Complainant is LEGO Juris A/S, Denmark, represented by CSC Digital Brand Services Group AB, Sweden.
Respondent is Contact Privacy Inc. Customer 1246240368, Canada / Nguyen Anh Duy, Viet Nam. 2. The Domain Name and Registrar
The disputed domain name The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 3, 2020. On April 3, 2020, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On April 4, 2020, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Disputed Domain Name which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to Complainant on April 6, 2020, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on April 7, 2020. The Center verified that the Complaint together with the amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified Respondent of the Complaint, and the proceedings commenced on April 9, 2020. In accordance with the Rules, paragraph 5, the due date for Response was April 29, 2020. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on April 30, 2020. The Center appointed Scott R. Austin as the sole panelist in this matter on May 6, 2020. 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 Complainant states in its Complaint, and provides evidence in the respective Annexes attached to its Complaint sufficient to support that: 1) Based in Denmark, Complainant is the owner of the trademark LEGO (the “LEGO Mark”), and all other trademarks used in connection with the LEGO brands of construction toys and other LEGO branded products. 2) “The Complainant’s licensees are authorized to exploit the Complainant’s intellectual property rights, including its trademark rights, in Canada, [Viet Nam] and elsewhere”; 3) “The Complainant has subsidiaries and branches throughout the world, and LEGO products are sold in more than 130 countries, including in Canada and [Viet Nam]”; 4) “The LEGO Mark is among the best-known trademarks in the world, due in part to decades of extensive advertising, which prominently depicts the LEGO mark on all products, packaging, displays, advertising, and promotional materials”; 5) “[T]he LEGO Mark and brand have been recognized as being famous”; 6) “[T]he Reputation Institute recognized the LEGO Group as number 1 on its list of the world’s Top10 Most Reputable Global Companies of 2020, and applauded the LEGO Group’s strong reputation, having been on its top 10 list for 10 consecutive years”; 7) “In 2014, TIME also announced LEGO to be the Most Influential Toy of All Time”; 8) Complainant has provided in the Annexes attached to its Complaint lists of the registered trademarks on which its Complaint is based, along with copies of the trademark certificates for the LEGO Mark in a number of jurisdictions, including but not limited to, the following: a) Canadian Trademark Registration No. TMA106457, LEGO, registered on April 26, 1957, claiming use in Canada since March 5, 1954, for “Toys being block building sets, toy-vehicles, toy-boats, toy-houses, model traffic signs and similar goods, parts thereof and accessories thereto” in International Class 28; b) European Union Trade Mark Registration No. 000039800, LEGO, registered on May 10, 1998, for, inter alia, a range of goods in International Class 28; and c) Vietnamese Trademark Registration No. 4-0060988-000, , registered on March 14, 2005, for, inter alia, a range of goods in International Class 28. 9) “Complainant is the owner of close to 5,000 domain names containing the term LEGO”; 10) “The LEGO Group also maintains an extensive website under the domain name LEGO.com”; 11) The Disputed Domain Name was registered on January 11, 2020, and resolves “to an unauthorized commercial website offering LEGO products” […] where “Complainant’s logo is displayed” along with the LEGO Mark and logotype “displayed as the browser tab favicon when navigating to the Disputed Domain Name’s website”; and 12) “It is to be noted that the Disputed Domain Name is registered with ‘privacy protection service’”, and that “although the proxy service resides in Canada, the Respondent resides in [Viet Nam]”. 