The Complainants are Northill Capital (Jersey) L.P. of Saint Helier, Bailiwick of Jersey and Northill Global Fund Managers Limited of Dublin, Ireland, represented by Dechert, United Kingdom of Great Britain and Northern Ireland (“United Kingdom”).
The Respondent is Name Redacted1 . 2. The Domain Name and Registrar
The disputed domain name is registered with Shinjiru MSC Sdn Bhd (the “Registrar”). 3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 20, 2017. On October 24, 2017, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 1, 2017, 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 November 10, 2017. In accordance with the Rules, paragraph 5, the due date for Response was November 30, 2017. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 1, 2017. An email communication from a third party was received by the Center on November 30, 2017.
The Center appointed Andrew D. S. Lothian as the sole panelist in this matter on December 17, 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 Complainants’ corporate group was founded in 2010 and trades under the NORTHILL trademark and the “Northill Global” brand. The Complainants’ group provides seed capital to start-up entities or early stage asset managers and equity capital to replace existing shareholders in larger, more established asset management businesses. The Complainants’ group owns a majority interest in assets under management totaling approximately USD 48 billion as at September 30, 2017. The second Complainant, which is a wholly owned subsidiary of the first Complainant, was registered on February 27, 2012 and has traded under the “Northill Global” brand since that date. The Complainants note that the second Complainant is authorized as a management company by the Central Bank of Ireland under applicable legislation.
The first Complainant is the owner of European Union registered trademark no. 10057198 for the word mark NORTHILL registered on November 17, 2011 in international classes 35 and 36. It is also the owner of United Kingdom registered trademark no. 2590817 for the word mark NORTHILL registered on November 11, 2011 in international class 36. The NORTHILL trademarks are used by the second Complainant under the authority of the first Complainant.
The WhoIs record for the disputed domain name shows that it has a “Created Date” of September 17, 2017. Initially, the registrant of the disputed domain name was a privacy service and the underlying registrant was revealed following a request by the Complainants’ representatives. Thereafter, the WhoIs record showed a registrant name which is the same as one of the first Complainant’s directors but with a different address to those of the Complainants’ various offices. According to a screenshot of September 21, 2017 produced by the Complainant, the website associated with the disputed domain name consisted of a financial services site offering savings accounts, savings bonds and related financial services under the name “Northill Global”. The contact details listed on such site consisted of the name and address of the second Complainant. Under the legend “FCA REGISTERED” the website listed the second Complainant’s registration number on the United Kingdom Financial Conduct Authority’s register of authorized financial services entities. The Complainants note that the said reference number contained a hyperlink directly to the relevant entry for the second Complainant on the Financial Conduct Authority’s online register. The website also contained a disclaimer stating “Northill Global are not connected to Northill Capital in any way. We are completely separate entities.”
The Complainants say that the disputed domain name came to light on September 11, 2017 when the Complainants were contacted by one of their customers who had been confused by a website at “”. Although unauthorized by and unconnected to the Complainants, this website appeared to be an official site operated by the Complainants. The Complainants add that a range of other domain names pointing to substantially identical websites, including the disputed domain name, subsequently came to light. The additional domain names are stated to be , and . The Complainants removed a number of the associated websites through correspondence with the applicable hosting company. The domain names , , and do not form part of the present administrative proceeding.
The Complainants subsequently obtained a copy of an email dated September 18, 2017 which had been sent to one of the Complainants’ clients. The client had provided their details via the website associated with the disputed domain name. The email stated inter alia that an account would be set up for the client using the disputed domain name and referenced the name of a director of the first Complainant with whom the client was said to have previously been dealing. The Complainants note that despite having no connection with the Complainants’ businesses, the email contains a confidentiality notice which makes reference to a genuine affiliate of the Complainants by name, registration number and address.
