingly Similar
The InterContinental Hotels Group is the world's largest hotel group in terms of the number of rooms it owns, manages or controls (being over 4,300 hotels and 630,000 rooms in almost 100 countries around the world). IHG hotel brands include Holiday Inn, InterContinental, Crowne Plaza, Hotel Indigo, Staybridge Suites and Candlewood Suites.
IHG also manages the world's largest hotel loyalty program, Priority Club Rewards. Holiday Inn brand
This brand was founded in 1952 and is currently used in connection with over 3,000 hotels worldwide, offering over 420,000 hotel rooms.
The Complainant or its affiliates own over 1,750 trade mark registrations in at least 200 countries or geographic regions worldwide which consist of or contain the mark HOLIDAY INN. One of the first HOLIDAY INN trade mark registrations was registered in the United States on July 13, 1954. Previous UDRP decisions have found that the Complainant owns strong rights in and to the HOLIDAY INN trade mark (i.e. that the name is inherently distinctive, widely recognised, famous and/or iconic).
The Complainant (Six Continents Hotels, Inc.) is the registrant of over 1,000 domain names that consist of or contain the mark HOLIDAY INN or variations thereof. Intercontinental brand
This brand was founded in 1948 and is currently used in connection with over 150 hotels worldwide, offering over 54,000 hotel rooms.
The Complainant or its affiliates own at least 370 trade mark registrations in at least 165 countries or geographic regions worldwide, which consist of or contain the mark INTERCONTINENTAL. One of the first INTERCONTINENTAL trade mark registrations was registered in the United States on April 28, 1970. Previous UDRP decisions have found that the Complainant owns trade mark rights in INTERCONTINENTAL.
The Complainant (Six Continents Hotels, Inc.) is the registrant of over 290 domain names that consist of or contain the mark INTERCONTINENTAL or variations thereof. Crowne Plaza brand
This brand was founded in 1983 and is currently used in connection with over 350 hotels worldwide, offering over 98,000 hotel rooms.
The Complainant or its affiliates own at least 275 trade mark registrations in at least 95 countries or geographic regions worldwide, which consist of or contain the mark CROWNE PLAZA. One of the first CROWNE PLAZA trade mark registrations was registered in the United States on September 18, 1984. Previous UDRP decisions have found that the Complainant owns strong trade mark rights in CROWNE PLAZA (i.e. that the name is well-known in many countries, and has developed significant goodwill).
The Complainant (Six Continents Hotels, Inc.) is the registrant of over 270 domain names that consist of or contain the mark CROWNE PLAZA or variations thereof. Staybridge Suites brand
This brand was founded in 1997 and is currently used in connection with over 160 hotels worldwide, offering over 18,000 hotel rooms.
The Complainant or its affiliates own at least 96 trade mark registrations in at least 50 countries or geographic regions worldwide, which consist of or contain the mark STAYBRIDGE SUITES. One of the first STAYBRIDGE SUITES trade mark registrations was registered in the United States on June 29, 1999. Previous UDRP decisions have found that the Complainant owns strong trade mark rights in STAYBRIDGE SUITES.
The Complainant (Six Continents Hotels, Inc.) is the registrant of over 140 domain names that consist of or contain the mark STAYBRIDGE SUITES or variations thereof. Hotel Indigo brand
This brand was founded in 2004 and is currently used in connection with 28 hotels worldwide, offering over 3,000 hotel rooms.
The Complainant or its affiliates own at least 133 trade mark registrations in at least 60 countries or geographic regions worldwide, which consist of or contain the mark HOTEL INDIGO. One of the first HOTEL INDIGO trade mark registrations was registered in the United States on May 17, 2005.
The Complainant (Six Continents Hotels, Inc.) is the registrant of over 80 domain names that consist of or contain the mark HOTEL INDIGO or variations thereof. Candlewood Suites brand
This brand was founded in 1995 and is currently used in connection with 229 hotels worldwide, offering over 22,000 hotel rooms.
The Complainant or its affiliates own at least 67 trade mark registrations in at least 34 countries or geographic regions worldwide, which consist of or contain the mark CANDLEWOOD. One of the first CANDLEWOOD trade mark registrations was registered in the United States on December 24, 1996.
The Complainant (Six Continents Hotels, Inc.) is the registrant of over 55 domain names that consist of or contain the mark CANDLEWOOD or variations thereof. The disputed domain names
Each disputed domain name contains one of the Complainant's trade marks in its entirety, plus one or more hyphens, plus one or more geographic identifiers. Hyphens (as punctuation) are not a distinguishing feature of the disputed domain names and do not prevent a finding of confusingly similarity.
