Citigroup Inc. v. Quan Wen Jun
Claim Number: FA1708001742937
Complainant is Citigroup Inc. (“Complainant”), represented by James L. Vana of Perkins Coie LLP, Washington, USA. Respondent is Quan Wen Jun (“Respondent”), People’s Republic of China.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan>, registered with West263 International Limited.
The undersigned certifies he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.
Houston Putnam Lowry, Chartered Arbitrator, as Panelist.
Complainant submitted a Complaint to the Forum electronically on August 3, 2017; the Forum received payment on August 3, 2017.
On August 3, 2017, West263 International Limited confirmed by e-mail to the Forum that the <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan> domain names 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 ICANN’s Uniform Domain Name Dispute Resolution Policy (the “Policy”).
On August 4, 2017, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 24, 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@www-ecitic-com.loan, postmaster@www-citibank-com.loan, postmaster@www-citict-com.loan. Also on August 4, 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 August 25, 2017, pursuant to Complainant's request to have the dispute decided by a single-member Panel, the Forum appointed Houston Putnam Lowry, Chartered Arbitrator, 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 the domain names be transferred from Respondent to Complainant.
A. Complainant
Trademark/Service Mark Information: Rule 3(b)(viii).
This Complaint is premised on Complainant’s and its wholly owned subsidiaries’ (collectively, “Citi’s”) incontestable rights in the famous CITI and CITI-formative trademarks (collectively, the “CITI Marks”), which uniquely and exclusively identify Citi. Citi is an American multinational banking and financial services corporation with headquarters in New York, New York, and was first founded as City Bank of New York in 1812. In 2016, Citi was the 13th largest bank holding company in the world as measured by assets, and the 7th largest as measured by market capitalization. Citi first opened an office in China on May 15, 1902 and was one of the first international banks to incorporate locally in mainland China. Citi’s locally incorporated entity is known as Citibank (China) Co. Ltd., which is wholly owned by Citibank N.A. Today, Citi is a leading international bank in China and has branches and sub-branches in thirteen cities across China.
Citi has spent substantial time, effort, and money promoting the CITI Marks in the U.S. and worldwide and, as a result, the CITI Marks have enjoyed widespread international recognition. In 2017, Citi was ranked the 36th and 62nd most valuable global brand by Brand Finance and Forbes, respectively. Citi was also ranked the 49th best global brand by Interbrand in 2016.
Citi owns a worldwide portfolio of registrations for the CITI Marks, including those registrations in the United States and China. For purposes of this Proceeding, Citi’s most relevant registrations are detailed in the Complaint.
Citi first used the CITIBANK service mark in 1959 for banking services and has used the remaining CITI Marks in connection with banking, financial, and related services since as early as 1979. Citi has used the CITI Marks in China since as early as 2000. Citi has continuously used the CITI Marks since those times.
Citi has not licensed the CITI Marks to Respondent, nor has Citi otherwise authorized or permitted Respondent to make use of the CITI Marks.
Citi currently owns registrations for numerous domain names, but primarily uses <citi.com> and <citibank.com> (collectively, the “Citi Domain Names”). Citi began using the Citi Domain Names in connection with its business as early as 1998, and the Domains have been continuously used and associated with Citi’s business since that time. Citi’s primary Internet website is located at <www.citi.com> (the “Citi Website”), and both Citi Domain Names resolve to the Citi Website. The Citi Website contains extensive usage of Citi’s famous CITI Marks.
FACTUAL AND LEGAL GROUNDS
This Complaint is based on the following factual and legal grounds: UDRP Rule 3(b)(ix). [a.] [a] The Disputed Domains are Confusingly Similar to the CITI Marks
[i.] Citi owns numerous registrations for the CITI Marks, including the Citi Registrations. Such registrations have consistently been held to be sufficient evidence of Registrant’s ownership of its marks under Policy ¶4(a)(i). See, e.g., Microsoft Corp. v. lucy green, FA1728637 (Forum May 23, 2017) (complainant’s registration of its mark with the USPTO is sufficient to allow the Panel to conclude that complainant has rights in its mark under the Policy).