5. Parties’ Contentions A. Complainant The Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which Complainant has rights because: a) “The dominant part of the Disputed Domain Name comprises the term ‘lego’, identical to the registered trademark LEGO, registered by the Complainant as trademarks and domain names in numerous countries all over the world”; b) “The fame of the LEGO Mark has been confirmed in numerous previous UDRP decisions”; c) “[I]t is a long-established precedent that confusing similarity is generally recognized when well-known trademarks are paired up with different kinds of generic prefixes and suffixes” and “In this case, the suffix ‘haha’ does not detract from the overall impression”; d) “The addition of the top-level domain [TLD] ‘.com’ does not have any impact on the overall impression of the dominant portion of the Disputed Domain Name and is therefore irrelevant to determine the confusing similarity between the trademark and the Disputed Domain Name”; e) “Anyone who sees the Disputed Domain Name is bound to mistake it for a name related to Complainant”; f) “With reference to the reputation of the LEGO Mark, there is a considerable risk that the trade public will perceive Respondent’s Domain Name either as a domain name[] owned by the Complainant, or that there is some kind of commercial relation with the Complainant”; Respondent has no rights or legitimate interests in the Disputed Domain Name because: a) “No license or authorization of any other kind, has been given by the Complainant to the Respondent, to use the LEGO Mark”; b) “LEGO is a famous trademark worldwide.” and “use of such a trademark in a domain name would violate the rights of the trademark owner”; c) “As no evidence has been found that the Respondent is using the name LEGO as a company name or has any other legal rights in the name, it is quite clear that the Respondent is simply trying to benefit from the Complainant’s world famous trademark”; d) “Respondent has intentionally chosen a domain name based on a registered trademark in order to generate traffic and income through an unauthorised website offering LEGO® products”; e) “Respondent does not adequately disclose the relationship, or lack thereof, between the Respondent and the Complainant, and therefore conveys the false impression that the Respondent is authorized to use the Complainant’s trademark” on Respondent’s website selling Complainant’s toys.’; f) “Complainant’s LEGO Mark and logotype is displayed as the browser tab favicon when navigating to the Disputed Domain Name’s website is further evidence that Respondent’s use of the domain name in connection with its offering of goods or services was not bona fide”. The Disputed Domain Name has been registered and is being used in bad faith because: a) “[T]he LEGO Mark in combination with other words has always been attractive to domain name infringers” as shown by over 50 UDRP proceedings filed by Complainant in 2019 alone referenced by case number in the Complaint; b) The registration date of the Disputed Domain Name “is subsequent to when the Complainant registered the LEGO Mark in Canada, [Viet Nam] and elsewhere, by decades.”; c) “Respondent cannot claim to have been using the LEGO Mark, without being aware of the Complainant’s rights to it”; d) Despite that multiple reminders were sent, no reply was ever received to Complainant’s cease and desist letters sent to Respondent; e) “[T]he Disputed Domain Name is currently connected to an unauthorized commercial website offering LEGO products, on which [t]he Complainant’s logo is displayed […] and browser tab as the favicon, contributing to create a confusing similarity with the Complainant.”; and f) “By using the Disputed Domain Name, the Respondent is not making a legitimate noncommercial or fair use but is misleadingly diverting consumers for his own commercial gain.” B. Respondent Respondent did not reply to Complainant’s contentions. Respondent’s default does not automatically result in a decision in favor of Complainant. Complainant must establish each of the three elements required by paragraph 4(a) of the Policy. Section 4.3 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”) states: “Does a respondent’s default/failure to respond to the complainant’s contentions automatically result in the complaint succeeding? Noting the burden of proof is on the complainant, a respondent’s default (i.e., failure to submit a formal response) would not by itself mean that the complainant is deemed to have prevailed; a respondent’s default is not necessarily an admission that the complainant’s claims are true.” Thus, although in this case Respondent has failed to respond to the Complaint, the burden remains with Complainant to establish the three elements of paragraph 4(a) of the Policy by a preponderance of the evidence. See, e.g., The Knot, Inc. v. In Knot We Trust LTD,WIPO Case No. D2006-0340. 