The Complainants note that the Central Bank of Ireland has issued a warning notice which indicates that those behind the disputed domain name and/or its associated website have “cloned” the second Complainant’s details, that there is no connection between them and that such cloning can be associated with the provision of unauthorized financial services which is a criminal offense in Ireland. A notice has also been issued by the United Kingdom Financial Services Authority which refers to the fact that a “clone firm” is operating under the name Northill Global “without the correct authorization or is running a scam”. 5. Parties’ Contentions A. Complainant
The Complainants contend that the disputed domain name is identical or confusingly similar to a trademark in which they own rights; that the Respondent has no rights or legitimate interests in the disputed domain name; and that the disputed domain name has been registered and is being used in bad faith.
The Complainants note with reference to previous cases under the Policy that the content of a website can be taken into account in considering whether a domain name is confusingly similar to a trademark, adding that such content indicates how Internet users would perceive the domain name of that website, and that it has been established that an abbreviation of a trademark can be similar to the trademark itself. The Complainants assert that the content, including the sign “Northill Global” will cause Internet users to interpret the disputed domain name as representing the words “Northill Global UK clients” and that conceptually the first two letters of the disputed domain name will therefore be taken as representing the words “Northill Global”. The Complainant adds that the first letter of the disputed domain name is identical to the first letter of the Complainant’s NORTHILL trademark and would similarly be taken as representing the word “Northill” being identical thereto. The Complainant asserts that the term “UK” in the disputed domain name is descriptive of the territory where the Complainants are headquartered and that the term “clients” is descriptive of the asset management business operated by the Complainants. The Complainants consider that the terms “UK” and “clients” in the disputed domain name therefore increase confusing similarity.
The Complainants assert that without further evidence it would be reasonable to infer that the Respondent must have known of the Complainants’ business when the disputed domain name was registered. The Complainants submit that this is not in doubt due to the purported disclaimer on the Respondent’s website and the fact that the website uses the second Complainant’s details and official authorization number. The Complainants state that this demonstrates that the Respondent engaged in a deliberate attempt to fraudulently trade off the back of the Complainants’ trademark and brand.
The Complainants submit that the registration of the disputed domain name in a name matching that of a director of the first Complainant was an intentional attempt to hide the Respondent’s identity and to facilitate fraud upon the Complainants’ clients. The Complainants submit that the notices by the Financial Conduct Authority and Central Bank of Ireland constitute an official acknowledgement of the alleged fraud and of the use of a “clone firm” by the Respondent. The Complainants assert that the Respondent chose the disputed domain name specifically because it is confusingly similar to the Complainants’ trademark and brand and that its use and registration can neither constitute use of or demonstrable preparations to use the disputed domain name in connection with a bona fide offering of services nor give rise to any possibility of use in connection with the good faith offering of goods or services or the operation of a business, adding that the Respondent cannot rely on any of the circumstances in paragraph 4(c) of the Policy to demonstrate rights or legitimate interests in the disputed domain name. The Complainants state that the use of the disputed domain name to imitate the Complainants’ website together with the listing of the second Complainant’s address and authorization number cannot be understood to be legitimate. The Complainants further contend that the commercial purposes for which the disputed domain name is being used, which are not bona fide, could not be considered noncommercial or fair use of the disputed domain name.
The Complainants note that they have not licensed, otherwise permitted or authorized the Respondent to use the Complainants’ trademark or brand or to apply for any domain name that is confusingly similar to such mark or brand. The Complainants add that the Respondent’s name does not include the Complainant’s trademark or brand, that it is not commonly known by such mark or brand and that it cannot rely on any defense under paragraph 4(c)(ii) of the Policy where the disputed domain name was registered in bad faith.
The Complainants submit that the Respondent registered the disputed domain name in order to benefit unfairly from the Complainant’s rights in its trademark and brand, primarily to disrupt the Complainants’ business, with knowledge of the Complainants and of the use which the Complainants make of such trademark and brand. The Complainants assert that such knowledge is demonstrated by the use of the disputed domain name to promote similar or identical services to those of the Complainants, the use of the first Complainant’s director’s name as the name of the registrant, the fact that the website associated with the disputed domain name includes the name and details of the second Complainant and the fact that the Complainants had taken steps to remove the websites of other domain names featuring the same website prior to the registration of the disputed domain name.
