Complainant is Gilead Sciences, Inc., United States of America (“United States”), of United States, represented Al Tamimi & Company, United Arab Emirates.
Respondent is Mohammadali Mokhtari, of Iran (Islamic Republic of).
2. The Domain Name and RegistrarThe disputed domain name
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 5, 2021. On July 9, 2021, the Center transmitted by email to IRNIC a request for registrar verification in connection with the disputed domain name. On July 10, 2021, IRNIC transmitted by email to the Center its verification response confirming that Respondent is listed as the registrant and providing the contact details.
On July 28, 2021, the Center sent a request for clarification. On August 2, 2021, Complainant submitted an amended Complaint.
The Center verified that the Complaint and the amended Complaint satisfied the formal requirements of the .ir Domain Name Dispute Resolution Policy (the “Policy” or “irDRP”), the Rules for .ir Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for .ir Domain Name Dispute Resolution Policy (the “Supplemental Rules”).
In accordance with the Rules, paragraphs 2(a) and 4(a), the Center formally notified Respondent of the Complaint, and the proceedings commenced on August 6, 2021. In accordance with the Rules, paragraph 5(a), the due date for Response was August 26, 2021. Further to Respondent’s request, the Center granted an extension of Response due date and the Response was filed with the Center on September 5, 2021.
The Center appointed Reyes Campello Estebaranz as the sole panelist in this matter on October 7, 2021. 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 BackgroundComplainant is a large global biopharmaceutical company founded in 1987 and listed at the Nasdaq Stock Exchange since 1992. Complainant focuses primarily on antiviral drugs used in the treatment of various diseases including HIV, hepatitis B, hepatitis C, and influenza. Complainant employs about 14,500 employees worldwide, is listed as 140 on the Fortune 500 Companies, and its worldwide revenue in 2020 was approximately USD 24.3 billion.
Complainant operates under the GILEAD brand for over 30 years, owning exclusive trademark rights over this mark through over 120 trademark registrations around the world, including:
-United States Registration No. 3251595, GILEAD, registered on June 12, 2007, in classes 6, 18, 44, 46, 51 and 52;
-European Union Trade Mark Registration No. 3913167, GILEAD, registered on November 7, 2005, in classes 1, 5 and 42; and
- International Registration No. 1494292, GILEAD, registered on September 9, 2019, in class 5, designating among other jurisdictions Iran (Islamic Republic of), (collectively the “GILEAD mark”).
Prior decisions under the Uniform Domain Name Dispute Resolution Policy (the “UDRP”) have recognized the well-known character of the GILEAD mark.1
Complainant owns the domain name
The disputed domain name was registered on September 30, 2018, and it currently resolves to a landing page containing various images related to “The Handmaid’s Tale”, a novel written by Canadian author Margaret Atwood, as well as to the television series based on this novel. These images refer to various scenes of the television series as well as to the books “The Handmaid’s Tale” and its sequel “Testaments”, and a map of the United States headed by the name “Republic of Gilead”. The page linked to the disputed domain name further contains various texts in Persian language inserted in the mentioned images, and an email address. According to the evidence provided by Complainant, at the time of filing the Complaint, the disputed domain name was inactive resolving to an Internet browser error message.
5. Parties’ Contentions A. ComplainantKey contentions of the Complaint may be summarized as follows:
The GILEAD mark is worldwide well-known and has been used for over 30 years by Complainant. Prior decisions under the UDRP have acknowledged that the GILEAD mark is famous.
The disputed domain name incorporates in its entirety the GILEAD mark being identical to this trademark, as well as to a number of domain names owned and operated by Complainant including its domain name
Respondent has no rights or legitimate interests in respect of the disputed domain name. The mere registration does not establish rights or legitimate interests in a domain name, the Parties have no connection, and no license or authorization has been given to Respondent to use Complainant’s GILEAD mark. There is no evidence that Respondent is known as or uses the name “gilead”. The disputed domain name is inactive, not being used in connection with a bona fide offering of goods or services. On May 9, 2020, Complainant sent a cease and desist letter to Respondent followed by several WhastApp messages, which have not been replied by Respondent to evidence a right, legitimate interest or bona fide offering of goods or services. Respondent contact details in the WhoIs record for the disputed domain name are not accurate.
