Citigroup Inc. v. Chen Ying Quan / 陈应全 / ying quan chen
Claim Number: FA1701001714851
Complainant is Citigroup Inc. (“Complainant”), represented by Brian J. Winterfeldt of Mayer Brown LLP, District of Columbia, USA. Respondent is Chen Ying Quan / 陈应全 / ying quan chen (“Respondent”), China.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <citigroup.pub> and <citigroup.mom>, registered with Alibaba Cloud Computing Ltd. d/b/a HiChina (www.net.cn); <citigroup.kim>,<citibank.pro>,<citibank.kim>, and <citigroup.pink>, registered with West263 International Limited; and <citi.ink>, <citibank.wiki>, <citicorp.club>, <citicorp.online>, <citicorp.site>, <citicorp.vip>, <citigroup.ink>, and <citigroup.wiki>, registered with Chengdu West Dimension Digital Technology Co., Ltd.
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 January 30, 2017; the Forum received payment on January 30, 2017.
On February 2, 2017, Chengdu West Dimension Digital Technology Co., Ltd. confirmed by e-mail to the Forum that the <citi.ink>, <citibank.wiki>, <citicorp.club>, <citicorp.online>, <citicorp.site>, <citicorp.vip>, <citigroup.ink>, and <citigroup.wiki> domain names are registered with Chengdu West Dimension Digital Technology Co., Ltd. and that Respondent is the current registrant of the names. Chengdu West Dimension Digital Technology Co., Ltd. has verified that Respondent is bound by the Chengdu West Dimension Digital Technology Co., Ltd. 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 February 3, 2017, West263 International Limited confirmed by e-mail to the Forum that <citigroup.kim>,<citibank.pro>, <citibank.kim>, and <citigroup.pink> are registered with West263 International Limited and that Respondent is the current registrant of the names. West263 International Limited has verified that Respondent is bound by the West263 International Limited registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with the Policy.
On February 3, 2017, Alibaba Cloud Computing Ltd. d/b/a HiChina (www.net.cn) confirmed by e-mail to the Forum that <citigroup.pub> and <citigroup.mom> are registered with Alibaba Cloud Computing Ltd. d/b/a HiChina (www.net.cn) and that Respondent is the current registrant of the names. Alibaba Cloud Computing Ltd. d/b/a HiChina (www.net.cn) has verified that Respondent is bound by the Alibaba Cloud Computing Ltd. d/b/a HiChina (www.net.cn) registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with the Policy.
On February 3, 2017, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 23, 2017 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@citi.ink, postmaster@citibank.kim, postmaster@citibank.pro, postmaster@citibank.wiki, postmaster@citicorp.club, postmaster@citicorp.online, postmaster@citicorp.site, postmaster@citicorp.vip, postmaster@citigroup.ink, postmaster@citigroup.kim, postmaster@citigroup.mom, postmaster@citigroup.pink, postmaster@citigroup.pub, and postmaster@citigroup.wiki. Also on February 3, 2017, 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 March 9, 2017, 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.
A. Complainant
Complainant made the following contentions.
Complainant has registered several trademarks with the United States Patent and Trademark Office (“USPTO”) and China’s State Administration for Industry and Commerce (“SAIC”) for marks used on or in connection with Complainant’s business in the financial industry. For example, Complainant has registered the CITI mark (e.g., USPTO Reg. No. 1,181,467, registered Dec. 8, 1981), the CITIBANK mark (e.g., USPTO Reg. No. 691,815, registered Jan. 19, 1960; SAIC Reg. No. 180,123, registered July 5, 1983), the CITICORP mark (e.g., USPTO Reg. No. 1,401,133, registered July 15, 1986; SAIC Reg. No. 180,124, registered July 5, 1983), and the CITIGROUP mark (e.g., USPTO Reg. No. 2,406,753, registered Nov. 21, 2000; SAIC Reg. No. 1,452,796, registered Oct. 7, 2000), establishing rights in the marks (hereinafter, the “CITI marks”). Respondent’s <citi.ink>, <citibank.kim>, <citibank.pro>, <citibank.wiki>, <citicorp.club>, <citicorp.online>, <citicorp.site>, <citicorp.vip>, <citigroup.ink>, <citigroup.kim>, <citigroup.mom>, <citigroup.pink>, <citigroup.pub>, and <citigroup.wiki> domain names are identical to Complainant’s marks as they each incorporate one of Complainant’s marks and merely append a top-level domain (“TLD”).