Use of the entire trade mark in a domain name is sufficient to establish confusing similarity under the Policy. Previous panel decisions have also found that use of one of the Complainant's trade marks in association with a geographic term (such as Phi Phi Island or South Carolina) is also confusingly similar.
Each of the disputed domain names is confusingly similar to one of the Complainant's trade marks referred to above. Rights or Legitimate Interests
The Complainant has never assigned, granted, licensed, sold, transferred or authorised the Respondent to register or use any trade mark referred to above. Therefore there is no relationship between the Complainant and Respondent, commercial or otherwise, which entitles the Respondent to use the Complainant's trade marks.
The Respondent has never used or made preparations to use the disputed domain names in connection with a bona fide offering of goods or services. Rather the Respondent uses the disputed domain names in relation to websites which falsely appear to be associated with the Complainant. A typical website displays information about a single hotel and provides links for more information including reservations. The links then display Google advertisements for websites which offer hospitality services in competition with the Complainant's services (such as Marriott, Travel Lodge, etc). Such use of the disputed domain names is not bona fide, because it attracts traffic by using a domain name which is confusingly similar to an established trade mark, creating confusion amongst the Complainant's customers.
The Respondent does not appear to have ever been known by any of the disputed domain names, or acquired any trade mark rights in such names. The registrant of the disputed domain names is “Daniel Kirchhof” which is not similar to any of the disputed domain names. It is extremely unlikely that the Respondent would be known by any of these domain names, given that the Complainant's rights in its trade marks have existed for between 5 and 50 years or more.
The Respondent is not making a legitimate noncommercial or fair use of the disputed domain names. Instead, the Respondent has made an illegitimate, commercial, unfair use of the disputed domain names, with intent for commercial gain by misleadingly diverting consumers and advertising services that compete with the Complainant's services. The Respondent's obvious purpose is to mislead consumers into believing that the Respondent's websites are associated with the Complainant. Registered and used in bad faith
The Respondent has demonstrated bad faith under paragraph 4(b)(ii) of the Policy in that he has registered the disputed domain names to prevent the Complainant from reflecting its trade marks in corresponding domain names, and has clearly engaged in a pattern of such conduct (by registering over 1,500 domain names). The Respondent also owns a large number of domain names (over 22,000 names) that contain trade marks owned by hotel companies other than the Complainant, including Best Western, Doubletree and Hilton.
The Respondent has demonstrated bad faith under paragraph 4(b)(iii) of the Policy in that he has registered the disputed domain names for the purpose of disrupting the business of a competitor, being the Complainant. The websites operating from the disputed domain names falsely appear to be associated with the Complainant by displaying information about the Complainant's hotels, together with links for hospitality information and services of other hotels. The Respondent is therefore a competitor to the Complainant because he is selling hotel services. By selling such services under the Complainant's trade marks, the Respondent is disrupting the Complainant's business.
The Respondent has demonstrated bad faith under paragraph 4(b)(iv) of the Policy in that he has registered the disputed domain names to intentionally attempt to attract for commercial gain, Internet users to his websites, by creating a likelihood of confusion with the Complainant's trade marks. The Respondent would have known of the Complainant's trade marks at the time of registering the disputed domain names, because such marks are well-known throughout the world and the subject of a large number of trade mark registrations. It is clear that the Respondent would have been aware of the Complainant's marks as well as the Complainant's related domain names, which constitutes strong evidence of bad faith.
The Respondent registered the disputed domain names well after the establishment and registration of the Complainant's trade marks, and in some cases over 50 years later.
The Complainant's legal representative sent a letter of demand to the Respondent on July 28, 2009 and the Respondent has never responded to this letter. B. Respondent
The Respondent did not reply to the Complainant's contentions.
On December 10, 2009, the Center was contacted by telephone by Mr. Witzmann, who claimed to be a representative of the Respondent. Mr. Witzmann made general enquiries regarding the UDPR process, but did not provide any substantive response or statements on behalf of the Respondent.
On January 11, 2009, the Center was contacted by telephone by Mr. Witzmann on behalf of Respondent. Mr. Witzmann requested information regarding the possibility of settlement of these proceedings, but did not provide any substantive response or statement in relation to the proceeding.
On January 14, 2009, Mr. Witzmann sent an email to the Center and the Complainant, stating that the Respondent “is willing to give his consent to transfer, not to simply delete or release the domains in dispute. Therefore he announces his approval for a transfer of all domains that he still holds according to the latest information of PSI to the complainant. It is now up to the complainant to initiate a domain transfer. In case you deem this declaration not satisfactory to stop the proceedings, please contact me in order to enable a formally correct statement by Mr. Kirchhof.” (The Panel notes that any issue of “formal” correctness was in any event made moot by Complainant's subsequent comments of January 14, 2010 indicating rejection of this offer). 8. Discussion and Findings
At the time of finalising this decision, the Panel was not made aware of any settlement that had been reached between the Parties in relation to the disputed domain names. Accordingly, the Panel has proceeded to make the following decision on the basis of the record provided to it.