The Complainants contend that the Respondent operates the disputed domain name intentionally to attract Internet users to its website for commercial gain by creating a likelihood of confusion as to source, sponsorship, affiliation or endorsement of such website or of the services thereon, constituting registration and use in bad faith under paragraph 4(b)(iv) of the Policy. In support of this submission, the Complainants point to the steps taken by the competent authorities to publish warning notices to consumers. The Complainants also assert that the disputed domain name has been used in a way which dilutes the reputation of the Complainants’ trademark and brand. The Complainants argue that the absence of any legitimate interest in the disputed domain name on the part of the Respondent in the context of the Complainants’ more than five years of use of its brand and more than seven years of trading under their trademark indicates that the registration of the disputed domain name cannot have been in good faith.
The Complainants contend that the use of the second Complainants’ details on the website associated with the disputed domain name when no member of the Complainants’ group has any involvement in the registration or use of the disputed domain name is strongly indicative of bad faith. The Complainants also assert that the use by the Respondent of the purported disclaimer on the Respondent’s website demonstrates that it had prior knowledge of the Complainants and their rights. The Complainants point to previous cases under the Policy which are supportive of the notion that a website imitating a complainant’s website is strongly suggestive of bad faith. The Complainants conclude that the lack of any legitimate good faith use of or legitimate purpose for the disputed domain name likewise suggests bad faith. B. Respondent
The Respondent did not reply to the Complainants’ contentions. 6. Discussion and Findings
To succeed, the Complainants must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied:
(i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainants have rights;
(ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and
(iii) the disputed domain name has been registered and is being used in bad faith. A. Preliminary Issue - Consolidation of Complainants
The Panel notes that the present Complaint has been filed by multiple Complainants. On this subject, paragraph 4.11.1 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”) provides inter alia as follows:
“Paragraph 10(e) of the UDRP Rules grants a panel the power to consolidate multiple domain name disputes. At the same time, paragraph 3(c) of the UDRP 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.
In assessing whether a complaint filed by multiple complainants may be brought against a single respondent, panels look at whether (i) the complainants have a specific common grievance against the respondent, or the respondent has engaged in common conduct that has affected the complainants in a similar fashion, and (ii) it would be equitable and procedurally efficient to permit the consolidation.”
In the present case, the Complainants submit that they are members of the same corporate group, that the Respondent has instigated a fraud against the Complainants’ group and clients and that in so doing, the Respondent has used indicia of each of the Complainants as part of the same overall fraudulent activity such that the Complainants have a specific common grievance against the Respondent. The Complainants add that the Respondent is engaged in common conduct that is affecting both the Complainants in a similar fashion and submit that it would be equitable and procedurally efficient to permit the Complainants to make the Complaint jointly.
The Panel considers that the Complainants have established that they have both common interests and a common grievance against the Respondent. The Panel is satisfied that it would be equitable and procedurally efficient to permit consolidation of the Complainants’ respective complaints. Furthermore, the Panel notes that the Respondent has not responded to the Complaint and thus has neither taken issue with the Complainants’ submissions on this topic nor otherwise objected to such consolidation. In the absence of any Response and in the circumstances of this case, the Panel cannot identify or foresee any prejudice arising to the Respondent were such consolidation to be ordered by the Panel.
Accordingly, the Panel allows consolidation of the Complainants’ respective complaints against the Respondent in this case and will proceed to a decision on that basis. The Panel notes that the remedy sought by the Complainants in the event that the Complaint is made out is that the disputed domain name be transferred to the first Complainant. B. Identical or Confusingly Similar
The Complainants rely upon their registered trademark rights in the mark NORTHILL together with unregistered or common law trademark rights in the brand NORTHILL GLOBAL. The Panel finds that the Complainants have UDRP-relevant rights in the NORTHILL mark by virtue of the registered trademarks cited in the Complaint and noted in the factual background section above.