6. Discussion and Findings Pursuant to the Policy, paragraph 4(a), Complainant is required to prove the presence of each of the following three elements to obtain the relief it has requested: (i) the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; (ii) 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. The standard of proof under the Policy is often expressed as the “balance of the probabilities” or “preponderance of the evidence” standard. Under this standard, an asserting party needs to establish that it is more likely than not that the claimed fact is true. See section 4.2, WIPO Overview 3.0. A. Identical or Confusingly Similar To prove this element, Complainant must have trade or service mark rights and the Disputed Domain Name must be identical or confusingly similar to Complainant’s trade or service mark. Ownership of a trademark registration is generally sufficient evidence that a complainant has the requisite rights in a mark for purposes of paragraph 4(a)(i) of the Policy. WIPO Overview 3.0, section 1.2.1. Moreover, “[n]oting in particular the global nature of the Internet and Domain Name System, the jurisdiction(s) where the trademark is valid is not considered relevant to panel assessment under the first element. […] the filing/priority date, date of registration, and date of claimed first use, are not considered relevant to the first element test. These factors may however bear on a panel’s further substantive determination under the second and third elements”. WIPO Overview 3.0, section 1.1.2. The Panel notes here Complainant’s evidence submitted of registration of the LEGO Mark in Viet Nam, establishing trademark rights in the country where Respondent resides, which is considered in more detail under Sections 6B and 6C below for the Panel’s determination under the second and third elements. Based upon the numerous trademark registrations cited by Complainant, as well as supporting documents, the Panel finds that Complainant has established trademark rights in and to its LEGO Mark used by Complainant and its licensees in connection with, inter alia, the sale of its construction toys. The Panel also finds as have previous UDRP panels, that the LEGO Mark has achieved the status of worldwide fame. See e.g., LEGO Juris A/S v. Level 5 Corp,WIPO Case No. D2008-1692 (“The Panel finds that the Complainant has established that LEGO and LEGOLAND are well-recognized and world famous trademarks and that the trademarks are distinctive”); LEGO Juris A/S v. Michael Longo,WIPO Case No. D2008-1715 (“The Panel finds, as numerous panels have found before, that the Complainant has established that LEGO is a well-known trademark and that the trademark is distinctive and famous”). The Panel also finds, based on the registration evidence submitted by Complainant, that its rights in its famous LEGO Mark existed and were used for decades prior to the registration of the Disputed Domain Name. Having met its burden for established trademark rights in the LEGO Mark, Complainant next contends that the Disputed Domain Name is identical or confusingly similar to Complainant’s LEGO Mark because the “dominant part of the [Disputed] Domain Name[] comprises the term LEGO, identical to the registered trademark LEGO, registered by the Complainant as trademarks and domain names in numerous countries all over the world”. For the Disputed Domain Name to be found identical or confusingly similar the LEGO Mark, the relevant comparison is with the second-level portion of the Disputed Domain Name, in this case “legohaha”, as it is well established that the TLD, in this case “.com” may generally be disregarded for this purpose. See WIPO Overview 3.0, section 1.11 (the TLD as technical requirement for domain name registration is disregarded under the confusing similarity test). Prior UDRP panels have held “the fact that a domain name wholly incorporates a complainant’s registered mark is sufficient to establish identity or confusing similarity for purposes of the Policy”. Oki Data Americas, Inc. v. ASD, Inc.,WIPO Case No. D2001-0903. The Panel agrees and notes that section 1.7 of the WIPO Overview 3.0 provides: “It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the complainant’s trademark and the disputed domain name.” The Panel finds Complainant’s LEGO Mark is incorporated in its entirety into the Disputed Domain Name to render the Disputed Domain Name confusingly similar to Complainant’s LEGO Mark in which Complainant has established trademark rights. Accordingly, the Panel finds that Complainant has satisfied paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests Under this second element of the Policy, a complainant is required to make out a prima facie case that the respondent lacks rights or legitimate interests. Once such prima facie case is made, the burden of production shifts to respondent to come forward with appropriate evidence demonstrating rights or legitimate interests in the domain name. If the respondent fails to come forward with such appropriate