According to paragraph 15(a) of the Rules: “A Panel shall 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 provides that a complainant must prove each of the following:
(i) that the disputed domain name is identical or confusingly similar to a trademark or a service mark in which the complainant has rights; and
(ii) that the respondent has no rights or legitimate interests in the disputed domain name; and
(iii) that the disputed domain name has been registered and is being used in bad faith.
Paragraph 4(a) of the Policy states that the burden of proof lies with the complainant to establish that all these three elements are satisfied. A. Identical or Confusingly Similar
A small selection of the Complainant's trade mark registrations relevant to this case are as follows: HOLIDAY INN:
- United States Trade Mark Registration No. 0592539, registered from July 13, 1954.
- Australian Trade Mark Registration No. 213211, registered from September 6, 1967.
- CTM Registration No. 0948949 (for the mark H HOLIDAY INN), registered from December 13, 2007. HOLIDAY INN EXPRESS
- United States Trade Mark Registration No. 2207318 (word and design mark) registered from December 1, 1998.
- Australian Trade Mark Registration No. 585530, registered from August 31, 1992.
- CTM Registration No. 0952876 (for the mark H HOLIDAY INN EXPRESS), registered from December 14, 2007. INTERCONTINENTAL
- United States Trade Mark Registration No. 0890271, registered from April 28, 1970.
- Australian Trade Mark Registration No. 221775 (word and design mark), registered from August 23, 1968.
- CTM Registration No. 002787646 (word and design mark), registered from June 14, 2006. CROWNE PLAZA
- United States Trade Mark Registration No. 1297211, registered from September 18, 1984.
- Australian Trade Mark Registration No. 393927, registered from July 11, 1983.
- CTM Registration No. 001017946, registered from December 17, 2002. STAYBRIDGE SUITES
- United States Trade Mark Registration No. 2257830, registered from June 29, 1999.
- Australian Trade Mark Registration No. 750151, registered from December 2, 1997.
- CTM Registration No. 000692988, registered from March 15, 1999. STAYBRIDGE
- United States Trade Mark Registration No. 2908784, registered from December 7, 2004.
- CTM Registration No. 003582038, registered from March 18, 2005. HOTEL INDIGO
- United States Trade Mark Registration No. 2953309, registered from May 17, 2005.
- Australian Trade Mark Registration No. 1024780, registered from October 12, 2004.
- CTM Registration No. 004126199 (word and design mark), registered from April 21, 2006. CANDLEWOOD
- United States Trade Mark Registration No. 2025101, registered from December 24, 1996. CANDLEWOOD SUITES
- United States Trade Mark Registration No. 2282959, registered from October 5, 1999.
- Australian Trade Mark Registration No. 1042148, registered from February 15, 2005.
- CTM Registration No. 001267962, registered from August 17, 2000.
The Panel is satisfied that the Complainant has registered trade mark rights in each of the marks referred to above. Further, the Panel agrees with previous decisions which accept that some of these trade marks are extremely well-known throughout the world: see for example, Six Continents Hotels, Inc. v. Ameriasa,WIPO Case No. D2002-1132; Six Continents Hotels, Inc. v. Patrick Ory,WIPO Case No. D2003-0098; Six Continents Hotels, Inc. v. CredoNIC.com / Domain For Sale, WIPO Case No. D2005-0755. Many cases involving the Complainant have decided that the Complainant's trade marks are distinctive, even when combined with other terms.
The Complainant is part of a large, international hotel group, which claims to be the world's largest hotel group based on the number of rooms it makes available. The majority, if not all, of these trade marks are registered in a large number of countries throughout the world. The majority are also longstanding trade marks, which have been registered and continuously maintained by the Complainant for decades.
The next question to determine is whether the disputed domain names are identical or confusingly similar to the Complainant's trade marks.
For convenience, the Panel has divided the disputed domain names into the following four categories: 1. Disputed domain names which contain one of the Complainant's trade marks in its entirety combined with a geographic term (or abbreviation of a geographic term)
The geographic term may be the name of a locality, town, suburb, city or country, or a landmark or place (such as an airport or university). Domain names in this category include: , , , , , , , and .
The majority of disputed domain names fall within this first category.
In relation to this category, the Panel notes that when a domain name incorporates a complainant's trade mark in its entirety, it is usually found to be confusingly similar to that trade mark despite the addition of other words. See, for example, Chanel, Inc. v. Estco Technology Group,WIPO Case No. D2000-0413.