[ii] The Disputed Domains are confusingly similar to the CITI Marks in that they wholly incorporate Citi’s famous CITI and CITIBANK marks. While each Disputed Domain contains additional elements beyond Citi’s Marks, those additional elements do not change the obvious conclusion that the Disputed Domains are confusingly similar to the CITI Marks.
[iii] First, each Disputed Domain follows the format “www-[CITI formative]- com.loan.” However, the addition of the top level domains “com” and “.loan”, and the standard website prefix “www,” have no bearing on the confusing similarity analysis. See, e.g., Little League Baseball, Inc. v. Domain Manager, FA1651999 (Forum Jan. 18, 2016) (adding “www” to another’s mark takes advantage of a common typing error, and thus does not distinguish the domain name from the mark so as to avoid a finding of confusing similarity); Microsoft Corp. v. lucy green, supra (adding “com” to a mark prior to the generic top level domain extension takes advantage of a common typographical error and does not change a finding that the domain name is confusingly similar to the complainant’s mark); CSC Holdings, Inc. v. Elbridge Gagne, No. D2003-0273 (WIPO Jun. 18, 2003) (noting that domain names that consist of the prefix “www” affixed to a trademark are substantially similar to the relevant trademark). This is especially true given that the Disputed Domains use dashes to separate the generic “www” prefix and “com” gTLD suffix.
[iv] Second, two of the Disputed Domains (<www-ecitic-com.loan> and <www- citict-com.loan>) add two additional letters to Citi’s famous CITI Mark. However, these minor variations do little to change the commercial impression created by those Disputed Domains, which remain overwhelmingly tied to Citi’s famous CITI Mark. See ACCOR v. Brigit Klostermann, D2005-0627 (WIPO Aug. 8, 2005) (noting that “typosquatting, the practice of misspelling an element of the mark, has consistently been regarded as creating domain names confusingly similar to the relevant mark”). As a result, it is clear that each Disputed Domain is confusingly similar to the CITI Marks.
[v.] Further, the use of “.loan” enhances the risk that Internet users will presume that the Disputed Domains are affiliated with Citi’s financial services. This is consistent with prior Panel decisions regarding the use “.loan” in connection with trademarks owned by financial institutions. See AXA SA v. Ran Jian, No. D2017-0205 (WIPO Panel Apr. 4, 2017) (respondent’s <axa3k.loan> held confusingly similar to a financial institution’s AXA SA mark because “.loan” suggested a link to financial services).
[vi.] Therefore, the Disputed Domains are confusingly similar to Citi’s CITI Marks under Policy ¶4(a)(i).
[b.] The Respondent Has No Rights or Legitimate Interests in the Disputed Domains
[i.] A complainant must prove that a respondent has “no rights or legitimate interests in respect of the domain name.” Policy ¶4(a)(ii). Here, Respondent is not a licensee or authorized user of the CITI Marks (or any variation thereof) and is not commonly known by the Disputed Domains or any variation of Citi’s CITI Marks (the WHOIS information lists “Quan Wen Jun” as registrant). See Tercent Inc. v. Yi, FA139720 (Forum Feb. 10, 2003) (stating “nothing in [the respondent’s] WHOIS information implies that [the respondent] is ‘commonly known by’ the disputed domain name” as one factor in determining that Policy ¶4(c)(ii) does not apply); Braun Corp. v. Loney, FA699652 (Forum Jul. 7, 2006) (concluding that the respondent was not commonly known by the disputed domain names where the WHOIS information, as well as all other information in the record, gave no indication that the respondent was commonly known by the domain names, and the complainant had not authorized the respondent to register a domain name containing its registered mark).