evidence, a complainant is generally deemed to have satisfied the second element under the UDRP. WIPO Overview 3.0, section 2.1. See also, Malayan Banking Berhad v. Beauty, Success & Truth International,WIPO Case No. D2008-1393. Respondent here has failed to appear to present any evidence of its rights or legitimate interests in the Disputed Domain Name. For the following reasons the Panel finds that Complainant has established a prima facie case that Respondent has no rights or legitimate interests in the Disputed Domain Name. First, Complainant asserts that “No license or authorization of any other kind, has been given by the Complainant to the Respondent, to use the LEGO Mark”. Prior panels under the Policy have found that “[i]n the absence of any license or permission from the Complainant to use its trademark, no actual or contemplated bona fide or legitimate use of the Disputed Domain Name could reasonably be claimed”. See Sportswear Company S.P.A. v. Tang Hong,WIPO Case No. D2014-1875; Guerlain S.A. v. Peikang,WIPO Case No. D2000-0055 (“in the absence of any license or permission from the Complainant to use any of its trademarks or to apply for or use any domain name incorporating those trademarks, it is clear that no actual or contemplated bona fide or legitimate use of the domain name could be claimed by Respondent.”); see also Six Continents Hotels, Inc. v. Patrick Ory,WIPO Case No. D2003-0098 (“There is no evidence of any commercial relationship between the Complainant and the Respondent which would entitle the Respondent to the mark. Consequently, the Panel concludes that the Respondent has no rights nor legitimate interests in the Domain Name given there exists no relationship between the Complainant and the Respondent that would give rise to any license, permission or authorization by which the Respondent could own or use the Domain Name.”). The Panel finds that Respondent has neither any connection with Complainant, nor has Respondent been authorized or licensed by Complainant to use and register the LEGO Mark or to register any domain name incorporating Complainant’s LEGO Mark. Complainant next contends Respondent is not commonly known by either of the Disputed Domain Name or the LEGO Mark, in accordance with paragraph 4(c)(ii) of the Policy. Complainant asserts and the WhoIs record submitted in the Annex to the Complaint supports that, “nothing would suggest that the Respondent has been using LEGO in any other way that would give them any legitimate rights in the name”. The Panel notes that whether Respondent is operating under the privacy proxy service name of “Contact Privacy Inc. Customer 1246240368”, or “Nguyen Anh Duy”, neither remotely resembles the Disputed Domain Name. The Panel finds upon review of the record and evidence submitted by Complainant that Respondent is not commonly known by either of the Disputed Domain Name. Since Respondent elected to submit no evidence in these proceedings, there is no evidence from Respondent to the contrary, i.e., that Respondent has been authorized or licensed to use Complainant’s LEGO Mark or is commonly known by the Disputed Domain Name. It is generally regarded as prima facie evidence of no rights or legitimate interests if a complainant shows that the disputed domain name is identical or confusingly similar to the complainant’s trademark, that the respondent is not commonly known by the disputed domain name, and that the complainant has not authorized the respondent to use its mark (or an expression which is confusingly similar to its mark), whether in the disputed domain name or otherwise. See Roust Trading Limited v. AMG LLC,WIPO Case No. D2007-1857; see also Marriott International, Inc. v. Thomas, Burstein and Miller,WIPO Case No. D2000-0610 (no rights or legitimate interests when there is no evidence that respondent is commonly known by the domain name). The Panel accepts Complainant’s contentions that Respondent is not commonly known by the Disputed Domain Name and that Respondent has never been authorized by Complainant to use Complainant’s LEGO Mark. The Panel is therefore satisfied that Complainant has provided sufficient prima facie evidence that Respondent has no rights or legitimate interests in the Disputed Domain Name. Complainant next contends that “Respondent is not using the Domain Name[] in connection with a bona fide offering of goods or services […]” but “has intentionally chosen a domain name based on a registered trademark in order to generate traffic and income through an unauthorised website offering LEGO® products”. The Panel notes that the record of web page printout evidence submitted in the Annex