Previous panels have expressed the opinion that a domain name that consists of a trade mark plus a geographic term is confusingly similar to the trade mark. See, for example, Accor v. Lee Dong Youn,WIPO Case No. D2008-0705.
This same line of reasoning is certainly applicable in this case, particularly because the Complainant's trade marks are famous or at least well-known in many countries, highly distinctive (either due to their notoriety or due to the fact that they are made-up words), and the geographic term relates to a city or town where one of the Complainant's hotels are or could be located.
Disputed domain names falling within this category are confusingly similar to the Complainant's trade marks. 2. Disputed domain names which contain one of the Complainant's trade marks in its entirety combined with a descriptive term (or an abbreviation of a descriptive term)
Domain names in this category include: , , , and .
This category is very similar in nature to the first category and similar comments apply.
Previous panels have held that the addition of a generic term to a trade mark does not necessarily eliminate the likelihood of confusion. Many previous decisions have found a domain name to be confusingly similar to a registered trade mark where that name consists of the trade mark coupled with a generic term. See, for example, Minnesota Mining and Manufacturing Company v. Mark Overbey,WIPO Case No. D2001-0727.
The Complainant's primary business is providing hotel accommodation, and the disputed domain names within this category incorporate words which have some relevance to goods or services provided within this industry. For example, it would not be unreasonable for a user to believe that the disputed domain name provides information on Holiday Inn Express hotels near universities. For the majority of these disputed domain names, the generic words appear to relate to the common or trading name of the hotel operated by the Complainant (for example, “Candlewood Houston By The Galleria” or “Crowne Plaza Pensacola Grand Hotel”).
As mentioned above, a number of the Complainant's trade marks are extremely well-known and highly distinctive. The combination of these distinctive trade marks with generic words relevant to potential hotel guests creates an immediate potential for false association with the Complainant's trade marks. See, for example, adidas-Salomon AG v. Digi Real Estate Foundation, Patrick Williamson,WIPO Case No. D2006-0748.
Disputed domain names falling within this category are confusingly similar to the Complainant's trade marks. 3. Disputed domain names which commence with part of the Complainant's trade mark in combination with a geographic location or generic term (or abbreviation thereof)
An example of domain names in this category are: , , , , , , , , and . Generally, these domain names commence with the prefix “indigo”, “holiday-exp”, “holiday” or “holiday-suites”.
Although “indigo” has an ordinary dictionary meaning, this word is not widely used in commerce, and the Panel finds that it is a distinctive part of the Complainant's HOTEL INDIGO trade marks. Accordingly, the disputed domain names commencing with “indigo” and coupled with a geographic or generic term, are confusingly similar to the Complainant's trade marks.
The marks containing “hotel” or “holiday” require further discussion, as these terms are widely used, generic terms, and when coupled with another generic term or a geographic location, there is a possibility that they will be recognised for their generic value, rather than as a trade mark (or an abbreviation of a trade mark).
An abbreviation of a registered trade mark incorporated into a domain name may be confusingly similar to the trade mark (see, for example, Dow Jones & Company, Inc. & Dow Jones LP v. T.S.E. Parts,WIPO Case No. D2001-0381), however this is not an absolute rule and whether an abbreviation is considered to be confusingly similar will turn on the facts of each case (see, for example, Banque Saudi Fransi v. ABCIB,WIPO Case No. D2003-0656).
The Complainant did not submit any evidence that it abbreviates its HOLIDAY INN, HOLIDAY INN EXPRESS or HOTEL INDIGO trade marks, or that abbreviations of its trade marks are recognised as relating to the Complainant.
In the case of disputed domain names incorporating the prefix “holiday-exp”, the Panel finds that the disputed domain names with such abbreviation are confusingly similar to the Complainant's well-known HOLIDAY INN EXPRESS trade mark. This is because “exp” is a common and well-known abbreviation for “express”.
The Panel also finds the disputed domain names incorporating the prefix “holiday-suites” to be confusingly similar to the Complainant's trade marks referred to above. This is because the domain name could be viewed as replacing one word in one of the Complainant's trade mark (i.e. “Inn”), with a word which has a similar meaning and has a clear connection to hotels and accommodation (i.e. “Suites”). Further, “suites” is a word that the Complainant utilises in its trade marks (for example, STAYBRIDGE SUITES) and this combination (of “holiday” and “suites”) likely would be associated with the Complainant due to the nature of the Complainant's business. When “holiday-suites” is used in a disputed domain name, in combination with a geographic location or generic term related to hotel services, there is confusing similarity with the Complainant's HOLIDAY INN and HOLIDAY INN EXPRESS trade marks.