The disputed domain name was registered or is being used in bad faith. Given the international reputation of the GILEAD mark, Respondent must have registered the disputed domain name with knowledge of Complainant and its rights. The GILEAD mark has been in use for over 30 years and it has been thrust into fame in light of the news coverage of Complainant’s COVID-19 treatment, Veklury® (remdesivir), including clinical trials of this pharmaceutical product in Iran (Islamic Republic of). Respondent’s bad faith is reinforced by his involvement in, at least, 8 prior cases under the Policy,1 having engaged in a pattern of bad faith registration and use of domain names corresponding to well-known trademarks belonging to third parties. Additionally, Respondent has provided inaccurate contact information when registering the disputed domain name, and, at the time of filing the Complaint, the disputed domain name is inactive, which does not prevent a finding of bad faith under the doctrine of passive holding. Under the Policy, it is sufficient to prove that the disputed domain name has been either registered or used in bad faith; however, taking into account all the circumstances of this case, Complainant submits that Respondent has registered and is using the disputed domain name in bad faith.
Complainant cites previous decisions under the UDRP and various sections of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”) that it considers supportive of its position, and requests the transfer of the disputed domain name.
B. RespondentKey contentions of the Response may be summarized as follows:
No authorization or other document that establish Complainant’s representation has been submitted with the Complaint.
Respondent has rights or legitimate interests in respect of the disputed domain name. Respondent is the director of various companies and has been involved in several projects in Information, Computer and Telecommunication (“ICT”) and engineering, as well as other various fields (including Import and Export, Trading and Finance, JV and especially ICT, Communication, Computer, Network, Electronic Trading, E-Commerce, Domain Registration, Web Development, Consulting Administrative Services). Respondent planned using several domain names for his projects in connection to bona fide offerings of goods or services since 2006 up to present date. Similarly as other cases where respondent’s main activity is web developing and purchasing domain names and developing websites “[…] there is nothing wrong per se in a domain name investor registering domain names and holding them provided that the circumstances do not indicate illegitimate conduct or bad faith […]”.3
The disputed domain name responds to a fan page for “the Republic of Gilead”, in connection to “The Handmaid’s Tale”, a widely known book and television series. “The Republic of Gilead”, colloquially referred to as simply “Gilead” or “the Divine Republic", is a totalitarian patriarchal theocracy that rules over most of the territory that belonged to the former United States in this fiction novel. This novel has a sequence “The Testaments” (2019) and there is as well a prior book from a different author titled “Gilead” (2005). Respondent has these books, which were translated into Persian (“Gilead” was translated in 2013 and “The Handmaid’s Tale” in 2018), and registered three other domain names in respect of his fan project related to these books:
The term “giled” is a dictionary term meaning “hill or mountain of testimony” in the Bible or a geographical term corresponding to a region in ancient Palestine, and it can also be a person’s name, and was the name of a Pulitzer Winner Prize Book, Gilead (2005). “Gilead” (or “gilad”) is the name of three people and two geographic places in the Bible, various quotations of the Bible refer to this term (as “the Hill of Testimony”, a region east of the Jordan river, or a male Hebrew name); and it is also used as an indication of an illiberal and oppressive place, especially on matters related to women's rights, reproduction, or sex (from the novel “The Handmaid's Tale”). The term “gilead” is generic; no exclusive rights can be claimed over it. It is not a breach of the Policy to register a third party’s trademark as a domain name when this mark is a generic word. Respondent has a right to register and use the disputed domain name to attract Internet traffic based on the appeal of a commonly used descriptive or dictionary term, in the absence of circumstances indicating that Respondent’s aim in registering the disputed domain name was to profit from and exploit Complainant’s trademark. Respondent provides examples of various websites that contain the term “gilead” in their domain names and content, various references to this term in dictionaries and biblical encyclopedias, as well as various books and articles referring to this term.
