Dell Inc. v. Geeks Technical Solutions Inc.
Claim Number: FA1509001637797
Complainant is Dell Inc. (“Complainant”), represented by S. Erik Combs, Texas, USA. Respondent is Geeks Technical Solutions Inc. (“Respondent”), New York, USA.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <contactdell.org>, <contactdellsupport.org>, <dell-antivirus.org>, <dell-backup.org>, <dell-help.org>, <dell-login.org>, <dell-manager.org>, <dell-premier.org>, <dell-protection.org>, <dell-service.org>, <dell-services.org>, <dell-software.org>, <dell-update.org>, <dell-virus.org>, <dellbackuprecovery.org>, <dellbiosupdate.org>, <dellchat.org>, <dellchatsupport.org>, <dellcomputer-support.org>, <dellcontact.org>, <dellcontactnumber.org>, <dellcustomer-service.org>, <dellcustomercare.org>, <dellcustomerhelp.org>, <dellcustomerservicenumber.org>, <dellcustomersupport.org>, <delldatasafe.org>, <delldownloads.org>, <delldriver.org>, <delldriverdownload.org>, <delldrivers.org>, <delldriversupport.org>, <delldriverswindows.org>, <delldriverupdate.org>, <dellerror.org>, <dellerrorcode.org>, <dellfactoryrestore.org>, <delllaptopsupport.org>, <dellnumber.org>, <dellphonenumber.org>, <dellprinterdrivers.org>, <dellprintersupport.org>, <dellproblem.org>, <dellprosupport.org>, <dellrecoverydisk.org>, <dellrecoverypartition.org>, <dellrepair.org>, <dellrescue.org>, <dellrestore.org>, <dellserialnumber.org>, <dellservicecenter.org>, <dellservicetag.org>, <dellsupportchat.org>, <dellsupportdrivers.org>, <dellsupportnumber.org>, <dellsupportphonenumber.org>, <dellsystemrestore.org>, <delltech-support.org>, <delltechnical-support.org>, <delltechnicalsupport.org>, <delltechsupportnumber.org>, <dellwarranty.org>, <dellwarrantycheck.org>, <dellwarrantylookup.org>, <dellwarrantystatus.org>, <dellwarrantysupport.org>, <dellwebsite.org>, <driversdell.org>, <my-dell.org>, <reset-dell.org>, <resetdell-laptop.org>, and <supportdell.org>, registered with Godaddy.Com, Llc.
The undersigned certifies that he or she has acted independently and impartially and to the best of his or her knowledge has no known conflict in serving as Panelist in this proceeding.
Richard Hill as Panelist.
Complainant submitted a Complaint to the Forum electronically on September 15, 2015; the Forum received payment on September 15, 2015.
On September 15, 2015, Godaddy.Com, Llc confirmed by e-mail to the Forum that the <contactdell.org>, <contactdellsupport.org>, <dell-antivirus.org>, <dell-backup.org>, <dell-help.org>, <dell-login.org>, <dell-manager.org>, <dell-premier.org>, <dell-protection.org>, <dell-service.org>, <dell-services.org>, <dell-software.org>, <dell-update.org>, <dell-virus.org>, <dellbackuprecovery.org>, <dellbiosupdate.org>, <dellchat.org>, <dellchatsupport.org>, <dellcomputer-support.org>, <dellcontact.org>, <dellcontactnumber.org>, <dellcustomer-service.org>, <dellcustomercare.org>, <dellcustomerhelp.org>, <dellcustomerservicenumber.org>, <dellcustomersupport.org>, <delldatasafe.org>, <delldownloads.org>, <delldriver.org>, <delldriverdownload.org>, <delldrivers.org>, <delldriversupport.org>, <delldriverswindows.org>, <delldriverupdate.org>, <dellerror.org>, <dellerrorcode.org>, <dellfactoryrestore.org>, <delllaptopsupport.org>, <dellnumber.org>, <dellphonenumber.org>, <dellprinterdrivers.org>, <dellprintersupport.org>, <dellproblem.org>, <dellprosupport.org>, <dellrecoverydisk.org>, <dellrecoverypartition.org>, <dellrepair.org>, <dellrescue.org>, <dellrestore.org>, <dellserialnumber.org>, <dellservicecenter.org>, <dellservicetag.org>, <dellsupportchat.org>, <dellsupportdrivers.org>, <dellsupportnumber.org>, <dellsupportphonenumber.org>, <dellsystemrestore.org>, <delltech-support.org>, <delltechnical-support.org>, <delltechnicalsupport.org>, <delltechsupportnumber.org>, <dellwarranty.org>, <dellwarrantycheck.org>, <dellwarrantylookup.org>, <dellwarrantystatus.org>, <dellwarrantysupport.org>, <dellwebsite.org>, <driversdell.org>, <my-dell.org>, <reset-dell.org>, <resetdell-laptop.org>, <supportdell.org> domain names are registered with Godaddy.Com, Llc and that Respondent is the current registrant of the names. Godaddy.Com, Llc has verified that Respondent is bound by the Godaddy.Com, Llc registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN’s Uniform Domain Name Dispute Resolution Policy (the “Policy”).
On September 16, 2015, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of October 6, 2015 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent’s registration as technical, administrative, and billing contacts, and to postmaster@contactdell.org, postmaster@contactdellsupport.org, postmaster@dell-antivirus.org, postmaster@dell-backup.org, postmaster@dell-help.org, postmaster@dell-login.org, postmaster@dell-manager.org, postmaster@dell-premier.org, postmaster@dell-protection.org, postmaster@dell-service.org, postmaster@dell-services.org, postmaster@dell-software.org, postmaster@dell-update.org, postmaster@dell-virus.org, postmaster@dellbackuprecovery.org, postmaster@dellbiosupdate.org, postmaster@dellchat.org, postmaster@dellchatsupport.org, postmaster@dellcomputer-support.org, postmaster@dellcontact.org, postmaster@dellcontactnumber.org, postmaster@dellcustomer-service.org, postmaster@dellcustomercare.org, postmaster@dellcustomerhelp.org, postmaster@dellcustomerservicenumber.org, postmaster@dellcustomersupport.org, postmaster@delldatasafe.org, postmaster@delldownloads.org, postmaster@delldriver.org, postmaster@delldriverdownload.org, postmaster@delldrivers.org, postmaster@delldriversupport.org, postmaster@delldriverswindows.org, postmaster@delldriverupdate.org, postmaster@dellerror.org, postmaster@dellerrorcode.org, postmaster@dellfactoryrestore.org, postmaster@delllaptopsupport.org, postmaster@dellnumber.org, postmaster@dellphonenumber.org, postmaster@dellprinterdrivers.org, postmaster@dellprintersupport.org, postmaster@dellproblem.org, postmaster@dellprosupport.org, postmaster@dellrecoverydisk.org, postmaster@dellrecoverypartition.org, postmaster@dellrepair.org, postmaster@dellrescue.org, postmaster@dellrestore.org, postmaster@dellserialnumber.org, postmaster@dellservicecenter.org, postmaster@dellservicetag.org, postmaster@dellsupportchat.org, postmaster@dellsupportdrivers.org, postmaster@dellsupportnumber.org, postmaster@dellsupportphonenumber.org, postmaster@dellsystemrestore.org, postmaster@delltech-support.org, postmaster@delltechnical-support.org, postmaster@delltechnicalsupport.org, postmaster@delltechsupportnumber.org, postmaster@dellwarranty.org, postmaster@dellwarrantycheck.org, postmaster@dellwarrantylookup.org, postmaster@dellwarrantystatus.org, postmaster@dellwarrantysupport.org, postmaster@dellwebsite.org, postmaster@driversdell.org, postmaster@my-dell.org, postmaster@reset-dell.org, postmaster@resetdell-laptop.org, and postmaster@supportdell.org. Also on September 16, 2015, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent’s registration as technical, administrative and billing contacts.
