Empowered Medical Solutions, Inc. d/b/a QRS-Direct and QRS Magnovit AG v. NULL NULL / QUANTRON RESONANCE SYSTEMS / JIM ANDERSON / HTR / unknown HTR / HTR
Claim Number: FA1805001784937
Complainant is Empowered Medical Solutions, Inc. d/b/a QRS-Direct and QRS Magnolia AG (“Complainant”), represented by Brian M. Talon of McHale & Slaving, P.A., Florida, USA. Respondent is NULL NULL/ QUANTRON RESONANCE SYSTEMS / JIM ANDERSON / HTR / unknown HTR / HTR (“Respondent”), Massachusetts, USA.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <quantronresonance.com>, <quantronresonance.org>, <quantronresonance.net>, <quantronresonancesystem.com>, <quantronresonancesystem.org>, <quantronresonancesystem.net> and <quantronresonancesystems.com>, registered with eNom, LLC.
The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.
The Honourable Neil Anthony Brown QC as Panelist.
Complainant submitted a Complaint to the Forum electronically on May 3, 2018; the Forum received payment on May 3, 2018.
On May 4, 2018, eNom, LLC confirmed by e-mail to the Forum that the <quantronresonance.com>, <quantronresonance.org>, <quantronresonance.net>, <quantronresonancesystem.com>, <quantronresonancesystem.org>, <quantronresonancesystem.net> and <quantronresonancesystems.com> domain names are registered with eNom, LLC and that Respondent is the current registrant of the names. eNom, LLC has verified that Respondent is bound by the eNom, 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 May 16, 2018, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of June 5, 2018 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@quantronresonance.com, postmaster@quantronresonance.org, postmaster@quantronresonance.net, postmaster@quantronresonancesystem.com, postmaster@quantronresonancesystem.org, postmaster@quantronresonancesystem.net, and postmaster@quantronresonancesystems.com. Also on May 16, 2018, 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 June 8, 2018, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the Forum appointed The Honourable Neil Anthony Brown QC 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.
Preliminary Issue: Multiple Complainants
In the instant proceedings, there are two Complainants. Paragraph 3(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”) provides that “[a]ny person or entity may initiate an administrative proceeding by submitting a complaint.” The Forum’s Supplemental Rule 1(e) defines “The Party Initiating a Complaint Concerning a Domain Name Registration” as a “single person or entity claiming to have rights in the domain name, or multiple persons or entities who have a sufficient nexus who can each claim to have rights to all domain names listed in the Complaint.”
There are two (2) Complainants in this matter: Empowered Medical Solutions, Inc. d/b/a QRS-Direct and QRS Magnovit AG. The QUANTRON RESONANCE SYSTEMS trademark is owned internationally by QRS International AG. Complainant QRS Magnovit is the wholly-owned subsidiary of QRS International responsible for the commercialization of products bearing this trademark, the QRS trademark, and other trademarks worldwide. In the United States, QRS-Direct is the authorized distributor of such products. See Compl. Annex 8. QRS-Direct has further been authorized by QRS Magnovit and QRS International to prosecute U.S. Trademark Applications for the QUANTRON RESONANCE SYSTEMS and QRS trademarks in the name of QRS-Direct.
Previous panels have interpreted the Forum’s Supplemental Rule 1(e) to allow multiple parties to proceed as one party where they can show a sufficient link to each other. For example, in Vancouver Org. Comm. for the 2010 Olympic and Paralymic Games & Int’l Olympic Comm. v. Malik, FA 666119 (Forum May 12, 2006), the panel stated:
“It has been accepted that it is permissible for two complainants to submit a single complaint if they can demonstrate a link between the two entities such as a relationship involving a license, a partnership or an affiliation that would establish the reason for the parties bringing the complaint as one entity.”
In Tasty Baking, Co. & Tastykake Invs., Inc. v. Quality Hosting, FA 208854 (Forum Dec. 28, 2003), the panel treated the two complainants as a single entity where both parties held rights in trademarks contained within the disputed domain names. Likewise, in Am. Family Health Srvs. Group, LLC v. Logan, FA 220049 (Forum Feb. 6, 2004), the panel found a sufficient link between the complainants where there was a license between the parties regarding use of the TOUGHLOVE mark. But see AmeriSource Corp. v. Park, FA 99134 (Forum Nov. 5, 2001) (“This Panel finds it difficult to hold that a domain name that may belong to AmerisourceBergen Corporation (i.e., the subject Domain Names) should belong to AmeriSource Corporation because they are affiliated companies.”).