Finally, in the case of disputed domain names with the prefix “holiday” or “hotel”, the Panel finds that, on balance, these disputed domain names are confusingly similar to the Complainant's HOLIDAY INN and HOLIDAY INN EXPRESS trade marks or HOTEL INDIGO marks (as applicable).
The Panel has given due consideration to the fact that “holiday” or “hotel” are on their own, generic and widely used terms. However, in the unusual circumstances of this dispute, the Panel is prepared to find confusingly similarity in relation to disputed domain name starting with “holiday” or “hotel”. In doing so, the Panel took into account the following factors:
- previous decisions refer to the HOLIDAY INN and HOLIDAY INN EXPRESS marks being “famous”, “extremely well known” or even “iconic” (see, for example, Six Continents Hotels, Inc. v. Ameriasa,WIPO Case No. D2002-1132; Six Continents Hotels, Inc. v. CredoNIC.com / Domain For Sale,WIPO Case No. D2005-0755);
- HOLIDAY INN and HOLIDAY INN EXPRESS trade marks have been registered for many years before the Respondent's registration of the disputed domain names;
- the trade mark HOLIDAY INN and HOLIDAY INN EXPRESS are used in relation to more than three thousand hotels around the world;
- use of “holiday” or “hotel” at the beginning of the disputed domain names draws attention to that component of the disputed domain name, and this is also the first word of the Complainant's trade marks;
- “holiday” or “hotel” are followed by a reference to a location which is a location of one of the Complainant's hotels;
- the volume and nature of the domain names registered by the Respondent; and
- the Respondent's statements of January 14, 2010 referred to in paragraph 7.B above.
Accordingly, the Panel is prepared to find, on the specific facts of this case, that disputed domain names commencing with the prefix “holiday” or “hotel”, are confusingly similar to the Complainant's registered trade marks.
Disputed domain names falling within this category are confusingly similar to the Complainant's trade marks. 4. Disputed domain names which do not contain any of the Complainant's trade marks
These domain names are: , , , , , , , , and .
The Panel notes that some of these disputed domain names also contain the word “holiday” (and could fall within the third category). However the Panel draws a distinction, as in this category “holiday” is not the first word of the domain name, and a person's attention is not drawn to the “holiday” component to the extent that it would be were the “holiday” component was positioned at the beginning of the disputed domain name.
The association between these disputed domain names and the Complainant is not obvious, and the Complainant did not set out how these disputed domain names are associated with the Complainant or its trade marks.
The Panel notes that some of the websites operating from the above disputed domain names do advertise hotels owned or managed by the Complainant (for example, ). However, as noted in the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, paragraph 1.2, “the content of a website (whether it is similar or different to the business of a trademark owner) is irrelevant in the finding of confusing similarity” (see for example, Arthur Guinness Son & Co. (Dublin) Limited v. Dejan Macesic,WIPO Case No. D2000-1698).
On this basis, based on the evidence before the Panel, the Panel is unable to find that the ten disputed domain names in this fourth category are identical or confusingly similar to a trade mark belonging to the Complainant. Any reference to “disputed domain names” in the remainder of this decision should be read as a reference to the disputed domain names, excluding the ten domain names listed above in this paragraph (and as set out in Annex A.2). B. Rights or Legitimate Interests
According to paragraph 4(c) of the Policy, a respondent may establish its rights or legitimate interests in a domain name, among other circumstances, by showing any of the following elements:
“(i) before any notice to you [respondent] of the dispute, your use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or
(ii) you [respondent] (as an individual, business, or other organization) have been commonly known by the domain name, even if you have acquired no trademark or service mark rights; or
(iii) you [respondent] are making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.”
To succeed on this element, the complainant must make out an initial prima facie case that the respondent lacks rights or legitimate interests in the disputed domain name. If such a prima facie case is made out, the respondent then has the burden of demonstrating rights or legitimate interests in the domain name.
In relation to this element, the Complainant has made the following assertions:
1. The Complainant has never granted the Respondent any right or licence to use its trade marks, in domain names or otherwise. There is no commercial or other relationship between the Complainant and the Respondent.
2. The Respondent does not appear to have ever been known by the disputed domain names.
3. The Respondent is not making a legitimate noncommercial use or fair use of the disputed domain names.
4. The Respondent had not used (and has no intention of using) the disputed domain names in connection with a bona fide offering of goods and services.
The Panel agrees with each of the Complainant's statements in this regard.
After reviewing the websites operating from the disputed domain names, there is clearly no legitimate noncommercial or fair use on the part of the Respondent. The websites contain a mechanism for booking rooms in the Complainant's hotels using a third party booking engine. The websites also contain links to third party websites (or the Complainant's own websites), and sponsored advertising which is likely to entitle the Respondent to receive commercial revenue and directs potential customers of the Complainant to websites of its competitors. This clearly constitutes commercial use of the disputed domain names without the Complainant's authorisation.
