WIPO Domain Name Decision DTV2001-0013 for bellsouth.tv

WIPO Arbitration and Mediation Center

ADMINISTRATIVE PANEL DECISION

BellSouth Intellectual Property Corp. v. Melos aka Thomas Stergios

Case No. DTV2001-0013

1. The Parties

Complainant is BellSouth Intellectual Property Corporation ("Complainant" or "BellSouth"), a corporation organized under the laws of the State of Delaware with its principal place of business located at 824 Market Street, Suite 510, Wilmington, Delaware 19801, USA.

Respondent is Melos, aka Thomas Stergios ("Respondent" or "Melos") located at 2232 Brewers Landing, Memphis, Tennessee 38104, USA.

2. The Domain Name and Registrar

The domain name at issue is (the "Domain Name"). The registrar is dotTV, located at The .tv Corporation International, 1100 Glendon Avenue, 9th Floor, Los Angeles, California, 90024, USA.

3. Procedural History

On May 23, 2001, the WIPO Arbitration and Mediation Center (the "Center") received a copy of the Complaint of Complainant via email. On May 28, 2001, the Center received hardcopy of the Complaint. On May 28, 2001, the Center sent an Acknowledgment of Receipt of Complaint to Complainant. The Complainant paid the required fee.

On June 11, 2001, after the Center sent a Request for Verification to the Registrar requesting verification of registration data, the Registrar confirmed, inter alia, that it is the registrar of the Domain Name and that the Domain Name is registered in the Respondent's name.

The Center verified that the Complaint satisfies the formal requirements of the ICANN Uniform Domain Name Dispute Resolution Policy (the "Policy"), the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules"), and the Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the "Supplemental Rules").

On June 12, 2001, the Center sent a Notification of Complaint and Commencement of Administrative Proceeding to the Respondent together with copies of the Complaint, with a copy to the Complainant. This notification was sent by the methods required under paragraph 2(a) of the Rules.

On July 3, 2001, the Center advised Respondent that it was in default for failing to file its Response. No Response has been received.

After the Center received a completed and signed Statement of Acceptance and Declaration of Impartiality and Independence from Richard W. Page (the "Sole Panelist"), the Center notified the parties of the appointment of a single-arbitrator panel consisting of the Sole Panelist.

4. Factual Background

The Complainant and its predecessors, affiliates, and licensees have adopted and used a number of marks incorporating the term "BELL" since the 1880�s, including SOUTHERN BELL, and SOUTH CENTRAL BELL, among others. Prior to its divestiture, American Telephone & Telegraph Company ("AT&T") operated the "Bell System," consisting of twenty-two (22) "Bell" operating telephone companies that provided local telecommunications exchange services, including Southern Bell Telephone & Telegraph Company ("Southern Bell") and South Central Bell Telephone Company ("South Central Bell"). Each Bell operating company used the BELL mark in connection with the sale and provision of various telephone and communications goods and services.

On January 1, 1984, AT&T was divested of the Bell operating companies pursuant to the orders of the United States District Court for the District of Columbia, ("D.C. Court") in United States v. Western Electric Co., Inc., Civil Action No. 82-0192. AT&T then assigned all of its right, title and interest within the United States in the BELL marks to seven regional holding companies established in connection with divestiture. Complainant�s affiliate, BellSouth Corporation, was one of these holding companies formed to serve Southern Bell and South Central Bell�s regions. BellSouth Corporation thus obtained exclusive rights to the famous BELL mark in its geographical territory, i.e., the Southern part of the United States, subject only to the concurrent user rights of the other companies that shared in the AT&T heritage in other regions of the country.

Since 1984, BellSouth Corporation, together with its affiliates, has provided a wide variety of telecommunications services and related goods in connection with the BELL mark, not only in the Southeastern United States, but also around the world.

Complainant is an affiliated BellSouth company that owns and manages BellSouth intellectual property assets, including the trademarks at issue here, which have been assigned to it.

Complainant�s predecessor obtained U.S. Trademark Registration No. 1,565,562 for the mark BELL for: inter alia, "telephone and telephone accessories"; "installing and maintaining telecommunications systems and equipment for others"; and "providing telecommunication services to others," each with a date of first use of 1900.