The disputed domain name has not been registered and has not been used in bad faith. Complainant has not provided any evidence as to why Respondent knew or should have known of Complainant or its future business operations in Iran (Republic of) at the time the disputed domain name was registered, and the UDRP decisions cited by Complainant are not applicable to this case. The Parties are located in different jurisdictions and the relevant Complainant’s trademark was not registered, used or known in Iran (Islamic Republic of) at the time the disputed domain name was registered. In Respondent’s country, the disputed domain name was registered at least one year before Complainant registered its rights, and two years before Complainant’s rights may have become a distinctive identifier for its products due to Complainant’s treatment for COVID-19 disease. Complainant has not provided any evidence of its mark being a distinctive identifier in Iran (Islamic Republic of) before COVID-19 started, which earliest start date, was November 17, 2019. Complainant underlines that it is active in Iran (Islamic Republic of) for the purpose of COVID-19 treatment, indicating that in light of the recent news coverage of its treatment for this disease, including clinical trials of its products in this country, there is no doubt that Respondent was fully aware of Complainant’s trademarks when it registered the disputed domain name. Furthermore, Respondent is not a doctor or related to the medical industry. Respondent was not aware of Complainant and its trademarks until receiving Complainant and Complainant’s cease and desist letter on August 20, 2020. There is no evidence that Respondent had Complainant in mind when registering the disputed domain name.
Complainant makes false or incomplete allegations against Respondent. Respondent’s email and phone number indicated in the WhoIs record of the disputed domain name are correct, only the address indicated is inaccurate as a way to be protected against spams and scams. Equally, as it is a common practice to use privacy services for this purpose, which does not necessarily indicate bad faith. On August 20, 2020, Respondent was contacted by an unknown person through a WhatsApp message, including a copy of the cease and desist letter mentioned in the Complaint, but the following day (August 21, 2020) this person urged a reply, and, subsequently, deleted the message and the said letter. On August 24, 2020, Respondent replied to this person indicating the disputed domain name was registered before the registration of Complainant’s trademarks in Iran (Islamic Republic of), but the Complaint does not mention this fact.
Complainant’s unexplained 3-year delay in acting indicates that Complainant did not truly believe that the disputed domain name was registered or used in bad faith, and many circumstances of this case reveal Complainant’s bad faith in an attempt of Reverse Domain Name Hijacking (“RDNH”). When some years passed after domain name was registered, as in the present case, it is harder to establish bad faith and easier to prove RDNH. Complainant’s trademark registration does not provide an automatic right to prevent Respondent from registering and using the disputed domain name, and Complainant’s representatives (in due diligence) should have known that it was not possible to prove two of the three requirements under the Policy, providing false or incomplete information and evidence, in bad faith. Taking into consideration that Complainant has been involved in prior cases under the UDRP, it should be entirely aware of its lack of merit, having no realistic prospect of success. There is a false certification in the Complaint indicating that it is to the best of Complainant’s knowledge complete and accurate.
Respondent has cited numerous decisions under the UDRP as well as various sections of the WIPO Overview 3.0 that it considers supportive of its position, and requests the Panel to deny relief to Complainant.
6. Discussion and FindingsThe Complaint complies with all formal requirements and no deficiency has been observed according to the Policy, the Rules and the Supplemental Rules. Complainant has made the relevant assertions as required by the Policy and the dispute is properly within the scope of the Policy. The Panel has authority to decide the dispute examining the three elements in paragraph 4(a) of the Policy, taking into consideration all of the relevant evidence, annexed material and allegations, and performing some limited independent research under the general powers of the Panel articulated, inter alia, in paragraph 10 of the Rules. Noting the substantive similarities between the Policy and the UDRP, the Panel will refer to prior UDRP cases and doctrine where appropriate.
A. Identical or Confusingly SimilarComplainant has rights in the GILEAD mark by virtue of its numerous trademark registrations around the world, and as a result of its continuous international use of this mark (over 30 years), goodwill and reputation.
The Panel notes that Complainant’s rights over the GILEAD mark in Iran (Islamic Republic of) postdates the registration of the disputed domain name. However, it is to be noted that the expression “trademark or service mark” as used in paragraph 4(a)(i) of the Policy encompasses both registered and unregistered marks, and the jurisdictions where Complainant’s trademarks are valid are not considered relevant in the assessment under the first element of the Policy. The fact that the disputed domain name was registered before Complainant acquired trademark rights in the term “gilead” in this jurisdiction, does not by itself preclude Complainant’s standing to file this case, nor a finding of identity or confusing similarity under the first element. See section 1.1, WIPO Overview 3.0.
In cases where a domain name incorporates the entirety of a trademark, or where at least a dominant feature of the relevant mark is recognizable in the domain name, the domain name will normally be considered identical or confusingly similar to that mark for purposes of the Policy. Furthermore, the applicable generic Top-Level-Domain (“gTLD”) or ccTLD in a domain name is considered a standard technical registration requirement and, as such, is generally disregarded under the first element confusing similarity test. See sections 1.7, and 1.11, WIPO Overview 3.0.