Respondent has no rights or legitimate interests in the <citi.ink>, <citibank.kim>, <citibank.pro>, <citibank.wiki>, <citicorp.club>, <citicorp.online>, <citicorp.site>, <citicorp.vip>, <citigroup.ink>, <citigroup.kim>, <citigroup.mom>, <citigroup.pink>, <citigroup.pub>, and <citigroup.wiki> domain names. Respondent is not commonly known by the domain names. Further, Respondent has established no bona fide offering of goods or services or any legitimate noncommercial or fair use because each of the domain names resolves to an inactive page. See Compl., at Attached Ex. H (“This site can’t be reached”).
Respondent registered and used the <citi.ink>, <citibank.kim>, <citibank.pro>, <citibank.wiki>, <citicorp.club>, <citicorp.online>, <citicorp.site>, <citicorp.vip>, <citigroup.ink>, <citigroup.kim>, <citigroup.mom>, <citigroup.pink>, <citigroup.pub>, <citigroup.wiki> domain names in bad faith. First, Respondent has corresponded with Complainant seeking “some compensation” in exchange for the transfer of the domain names, imputing Policy ¶ 4(b)(i). See Compl., at Attached Exs. L–M. Second, Respondent has demonstrated a pattern of bad faith domain registrations under Policy ¶ 4(b)(ii) by registering several of Complainant’s marks in domain names and merely adding TLDs, and is involved in a larger cybersquatting scheme. See Compl,. at Attached Ex. J (Respondent’s domain portfolio including 456 domain names); see also Intesa Sanpaolo S.p.A. v. Ying Quan Chen / Chen Ying Quan, D2016-1576 (WIPO Sept. 16, 2016) (Respondent lost). Third, Respondent had actual or constructive knowledge of Complainant when registering and using the domain names. Fourth, Respondent’s inactive holding is further evidence of bad faith under Policy ¶ 4(a)(iii).
Panel Note: Supported Language Request
The Panel notes that Complainant requests that the language of this administrative proceeding proceed in the English language pursuant to UDRP Rule 11. Complainant makes this request in light of the Chinese language Registration Agreement. It is established practice to take UDRP Rules 10(b) and (c) into consideration for the purpose of determining the language of the proceeding to ensure fairness and justice to both parties. Factors which previous panels have seen as particularly compelling are: WHOIS information which establishes Respondent in a country which would demonstrate familiarity with the English language, filing of a trademark registration with an entity which shows an understanding of the English language, and any evidence (or lack thereof) exhibiting Respondent’s understanding of the Chinese language included in the Registration Agreement. See The Argento Wine Company Limited v. Argento Beijing Trading Company, D2009-0610 (WIPO July 1, 2009) (panel exercising discretion in deciding that the language of the proceedings advance in English, contrary to the Registration Agreement, based on evidence that respondent has command of the language). Further, the Panel may weigh the relative time and expense in enforcing the Chinese language agreement, which would result in prejudice toward either party. See Finter Bank Zurich v. Shumin Peng, D2006-0432 (WIPO June 12, 2006) (deciding that the proceeding should be in English, stating, “It is important that the language finally decided by the Panel for the proceeding is not prejudicial to either one of the parties in his or her ability to articulate the arguments for the case.”). Complainant gives three reasons in support of its submission: (i) Respondent has targeted English-language
trademarks which are reflected in the Disputed Domain Names; (ii) Respondent has targeted various English-language TLDs rendered in ASCII characters as reflected in the Disputed Domain Names; and (iii) Respondent replied to Complainant’s cease and desist letters in English, as evidenced in the attached supporting exhibits (see, e.g., Compl., at Attached Ex. L). Therefore, the Panel finds as follows.