With regard to the Complainants’ unregistered rights in the brand NORTHILL GLOBAL, section 1.3 of the WIPO Overview 3.0 sets out what a complainant needs to show to successfully assert such rights under the Policy, namely that the mark has become a distinctive identifier which consumers associate with the complainant’s goods or services, relevant evidence of which includes a range of factors such as (i) the duration and nature of use of the mark, (ii) the amount of sales under the mark, (iii) the nature and extent of advertising using the mark, (iv) the degree of actual public (e.g., consumer, industry, media) recognition, and (v) consumer surveys. In that context, the Panel notes that the principal direct evidence provided by the Complainants is the current company profile of the second Complainant taken from “” and an Irish company information entry from “”. The former merely states that the second Complainant “provides investment management services” and “offers portfolio management, financial planning and investment advisory services”, while the latter confirms that the second Complainant has been in business for some five years and nine months, that it is named Northill Global Fund Managers Limited and “may trade” under that name. The Central Bank of Ireland notice produced by the Complainants as evidence of the alleged fraudulent activity connected with the disputed domain name also demonstrates that the second Complainant, under the name Northill Global Fund Managers Limited, is an authorised and regulated financial services firm. Taken together, the Panel accepts that all of this evidence, while limited in extent, goes some way towards a demonstration of the duration and use of the mark NORTHILL GLOBAL.
In addition to relying upon these documents, the Complaint invites the Panel to seek more information about the Complainants, if required, from the website at “”. The Panel has visited this website, noting in terms of section 4.8 of the WIPO overview 3.0 that it has been accepted that a panel may undertake limited factual research into matters of public record if it would consider such information useful to assessing the case merits and reaching a decision. As the Complainants made specific reference to their website in the pleadings, the Panel does not find it necessary to invite the Parties to comment on the information disclosed on that site. In any event, the Complainants’ website does not add much by way of support to the Complainants’ position. The Panel can find only one mention of the term “Northill Global” in the website conditions of use which restate the corporate name of the second Complainant. Nevertheless, the website does indicate that the Complainants are part of a substantial regulated entity with assets under management totalling USD 48 billion as at September 30, 2017, this being an updated and higher amount from that listed in the Complaint.
Although the Panel would have preferred to see greater evidence of use of the term “Northill Global” along the lines anticipated by section 1.3 of the WIPO Overview 3.0, the Panel has been prepared to find that such term is a common law mark of the second Complainant to the purpose of the Policy for the following reasons. First, it has been demonstrated to the Panel’s satisfaction that such mark has been in use for a reasonably lengthy period as part of the corporate name of the second Complainant. Secondly, the Panel accepts that the Complainants operate in a highly regulated sector where corporate names, trading names and statements on websites are tightly controlled by the regulatory authorities in order to ensure that members of the public should be able to rely upon them. In these circumstances, it is reasonable for the Panel to take the Complainants’ statement of assets under management, which originally featured in the Complaint and which is provided in a more up to date amount on the Complainant’s website, into consideration. In the Panel’s view, this statement serves as a demonstration that the business which is carried on under the NORTHILL GLOBAL mark is considerable. The Panel therefore determines that due to the substantial nature of the Complainants’ business it is more likely than not that the second Complainant’s trading name has gained the appropriate degree of public and/or industry recognition.
The Panel therefore turns to a comparison between the disputed domain name and the Complainants’ marks. Section 1.7 of the WIPO Overview 3.0 discusses how the comparison process is conducted for the purposes of the first element under the Policy, noting that “This test typically involves a side-by-side comparison of the domain name and the textual components of the relevant trademark to assess whether the mark is recognizable within the disputed domain name.” On such typical comparison, it is evident that neither the NORTHILL nor NORTHILL GLOBAL marks are recognizable in this particular disputed domain name. However, section 1.7 of the WIPO Overview 3.0 also provides that in specific limited instances the broader case context, such as website content trading off the complainant’s reputation or a pattern of multiple respondent domain names targeting the complainant’s mark within the same proceeding, may support a finding of confusing similarity. It goes on to note that panels view the first element as a threshold test concerning a trademark owner’s standing to file a UDRP complaint, that is, to ascertain whether there is a sufficient nexus to assess the principles captured in the second and third elements and that in this context, panels have also found that the overall facts and circumstances of a case (including relevant website content) may support a finding of confusing similarity, particularly where it appears that the respondent registered the domain name precisely because it believed that the domain name was confusingly similar to a mark held by the complainant. The Panel considers that it is appropriate to review the broader case context in this particular matter.