Having received no response from Respondent, the Forum transmitted to the parties a Notification of Respondent Default.
On October 12, 2015, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the Forum appointed Richard Hill as Panelist.
Having reviewed the communications records, the Administrative Panel (the "Panel") finds that the Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, the Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent.
Complainant requests that the domain names be transferred from Respondent to Complainant.
A. Complainant
Complainant states that it is a world leader in computers, computer accessories, and other computer-related products and services. For several years, Complainant has been the world’s largest direct seller of computer systems. As a consequence its marketing and sales success, Complainant and its DELL marks have become famous in the United States and many other countries. Complainant uses its DELL mark in connection with its business. The mark has been registered in numerous jurisdictions, dating back to 1994. Respondent’s disputed domain names are confusingly similar as they incorporate the DELL mark entirely, incorporate hyphenation, and merely append the generic terms (and combinations thereof) highly likely to be associated with Dell and its goods and services, such as “antivirus,” “backup,” “bios,” “care,” “chat,” “check,” “computer,” “contact,” “data safe,” “disk,” “download(s),” “driver(s),” “error,” “error code,” “factory restore,” “help,” “laptop,” “login,” “lookup,” “manager,” “my,” “(phone) number,” “partition,” “premier,” “printer,” “problem,” “protection,” “recovery,” “repair,” “rescue,” “reset,” “restore,” “serial number,” “service,” “service center,” “service tag,” “status,” “support,” “system,” “tech,” “technical,” “update,” “virus,” “warranty,” “website,” and “windows.” One of the domain names also includes Complainant’s mark PROSUPPORT; i.e., <dellprosupport.org> (PROSUPPORT; USPTO Registry No. 3,186,589, registered Dec. 19, 2006). Further, the presence of a generic top-level domain (“.org”) is irrelevant in a UDRP 4(a)(i) analysis. Complainant cites UDRP precedents to support its position.
According to Complainant, Respondent has no rights or legitimate interests in respect of the disputed domain names. Respondent has no authorization to register domain names including the DELL mark, nor has Respondent evidenced that it has been commonly known by the disputed domain names in any context. Further, Respondent has not been making use of the disputed domain names in connection with any bona fide offering of goods or services or for any legitimate noncommercial or fair use. Rather, Respondent’s websites prominently display pictures of Complainant’s products and promotes Respondent’s competing computer support services. Respondent uses highly similar or identical webpages which feature similar elements at each of the disputed domain names. Respondent’s website located at <delltechsupportnumber.org> prominently displays a version of the Dell logo at the top of each page along with the words “Tech Support Number”. Respondent’s website encourages visitors to call “DELL TECH SUPPORT NUMBER TOLL FREE 1-800-838-4023,” a number not associated with Complainant. Complainant cites UDRP precedents to support its position.
Complainant alleges that Respondent has registered and used the disputed domain names in bad faith. First, Respondent has evinced a bad faith pattern of domain registrations by registering seventy-one infringing domains in the instant case. See Policy, at ¶ 4(b)(ii). Next, Respondent has offered competing services at the infringing domains, demonstrating bad faith per Policy ¶ 4(b)(iii). Additionally, Respondent has offered these competing services to deceive Internet users with the intent to commercially gain pursuant to Policy ¶ 4(b)(iv). Next, by using the disputed domain names for websites displaying the DELL Marks and images of Complainant’s products, Respondent has intentionally attempted to attract, for commercial gain, Internet users to Respondent’s websites by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of Respondent’s websites. Next, Respondent has registered and used the disputed domains with actual knowledge of the DELL mark and Complainant’s rights in the mark under Policy ¶ 4(a)(iii) because of the distinct connection of the domains’ offerings with those of Complainant, as well as the fame and notoriety associated with the DELL mark. Last, the existence of a disclaimer on the websites’ resolving pages does nothing to dispel a finding of bad faith. Complainant cites UDRP precedents to support its position.