The disputed domain name incorporates the GILEAD mark in its entirety, and the ccTLD “.ir” is a technical requirement, generally disregarded for the purpose of the analysis of the confusing similarity. Accordingly, the Panel finds that the disputed domain name is identical to Complainant’s trademark GILEAD, and the first element of the Policy under paragraph 4(a)(i) has been satisfied.
B. Rights or Legitimate InterestsAlthough Complainant bears the ultimate burden of establishing all three elements of paragraph 4(a) of the Policy, prior decisions under the Policy as well as under the UDRP have recognized that this could result in the often impossible task of proving a negative, requiring information that is primarily if not exclusively within Respondent’s knowledge. Thus, the consensus view is that paragraph 4(c) of the Policy shifts to Respondent the burden of production to come forward with relevant evidence of rights or legitimate interests in the disputed domain name, once Complainant has made a prima facie case that Respondent lacks rights or legitimate interests.
Complainant’s prima facie assertions and evidence effectively shift the burden to Respondent of producing evidence of rights or legitimate interests in the disputed domain name in order to rebut Complainant’s prima facie case.
Paragraph 4(c) of the Policy provides the circumstances, without limitation, for Respondent to contest Complainant’s prima facie case under paragraph 4(a)(ii) of the Policy, and to establish rights or legitimate interests in the disputed domain name.
Respondent alleges that before any notice of the dispute, he has used of the disputed domain name in connection with a fan page related to a novel and a television series that, due to local Internet rules in Iran (Islamic Republic of), was not accessible outside this country, inserting in the Response some images allegedly corresponding to this website. The Panel notes, however, that no actual and dated captures of this website have been provided by Respondent or any other evidence that may have allowed the Panel to evaluate the veracity of Respondent’s allegations in this respect, not being able to analyze whether the images and photographs provided were actually included in Respondent’s website before the notice of the dispute. The Panel considers that Respondent may have been able to provide, for example, captures of his website, which would include their respective dates, invoices related to the design and/or hosting of the site, or any other documentation that may normally be in his possession related to the design or development of this website and any project related to it.
The Panel further notes that, according to the evidence provided by Complainant, the disputed domain name was inactive at the time of filing the Complaint, circumstance that Respondent attributes to regulatory restrictions in his country. However, at the time of drafting this decision, the Panel has been able to access to Respondent’s website with no difficulty, not having Respondent provided any explanation for or information about this sudden change on Internet restrictions in his country.
The Panel further finds remarkable that, despite the time elapsed since the registration of the disputed domain name (approximately 3 years), the website linked to the disputed domain name appears to be just a landing page with not a single section or any content related to the images displayed, and with no reference to its owner or its copyright date. This site only includes several photographs and a map in connection to the books and television series “The Handmaid’s Tale” (the same images inserted in the Response), and an email address.
Respondent further mentions three other domain names allegedly related to the same project in connection to its fan page for “The Handmaid’s Tale”, namely
The Panel further notes that Respondents appears to mix up the concepts of a term being “generic” and a term “being included in the dictionary”, alleging that being the word “gilead” included in the dictionary and/or biblical encyclopedia (having this word various understandable meanings), it should be considered generic not being possible to claim any exclusive rights over it. This is a common mistake perfectly addressed by section 2.10 of the WIPO Overview 3.0, which the Panel finds important to partially reproduce: “The fact that a particular term has a dictionary meaning is sometimes confused with the notion of a “generic” term. When used in a non-dictionary distinctive sense (i.e., in a manner that bears no relation to the goods or services being sold), such dictionary terms can function as “arbitrary” trademarks. […]”
The Panel considers that the term “gilead” bears no direct relation or resemblance to the goods commercialized under Complainant’s trademarks, being a perfect and valid identifier of their origin, fulfilling all trademark’s functions. Additionally, the GILEAD mark has acquired a higher level of distinctiveness derived from its continued used over 30 years, its acquired goodwill and reputation.