Complainant�s predecessor subsequently obtained multiple U.S. Trademark Registrations for BELLSOUTH marks, including the following:

(i) U.S. Trademark Registration No. 1,565,559, issued November 14, 1989, for the mark BELLSOUTH for "customer premises telecommunications networks and parts therefor; telephones and telephone accessories; modems; computers; printers; facsimile machines; multiplexors; computer terminal; telephone answering machines; voice mail systems comprising telephone and computer interface, computer programs and controls for delivering and receiving messages over telephone lines; and computer programs dealing with telecommunications and business management �," each with a date of first use of June 1, 1984.

Complainant also owns other registrations for the mark BELLSOUTH, including the following which are valid, subsisting and unrevoked:

(ii) U.S. Trademark Registration No. 2,244,189, issued May 11, 1999 for BELLSOUTH for "computer software which facilitates searching for and transferring information across global computer communications networks, and for the execution of business transactions using global communications networks; remote control units for television.�;"

(iii) U.S. Trademark Registration No. 2,307,506, issued January 11, 2000, for the mark BELLSOUTH for "insurance services, namely underwriting loss protection and protection programs for pagers;" and

(iv) U.S. Trademark Registration No. 2,341,098 issued April 11, 2000, for the mark BELLSOUTH for "pagers."

(v) U.S. Trademark Registration No. 2,112,067, issued November 11, 1997, for the mark BELLSOUTH.NET for "computer software which facilitates searching for and transferring information across global computer communications networks and for the execution of business transactions using global computer communications networks," with a date of first use of August 16, 1996.

(vi) U.S. Trademark Registration No. 1,670,082, issued December 31, 1991, for the mark BELLSOUTH MOBILITY for "cellular telephones," with a date of first use of June 1, 1984.

(vii) U.S. Trademark Registration No. 1,698,835, issued July 7, 1992, for the mark BELLSOUTH PRODUCTS for "customer premises telecommunications networks and parts therefor; telephones and telephone accessories; modems; computers; printers; facsimile machines; multiplexors; computer terminals; telephone answering machines; voice mail systems comprising telephone and computer interface, computer programs and controls for delivering and receiving messages over telephone lines; and computer programs dealing with telecommunications and business management �," each with a date of first use of June 6, 1984.

(viii) U.S. Trademark Registration No. 2,234,737 for the mark BELLSOUTH #1 for "telephone communication services, namely providing long distance services," with a date of first use of April 30, 1998.

(ix) U.S. Trademark Registration No. 2,354,715 for the mark 1-800-BELLSOUTH for "credit cards and telephone calling cards with magnetic strips, providing credit card and telephone calling card services, and long distance telephone transmission services," each with a date of first use of October 15, 1997.

Complainant and its affiliates have extensively promoted goods and services in connection with the BELL and BELLSOUTH marks (the "Trademarks") through print, television, and radio advertising and online at its sites , , and .

5. Parties� Contentions

A. Complainant�s Contentions

(i) Complainant contends that it has registrations of the Trademarks, that its trademark registrations are valid, subsisting and unrevoked, and that they serve as prima facie evidence of its ownership and the validity of the Trademarks. 15 U.S.C. � 1115. Complainant further alleges that its registrations are incontestable and conclusive evidence of its exclusive right to use the mark in connection with the stated goods and services. 15 U.S.C. �� 1065 and 115(b).

Complainant further contends that as a result of exclusive and extensive use by the Bell operating companies, including Southern Bell and South Central Bell, the Trademarks acquired significant goodwill and became famous and over the years came to represent uncompromised quality, excellence, and integrity in a full range of telecommunications goods and services.

