Feel the World, Inc. v. winbest/ Tanya Stephens/ See PrivacyGuardian.org/ Domain Administrator/ dasdadaa/ asdasd asdada/ yfgs/ htyse fgdf/ lxuff/ asds ddgfd/ Joel Gilgeous/ ybaa/ Stephen Maynard/ susususu/ Joshua Almazan/ ybb/ Michael WilliamsHill/ Guihong Wu/ Tartan Drive/ sergio deviato/ dfdfdfd fdfdf/ Asdadad/ Asdasdasd Asdasdasd/ aaaabbb/ aavb csdf/ arkjdtk swswsw/ Watson Information Co., Ltd./ Ginifer Stark/ yy/ Moreno Marisol/ gdhfgj/ hgdjdjgh djhgjd/ lxuff/ asds ddgfd/ ybbb/ Jeremy Hickman/ ybb/ Michael WilliamsHill
Claim Number: FA2108001958852
Complainant is Feel the World, Inc. (“Complainant”), represented by Craig A. Beaker of Perkins Coie, Colorado, USA. Respondent is winbest/ Tanya Stephens/ See PrivacyGuardian.org/ Domain Administrator/ dasdadaa/ asdasd asdada/ yfgs/ htyse fgdf/ lxuff/ asds ddgfd/ Joel Gilgeous/ ybaa/ Stephen Maynard/ susususu/ Joshua Almazan/ ybb/ Michael WilliamsHill/ Guihong Wu/ Tartan Drive/ sergio deviato/ dfdfdfd fdfdf/ Asdadad/ Asdasdasd Asdasdasd/ aaaabbb/ aavb csdf/ arkjdtk swswsw/ Watson Information Co., Ltd./ Ginifer Stark/ yy/ Moreno Marisol/ gdhfgj/ hgdjdjgh djhgjd/ lxuff/ asds ddgfd/ ybbb/ Jeremy Hickman/ ybb/ Michael WilliamsHill (“Respondent”), USA.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <dealsxeroshoess.today>, <outletxeroshoess.today>, <pusbllmallxeroshoes.shop>, <storexeroshoes.today>, <xeroshoes.shop>, <xeroshoes.today>, <xeroshoesdeals.shop>, <xeroshoesdeals.today>, <xeroshoesmalldeals.shop>, <xeroshoesmalloutlet.today>, <xeroshoesmalls.shop>, <xeroshoesmallss.shop>, <xeroshoesmallsus.shop>, <xeroshoesnewmall.shop>, <xeroshoesnews.shop>, <xeroshoesnewus.shop>, <xeroshoesonline.shop>, <xeroshoesonlineus.shop>, <xeroshoesooutletqsxus.shop>, <xeroshoesoutlet.co>, <xeroshoesoutlet.shop>, <xeroshoesoutlet.today>, <xeroshoesoutlets.best>, <xeroshoesoutlets.today>, <xeroshoesqmallkyus.shop>, <xeroshoesshopoutlet.shop>, <xeroshoesshops.shop>, <xeroshoesshops.today>, <xeroshoesstores.shop>, <xeroshoestoday.co>, <xeroshoesus.shop>, <xeroshoesus.today>, <xeroshoesusdeals.shop>, <xeroshoesusoutlet.shop>, and <xeroshoesye.shop>, registered with NameSilo, 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.
Richard Hill as Panelist.
Complainant submitted a Complaint to the Forum electronically on August 10, 2021; the Forum received payment on August 10, 2021.