Pursuant to UDRP Rule 11(a), the Panel finds that persuasive evidence has been adduced by Complainant to suggest the likely possibility that the Respondent is conversant and proficient in the English language. After considering all the circumstance of the present case, the Panel decides that the proceeding should be in the English language.
B. Respondent
Respondent failed to submit a Response in this proceeding.
1. Complainant is a United States company engaged in the banking and financial serves industries.
2. Complainant has registered the CITI mark (e.g., USPTO Reg. No. 1,181,467, registered Dec. 8, 1981), the CITIBANK mark (e.g., USPTO Reg. No. 691,815, registered Jan. 19, 1960; SAIC Reg. No. 180,123, registered July 5, 1983), the CITICORP mark (e.g., USPTO Reg. No. 1,401,133, registered July 15, 1986; SAIC Reg. No. 180,124, registered July 5, 1983), and the CITIGROUP mark (e.g., USPTO Reg. No. 2,406,753, registered Nov. 21, 2000; SAIC Reg. No. 1,452,796, registered Oct. 7, 2000 (”the CITI marks”).
3. Respondent registered the disputed domain names on the following dates.
<citi.ink>..................................................................................................... May 18, 2016;
<citibank.kim>........................................................................................... May 11, 2016;
<citibank.pro>........................................................................................... May 18, 2016;
<citibank.wiki>.......................................................................................... May 18, 2016;
<citicorp.club>.......................................................................................... July 18, 2016;
<citicorp.online>....................................................................................... July 18, 2016;
<citicorp.site>............................................................................................ July 18, 2016;
<citicorp.vip>............................................................................................. July 18, 2016;
<citigroup.ink>.......................................................................................... May 18, 2016;
<citigroup.kim>......................................................................................... May 18, 2016;
<citigroup.mom>...................................................................................... May 14, 2016;
<citigroup.pink>....................................................................................... May 18, 2016;
<citigroup.pub>.............................................................................. June 20, 2015; and
<citigroup.wiki>........................................................................................ May 18, 2016.
4. Each of the domain names resolves to an inactive internet page.
5. Respondent has also asked for “some compensation” in exchange for the transfer of the domain names, indicating that Respondent is engaged in wide-spread cybersquatting.
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.”).
Preliminary Issue: Multiple Respondents
In the instant proceeding, Complainant has submitted 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 registrant’s name, Chen Ying Quan, is identical across all fourteen (14) domain names (noting that the Chinese character data provided in connection with the citicorp.vip domain name transliterates to “Chen Ying Quan”), and the 734852825@qq.com email address is associated with all
but three (3) of the domain names (these other three (3) domain names all use the same email address, namely 734686393@qq.com). Moreover, all but two (2) of the fourteen (14) domain names have been registered through the same two (2) affiliated registrars, while the remaining two (2) domain names have been registered through the same third registrar.
The Panel therefore finds that the domain names are commonly owned/controlled by a single Respondent who is using multiple aliases and that the proceeding is therefore compliant with the Rules.
The first issue that arises is whether Complainant has a trademark or service mark on which it may rely. Complainant claims it registered the CITI marks with the USPTO and SAIC in connection with its financial offerings. Registrations of marks with both governmental entities has been considered sufficient evidence of Policy ¶ 4(a)(i) rights. See Guess? IP Holder L.P. and Guess?, Inc. v. zhou hong hai, FA 1610066 (Forum May 1, 2015) (determining that “Complainant’s USPTO and SAIC registrations are sufficient to establish Complainant’s rights in the GUESS mark under Policy ¶ 4(a)(i).”). Therefore, the Panel finds that Complainant has adequately established its rights in the CITI marks under Policy ¶ 4(a)(i).