Complainant has registered trademarks for the name DELL, dating back to 1994. Its marks are famous around the world.
Complainant has not licensed or otherwise authorized Respondent to use its mark.
The disputed domain names were registered in 2015.
The products and services offered by Complainant are widely used and well known.
Respondent is using the disputed domain names to promote Respondent’s competing computer support services.
Respondent’s web sites attempt to deceive consumers into thinking that Respondent is at least affiliated or connected with, or authorized by, Complainant.
Some of Respondent’s web sites feature Complainant’s mark.
Paragraph 15(a) of the Rules instructs this Panel to "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."
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 registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and
(2) Respondent has no rights or legitimate interests in respect of the domain name; and
(3) the domain name has been registered and is being used in bad faith.
In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(e), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations and inferences set forth in the Complaint as true unless the evidence is clearly contradictory. See Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (Nat. Arb. Forum July 31, 2000) (holding that the respondent’s failure to respond allows all reasonable inferences of fact in the allegations of the complaint to be deemed true); see also Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (“In the absence of a response, it is appropriate to accept as true all allegations of the Complaint.”).
Complainant uses its registered mark DELL in connection with its business in the computer industry, selling laptops, desktops, computer parts and accessories, computer service and support, and other computer-related products and services. Additionally, Complainant has rights in the mark PROSUPPORT.
The disputed domain names are confusingly similar to Complainant’s mark DELL because they incorporate the mark entirely, add hyphenation, and merely append the generic terms (and combinations thereof) highly likely to be associated with Complainant and its goods and services, such as “antivirus,” “backup,” “bios,” “care,” “chat,” “check,” “computer,” “contact,” “data safe,” “disk,” “download(s),” “driver(s),” “error,” “error code,” “factory restore,” “help,” “laptop,” “login,” “lookup,” “manager,” “my,” “(phone) number,” “partition,” “premier,” “printer,” “problem,” “protection,” “recovery,” “repair,” “rescue,” “reset,” “restore,” “serial number,” “service,” “service center,” “service tag,” “status,” “support,” “system,” “tech,” “technical,” “update,” “virus,” “warranty,” “website,” and “windows.” Further, the presence of a generic top-level domain (“.org”) is irrelevant in a UDRP 4(a)(i) analysis. Panels have agreed that such alterations are insignificant when considering the dominant, trademarked portions of disputed domain names. See Chanel, Inc. v. Cologne Zone, D2000-1809 (WIPO Feb. 22, 2001) (“CHANEL, the salient feature of the Domain Names, is identical to a mark in which Complainant has shown prior rights. The addition of the generic term, “perfumes” is not a distinguishing feature, and in this case seems to increase the likelihood of confusion because it is an apt term for Complainant’s business.”); see also Klabzuba Oil & Gas, Inc. v. LAKHPAT SINGH BHANDARI, FA 1625750 (Nat. Arb. Forum July 17, 2015) (holding that “[t]he addition of a hyphen and a gTLD is insufficient to establish distinctiveness from a complainant’s mark.”). Therefore, the Panel concludes that the disputed domain names are confusingly similar to the DELL mark per Policy ¶ 4(a)(i).
The <dellprosupport.org> domain name combines the DELL and PROSUPPORT marks while including the gTLD suffix “.org.” Panels have found the combination of marks to be dispositive of confusing similarity under Policy ¶ 4(a)(i). See Yahoo! Inc. v. Domain Contact 3, FA 1222420 (Nat. Arb. Forum Oct. 13, 2008) (holding that the <hotjobsyahoo.com> domain name is confusingly similar to Complainant’s HOTJOBS mark because the disputed domain name merely combined Complainant’s HOTJOBS mark with Complainant’s YAHOO! mark). Therefore, the Panel concludes that the <dellprosupport.org> domain name is confusingly similar to the DELL and PROSUPPORT marks under Policy ¶ 4(a)(i).