On August 10, 2021, NameSilo, LLC confirmed by e-mail to the Forum that the <dealsxeroshoess.today>, <outletxeroshoess.today>, <pusbllmallxeroshoes.shop>, <storexeroshoes.today>, <xeroshoes.shop>, <xeroshoes.today>, <xeroshoesdeals.shop>, <xeroshoesdeals.today>, <xeroshoesmalldeals.shop>, <xeroshoesmalloutlet.today>, <xeroshoesmalls.shop>, <xeroshoesmallss.shop>, <xeroshoesmallsus.shop>, <xeroshoesnewmall.shop>, <xeroshoesnews.shop>, <xeroshoesnewus.shop>, <xeroshoesonline.shop>, <xeroshoesonlineus.shop>, <xeroshoesooutletqsxus.shop>, <xeroshoesoutlet.co>, <xeroshoesoutlet.shop>, <xeroshoesoutlet.today>, <xeroshoesoutlets.best>, <xeroshoesoutlets.today>, <xeroshoesqmallkyus.shop>, <xeroshoesshopoutlet.shop>, <xeroshoesshops.shop>, <xeroshoesshops.today>, <xeroshoesstores.shop>, <xeroshoestoday.co>, <xeroshoesus.shop>, <xeroshoesus.today>, <xeroshoesusdeals.shop>, <xeroshoesusoutlet.shop>, and <xeroshoesye.shop> domain names are registered with NameSilo, LLC and that Respondent is the current registrant of the names. NameSilo, LLC has verified that Respondent is bound by the NameSilo, 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 August 19, 2021, the Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of September 8, 2021 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@dealsxeroshoess.today, postmaster@outletxeroshoess.today, postmaster@pusbllmallxeroshoes.shop, postmaster@storexeroshoes.today, postmaster@xeroshoes.shop, postmaster@xeroshoes.today, postmaster@xeroshoesdeals.shop, postmaster@xeroshoesdeals.today, postmaster@xeroshoesmalldeals.shop, postmaster@xeroshoesmalloutlet.today, postmaster@xeroshoesmalls.shop, postmaster@xeroshoesmallss.shop, postmaster@xeroshoesmallsus.shop, postmaster@xeroshoesnewmall.shop, postmaster@xeroshoesnews.shop, postmaster@xeroshoesnewus.shop, postmaster@xeroshoesonline.shop, postmaster@xeroshoesonlineus.shop, postmaster@xeroshoesooutletqsxus.shop, postmaster@xeroshoesoutlet.co, postmaster@xeroshoesoutlet.shop, postmaster@xeroshoesoutlet.today, postmaster@xeroshoesoutlets.best, postmaster@xeroshoesoutlets.today, postmaster@xeroshoesqmallkyus.shop, postmaster@xeroshoesshopoutlet.shop, postmaster@xeroshoesshops.shop, postmaster@xeroshoesshops.today, postmaster@xeroshoesstores.shop, postmaster@xeroshoestoday.co, postmaster@xeroshoesus.shop, postmaster@xeroshoesus.today, postmaster@xeroshoesusdeals.shop, postmaster@xeroshoesusoutlet.shop, postmaster@xeroshoesye.shop. Also on August 19, 2021, 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 September 14, 2021, 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.
PRELIMINARY ISSUE: MULTIPLE RESPONDENTS
Complainant alleges 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. In support it notes that there is substantial overlap in the registrant contact information provided for the disputed domain names; for example, all but three of the disputed domain names were registered with a @bk.ru email address and identify the zip code “85014” in connection with Respondent—along with a city and state outside of Arizona, where that zip code is used; twelve of the disputed domain names were registered with the phone number “322-619-8237,” and 25 of the disputed domain names identify Respondent using a random assortment of letters such as “gdhfgj,” “yfgs,” or “dfdfdfd fdfdf.” All of the disputed domain names identify the registrar as NameSilo, LLC. The WHOIS records for all of the Disputed Domain Names display name servers with “NS CLOUDFLARE.COM.” Further, all of the disputed domain names follow a similar naming convention, namely, combining “XEROSHOES” in its entirety with generic words referencing the retail industry—such as “shop,” “outlet,” or “mall”—or some other generic word—like “online,” or “today,” or “new.” Several of the domain names also add miscellaneous letters that have no discernible meaning or significance.
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.”
The Panel finds the evidence presented by Complainant to be sufficient to establish that all the disputed domain names were registered by the same domain name holder. See The Valspar Corporation v. Zhou Zhiliang / zhouzhiliang / Zhiliang Zhou / Eric Chow / Visspa Ltd., FA100800133934 (Forum Sept. 28, 2010); see also BBY Solutions, Inc. v. White Apple / Dev Kumar, FA1805001787251 (Forum June 20, 2018).