The Panel accepts that the evidence in the Complaint is sufficient to establish a sufficient nexus or link between the Complainants, and accordingly it will treat them all as a single entity in this proceeding and the proceeding may go forward on that basis.
The Complainants will be collectively be referred to as “Complainant.”
Preliminary Issue: Multiple Respondents
In the instant proceedings, Complainant has alleged that the entities which control the domain names at issue are effectively controlled by the same person and/or entity, which is operating under several aliases. Paragraph 3(c) of the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”) provides that a “complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.”
Complainant contends that Respondents NULL NULL/ Quantron Resonance Systems, unknown HTR/ HTR, and Jim Anderson/HTR are all aliases of Daniel Bader, a former distributor who continued to sell Complainant’s products and unfairly competes with Complainant. See Compl. Annex 1. Complainant also claims:
1) All the registrants for the disputed domain names share a common Admin and Tech Support called “Scott Ash of Worldicom, Inc.” See Compl. Annex 2.
2) The “.org” share the same email address as Mr. Ash and the “.net” domain names share the same phone number as Mr. Ash.
3) The “.com” domain names are owned by Respondent, Quantron Resonance, but do not appear to have complete street address, phone number, or email address. Rather, the only available contact is Mr. Ash, who Complainant believes is Daniel Bader.
4) Worldicom, Inc., a dissolved company, was registered by Dan Baden, who Complainant believes is another alias for Mr. Bader. Worldicom, Inc. listed address is the same as Daniel Bader. See Compl. Annexes 3 and 4.
5) Mr. Ash is also the registrant for the <qrs.com> domain name and this disputed domain name resolves to a website identical to the <quantronresonance.com> domain name. See Compl. Annexes 5 and 6.
Having regard to the evidence and the above principles, the Panel finds the domain names are commonly owned/controlled by a single Respondent who is using multiple aliases and that the proceeding comes within the meaning of Paragraph 3(c) of the Rules and may proceed in the usual manner.
A. Complainant
Complainant made the following contentions
Complainant, Empowered Medical Solutions, Inc. d/b/a QRS-Direct and QRS Magnovit AG, uses its QUANTRON RESONANCE SYSTEMS mark to promote its products and services in the medical magnetic field therapy apparatus business. Complainant established rights in the QUANTRON RESONANCE SYSTEMS mark through its trademark registration with the United States Patent and Trademark Office (“USPTO”) (e.g., Reg. No. 5,427,339, registered Mar. 20, 2018). See Compl. Annex 7. Respondent’s <quantronresonance.com>, <quantronresonance.org>, <quantronresonance.net>, <quantronresonancesystem.com>, <quantronresonancesystem.org>, <quantronresonancesystem.net> and <quantronresonancesystems.com> domain names are confusingly similar to Complainant’s QUANTRON RESONANCE SYSTEMS mark as Respondent merely omits the descriptive term “systems” and/or adds the “.com,” “.org,” or “.net” generic top-level domain (“gTLD”) to Complainant’s mark.
Respondent does not have rights or legitimate interests in the <quantronresonance.com>, <quantronresonance.org>, <quantronresonance.net>, <quantronresonancesystem.com>, <quantronresonancesystem.org>, <quantronresonancesystem.net> and <quantronresonancesystems.com> domain names. Complainant has not licensed or otherwise authorized Respondent to use its QUANTRON RESONANCE SYSTEMS mark in any fashion. Further, Respondent is not using the domain name in connection with any bona fide offering of goods or services or legitimate noncommercial or fair use. Instead, Respondent is a former distributor who is using the domain names to facilitate the unauthorized sale of Complainant’s products.
Respondent registered and is using the disputed domain names in bad faith. Respondent uses the domain names to create confusion with Complainant’s mark for commercial gain. Further, some of the disputed domain names do not resolve to active websites. Further, Respondent renewed the disputed domain names after its business relationship with Complainant was terminated.
B. Respondent
Respondent failed to submit a Response in this proceeding.
1. Complainant is a United States and Liechtenstein company engaged in the provision of goods and services in the medical magnetic field therapy apparatus industry.