to the Complaint supports Complainant’s argument because it shows Respondent’s website features the use of Complainant’s LEGO Mark, logos and images of Complainant’s toys to suggest an affiliation with or sponsorship by Complainant. The Panel notes that Respondent has taken its false association a step further by employing an unauthorized favicon using the LEGO Mark and logotype displayed in the browser address bar when navigating to Respondent’s website. (Favicons are small square images usually 16×16 pixels which are used by web browsers to show a graphical representation of the site being visited at the left side of the browser’s address bar.) Complainant has shown that Respondent is not an authorized reseller of its LEGO Mark products and has also has provided sufficient argument and evidence to persuade the Panel that Respondent does not meet the criteria laid down in Oki Data Americas, Inc. v. ASD, Inc.,WIPO Case No. D2001-0903, and further described in section 2.8.1 of WIPO Overview 3.0, (“the Oki Data Test”) Complainant asserts that Respondent does not avail itself of the safe harbors for nominative fair use provided under the Oki Data Test because, inter alia, Respondent does not disclose the relationship, or lack thereof, between Respondent and Complainant, and thereby conveys the false impression that Respondent is authorized to use Complainant’s trademark. Respondent provides no visible disclaimer stating that the website is not endorsed nor sponsored by Complainant to explain the lack of authorization or any relationship with the trademark holder. Instead, Respondent displays Complainant’s logo and images of Complainant’s products and toys and offers them for sale. Based on these facts, the Panel agrees with previous UDRP panels who have found in similar circumstances that “the risk of misrepresentation has led panels to find that a respondent lacks rights or legitimate interests in cases involving a domain name identical to the complainant’s trademark”. WIPO Overview 3.0, section 2.8.2; see also Oki Data Americas, Inc , supra; Houghton Mifflin Co. v. Weatherman, Inc.,WIPO Case No. D2001-0211 (no bona fide offering where website's use of Complainant’s logo, and lack of any disclaimer, suggested that website was the official Curious George website). In view of the above, the Panel finds that Complainant has made out a prima facie case that Respondent has no rights or legitimate interests in the Disputed Domain Name. Respondent has not submitted any argument or evidence to rebut Complainant’s prima facie case. The Panel determines, therefore, that Respondent does not have rights or legitimate interests in the Disputed Domain Name and that Complainant has satisfied the requirements of paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith Whether a domain name is registered and used in bad faith for purposes of the Policy may be determined by evaluating four (non-exhaustive) factors set forth in the Policy, paragraph 4(b): (i) circumstances indicating that the registrant has registered or the registrant has acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registrations to complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of the registrant’s documented out-of-pocket costs directly related to the domain name; or (ii) the registrant has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in corresponding domain name, provided that the registrant has engaged in a pattern of such conduct; or (iii) the registrant has registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the disputed domain name, the registrant has intentionally attempted to attract, for commercial gain, Internet users to the registrant’s website or other online location, by creating a likelihood of confusion with complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the registrant’s website or location or of a product or service on the registrant’s website or location. The Panel finds that Respondent has registered and used the Disputed Domain Name in bad faith for at least the following reasons. First, Complainant contends and has provided persuasive support in its Complaint Annexes that Respondent registered the Disputed Domain Name fully aware of Complainant’s rights, stating that the registration date of the Disputed Domain Name “is subsequent to when the Complainant registered the LEGO Mark in Canada, [Viet Nam] and elsewhere, by decades” and, therefore, “Respondent cannot claim to have been using the LEGO Mark without being aware of the Complainant’s rights to it”. Complainant’s evidence in support of its allegations is sufficient for the Panel to agree that Respondent could not plausibly