[ii.] Further, Respondent has not and is not using the Disputed Domains in connection with a bona fide offering of goods or services, a legitimate noncommercial use, or a fair use. Indeed, the Disputed Domains resolve to pages featuring pornographic content and pictures of naked or partially naked women. Panels have consistently found that use of a domain name to divert to pornographic content cannot establish bona fide use of, or a legitimate interest in, a domain name. See AXA SA, supra (no bona fide offering of goods or services where <axa3k.loan> resolved to a website “featuring pornographic content and pictures of Asian women in various stages of undress.”); Target Brands, Inc. v. Bealo Grp. S.A., FA128684 (Forum Dec. 17, 2002) (use of <targetstore.net> to redirect Internet users to a pornographic website did not equate to a bona fide offering of goods or services under Policy ¶4(c)(i), or a legitimate noncommercial or fair use of a domain name under Policy ¶4(c)(iii)); Dipaolo v. Genero, FA0310000203168 (Forum Dec. 6, 2003) (“Diversion to pornography is not a bona fide offering of goods or services or a legitimate noncommercial or fair use of the domain name pursuant to Policy ¶¶4(c)(i) and (iii).”); Nat’l Football League Prop., Inc. v. One Sex Entm't Co., D2000-0118 (WIPO Apr. 17, 2000) (finding that the Respondent has no rights or legitimate interests in the domain names "chargergirls.com" and "chargergirls.net," used for pornographic websites).
[iii.] Thus, Respondent has no rights or legitimate interests in the Disputed Domains.
[c.] The Disputed Domains Have Been Registered and are Being Used in Bad Faith
[i.] Pursuant to Policy ¶4(b), complainant must show that a disputed domain name was registered and used in bad faith. Here, the CITI Marks have enjoyed international fame and notoriety due to Citi’s exclusive, worldwide use and promotion of its services under the Marks. As the attached Citi Declaration makes clear, Citi is one of the world’s largest bank holding companies and the CITI brand is one of the world’s most valuable brands. Accordingly, it is inconceivable that Respondent had no knowledge of Citi’s rights in the CITI Marks prior to registering the Disputed Domains. This is evidence of bad faith under Policy ¶4(a)(iii). See Nike, Inc. v. B.B. de Boer, D2000-1397 (WIPO Dec. 21, 2000) (finding bad faith where it was unlikely, if not impossible, that respondent was not aware it was infringing complainant’s well-known mark); Citigroup Inc. v. Chen Ying Quan, FA1714851 (Forum Mar. 13, 2017) (recognizing the global fame of Complainant’s CITI marks); Citigroup Inc. v. jose vicente gomar llacer/Ganidyork,SL - B98466980, FA1652712 (Forum Jan. 25, 2016) (“because of the global fame of Complainant’s mark, it is clear that Respondent registered the domain name [citi.land] with actual knowledge of the CITI mark”).
[ii.] Further, Respondent uses the Disputed Domains to divert Internet users to Respondents’ own websites featuring pornographic content for commercial gain, which is also evidence of bad faith. See Six Continents Hotels, Inc. v. Nowak, D2003-0022 (WIPO Mar. 4, 2003) (holding that “diversion of the domain name to a pornographic site is itself certainly consistent with the finding that the Domain Name was registered and is being used in bad faith.”); Allianz of Am. Corp. v. Bond, FA 680624 (Forum June 2, 2006) (finding bad faith registration and use under Policy ¶4(b)(iv) where the respondent was diverting Internet users searching for the complainant to its own website and likely profiting); DatingDirect.com Ltd. v. Aston, FA593977 (Forum Dec. 28, 2005) (“the Panel finds the respondent is appropriating the complainant’s mark in a confusingly similar domain name for commercial gain, which is evidence of bad faith registration and use pursuant to Policy ¶4(b)(iv).”).
[iii.] Therefore, Respondent has registered and is using the Disputed Domains in bad faith.
B. Respondent
Respondent failed to submit a Response in this proceeding.