2. Complainant has established its trademark rights in the QUANTRON RESONANCE SYSTEMS mark through its registration with the United States Patent and Trademark Office (“USPTO”) (e.g., Reg. No. 5,427,339, registered Mar. 20, 2018).
3. Respondent registered the disputed domain names on the following dates:
|
<quantronresonance.com> |
March 9, 2001 |
|
<quantronresonance.org> |
March 15, 2003 |
|
<quantronresonance.net> |
March 15, 2003 |
|
<quantronresonancesystem.com> |
March 11, 2001 |
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<quantronresonancesystem.org> |
March 15, 2003 |
|
<quantronresonancesystem.net> |
March 15, 2003 |
|
<quantronresonancesystems.com> |
March 15, 2003 |
4. Respondent is a former distributor of Complainant who is using the domain names to facilitate the unauthorized sale of Complainant’s products. Further, Respondent renewed the disputed domain names after its business relationship with Complainant was terminated.
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(f), 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 (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.”).
The first question that arises is whether Complainant has rights in a trademark or service mark on which it may rely. Complainant submits that it has rights in the QUANTRON RESONANCE SYSTEMS mark through its trademark registration with the USPTO. Registering a mark with the USPTO is sufficient to demonstrate rights in a mark under Policy ¶ 4(a)(i). See Home Depot Product Authority, LLC v. Samy Yosef / Express Transporting, FA 1738124 (Forum July 28, 2017) (finding that registration with the USPTO was sufficient to establish the complainant’s rights in the HOME DEPOT mark). Complainant provides a copy of its USPTO registration for the QUANTRON RESONANCE SYSTEMS mark (e.g., Reg. No. 5,427,339, registered Mar. 20, 2018). See Compl. Annex 7. The Panel notes Respondent’s disputed domain names were registered prior to Complainant’s registration of the QUANTRON RESONANCE SYSTEMS mark, but Complainant argues that the domain names were renewed by Daniel Bader, one of Complainant’s former distributors. See Compl. Annex 1 (cease and desist demands to Mr. Bader). Therefore, the Panel finds that despite Respondent’s predating disputed domain names, Complainant has rights in the mark per Policy ¶ 4(a)(i).
The next question that arises is whether the disputed domain names are identical or confusingly similar to Complainant’s QUANTRON RESONANCE SYSTEMS mark. Complainant contends Respondent’s <quantronresonance.com>, <quantronresonance.org>, <quantronresonance.net>, <quantronresonancesystem.com>, <quantronresonancesystem.org>, <quantronresonancesystem.net> and <quantronresonancesystems.com> domain names are confusingly similar to Complainant’s QUANTRON RESONANCE SYSTEMS mark. Adding or removing descriptive terms or a gTLD is insufficient to differentiate a disputed domain name from a complainant’s mark under Policy ¶ 4(a)(i). See VNY Model Management, Inc. v. Lisa Katz / Domain Protection LLC, FA 1625115 (Forum Aug. 17, 2015) (finding that Respondent’s <vnymodels.com> domain name is confusingly similar to the VNY MODEL MANAGEMENT mark under Policy ¶ 4(a)(i).); see also Dell Inc. v. Protection of Private Person / Privacy Protection, FA 1681432 (Forum Aug. 1, 2016) (“A TLD (whether a gTLD, sTLD or ccTLD) is disregarded under a Policy ¶ 4(a)(i) analysis because domain name syntax requires TLDs. Likewise, the absence of spaces must be disregarded under a Policy ¶ 4(a)(i) analysis because domain name syntax prohibits them.”). Complainant argues Respondent merely omits the term “systems” in the cases of the <quantronresonance.com>, <quantronresonance.org> and <quantronresonance.net> domain names and adds a gTLD (“.com,” “.org,” or “.net”) to Complainant’s mark and the Panel agrees.
In the cases of <quantronresonancesystem.com>, <quantronresonancesystem.org>, and <quantronresonancesystem.net> domain names, Respondent has omitted the letter “s” at the end of the word “systems”. In the case of the <quantronresonancesystems.com> domain name, the domain name is virtually the same as the trademark. In each case, an internet user would conclude that the domain name was invoking the trademark and was a domain name that would lead to a website dealing with Complainant’s goods and services provided under the trademark. Respondent has added a gTLD to Complainant’s mark in all cases. Therefore, the Panel finds that all of the disputed domain names are confusingly similar to Complainant’s QUANTRON RESONANCE SYSTEMS mark per Policy ¶ 4(a)(i).