The Panel accepts the Complainants’ contention that the disputed domain name can be split into three distinct component parts (disregarding the generic top-level domain (“gTLD”) “.com” on the grounds that this is required for technical reasons only such that it typically does not form part of the comparison). These are “ng”, “uk” and “clients”. The Complainants submit that the “ng” element is an abbreviation of the mark NORTHILL GLOBAL and that, as such, this element is confusingly similar to such mark. The Complainants add that “uk” is an abbreviation of “United Kingdom”, indicating a place where the Complainants’ group is headquartered, and that “clients” is a word used by those in the business of asset management such as the Complainants. The Complainants submit that these two elements are either generic or non-distinctive, or that they exacerbate confusing similarity due to the apparent connection with the Complainants’ activities.
There is no evidence before the Panel that either of the Complainants use the name or mark “ng” or that they are known by this term. Nevertheless, the Panel accepts the Complainants’ submission that “ng” can be seen as the initial letters of NORTHILL GLOBAL and thus as an abbreviation of the mark. Such abbreviations are often made for convenience by companies in the field of financial services and likewise are recognizable to their clients. It has been accepted in previous cases under the Policy that such an abbreviation of a complainant’s mark within a domain name, whether or not commonly used by the complainant itself, can give rise to a finding of confusing similarity, typically where there is also some evidence of Internet user confusion in the broader case context (see, for example, Council on International Educational Exchange v. Martin Schola / Petra Novak / CN Exchange,WIPO Case No. D2015-2137).
Considering the broader context in the present case, the Panel notes that evidence has been brought forward regarding specific Internet user confusion caused by the disputed domain name and its relative website content. In the Panel’s opinion, the evidence demonstrates that Internet users are likely to believe that there is a real connection between the disputed domain name, the associated website, the Complainants and the Complainants’ trademarks. Indeed, such connection sufficiently confused a client of the Complainants that they provided personal details via the Respondent’s website, which led to receipt of the email noted in the factual background above. That email itself purported to emanate from the Complainants’ group and continued to reference the disputed domain name as an “original client centre for our depositors in the UK”. In these circumstances, it appears to the Panel that the Respondent selected and registered the disputed domain name precisely because it believed that such domain name was confusingly similar to the Complainants’ mark (along with other domain names identified by the Complainant featuring or referencing the Complainants’ mark and forming part of the same pattern, namely , , and ) and thus would assist in an attempt to impersonate the Complainants’ business.
Accordingly, the Panel finds that the overall facts and circumstances of this case including the Respondent’s website and email content together with the evidence of actual Internet confusion support a finding of confusing similarity. The requirements of paragraph 4(a)(i) of the Policy have therefore been satisfied. C. Rights or Legitimate Interests
Paragraph 4(c) of the Policy lists several ways in which the Respondent may demonstrate rights or legitimate interests in the disputed domain name:
“Any of the following circumstances, in particular but without limitation, if found by the Panel to be proved based on its evaluation of all evidence presented, shall demonstrate your rights or legitimate interests to the domain name for purposes of paragraph 4(a)(ii):
(i) before any notice to you 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 (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 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.”
The consensus of previous decisions under the Policy is that a complainant may establish this element by making out a prima facie case, not rebutted by the respondent, that the respondent has no rights or legitimate interests in a domain name. Where the panel finds that a complainant has made out such a prima facie case, the burden of production shifts to the respondent to bring forward evidence of such rights or legitimate interests.