Complainant alleges that the Trademarks have continued to symbolize high quality communications services, and have become a household name across the United States. As a recent Wall Street Journal article explained: "The regional Bell phone companies are everything AT&T Corp. wanted to be. Each Bell is physically connected to virtually every home and office in its territory . . . they are in the Internet business . . . . They are the nation�s largest wireless carriers." See Shawn Young, As Their Onetime Parent Falters, Four Bells Flourish, Wall St. J., Oct. 26, 2000, at B1. The Trademarks have been recognized by U.S. Courts and in a UDRP proceeding as famous marks. See BellSouth Corp. v. B.E.L.-Tronic�s Limited, (Civil Action No. 1-93-CV-1714-CC) (the mark BELL "has been and continues to be a famous trademark.") Id. at p. 22. See also, Companía de Radiocomunicaciones Móviles S.A. and BellSouth Corp. v. Juan Bolinhas d/b/a "MOVICOM BELLSOUTH", WIPO Case No. D2000-0915, at � 7.9(b) (October 5, 2000) (finding that Complainant had a reasonable claim that the BELLSOUTH mark was famous or at least well known in the U.S., among other places).

Accordingly, consumers in the southeastern United States and elsewhere have come to recognize the Trademarks as indicating a product or service originating with a BellSouth company.

(ii) Complainant argues that the Domain Name is confusingly similar to the Trademarks, pursuant to Paragraph 4(a)(i) of the Policy, because the Domain Name wholly incorporates the phrase "bellsouth." Because the Complainant, its predecessors, and its affiliates have used the mark BELLSOUTH in connection with a wide variety of goods and services related to communications, the BELLSOUTH mark has become the central motif in Complainant�s family of marks. Accordingly, the public has come to perceive goods and services that are offered under a BELLSOUTH name or mark as emanating from or being endorsed by or affiliated with Complainant.

Complainant further argues that, as part of the divestiture arrangement, each regional "Bell" company agreed to use the BELL mark in conjunction with its respective regional geographical name, hence the mark: BELLSOUTH. Thus, due to this historical pattern of usage, consumers have grown accustomed to seeing the BELL mark used in conjunction with SOUTH and to associate that combination with Complainant.

(iii) Complainant contends that Respondent has no rights or legitimate interests in the Domain Name, pursuant to Paragraph 4(a)(ii), and that Respondent has failed to demonstrate any of the three circumstances that constitute rights to or legitimate interests in the Domain Name.

Complainant�s (and its predecessors�) first use of the BELL mark predates by almost 100 years any use Respondent may have made of "" as a trade name, domain name, or mark. In addition, Complainant�s first use of the BELLSOUTH mark predates Respondent�s domain name registration by more than 15 years. Because Complainant�s BELLSOUTH trademark registrations were issued long before Respondent registered the Domain Name, Respondent is charged with constructive knowledge of them under the Lanham Act. Therefore, for purposes of Paragraph (4)(c) of the Policy, any use Respondent may claim to have made was not "bona fide" because it was made with knowledge of Complainant�s prior rights in the BELLSOUTH mark.

Respondent has no registration for a corporation under the name "bellsouth" or "." Respondent has no fictitious business name registration for "bellsouth" or "." Having searched appropriate databases, Complainant has found no evidence that Respondent has ever used the trade name "" or been known as "". Respondent has not previously offered goods or services on the world wide web under the domain name .

(iv) Complainant contends that Respondent registered and is using the Domain Names in bad faith in violation of Paragraph 4(a)(iii).

Complainant reasonably believes that Respondent, prior to its adoption and use of the domain name was aware that Complainant was the owner of the Trademarks because of the widespread and long-standing advertising and marketing of goods and services under the BELL and BELLSOUTH names and marks. Moreover, based on Respondent�s domain name registration, Respondent has a personal residence or business located in Memphis, Tennessee. Memphis, Tennessee is in BellSouth�s service area. Accordingly, Respondent probably registered the Domain Name with actual knowledge of and an intent to trade on Complainant�s rights in the Trademarks.

In addition, the parties� communications evidence Respondent�s bad faith intent to profit wrongfully from the Domain Name containing Complainant�s mark. Prior to February 21, 2001, the Complainant became aware that the Respondent had registered the Domain Name but that Respondent was not operating a site under the Domain Name. On February 21, 2001, the Complainant wrote a cease and desist letter to Respondent.