Complainant has thus made out the first of the three elements that it must establish.
It is now well established that Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in a disputed domain names under Policy ¶ 4(a)(ii), then the burden shifts to Respondent to show it does have rights or legitimate interests. See Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011) (finding that a complainant must offer some evidence to make its prima facie case and satisfy Policy ¶ 4(a)(ii)); see also Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014) (“Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests”).
The Panel finds that Complainant has made out a prima facie case that arises from the following considerations:
(a) Respondent has chosen to take Complainant’s QUANTRON RESONANCE SYSTEMS trademark and to use it in its domain names with the minor variations referred to above which do not negate their confusing similarity with Complainant’s trademark;
(b) Respondent registered the domain names on the respective dates set out above;
(c) Respondent is a former distributor of Complainant who is using the domain names to facilitate the unauthorized sale of Complainant’s products. Further, Respondent renewed the disputed domain names after its business relationship with Complainant was terminated;
(d) Respondent has engaged in these activities without the consent or approval of Complainant;
(e) Complainant claims Respondent does not have rights or legitimate interests in the <quantronresonance.com>, <quantronresonance.org>, <quantronresonance.net>, <quantronresonancesystem.com>, <quantronresonancesystem.org>, <quantronresonancesystem.net> and <quantronresonancesystems.com> domain names. Complainant has not licensed or otherwise authorized Respondent to use its QUANTRON RESONANCE SYSTEMS mark in any fashion. Lack of authorization to use a complainant’s mark may suggest a respondent is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii). See Navistar International Corporation v. N Rahmany, FA1505001620789 (Forum June 8, 2015) (finding that the respondent was not commonly known by the disputed domain name where the complainant had never authorized the respondent to incorporate its NAVISTAR mark in any domain name registration). Complainant submits that Respondent is most likely Daniel Bader, a former distributor whose license to use Complainant’s mark was revoked. The Panel also notes the WHOIS information for the disputed domain names identify Respondent as either “NULL NULL/Quantron Resonance Systems,” “Jim Anderson/HTR,” or “Unknown HTR/HTR.” See Amend. Compl. Annex 2. While one of the registrants appears to be known by the disputed domain name, a respondent is required to provide affirmative evidence to support the WHOIS information. See Moneytree, Inc. v. Matt Sims / MoneyTreeNow, FA1501001602721 (Forum Mar. 3, 2015) (finding that even though the respondent had listed “Matt Sims” of “MoneyTreeNow” as registrant of the <moneytreenow.com> domain name, the respondent was not commonly known by the disputed domain name pursuant to Policy ¶ 4(c)(ii), because he had failed to list any additional affirmative evidence beyond the WHOIS information). Therefore, the Panel finds Respondent is not commonly known by the disputed domain names per Policy ¶ 4(c)(ii);
(f) Complainant contends Respondent is not using the <quantronresonance.com>, <quantronresonance.org>, <quantronresonance.net>, <quantronresonancesystem.com>, <quantronresonancesystem.org>, <quantronresonancesystem.net> and <quantronresonancesystems.com> domain names in connection with any bona fide offering of goods or services or legitimate noncommercial or fair use. Instead, Respondent is a former distributor who is using the domain names to facilitate the unauthorized sale of Complainant’s products. Selling complainant’s goods without authorization or license is not a bona fide offering of goods or services or legitimate noncommercial or fair use under Policy ¶¶ 4(c)(i) and (iii). See The Lincoln Electric Company v. Privacy protection service - whoisproxy.ru, FA 1651493 (Forum Jan. 13, 2016) (noting that, as Respondent used the disputed domain to promote Complainant’s distributor without license to do so, Respondent did not demonstrate any bona fide offering of goods or services or any legitimate noncommercial or fair use). Complainant provides screenshots from the disputed domain names that resolve to webpages which offer to sell Complainant’s goods. See Compl. Annex 6. Complainant also provides screenshots of other disputed domain names which resolve to inactive websites. See Compl. Annex 9. Therefore, the Panel finds Respondent’s unauthorized sale of Complainants goods is not a bona fide offering of goods or services or legitimate noncommercial or fair use per Policy ¶¶ 4(c)(i) and (iii).
All of these matters go to make out the prima facie case against Respondent. As Respondent has not filed a Response or attempted by any other means to rebut the prima facie case against it, the Panel finds that Respondent has no rights or legitimate interests in the disputed domain names.