Language of Proceedings
Complainant requests this administrative proceeding proceed in the English language pursuant to UDRP Rule 11(a). 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:
1. WHOIS information which establishes Respondent in a country which would evince a familiarity with the English language,
2. filing of a trademark registration with an entity which evinces an understanding of the English language, and
3. any evidence (or lack thereof) evincing Respondent’s understanding of the English 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). 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.”). In this case, Respondent targeted English language marks (even though the resolving web pages are in Chinese) and did not respond to a notice of this proceeding which was in Chinese.
Pursuant to UDRP Rule 11(a), the Panel finds there is sufficient persuasive evidence Respondent is conversant and sufficiently proficient in the English language. After considering the circumstance of the present case, the Panel decides that the balance of the proceeding should be in English.
(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.
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 Complainant prove the following three elements to obtain an order cancelling or transferring a domain name:
(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.”).
Complainant is a global provider of banking and financial services. Complainant uses the CITI marks in conjunction with its business practices. Complainant registered the CITI marks with the United States Patent and Trademark Office (“USPTO”) (e.g., Reg. No. 691,815, registered Jan. 19, 1960; Reg. No. 1,181,467, registered Dec. 8, 1981, respectively). Complainant also registered the CITI marks with Trademark Office of the State Administration for Industry and Commerce (“SAIC”) (e.g. Reg. No. 779495, registered Mar. 14, 1995; Reg. No. 6515039, registered Jan. 14, 2013, respectively). Registration with the USPTO (or any other governmental authority for that matter) suffices to demonstrate rights in a mark under Policy ¶4(a)(i), even if Respondent is located in another country. See Fossil Group, Inc. v. wuruima wu, FA 1544486 (Forum Mar. 21, 2014) (holding, “Complainant’s registration of the FOSSIL mark with trademark agencies worldwide, including the USPTO and SAIC, establishes Complainant’s rights in the FOSSIL mark pursuant to Policy ¶4(a)(i).”). Complainant’s registrations with USPTO and SAIC are sufficient to show its rights in the CITI marks.
Complainant claims Respondent’s <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan> are confusingly similar to Complainant’s CITI marks because they incorporate the marks in their entirety, adding hyphens, the generic word “com,” the letters “e,” “c,” and “t,” and the “.loan” TLD. “The added ‘com’ does not defeat a confusing similarity claim because it takes advantage of a common typographical error. It is a basic mistake to type ‘com’ twice without typing the period after the targeted search term.” Borders Props., Inc. v. Hewitt, FA 114618 (Forum July 23, 2002). Likewise, the addition of letters and hyphens are irrelevant for purposes of the Policy. A TLD (whether a gTLD, sTLD or ccTLD) is disregarded under a Policy ¶4(a)(i) analysis because domain name syntax requires TLDs. See e.g., ModCloth, Inc. v. James McAvoy, FA 1629102 (Forum Aug. 16, 2015) (“The Panel finds that the disputed domain name is confusingly similar to Complainant’s mark because it differs from Complainant’s mark by merely adding the letter ‘L.’”); Health Devices Corp. v. Aspen S T C, FA 158254 (Forum July 1, 2003) (“[T]he addition of punctuation marks such as hyphens is irrelevant in the determination of confusing similarity pursuant to Policy ¶4(a)(i).”); 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.”). The “.loan” sponsored top level domain targets banks and lenders, suggesting the owner of a domain name in that sTLD is a financial institution. Respondent’s <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan> domain names are confusingly similar to Complainant’s CITI marks.
The Panel finds Policy ¶4(a)(i) satisfied.
Complainant must first make a prima facie case Respondent lacks rights and legitimate interests in the disputed domain names under Policy ¶4(a)(ii). Then the burden shifts to Respondent to show it has 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.”).
Complainant claims Respondent does not have rights or legitimate interests in <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan>. Respondent is not commonly known by the disputed domain names. WHOIS information associated with this case identifies Respondent as “Quan Wen Jun.” Absent information in the record to the contrary, the WHOIS information and common sense allow the Panel to decide Respondent is not commonly known by the domain name under Policy ¶4(c)(ii). Tercent Inc. v. Lee Yi, FA 139720 (Forum Feb. 10, 2003). As such, “[g]iven the WHOIS contact information for the disputed domain [name],” the Panel may infer that “Respondent . . . is not commonly known by the [disputed] name . . . in any derivation.” Wells Fargo & Co. v. Onlyne Corp. Services11, Inc., FA 198969 (Forum Nov. 17, 2003). Respondent is not commonly known by any of the disputed domain names.