Complainant argues that Respondent has no rights or legitimate interests in respect of the disputed domain names. The Panel agrees. Respondent has no authorization to register domain names including the DELL mark, nor has Respondent evidenced that it has been commonly known by the disputed domain names in any context. Since the WHOIS information merely lists “Geeks Technical Solutions Inc.” as registrant of record, the Panel concludes that Respondent is not commonly known by any of the disputed domain names. See Reese v. Morgan, FA 917029 (Nat. Arb. Forum Apr. 5, 2007) (concluding that the respondent was not commonly known by the <lilpunk.com> domain name as there was no evidence in the record showing that the respondent was commonly known by that domain name, including the WHOIS information as well as the complainant’s assertion that it did not authorize or license the respondent’s use of its mark in a domain name).
Further, Respondent has not been making use of the disputed domain names in connection with any bona fide offering of goods or services or for any legitimate noncommercial or fair use. On the contrary, Respondent’s websites prominently display pictures of Complainant’s products and alleged marks, and promote Respondent’s competing computer support services. Respondent uses highly similar or identical webpages which feature similar elements at each of the disputed domain names. Panels have seen such use as constituting direct competition for commercial gain. See Alcon, Inc. v. ARanked, FA 1306493 (Nat. Arb. Forum Mar. 18, 2010) (“The Panel finds that capitalizing on the well-known marks of Complainant by attracting internet users to its disputed domain names where Respondent sells competing products of Complainant is not a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) or a noncommercial or fair use pursuant to Policy ¶ 4(c)(iii).”). Therefore, the Panel finds that Respondent does not have rights or a legitimate interest in the disputed domain names.
Respondent (who did not reply to Complainant’s contentions) has not presented any plausible explanation for its use of Complainant’s mark. In accordance with paragraph 14(b) of the Rules, the Panel shall draw such inferences from Respondent’s failure to reply as it considers appropriate. Accordingly, the Panel finds that Respondent did not have a legitimate use in mind when registering the disputed domain name.
Complainant asserts Respondent has registered and is using the disputed domain names in bad faith. The Panel agrees. First, Respondent has evinced a bad faith pattern of domain registrations by registering seventy-one infringing domains in the instant case. Past panels have seen registration of multiple infringing domains in an instant UDRP complaint to be indicative of bad faith under Policy ¶ 4(b)(ii). See EPA European Pressphoto Agency B.V. v. Wilson, D2004-1012 (WIPO Feb. 9, 2005) (finding that the respondent’s registration of the <epa-photo.com>, <epaphoto.com> and <epaphotos.com> domain names was sufficient to constitute a pattern pursuant to Policy ¶ 4(b)(ii)).
Next, Respondent has offered competing services at the infringing domains, using Complainant’s mark. This constitutes bad faith per Policy ¶ 4(b)(iii). See DatingDirect.com Ltd. v. Aston, FA 593977 (Nat. Arb. Forum Dec. 28, 2005) (“Respondent is appropriating Complainant’s mark to divert Complainant’s customers to Respondent’s competing business. The Panel finds this diversion is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).”); see also DatingDirect.com Ltd. v. Aston, FA 593977 (Nat. Arb. Forum Dec. 28, 2005) (“Respondent is appropriating Complainant’s mark to divert Complainant’s customers to Respondent’s competing business. The Panel finds this diversion is evidence of bad faith registration and use pursuant to Policy ¶ 4(b)(iii).”); see also Am. Online, Inc. v. Fu, D2000-1374 (WIPO Dec. 11, 2000) (finding that the respondent violated Policy ¶ 4(b)(iv) by displaying the complainant’s mark on its website and offering identical services as those offered by the complainant); see also Am. Int’l Group, Inc. v. Busby, FA 156251 (Nat. Arb. Forum May 30, 2003) (finding that the disputed domain name was registered and used in bad faith where the respondent hosted a website that “duplicated Complainant’s mark and logo, giving every appearance of being associated or affiliated with Complainant’s business . . . to perpetrate a fraud upon individual shareholders who respected the goodwill surrounding the AIG mark”).