By email dated February 26, 2001, Respondent offered to transfer the domain name in exchange for $75,000. This demanding of a ransom indicates Respondent�s intent to prevent Complainant from reflecting its mark in a corresponding domain name unless Complainant pays Respondent�s demanded sum. In addition, this highly unreasonable amount, coupled with the fact that Respondent has never activated a site even though he has held the Domain Name for almost a year, indicates that the Respondent acquired the Domain Name primarily for the purpose of selling or otherwise transferring the domain name registration to the Complainant for valuable consideration in excess of his documented out-of-pocket costs directly related to the Domain Name.

Complainant further alleges that Respondent is thus using the Domain Name in order to trade upon the public's recognition of Complainant's BELL and BELLSOUTH marks and the goodwill associated with them by compelling Complainant to pay for the Domain Name an amount that exceeds Respondent�s out of pocket costs and that is based on the value of Complainant�s marks embodied therein.

B. Respondent�s Contentions

(i) Respondent does not dispute that the Complainant has registrations of the Trademarks.

(ii) Respondent fails to contest Complainant�s assertions that the Domain Name is identical with and confusingly similar to the Trademarks.

(iii) Respondent failed to contest Complainant�s assertions that Respondent has no rights to or legitimate interest in the Domain Name.

(iv) Respondent fails to contest Complainant�s assertion that Respondent registered and used the Domain Name in bad faith.

6. Discussion and Findings

Paragraph 15(a) of the Rules instructs the Panel as to the principles the Panel is to use in determining the dispute: "A Panel shall decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules, and any rules and principles of law that it deems applicable."

Because both the Complainant and Respondent are domiciled in the United States and United States courts have recent experience with similar disputes, to the extent that it would assist the Panel in determining whether the Complainant has met its burden as established by Paragraph 4(a) of the Policy, the Panel shall look to rules and principles of law set out in decisions of the courts of the United States. Tribeca Film Center, Inc. v. Brusasco-Mackenzie, WIPO Case No. D2000-1772 (Apr. 10, 2001), n. 3.

Even though Respondent has failed to file a Response or to contest Complainant�s assertions, the Sole Panelist will review the evidence proffered by Complainant to verify that the essential elements of the claims are met.

Paragraph 4(a) of the Policy directs that the Complainant must prove each of the following:

i) that the domain name registered by the Respondent is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and,

ii) that the Respondent has no legitimate interests in respect of the domain name; and,

iii) that the domain name has been registered and is being used in bad faith.

Enforceable Trademark Rights

Complainant contends that it has registrations of the Trademarks, that its trademark registrations are valid, subsisting and unrevoked, and that they serve as prima facie evidence of its ownership and the validity of the Trademarks. 15 U.S.C. � 1115. Complainant further alleges that its registrations are incontestable and conclusive evidence of its exclusive right to use the mark in connection with the stated goods and services. 15 U.S.C. �� 1065 and 115(b).

Panel decisions have held that registration of a mark is prima facie evidence of validity, which creates a rebuttable presumption that the mark is inherently distinctive. Respondent has the burden of refuting this assumption. See, e.g., EAuto, L.L.C. v. Triple S. Auto Parts d/b/a Kung Fu Yea Enterprises, Inc., WIPO Case No. D2000-0047. It is the Panel's belief that Respondent has not met its burden.

Respondent has not contested the assertions by Complainant that it has valid registrations of the Trademarks. Therefore, the Sole Panelist finds that Complainant, for purposes of this proceeding, has enforceable rights in the Trademarks.

Identity or Confusing Similarity

Complainant further contends that the Domain Names are identical with and confusingly similar to the trademark pursuant to the Policy paragraph 4(a)(i).

Respondent has not contested the assertions by Complainant that the Domain Name is confusingly similar to the Trademarks.

As numerous courts and prior panels have recognized, the incorporation of a trademark in its entirety is sufficient to establish that a domain name is identical or confusingly similar to the complainant�s registered mark. See Paccar Inc. v. Telescan Technologies, L.L.C., 115 F. Supp. 772 (E.D. Mich. 2000) (finding that , and similar domain names are not appreciably different from the trademarks PETERBUILT and KENWORTH); Quixtar Investments Inc. v. Dennis Hoffman, WIPO Case No. D2000-0253 (May 29, 2000) (finding that QUIXTAR and are legally identical). The addition of other terms in the domain name does not affect a finding that the domain name is identical or confusingly similar to the Complainant�s registered trademark.