Complainant has thus made out the second of the three elements that it must establish.
It is clear that to establish bad faith for the purposes of the Policy, Complainant must show that the disputed domain names were registered in bad faith and have been used in bad faith. It is also clear that the criteria set out in Policy ¶ 4(b) for establishing bad faith are not exclusive, but that Complainants in UDRP proceedings may also rely on conduct that is bad faith within the generally accepted meaning of that expression.
Having regard to those principles, the Panel finds that the disputed domain names were registered and used in bad faith. That is so for the following reasons.
First, Complainant contends Respondent attempts to attract users to the disputed domain names to offer Complainant’s goods without its authorization. Offering to sell a complainant’s goods at the disputed domain name, which also competes with complainant, may be evidence of bad faith under Policy ¶ 4(b)(iv). See Fossil Inc. v. NAS, FA 92525 (Forum Feb. 23, 2000) (finding that the respondent acted in bad faith by registering the <fossilwatch.com> domain name and using it to sell various watch brands where the respondent was not authorized to sell the complainant’s goods); see also Xylem Inc. and Xylem IP Holdings LLC v. YinSi BaoHu YiKaiQi, FA1504001612750 (Forum May 13, 2015) (“The Panel agrees that Respondent’s use of the website to display products similar to Complainant’s, imputes intent to attract Internet users for commercial gain, and finds bad faith per Policy ¶ 4(b)(iv).”). Complainant provides screenshots of the disputed domain name’s resolving websites and argues that Mr. Bader, who was once a distributor, is unauthorized to sell Complainant’s products. See Compl. Annexes 2, 6, and 9. Therefore, the Panel finds Respondent’s renewal of the disputed domain names to sell Complainant’s goods constitutes bad faith per Policy ¶ 4(b)(iv).
Secondly, Complainant submits Respondent’s renewal of the disputed domain names is further evidence of bad faith. Renewal of a complainant’s, previously-owned domain name may support a finding of bad faith under Policy ¶ 4(a)(iii). See Dockeast LLC v. Jurmark, FA 149147 (Forum Apr. 24, 2003) (holding that the respondent’s renewal of the domain name registration, which changed the ownership of the domain name registration from its employer to itself, was effected in bad faith). Complainant argues Respondent’s renewal of the disputed domain name by Mr. Bader, a former distributor, was done so in bad faith. Further, Complainant argues Respondent’ subsequent failure to use the disputed domain names actively supports its arguments of bad faith. Thus, the Panel views Respondent’s renewal of the disputed domain names as having been done done so in bad faith and in breach of paragraph 2 of the Policy as explained in the decision in Eastman Sporto Group LLC v. Jim and Kenny, WIPO Case No. D2009-1688 (March 1, 2010).
Thirdly, Complainant claims some of the disputed domain names resolve to inactive websites and this should be considered to be evidence of bad faith. Failure to make active use of a disputed domain name may be evidence of bad faith under Policy ¶ 4(a)(iii). See Dermtek Pharmaceuticals Ltd. v. Sang Im / Private Registration, FA1310001522801 (Forum Nov. 19, 2013) (holding that because the respondent’s website contained no content related to the domain name and instead generated the error message “Error 400- Bad Request,” the respondent had registered and used the disputed domain name in bad faith pursuant to Policy ¶ 4(a)(iii)). Complainant provides screenshots of the disputed domain names that resolve to inactive websites. See Compl. Annex 9. Thus, the Panel finds Respondent’s failure to make active use at the disputed domain names constitutes bad faith per Policy ¶ 4(a)(iii)
Finally, in addition and having regard to the totality of the evidence, the Panel finds that, in view of Respondent’s registration of the disputed domain names using the QUANTRON RESONANCE SYSTEMS mark and in view of the conduct that Respondent has engaged in when using the disputed domain names, Respondent registered and used them in bad faith within the generally accepted meaning of that expression.
Complainant has thus made out the third of the three elements that it must establish.
Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <quantronresonance.com>, <quantronresonance.org>, <quantronresonance.net>, <quantronresonancesystem.com>, <quantronresonancesystem.org>, <quantronresonancesystem.net> and <quantronresonancesystems.com> domain names be TRANSFERRED from Respondent to Complainant.
The Honourable Neil Anthony Brown QC
Panelist
Dated: June 8, 2018
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