Additionally, Respondent has offered these competing services to deceive Internet users with the intent to commercially gain pursuant to Policy ¶ 4(b)(iv). Panels have seen attempts by respondents to confuse Internet users by appropriating identical services and/or goods in an attempt to gain commercially as a demonstration of bad faith under Policy ¶ 4(b)(iv). See Dell Inc. v. Innervision Web Solutions, FA 445601 (Nat. Arb. Forum May 23, 2005) (finding evidence of bad faith under Policy ¶ 4(b)(iv) where the respondent was using the <dellcomputerssuck.com> domain name to divert Internet users to respondent’s website offering competing computer products and services). Therefore, the Panel finds that the disputed domain names have been registered and used in bad faith Policy ¶ 4(b)(iv).
Complainant states that the existence of a disclaimer on the websites’ resolving pages does nothing to dispel a finding of bad faith. The Panel agrees. See Ciccone v. Parisi, D2000-0847 (WIPO Oct. 12, 2000) (“Respondent’s use of a disclaimer on its website is insufficient to avoid a finding of bad faith. First, the disclaimer may be ignored or misunderstood by Internet users. Second, a disclaimer does nothing to dispel initial interest confusion that is inevitable from Respondent’s actions. Such confusion is a basis for finding a violation of Complainant’s rights.”); see also Auxilium Pharm., Inc. v. Patel, FA 642141 (Nat. Arb. Forum Apr. 6, 2006) (“Respondent’s use of a disclaimer on its website does not mitigate evidence of bad faith registration and use under Policy ¶ 4(a)(iii).”).
Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <contactdell.org>, <contactdellsupport.org>, <dell-antivirus.org>, <dell-backup.org>, <dell-help.org>, <dell-login.org>, <dell-manager.org>, <dell-premier.org>, <dell-protection.org>, <dell-service.org>, <dell-services.org>, <dell-software.org>, <dell-update.org>, <dell-virus.org>, <dellbackuprecovery.org>, <dellbiosupdate.org>, <dellchat.org>, <dellchatsupport.org>, <dellcomputer-support.org>, <dellcontact.org>, <dellcontactnumber.org>, <dellcustomer-service.org>, <dellcustomercare.org>, <dellcustomerhelp.org>, <dellcustomerservicenumber.org>, <dellcustomersupport.org>, <delldatasafe.org>, <delldownloads.org>, <delldriver.org>, <delldriverdownload.org>, <delldrivers.org>, <delldriversupport.org>, <delldriverswindows.org>, <delldriverupdate.org>, <dellerror.org>, <dellerrorcode.org>, <dellfactoryrestore.org>, <delllaptopsupport.org>, <dellnumber.org>, <dellphonenumber.org>, <dellprinterdrivers.org>, <dellprintersupport.org>, <dellproblem.org>, <dellprosupport.org>, <dellrecoverydisk.org>, <dellrecoverypartition.org>, <dellrepair.org>, <dellrescue.org>, <dellrestore.org>, <dellserialnumber.org>, <dellservicecenter.org>, <dellservicetag.org>, <dellsupportchat.org>, <dellsupportdrivers.org>, <dellsupportnumber.org>, <dellsupportphonenumber.org>, <dellsystemrestore.org>, <delltech-support.org>, <delltechnical-support.org>, <delltechnicalsupport.org>, <delltechsupportnumber.org>, <dellwarranty.org>, <dellwarrantycheck.org>, <dellwarrantylookup.org>, <dellwarrantystatus.org>, <dellwarrantysupport.org>, <dellwebsite.org>, <driversdell.org>, <my-dell.org>, <reset-dell.org>, <resetdell-laptop.org>, <supportdell.org> domain names be TRANSFERRED from Respondent to Complainant.
Richard Hill, Panelist
Dated: October 13, 2015
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