The Sole Panelist notes that the entirety of the BELL SOUTH mark is included in the Domain Name.

Generally, a user of a mark "may not avoid likely confusion by appropriating another's entire mark and adding descriptive or non-distinctive matter to it." 3 J. Thomas McCarthy, McCarthy on Trademarks & Unfair Competition � 23:50 (4th ed. 1998).

The addition of the phrase ".com" is non-distinctive because it is a gTLD required for registration of a domain name.

Therefore, the Sole Panelist finds that the Domain Name is confusingly similar to the Trademarks pursuant to the Policy paragraph 4(a)(i).

Rights or Legitimate Interests

Complainant contends that Respondent has no rights or legitimate interests in the Domain Name pursuant to the Policy paragraph 4(a)(ii).

Paragraph 4(a)(ii) requires the Complainant to prove that the Respondent has no rights to or legitimate interests in the Domain Name. Once a Complainant establishes a prima facie showing that none of the three circumstances establishing legitimate interests or rights apply, the burden of production on this factor shifts to the Respondent to rebut the showing. The burden of proof, however, remains with Complainant to prove each of the three elements of Paragraph 4(a). See Document Technologies, Inc. v. International Electronic Communications, Inc., WIPO Case No. D2000-0270 (WIPO June 6, 2000).

Respondent has no relationship with or permission from Complainant for the use of the Trademarks.

The Policy paragraph 4(c) allows three nonexclusive methods for the Sole Panelist to conclude that Respondent has rights or a legitimate interest in the Domain Name:

(i) before any notice to you [Respondent] of the dispute, your use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or

(ii) you [Respondent] (as an individual, business, or other organization) have been commonly known by the domain name, even if you have acquired no trademark or service mark rights; or

(iii) you [Respondent] are making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.

The Complainant has asserted that it has conducted an investigation of readily available information regarding Respondent. Respondent has no registration for a corporation under the name "bellsouth" or "." Respondent has no fictitious business name registration for "bellsouth" or "." Having searched appropriate databases, Complainant has found no evidence that Respondent has ever used the trade name "" or been known as "". Respondent has not previously offered goods or services on the world wide web under the domain name .

Complainant has sustained its burden of proving that the Respondent lacks rights to or legitimate interests in the Domain Name. Respondent has failed to come forward with concrete evidence that the use of the Domain Name meets the elements for any of the nonexclusive methods provided for in the Policy paragraph 4(c). Therefore, the Sole Panelist finds that Respondent has no rights or legitimate interest in the Domain Name pursuant to the Policy paragraph 4(a)(ii).

Bad Faith

Complainant contends that Respondent registered and is using the Domain Name in bad faith in violation of the Policy paragraph 4(a)(iii).

The Policy paragraph 4(b) sets forth four nonexclusive criteria for Complainant to show bad faith registration and use of domain names:

(i) circumstances indicating that you have registered or you have acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the domain name; or

(ii) you have registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or

(iii) you have registered the domain name primarily for the purpose of disrupting the business of a competitor; or

(iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your web site or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of your web site or location or of a product

Complainant alleges that by email dated February 26, 2001, Respondent offered to transfer the Domain Name in exchange for $75,000. In addition, Respondent has never activated a site even though he has held the Domain Name for almost a year. This is sufficient evidence for the Sole Panelist to conclude that the Respondent acquired the Domain Name primarily for the purpose of selling or otherwise transferring the Domain Name to the Complainant for valuable consideration in excess of his documented out-of-pocket costs directly related to the Domain Name.

Therefore, the Sole Panelist finds that Complainant has shown the necessary elements of bad faith under the Policy paragraph 4(b)(i).

The four criteria set forth in the Policy paragraph 4(b) are nonexclusive. Telstra Corporation Limited v. Nuclear Marshmellows, WIPO Case No. D2000-0003 (Feb. 18, 2000). In addition to these criteria, other factors alone or in combination can support a finding of bad faith.