Similarly, the use of the disputed domain names in this manner cannot be considered use in connection with a bona fide offering of goods or services. Attempting to attract Internet users through misuse of a well-known trade mark, and the provision of links which promote goods and services competitive to the Complainant, cannot be considered a bona fide use.
In the Panel's view, the Respondent cannot be considered as an authorized sales or service agent of the Complainant's trade marked services, as was the case in Oki Data Americas, Inc. v. ASD, Inc.,WIPO Case No. D2001-0903. The Respondent is not using the websites to sell only the Complainant's goods - the websites contain numerous links to third party websites which offer competing goods and services to the Complainant's goods and services. Further, the websites do not accurately clarify the Respondent's relationship with the trade mark owner, and they falsely suggest that the website is the official site, rather than merely one website which a potential visitor may use to book a stay at the Complainant's hotel.
Therefore, the fact that the Respondent's websites link to a booking engine for hotels (even a booking engine that allows one to book the Complainant's hotels) is not sufficient to constitute rights or legitimate interests, or an offering of bona fide goods and services. The Respondent is using the disputed domain names containing the Complainant's trade marks to sell rooms in the Complainant's hotel, without the Complainant's knowledge or approval. By controlling the disputed domain names, the Respondent has illegitimately placed itself in a stronger position than other authorised resellers of the accommodation managed by the Complainant's related entities (Mikimoto (America) Co. v. Asanti Fine Jewellers Ltd., Case No. AF-0126, cited in Nikon, Inc. and Nikon Corporation v. Technilab, Inc.,WIPO Case No. D2000-1774).
The websites resolving from the disputed domain names create the impression that they are official websites for the relevant hotel, or potentially, that the Respondent manages the hotel. By using the Complainant's trade marks, the Respondent is falsely suggesting he is the trade mark owner or the website is the official site for the accommodation of the Complainant's related entities when it is not (Houghton Mifflin Co. v. The Weathermen, Inc.,WIPO Case No. D2001-0211; R.T. Quaife Engineering, Ltd. and Autotech Sport Tuning Corporation d/b/a Quaife America v. Bill Luton,WIPO Case No. D2000-1201). This is not a legitimate or fair use of the disputed domain names.
Each of the Complainant's trade marks are well-known around the world, and the Panel considers it unlikely that any registrant would legitimately choose to use any of them without deliberate reference to the Complainant. It is more likely that the purpose is to create an impression of an association with the Complainant (see Sony Kabushiki Kaisha a/t/a Sony Corporation v. A Lista Brasil - Internet Solutions Ltda,WIPO Case No. D2005-0633).
Accordingly, the Panel concludes that the Respondent intentionally selected domain names which contained the Complainant's trade marks, and added a word or words which do not serve to distinguish them, but which strengthens the association with the Complainant or its goods and services, for the purpose of redirecting Internet users to his own websites. Such use cannot constitute a bona fide offering of goods of services (see The Coryn Group, Inc., Apple Vacations West, Inc. v. V.S. International,WIPO Case No. D2003-0664).
The Complainant has presented a strong prima facie case indicating that the Respondent does not have any rights or legitimate interests in the disputed domain names. The Panel notes that the Respondent has failed to submit a Response in this proceeding. As such, the Respondent has failed to rebut the Complainant's strong prima facie case. C. Registered and Used in Bad Faith
Paragraph 4(b) of the Policy enumerates four non-inclusive circumstances that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. The Complainant alleges that the Respondent has engaged in the type of behaviour described in subparagraphs (ii), (iii) and (iv) of paragraph 4(b) of the Policy, and has also engaged in other acts of bad faith.
Subparagraph (ii) provides for circumstances where the respondent has engaged in a pattern of conduct of registering domain names in order to prevent the owner of the trade mark from reflecting the mark in a corresponding domain name.
The Respondent has not been named as a respondent in previous UDRP decisions. However the fact that this proceeding has been brought in relation to over 1,500 domain names which contain the Complainant's trade marks, makes it clear that the Respondent has engaged in a pattern of registering domain names in order to prevent a trade mark owner from reflecting their mark in a corresponding domain name. The Panel's view is further supported by the fact that the Respondent owns a vast array of other domain names.
This is clear evidence of bad faith.
Subparagraph (iii) relates to respondents who have registered a domain name primarily for the purpose of disrupting the business of a competitor.
Under this subparagraph, there are three elements that must all be satisfied for a finding against the Respondent, being that: the Respondent knew of the Complainant's business, the “primary purpose” of the Respondent's registration was to disrupt the Complainant's business, and the Respondent and the Complainant are competitors (see for example, RuggedCom, Inc. v. LANstore, Inc.,WIPO Case No. D2005-0760).
