Complainant has also spent considerable money to establish high priority on search engines.
Respondent registered the domain name on May 27, 2005. 29, 2000) (In the absence of a response, it is appropriate to accept as true all allegations of the Complaint.). 27, 2002) (finding the respondents use of a confusingly similar domain name to operate a pay-per-click search engine, in competition with the complainant, was not a bona fide offering of goods or services); Computerized Sec.
Complainant requests that the domain name be transferred from Respondent to Complainant. Complainant makes the following assertions: [a.] Factual background: (i.) Complainant The Complainants solicitors sent a cease and desist email, on 12 July 2005, to the Respondent to which the Registrant responded as follows: there are many thousands of domain names out there that use 'direct' in there domain names. An updated version of the initial website replaced the above site as of 4 November 2005.
[b.] The manner in which the domain names are confusingly similar to a trademark or service mark in which the Complainant has rights. (i.) Rights The Complainant also relies on common law rights.
Complainant submitted a Complaint to the National Arbitration Forum electronically on November 11, 2005; the National Arbitration Forum received a hard copy of the Complaint on November 11, 2005. confirmed by e-mail to the National Arbitration Forum that the domain name is registered with Tucows Inc.
Respondents website features a website offering sex dates. Forum July 31, 2000) (holding that the respondents failure to respond allows all reasonable inferences of fact in the allegations of the complaint to be deemed true); see also Talk City, Inc. Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred: (1)the domain name has been registered and is being used in bad faith.