The second issue that arises is whether the disputed domain names are identical or confusingly similar to Complainant’s CITI marks. Complainant argues that Respondent’s <citi.ink>, <citibank.kim>, <citibank.pro>, <citibank.wiki>, <citicorp.club>, <citicorp.online>, <citicorp.site>, <citicorp.vip>, <citigroup.ink>, <citigroup.kim>, <citigroup.mom>, <citigroup.pink>, <citigroup.pub>, and <citigroup.wiki> domain names are identical to Complainant’s marks as they each incorporate one of Complainant’s marks and merely append a TLD. TLD additions have been considered irrelevant in this consideration. See Gardline Surveys Ltd. v. Domain Fin. Ltd., FA 153545 (Forum May 27, 2003) (“The addition of a top-level domain is irrelevant when establishing whether or not a mark is identical or confusingly similar, because top-level domains are a required element of every domain name.”). Accordingly, the Panel finds that the disputed domain names are confusingly similar to the CITI marks under 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 the disputed domain names under Policy ¶ 4(a)(ii), and then the burden shifts to Respondent to show it does have rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Entm’t Commentaries, FA 741828 (Forum Aug. 18, 2006) (holding that the complainant must first make a prima facie case that the respondent lacks rights and legitimate interests in the disputed domain name under UDRP ¶ 4(a)(ii) before the burden shifts to the respondent to show that it does have rights or legitimate interests in a domain name); see also AOL LLC v. Gerberg, FA 780200 (Forum Sept. 25, 2006) (“Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light. If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names.”).
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 prominent CITI marks and to use them in its domain names;
(b) Respondent registered the disputed domain names on the following dates.
<citi.ink>..................................................................................................... May 18, 2016;
<citibank.kim>........................................................................................... May 11, 2016;
<citibank.pro>........................................................................................... May 18, 2016;
<citibank.wiki>.......................................................................................... May 18, 2016;
<citicorp.club>.......................................................................................... July 18, 2016;
<citicorp.online>....................................................................................... July 18, 2016;
<citicorp.site>............................................................................................ July 18, 2016;
<citicorp.vip>............................................................................................. July 18, 2016;
<citigroup.ink>.......................................................................................... May 18, 2016;
<citigroup.kim>......................................................................................... May 18, 2016;
<citigroup.mom>...................................................................................... May 14, 2016;
<citigroup.pink>....................................................................................... May 18, 2016;
<citigroup.pub>.............................................................................. June 20, 2015; and
<citigroup.wiki>........................................................................................ May 18, 2016.
(c) :each of the domain names resolves to an inactive internet page;
(d) Respondent engaged in the aforementioned activities without the permission or authority of Complainant;
(e) Complainant argues that Respondent has no rights or legitimate interests in the<citi.ink>, <citibank.kim>, <citibank.pro>, <citibank.wiki>, <citicorp.club>, <citicorp.online>, <citicorp.site>, <citicorp.vip>, <citigroup.ink>, <citigroup.kim>, <citigroup.mom>, <citigroup.pink>, <citigroup.pub>, and <citigroup.wiki> domain names. Complainant contends that Respondent is not commonly known by the domain names. Where no response is on record, WHOIS information has been considered dispositive of Policy ¶ 4(c)(ii). See Guardair Corporation v. Pablo Palermo, FA1407001571060 (Forum Aug. 28, 2014) (holding that the respondent was not commonly known by the <guardair.com> domain name according to Policy ¶ 4(c)(ii), as the WHOIS information lists “Pablo Palermo” as registrant of the disputed domain name). Here, the WHOIS lists “Chen Ying Quan / 陈应全 / ying quan chen” as registrant. The Panel agrees that the WHOIS bears no relation to the domain names at issue and thus Respondent is not commonly known by the domain names under Policy ¶ 4(c)(ii);
(f) Complainant argues that Respondent has established no bona fide offering of goods or services or any legitimate noncommercial or fair use because each of the domain names resolves to an inactive page. See Compl., at Attached Ex. H (“This site can’t be reached”). Failure to make any use of a site cannot amount to rights and legitimate interests. See Bloomberg L.P. v. SC Media Servs. & Info. SRL, FA 296583 (Forum Sept. 2, 2004) (“Respondent is wholly appropriating Complainant’s mark and is not using the <bloomberg.ro> domain name in connection with an active website. The Panel finds that the [failure to make an active use] of a domain name that is identical to Complainant’s mark is not a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use of the domain name pursuant to Policy ¶ 4(c)(iii).”). Accordingly, the Panel finds that no bona fide offering of goods or services or any legitimate noncommercial or fair use has been made under Policy ¶¶ 4(c)(i) or (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 submits Respondent registered and used the <citi.ink>, <citibank.kim>, <citibank.pro>, <citibank.wiki>, <citicorp.club>, <citicorp.online>, <citicorp.site>, <citicorp.vip>, <citigroup.ink>, <citigroup.kim>, <citigroup.mom>, <citigroup.pink>, <citigroup.pub>, and <citigroup.wiki> domain names in bad faith. First, Complainant avers that Respondent has corresponded with Complainant seeking “some compensation” in exchange for the transfer of the domain names, imputing Policy ¶ 4(b)(i). See Compl., at Attached Exs. L–M. “A respondent’s general offer to sell a disputed domain name for an excess of out-of-pocket costs is evidence of bad faith under Policy ¶ 4(b)(i).” Vanguard Trademark Holdings USA LLC v. Wang Liqun, FA1506001625332 (Forum July 17, 2015). The Panel agrees that the evidence Complainant has submitted demonstrates Respondent’s willingness or intent to sell the domain names in excess of out-of-pocket costs under Policy ¶ 4(b)(i).