One such factor is that Respondent has made no use of the Domain Name. Complainant alleges that Respondent has not developed any active website at or made any other use of the Domain Name. See Telstra Corp. v. Nuclear Marshmallows, WIPO Case No. D2000-0003.

In Telstra it was established that registration together with "inaction" and other facts can constitute bad faith use, and the Telstra decision has since been cited for that proposition and followed by subsequent Panels. Ingersoll-Rand Co. v. Frank Gully, d/b/a Advcomren, WIPO Case No. D2000-0021; Guerlain, S.A. v. Peikang, WIPO Case No. D2000-0055; Compaq Computer Corp. v. Boris Beric, WIPO Case No. D2000-0042; Sanrio Co. Ltd. and Sanrio, Inc. v. Neric Lau, WIPO Case No. D2000-0172; 3636275 Canada, dba eResolution v. eR, WIPO Case No. D2000-0110; Marconi Data Systems, Inc. v. IRG Coins and Ink Source, Inc., WIPO Case No. D2000-0090; Strålfors AB v. P D S AB, WIPO Case No. D2000-0112; InfoS, Inc. v. Ofer, WIPO Case No. D2000-0075.

To quote a prior Panel decision, "[B]ecause Respondent is contributing no value-added to the Internet -- it is merely attempting to exploit a general rule of registration -- the broad community of Internet users will be better served by transferring the domain name to a party with a legitimate use for it." Educational Testing Service v. TOEFL, WIPO Case No. D2000-0044.

A second factor found to support a finding of bad faith is Respondent�s knowledge of the Complainant�s Trademarks when Respondent registered the Domain Name. Complainant has alleged, without refutation, that Respondent had actual knowledge of the Trademarks because Respondent lived within the service area.

In addition, Respondent had constructive notice of the Trademarks, as a trademark search on the date of the registration of the Domain Name would have revealed Complainant�s registrations in the United States. Actual or constructive knowledge of the Complainant�s rights in the Trademarks is a factor supporting bad faith. See Expedia, Inc. v. European Travel Network, WIPO Case No. D2000-0137 (April 18, 2000); Document Technologies v. International Electronic Communications, Inc., WIPO Case No. D2000-0270 (June 6, 2000) (Respondent�s knowledge of complainant�s mark at the time of registration of the domain name suggests bad faith).

A third factor is the use of Complainant�s entire mark in the Domain Name, thus making it difficult to infer a legitimate use of the Domain Name by Respondent. In Cellular One Group v. Paul Brien, WIPO Case No. D2000-0028 (March 10, 2000), Complainant filed a WIPO complaint against the Registrant of domain name . The WIPO panel agreed with Complainant that the Registrant unlawfully registered an identical or confusingly similar domain name in bad faith. Moreover, the Panel inferred bad faith use of , because the domain name included Complainant�s entire trademark. In light of Cellular One�s trademark registrations and applications, "it is not possible to conceive of a plausible circumstance in which Respondent could legitimately use the domain name." See Telstra Corp. Ltd. v. Nuclear Marshmallows, WIPO Case No. D2000-0003, paragraph 7.

The evidence establishes: (i) inaction by Respondent in the use the Domain Name to post any content on the Internet or for any other legitimate purpose; (ii) actual and constructive knowledge by Respondent of Complainant�s rights in the Trademarks upon the registration of the Domain Name; and (iii) the use of Complainant�s entire mark creating an absence of any plausible use of the Domain Name that would constitute good faith.

Based upon this evidence, the Sole Panelist finds that Complainant has shown sufficient facts to support a finding that the Domain Name was registered and used in bad faith pursuant to the Policy paragraph 4(a)(iii).

7. Decision

The Sole Panelist concludes (a) that the Domain Name is identical with or confusingly similar to Complainant�s registered Trademarks, (b) that Respondent has no rights or legitimate interest in the Domain Name and (c) that Respondent registered and used the Domain Name in bad faith. Therefore, pursuant to paragraphs 4(i) of the Policy and 15 of the Rules, the Sole Panelist orders that the Domain Name be transferred to Complainant.

Richard W. Page
Sole Panelist

Dated: September 16, 2001

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