The Panel is satisfied that the Complainants’ submissions make out the requisite prima facie case. The Complainants assert that they have not licensed, otherwise permitted or authorized the Respondent to use the Complainants’ trademark or brand or to apply for any domain name that is confusingly similar to such mark or brand. The Complainants note that the Respondent’s name does not include the Complainant’s trademark or brand, that it is not commonly known by such mark or brand and that it cannot rely on any defense under paragraph 4(c)(ii) of the Policy. More importantly, the Complainants describe, with the support of appropriate evidence, the manner in which the disputed domain name and website content has been used to impersonate the Complainants such that a regulatory authority has issued a warning notice to consumers which specifically references the disputed domain name in connection with “cloned details”. The Panel considers that the use of the disputed domain name could not give rise to any conceivable rights or legitimate interests on the part of the Respondent.
The Panel notes that the Complainants’ allegations regarding the disputed domain name are of a serious nature and observes that such allegations have likewise been taken seriously and acted upon by no less than two national financial services regulators. Such allegations call for an answer from the Respondent, which is notably absent in the present case. On the contrary, all that has been forthcoming in response to the Complaint is a communication from a third party (unrelated to the officer of the first Complainant whose name the Complainants say was being targeted by the Respondent). This communication indicates that the third party has received the Complaint, presumably because its details were used in the registration of the disputed domain name, and asserts that it has no involvement with the disputed domain name and has launched an investigation with the company which administers its registered office address. None of these circumstances are consistent with the Respondent being able to maintain any rights or legitimate interests in the disputed domain name.
The Panel therefore concludes that there are no facts and circumstances identified or available to it which appear to rebut the Complainant’s prima facie case. In these circumstances, the Panel finds that the Respondent has no rights or legitimate interests in respect of the disputed domain name and that the requirements of paragraph 4(a)(ii) of the Policy have been satisfied. D. Registered and Used in Bad Faith
It follows from the discussion in the previous section that the evidence before the Panel does not support any possible good faith motivation on the part of the Respondent regarding the registration and use of the disputed domain name. The Respondent has failed to provide any explanation regarding its conduct which might be consistent with good faith activities and the Panel cannot reasonably conceive of any possible good faith intent on the Respondent’s part relating to the disputed domain name.
The examples contained in paragraph 4(b) of the Policy which may be evidence of registration and use in bad faith are not exhaustive of all circumstances in which bad faith may be found. The Complainants’ evidence and submissions in the present case are in the Panel’s opinion sufficient for it to find on the balance of probabilities that the disputed domain name was registered and is being used a part of a scheme to impersonate the Complainants’ corporate identity. This appears to have been done with a view to lending credibility to the Respondent’s various activities using the website associated with the disputed domain name as more particularly described in the warning notices from the financial services authorities. The Panel is satisfied that this conduct constitutes registration and use in bad faith within the meaning of the Policy.
The Panel therefore finds that the Respondent has registered and is using the disputed domain name in bad faith and accordingly that the requirements of paragraph 4(a)(iii) of the Policy have been satisfied. 7. Decision
For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name be transferred to the first Complainant.
Andrew D. S. Lothian
Sole Panelist
Date: December 31, 2017
1 The Panel decided to redact the name of the named Respondent, adopting the criterion of the UDRP panels in Intesa Sanpaolo S.p.A. v. Name Redacted,WIPO Case No. D2016-1286 and Banco Bradesco S.A. v. FAST-12785241 Attn. B / Name Redacted,WIPO Case No. D2009-1788 (“The Panel has decided that no purpose is to be served by including the named Respondent in this decision, and has therefore redacted its name from the caption and body of this decision. The Panel has, however, attached as Annex 1 to this Decision an instruction to the Registrar regarding transfer of the disputed domain name that includes the named Respondent, and has authorized the Center to transmit Annex 1 to the Registrar as part of the order in this proceeding. However, the Panel has further directed the Center, pursuant to paragraph 4(j) of the Policy and paragraph 16(b) of the Rules, that Annex 1 to this Decision shall not be published based on exceptional circumstances”).
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