Secondly, Complainant argues that Respondent has demonstrated a pattern of bad faith domain name registrations under Policy ¶ 4(b)(ii) by registering several of Complainant’s marks in domain names and merely adding TLDs, and is involved in a larger cybersquatting scheme. See Compl,. at Attached Ex. J (Respondent’s domain portfolio including 456 domain names); see also Intesa Sanpaolo S.p.A. v. Ying Quan Chen / Chen Ying Quan, D2016-1576 (WIPO Sept. 16, 2016) (Respondent lost). Both registration of several confusingly similar domains and a demonstrated history of bad faith have resulted in Policy ¶ 4(b)(ii) findings. See The Toronto-Dominion Bank v. Ryan G Foo / PPA Media Services / Jinesh Shah / Whois Privacy Corp. / Domain Administratory / Fundacion Private Whois / Domain Admin / Whois Privacy Corp, FA1408001576648 (Forum Jan. 12, 2015) (“The Panel determines that Respondent’s documented history of adverse UDRP rulings, as well as Respondent’s multiple registrations relating to Complainant’s marks, are independently sufficient to constitute a pattern as described by Policy ¶ 4(b)(ii). Therefore the Panel finds bad faith under the provision.”). Thus, the Panel finds that Respondent’s domain names in this proceeding along with its history of bad faith in UDRP proceedings show a pattern pursuant to Policy ¶ 4(b)(ii).
Thirdly, because of the global fame of Complainant’s CITI marks, Complainant argues that it is clear that Respondent registered the domain names with actual knowledge of the CITI marks. The Panel agrees with Complainant regarding Respondent's actual knowledge and concludes that Respondent registered the domain names in bad faith according to Policy ¶ 4(a)(iii). See Immigration Equality v. Brent, FA 1103571 (Forum Jan. 11, 2008) ("That Respondent proceeded to register a domain name identical to, and with prior knowledge of Complainant's mark is sufficient to prove bad faith registration and use under Policy ¶ 4(a)(iii).").
Fourthly, Complainant contends that Respondent’s inactive holding is further evidence of bad faith under Policy ¶ 4(a)(iii). Such inactive holding has been considered an ancillary representation of bad faith under the Policy. See VideoLink, Inc. v. Xantech Corporation, FA1503001608735 (Forum May 12, 2015) (“Failure to actively use a domain name is evidence of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).”). The Panel notes the resolving pages of the websites to which the domain names resolve at Attached Exhibit H (“This site can’t be reached”). Therefore, the Panel agrees that the inactive holding by Respondent is additional evidence of bad faith under 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 CITI marks and in view of the conduct that Respondent engaged in related to 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 <citi.ink>, <citibank.kim>, <citibank.pro>, <citibank.wiki>, <citicorp.club>, <citicorp.online>, <citicorp.site>, <citicorp.vip>, <citigroup.ink>, <citigroup.kim>, <citigroup.mom>, <citigroup.pink>, <citigroup.pub>, and <citigroup.wiki> domain names be TRANSFERRED from Respondent to Complainant.
The Honourable Neil Anthony Brown QC
Panelist
Dated: March 13, 2017
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