It is further to be noted that a core factor in assessing fair use of the disputed domain name is that it does not falsely suggest affiliation with Complainant’s trademarks. See section 2.5, WIPO Overview 3.0. The disputed domain name incorporates the GILEAD mark being identical to this trademark, reproducing the main element of Complainant’s company name and being identical (excluding the ccTLD “.ir”) to Complainant’s corporate website’s domain name (
All the above-mentioned circumstances lead the Panel to conclude that Respondent has not produced sufficient evidence to rebut Complainant’s prima facie case, and all the case cumulative facts and circumstances point to consider that Respondent lacks any rights or legitimate interests in the disputed domain name. Therefore, the second element of the Policy under paragraph 4(a)(ii) has been established.
C. Registered or Used in Bad FaithThe Policy, paragraph 4(a)(iii), requires that Complainant establishes that the disputed domain name has been registered or is being used in bad faith.
The applicable standard of proof in UDRP cases is the “balance of probabilities” or “preponderance of the evidence”, being the Panel prepared to draw certain inferences in light of the particular facts and circumstances of the case. See section 4.2, WIPO Overview 3.0. The Panel considers such standard appropriate in the present case.
The Panel considers that all cumulative circumstances of this case point to bad faith registration of the disputed domain name:
(i) the disputed domain name incorporates the GILEAD mark in its entirety, being identical to this trademark, to Complainant’s domain name, and to the main element of Complainant’s company name, which creates a likelihood of confusion or implied affiliation and the impression that the disputed domain name refers to Complainant’s official website for Iran (Islamic Republic of), suggesting sponsorship or endorsement by Complainant;
(ii) Complainant’s trademark is being used for over 30 years and is internationally reputed, having a high presence over the Internet, which, due to its global nature, expands its content to all jurisdictions including Iran (Republic of) where Respondent is located;
(iii) Respondent has been involved in prior cases under the Policy, being respondent in up to eight other cases, decided in favor to the respective complainants (except for Chevron Intellectual Property LLC v. Mohammadali Mokhtari, Mohammad Ali Mokhtari,WIPO Case No. DIR2020-0017, where the panel ordered the transfer of two disputed domain names, and denied the complaint regarding the third one). The Panel notes that these cases refer to reputed third parties’ trademarks being the disputed domain names identical to these marks (only adding the ccTLD “.ir”), and one of these cases refers to a well-known trademark in the pharmaceutical industry (see F. Hoffmann-La Roche AG v. Mohammadali Mokhtari,WIPO Case No. DIR2019-0007);
(iv) as Respondent has experience both in the Policy (due to the above-mentioned prior cases), and in ICT (having worked in various different projects related to other websites and domain names since 2006), it would have been normal, in the Panel’s view, that Respondent had conducted some searches over the Internet regarding the term “gilead” before registering the disputed domain name; and the Panel considers that any of these searches would have revealed probably Complainant’s trademark and its corporate website under the domain name
(v) Respondent has not provided sufficient evidence supporting its allegations in respect to the use of the disputed domain name in connection to a fan page before the notice of the dispute, not having provided any relevant evidence that may allow the Panel to evaluate the veracity of such allegations;
(vi) Respondent has alleged that, due to regulatory restrictions, his website was not accessible outside Iran (Republic of), but this website started to be accessible at some point in time after the filing of the Complaint and is accessible at the time of drafting this decision, not having Respondent provided any explanation in this respect;
(vii) Respondent’s website (currently) linked to the disputed domain name (and accessible), is just a landing page with a very few photographs, not containing any section or any content related to the images displayed a part from some brief texts inserted in some of the photographs, and not including any reference to its owner or its copyright date;
(viii) other domain names registered by Respondent, allegedly as part of the same fan page project related to the disputed domain name, are resolving to parked websites that offer them for sale and contain PPCs; and
The fact that Respondent has registered, at least, eight other domain names incorporating third parties’ trademarks related to the ccTLD “.ir”, which have been subject of previous proceedings under the Policy4, one of them related to a well-known trademark in the same industry of Complainant’s (the pharmaceutical industry), is particularly relevant. The Panel considers that these circumstances corroborate the finding of Respondent’s bad faith, indicating a pattern of bad faith registrations targeting third parties’ trademarks.
Additionally, the Panel considers more likely than not that the disputed domain name was inactive or equally linked to a parked website including PPCs, as the other three domain names registered by Respondent – in his words – as part of the same project, being the current landing page linked to the disputed domain name just a pretext for Respondent’s illegitimate activity. However, it is sufficient under the Policy to prove the registration or the use of the disputed domain name in bad faith, not being, therefore, necessary to make a decision about the possible bad faith use of the disputed domain name.