Complainant has neither authorized nor licensed Respondent to use the CITI marks in any fashion. Respondent is not affiliated with Complainant. Respondent has not made a bona fide offering of goods or services, or a legitimate non-commercial or fair use of the domain because the disputed domain names resolved to pornographic web sites which are unrelated to Complainant’s business. A respondent’s use of the complainant’s mark and the goodwill surrounding that mark as a means of attracting Internet users to an unrelated business (especially if it is pornographic) is not a bona fide offering of goods or services. See U.S. Franchise Sys., Inc. v. Howell, FA 152457 (Forum May 6, 2003). Using a domain name that is confusingly similar to an established mark to divert Internet users to an adult-oriented website “tarnishes [c]omplainant’s mark and does not evidence noncommercial or fair use of the domain name by a respondent.” Paws, Inc. v. Zuccarini, FA 125368 (Forum Nov. 15, 2002). The Panel must conclude Respondent does not have rights or legitimate interests in <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan> pursuant to Policy ¶¶4(c)(i) or 4(c)(iii).
The Panel finds Policy ¶4(a)(ii) satisfied.
Complainant claims Respondent registered and is using <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan> domain names in bad faith. Respondent’s <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan> domain names host websites featuring adult content unrelated to Complainant, presumably blemishing the goodwill surrounding Complainant’s mark. It is a reasonable assumption the disputed domain names attract internet users to Respondent’s websites for commercial gain. “Registration and use of a domain name that incorporates another's mark with the intent to deceive Internet users in regard to the source or affiliation of the domain name is evidence of bad faith.” Am. Univ. v. Cook, FA 208629 (Forum Dec. 22, 2003). Using the disputed domain names to tarnish Complainant’s goodwill by resolving to adult-oriented websites is evidence the domain names were registered and are being used in bad faith. See Wells Fargo & Co. v. Party Night Inc., FA 144647 (Forum Mar. 18, 2003). Respondent registered and is using <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan> in bad faith under the Policy.
Complainant claims Respondent registered <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan> with actual knowledge of Complainant and its rights to the CITI marks. It is inconceivable Respondent could have registered the disputed domain names without actual knowledge of Complainant's rights in the marks in light of the fame and notoriety of Complainant's CITI marks in China. Complainant has done business in China since 1902. Complainant operates in 14 Chinese cities (consisting of roughly 47 consumer bank outlets). See Victoria’s Secret Stores Brand Mgmt., Inc. v. Michael Bach, FA 1426668 (Forum March 2, 2012) (“Although Complainant has not submitted evidence indicating actual knowledge by Respondent of its rights in the trademark, the Panel finds that, due to the fame of Complainant’s [VICTORIA’S SECRET] mark, Respondent had actual notice at the time of the domain name registration and therefore registered the domain name in bad faith under Policy ¶4(a)(iii).”). Respondent had actual knowledge of Complainant's CITI marks when it registered <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan>. The Panel finds bad faith on those grounds. Deep Foods, Inc. v. Jamruke, LLC, FA 648190 (Forum Apr. 10, 2006).
The Panel finds Policy ¶4(a)(iii) satisfied.
Having established all three elements required under the ICANN Policy, the Panel concludes relief shall be GRANTED.
Accordingly, it is Ordered the <www-ecitic-com.loan>, <www-citibank-com.loan>, and <www-citict-com.loan> domain names be TRANSFERRED from Respondent to Complainant.
Houston Putnam Lowry, Chartered Arbitrator, Panelist
Dated: Monday, August 28, 2017
Click Here to return to the main Domain Decisions Page.
Click Here to return to our Home Page