It is not clear on the evidence that the Respondent's primary purpose was to disrupt the Complainant's business. Rather, the primary purpose appears to be to receive affiliate fees for referring potential guests to the “www.” booking engine.
Subparagraph (iv) includes circumstances where the respondent, by using a domain name, has intentionally attempted to attract, for commercial gain, Internet users to its website, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of the respondent's website.
It is extremely likely that the Respondent knew of the Complainant's trade marks and brand prior to the registration of the disputed domain names. The Panel infers that the Respondent registered the disputed domain names because they were likely to be confused by Internet users with the Complainant's trade marks and hotel business.
When arriving at the Respondent's websites, Internet users were likely to believe that they had arrived at the official website for one of the Complainant's hotels, as that is the clear impression given by the website content. As the websites provide a mechanism for booking at the hotel (albeit through another provider), the Complainant is likely to suffer commercial loss when an Internet user books through the Respondent's website when compared with a booking directly on one of the Complainant's websites. The Respondent is likely to receive a commercial gain through such transactions, as well as from displaying sponsored links to competitive goods and services.
The Complainant refers to other instances of bad faith, however given the ample evidence of bad faith discussed above, the Panel does not find it necessary to address these instances. 9. Decision
Of the 1,542 disputed domain names contested in this proceeding, the Panel makes the following order:
a) For all the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that 1,519 (of the 1,542) disputed domain names, as set out in Annex A.1 to this decision, be transferred to the Complainant Six Continents Hotels, Inc.
b) The Complaint is denied with regards to 10 disputed domain names, as set out in Annex A.2 to this decision.
c) The remaining 13 disputed domain names requested by the Complainant to be withdrawn from the original filed Complaint are confirmed as withdrawn, as set out in Annex A.3 to this decision.
John Swinson
Sole Panelist
Dated: January 19, 2010 ANNEX A
ANNEX A.1 - TRANSFERRED DOMAINS
Number
Disputed Domain Name
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
381
382
383
384
385
386
387
388
389
390
391
392
393
394
395
396
397
398
399
400
401
402
403
404
405
406
407
408
409
410
411
412
413
414
415
416
417
418
419
420
421
422
423
424
425
426
427
428
429
430
431
432
433
434
435
436
437
438
439
440
441
442
443
444
445
446
447
448
449
450
451
452
453
454
455
456
457
458
459
460
461
462
463
464
465
466
467
468
469
470
471
472
473
474
475
476
477
478
479
480
481
482
483
484
485
486
487
488
489
490
491
492
493
494
495
496
497
498
499
500
501
502
503
504
505
506
507
508
509
510
511
512
513
514
515
516
517
518
519
520
521
522
523
524
525
526
527
528
529
530
531
532
533
534
535
536
537
538
539
540
541
542
543
544
545
546
547
548
549
550
551
552
553
554
555
556
557
558
559
560
561
562
563
564
565
566
567
568
569
570
571
572
573
574
575
576
577
578
579
580
581
582
583
584
585
586
587
588
589
590
591
592
593
594
595
596
597
598
599
600
601
602
603
604
605
606
607
608
609
610
611
612
613
614
615
616
617
618
619
620
621
622
623
624
625
626
627
628
629
630
631
632
633
634
635
636
637
638
639
640
641
642
643
644
645
646
647
648
649
650
651
652
653
654
655
656
657
658
659
660
661
662
663
664
665
666
667
668
669
670
671
672
673
674
675
676
677
678
679
680
681
682
683
684
685
686
687
688
689
690
691
692
693
694
695
696
697
698
699
700
701
702
703
704
705
706
707
708
709
710
711
712
713
714
715
716
717
718
719
720
721
722
723
724
725
726
727