Therefore, on the balance of probabilities, taking into consideration all cumulative circumstances of this case, the Panel considers that the disputed domain name was very likely registered targeting Complainant’s reputed GILEAD mark with the intention of obtaining a free ride on its established reputation.
In addition, the Panel notes that Respondent had registered other domain names that were offered for sale and that were subject of previous proceedings under the Policy, see Clair AG v. Mohammadali Mokhtari,WIPO Case No. DIR2020-0004; and Tetra Laval Holdings & Finance S.A. v. Mohammad Ali Mokhtari,WIPO Case No. DIR2010-0007. Noting the circumstances of this case, the Panel finds that the disputed domain name was probably registered primarily for transferring it to Complainant (or even to one of its competitors) for a likely valuable consideration in excess of the documented out-of-pocket costs directly related to the disputed domain name, which constitutes bad faith under the Policy.
Finally, Respondent’s conduct has further prevented Complainant from reflecting its trademark in a corresponding domain name in connection to the Iranian market.
All of the above-mentioned circumstances lead the Panel to conclude that the disputed domain name was registered in bad faith. Accordingly, the Panel concludes that the third element of the Policy under paragraph 4(a)(iii) has been established.
D. Reverse Domain Name Hijacking (“RDNH”)The Panel finds that Complainant’s conduct throughout it proceeding is not uncommon.
Complainant evidently and understandably considered the disputed domain name identical to its trademark and its corporate website domain name starting this proceeding to find relief for this situation. The circumstance of being the disputed domain name registered before Complainant’s trademark was registered in Iran (Republic of) is perfectly admissible under the Policy, as well as the three years’ time period lapsed between the registration of the disputed domain and the filing of the Complaint. The Panel finds that the period of three years is not particularly long, and, in any case, mere delay between the registration of the disputed domain name and the filing of the Complaint does not bar Complainant from filing this case and does not affect the outcome of the proceeding. Trademark owners cannot reasonably be expected to permanently monitor for every instance of potential trademark abuse, nor to instantaneously enforce each such instance they may become aware of. See section 4.17, WIPO Overview 3.0.
Accordingly, the Panel finds no reason to consider that the Complaint was brought abusively.
7. DecisionFor 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
Reyes Campello Estebaranz
Sole Panelist
Date: October 21, 2021
1 See, among others, Gilead Sciences, Inc. v. Brandon Bomberg, Twin Cities Holdings,WIPO Case No. D2020-0613; Gilead Sciences, Inc. v. Paul Berressem,WIPO Case No. D2020-3256; Gilead Sciences, Inc. v. WhoisGuard Protected, WhoisGuard, Inc. / Krug Jr Robert John,WIPO Case No. D2020-2662; Gilead Sciences, Inc. v. James Milner,WIPO Case No. D2021-1602; Gilead Sciences, Inc. v. WhoisGuard Protected, WhoisGuard, Inc. / Ling Ye, Shionogi Co. Ltd.,WIPO Case No. D2020-0731; Gilead Sciences, Inc. v. Whois Agent, Domain Protection Services, Inc. / Syed Hussain, IBN7 Media Group,WIPO Case No. D2020-1916.
2 Complainant cites the following cases:
- Clair AG v. Mohammadali Mokhtari,WIPO Case No. DIR2020-0004;
- Tetra Laval Holdings & Finance S.A. v. Mohammad Ali Mokhtari,WIPO Case No. DIR2010-0007;
- Petróleo Brasileiro S.A. -Petrobras v. Mohammad Ali Mokhtari,WIPO Case No. DIR2013-0004;
- Amundi v. Mohammad Ali Mokhtari,WIPO Case No. DIR2015-0010;
- Accor v. Mohammad Ali Mokhtari,WIPO Case No. DIR2016-0004;
- Sodexo v. Mohammad Ali Mokhtari,WIPO Case No. DIR2017-0006;
- Bollore v. Mohammadali Mokhtari,WIPO Case No. DIR2018-0014; and
- F. Hoffmann-La Roche AG v. Mohammadali Mokhtari,WIPO Case No. DIR2019-0007.
3 In this respect, Respondent cites various cases including Energysquare v. Management Team,WIPO Case No. D2021-1219; and Gigglesworld Corporation v. Mrs Jello,WIPO Case No. D2007-1189.
4 See footnote number 2, supra.