argue that it did not have knowledge of Complainant’s world famous LEGO Mark, registered in Canada since 1957 and Viet Nam since 2005, when Respondent registered the Disputed Domain Name decades later in January 2020. Prior UDRP panels have acknowledged that it is highly unlikely that a respondent would not have had awareness of Complainant’s rights given Complainant’s fame worldwide. See, e.g., cases cited under Section 6A above, e.g., LEGO Juris A/S v. Level 5 Corp,WIPO Case No. D2008-1692 (“The Panel finds that the Complainant has established that LEGO and LEGOLAND are well-recognized and world famous trademarks and that the trademarks are distinctive”). The Panel finds that given the decades of prior use of Complainant’s LEGO Mark prior to Respondent’s registration of the Disputed Domain Name, the worldwide fame or the LEGO Mark and Respondent’s website landing page targeting Complainant’s LEGO Mark, Respondent registered the Disputed Domain Name with actual knowledge of Complainant’s LEGO Mark in bad faith. See Royds Withy King LLP v. Help Tobuy,WIPO Case No. D2019 0624. See WIPO Overview 3.0, section 3.2.2; see, e.g., eBay Inc. v. Sunho Hong,WIPO Case No. D2000-1633 (actual knowledge of Complainant’s rights in its trademarks a factor supporting bad faith). Complainant also contends and has submitted evidence to support that despite multiple reminders being sent, no reply was ever received to Complainant’s cease and desist letter to Respondent. Previous UDRP panels have found that a Respondent’s failure to respond to a cease and desist letter, or a similar attempt at contact, has been considered relevant in a finding of bad faith. See e.g., News Group Newspapers Limited and News Network Limited v. Momm Amed Ia,WIPO Case No. D2000-1623; Nike, Inc. v. Azumano Travel,WIPO Case No. D2000-1598; and America Online, Inc. v. Antonio R. Diaz,WIPO Case No. D2000-1460. Moreover, the Panel in Intel Corporation v. The Pentium Group,WIPO Case No. D2009-0273, stated that, “[t]he incorporation of a well-known trademark into a domain name by a registrant having no plausible explanation for doing so may be, in and of itself, an indication of bad faith”. See also Veuve Clicquot Ponsardin, Maison Fondée en 1772 v. The Polygenix Group Co.,WIPO Case No. D2000-0163; General Electric Company v. CPIC NET and Hussain Syed,WIPO Case No. D2001-0087; Microsoft Corporation v. Montrose Corporation,WIPO Case No. D2000-1568). Respondent has had multiple opportunities to explain and justify how Respondent came to register the Disputed Domain Name but has failed to do so. Indeed, the fact that Respondent has elected not to appear in this proceeding underscores that Respondent likely has no valid explanation for Respondent’s actions, which to this Panel appears on the evidence submitted to have been undertaken in bad faith. See, e.g., Volkswagen Group of America, Inc. v. Super Privacy Service Ltd. c/o Dynadot,WIPO Case No. D2019-2521. Finally, Complainant contends Respondent’s actions constitute use of the Disputed Domain Name in bad faith because “[T]he Disputed Domain Name is currently connected to an unauthorized commercial website offering LEGO products”, on which “[t]he Complainant’s logo is displayed […] and browser tab as the favicon, contributing to create a confusing similarity with the Complainant”. Based on the evidence submitted, as noted in section 6B above, the Panel finds that Respondent’s website accessed through the Disputed Domain Name features the use of Complainant’s LEGO Mark, logos and images of Complainant’s toys to suggest an affiliation with or sponsorship by Complainant. Based on these facts, the Panel finds, therefore, that Respondent is using the Disputed Domain Name to intentionally attempt to attract Internet users to a website for commercial gain, by creating a likelihood of confusion with Complainant’s mark as to the source, sponsorship, affiliation or endorsement of its website in violation of Policy paragraph 4(b)(iv). Such use “constitutes evidence of both bad faith registration and bad faith use, for the purposes of paragraph 4(a)(iii)”. See Philip Morris Inc. v. Alex Tsypkin,WIPO Case No. D2002-0946. The Panel finds Complainant’s arguments and evidence persuasive and no arguments or evidence submitted by Respondent to the contrary. Considering all the circumstances, the Panel concludes that Respondent has registered and used the Disputed Domain Name in bad faith and Complainant has satisfied paragraph 4(a)(iii) of the Policy. 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 Scott R. Austin
Sole Panelist
Date: May 20, 2020
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