728
729
730
731
732
733
734
735
736
737
738
739
740
741
742
743
744
745
746
747
748
749
750
751
752
753
754
755
756
757
758
759
760
761
762
763
764
765
766
767
768
769
770
771
772
773
774
775
776
777
778
779
780
781
782
783
784
785
786
787
788
789
790
791
792
793
794
795
796
797
798
799
800
801
802
803
804
805
806
807
808
809
810
811
812
813
814
815
816
817
818
819
820
821
822
823
824
825
826
827
828
829
830
831
832
833
834
835
836
837
838
839
840
841
842
843
844
845
846
847
848
849
850
851
852
853
854
855
856
857
858
859
860
861
862
863
864
865
866
867
868
869
870
871
872
873
874
875
876
877
878
879
880
881
882
883
884
885
886
887
888
889
890
891
892
893
894
895
896
897
898
899
900
901
902
903
904
905
906
907
908
909
910
911
912
913
914
915
916
917
918
919
920
921
922
923
924
925
926
927
928
929
930
931
932
933
934
935
936
937
938
939
940
941
942
943
944
945
946
947
948
949
950
951
952
953
954
955
956
957
958
959
960
961
962
963
964
965
966
967
968
969
970
971
972
973
974
975
976
977
978
979
980
981
982
983
984
985
986
987
988
989
990
991
992
993
994
995
996
997
998
999
1000
1001
1002
1003
1004
1005
1006
1007
1008
1009
1010
1011
1012
1013
1014
1015
1016
1017
1018
1019
1020
1021
1022
1023
1024
1025
1026
1027
1028
1029
1030
1031
1032
1033
1034
1035
1036
1037
1038
1039
1040
1041
1042
1043
1044
1045
1046
1047
1048
1049
1050
1051
1052
1053
1054
1055
1056
1057
1058
1059
1060
1061
1062
1063
1064
1065
1066
1067
1068
1069
1070
1071
1072
1073
1074
1075
1076
1077
1078
1079
1080
1081
1082
1083
1084
1085
1086
1087
1088
1089
1090
1091
1092
1093
1094
1095
1096
1097
1098
1099
1100
1101
1102
1103
1104
1105
1106
1107
1108
1109
1110
1111
1112
1113
1114
1115
1116
1117
1118
1119
1120
1121
1122
1123
1124
1125
1126
1127
1128
1129
1130
1131
1132
1133
1134
1135
1136
1137
1138
1139
1140
1141
1142
1143
1144
1145
1146
1147
1148
1149
1150
1151
1152
1153
1154
1155
1156
1157
1158
1159
1160
1161
1162
1163
1164
1165
1166
1167
1168
1169
1170
1171
1172
1173
1174
1175
1176
1177
1178
1179
1180
1181
1182
1183
1184
1185
1186
1187
1188
1189
1190
1191
1192
1193
1194
1195
1196
1197
1198
1199
1200
1201
1202
1203
1204
1205
1206
1207
1208
1209
1210
1211
1212
1213
1214
1215
1216
1217
1218
1219
1220
1221
1222
1223
1224
1225
1226
1227
1228
1229
1230
1231
1232
1233
1234
1235
1236
1237
1238
1239
1240
1241
1242
1243
1244
1245
1246
1247
1248
1249
1250
1251
1252
1253
1254
1255
1256
1257
1258
1259
1260
1261
1262
1263
1264
1265
1266
1267
1268
1269
1270
1271
1272
1273
1274
1275
1276
1277
1278
1279
1280
1281
1282
1283
1284
1285
1286
1287
1288
1289
1290
1291
1292
1293
1294
1295
1296
1297
1298
1299
1300
1301
1302
1303
1304
1305
1306
1307
1308
1309
1310
1311
1312
1313
1314
1315
1316
1317
1318
1319
1320
1321
1322
1323
1324
1325
1326
1327
1328
1329
1330
1331
1332
1333
1334
1335
1336
1337
1338
1339
1340
1341
1342
1343
1344
1345
1346
1347
1348
1349
1350
1351
1352
1353
1354
1355
1356
1357
1358
1359
1360
1361
1362
1363
1364
1365
1366
1367
1368
1369
1370
1371
1372
1373
1374
1375
1376
1377
1378
1379
1380
1381
1382
1383
1384
1385
1386
1387
1388
1389
1390
1391
1392
1393
1394
1395
1396
1397
1398
1399
1400
1401
1402
1403
1404
1405
1406
1407
1408
1409
1410
1411
1412
1413
1414
1415
1416
1417
1418
1419
1420
1421
1422
1423
1424
1425
1426
1427
1428
1429
1430
1431
1432
1433
1434
1435
1436
1437
1438
1439
1440
1441
1442
1443
1444
1445
1446
1447
1448
1449
1450
1451
1452
1453
1454
1455
1456
1457
1458
1459
1460
1461
1462
1463
1464
1465
1466
1467
1468
1469
1470
1471
1472
1473
1474
1475
1476
1477
1478
1479
1480
1481
1482
1483
1484
1485
1486
1487
1488
1489
1490
1491
1492
1493
1494
1495
1496
1497
1498
1499
1500
1501
1502
1503
1504
1505
1506
1507
1508
1509
1510
1511
1512
1513
1514
1515
1516
1517
1518
1519
ANNEX A.2 - DENIED DOMAINS
Number
Disputed Domain Name
1
2
3
4
5
6
7
8
9
10
ANNEX A.3 - WITHDRAWN DOMAINS
Number
Disputed Domain Name
1
2
3
4
5
6
7
8
9
10
11
12
13
Full & Egal Universal Law Academy