Consequently, the Panel will rule on all the disputed domain names, and the registrants are collectively referred to as “Respondent”.
A. Complainant
Complainant states that it offers apparel and footwear for sale. Complainant is best known for its innovative lightweight and minimalist footwear designed for walking, running, and other athletic activities. Since Complainant launched its business in 2011, it has expanded to include other types of footwear, apparel, and accessories offered under or in connection with the XERO and XEROSHOES marks. Complainant’s products are sold in more than 130 countries around the world. Since 2011, Complainant has gained widespread recognition and notoriety within the footwear and apparel space. For example, Complainant has been featured in multiple third-party publications and media outlets in connection with the products sold under the XERO marks. In addition, Complainant has been honored by multiple organizations, including on the Colorado Office of Economic Development’s “Colorado Companies to Watch” list, Colorado Biz Magazine’s “2018 Top Women-Owned Business List,” and Biz West Magazine’s “Mercury 100” list. Complainant has rights in the XERO and XEROSHOES marks based upon their registration in the United States in, respectively, 2013 and 2014.
Complainant alleges that the disputed domain names are confusingly similar to its XEROSHOES marks because each of them incorporates the mark in its entirety, merely adding one or more generic words, most of which directly reference the retail industry in which Complainant operates, such as “shop” or “outlet.” Several of the disputed domain names incorporate other generic terms that similarly do not serve to distinguish the domain names from Complainant’s XEROSHOES mark, such as “online” or “today.” In addition, several of the disputed domain names add miscellaneous letters that have no discernible meaning or significance. Complainant cites UDRP precedents to support its position.
According to Complainant, Respondent does not have rights or legitimate interests in the disputed domain names since Respondent is not commonly known by the disputed domain names. Additionally, Respondent doesn’t use the disputed domains for any bona fide offering of goods or services or legitimate noncommercial or fair use. Instead, Respondent uses some of the domain names in connection with an illegal phishing scheme and makes no active use of the remaining domain names. Complainant cites UDRP precedents to support its position.
Further, says Complainant, Respondent registered and uses the disputed domain names in bad faith since each domain name is either used in connection with phishing or is passively held. The WHOIS information is false for several of the disputed domain names. Additionally, Respondent was aware of Complainant’s rights in the XERO and XEROSHOES marks at the time the disputed domain names were registered. Complainant cites UDRP precedents to support its position.
B. Respondent
Respondent failed to submit a Response in this proceeding.
Complainant owns the mark XEROSHOES uses it market footwear and other apparel
Complainant’s rights in its mark date back to 2014.
The disputed domain names were registered between October 28, 2020 and March 17, 2021.
Complainant has not licensed or otherwise authorized Respondent to use its mark.
Some of the disputed domain names are being used for phishing; others are not used; the WHOIS information is false for many of the disputed domain names.
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 set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) (“Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint”).
Each of the disputed domain names incorporates Complainant’s XEROSHOES mark in its entirety, merely adding one or more generic words, most of which directly reference the retail industry in which Complainant operates, such as “shop” or “outlet”; several of the disputed domain names incorporate other generic terms that similarly do not serve to distinguish the domain names from Complainant’s XEROSHOES mark, such as “online” or “today”; in addition, several of the disputed domain names add miscellaneous letters that have no discernible meaning or significance. Minor additions to a mark, such as generic, descriptive, or geographic terms, letters, and gTLDs are generally insufficient to overcome the confusing similarity between a domain name and the mark it incorporates under Policy ¶ 4(a)(i). See Bloomberg Fin. L.P. v. Nexperian Holding Ltd., FA 1782013 (Forum June 4, 2018) (“Where a relevant trademark is recognizable within a disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) does not prevent a finding of confusing similarity under the first element.”); see also Doosan Corporation v. philippe champain, FA 1636675 (Forum Oct. 13, 2015) (finding that geographic designations or terms descriptive of a complainant’s business operations do not remove a domain name from the realm of confusing similarity.); see also Am. Express Co. v. MustNeed.com, FA 257901 (Forum June 7, 2004) (finding the domain name <amextravel.com> confusingly similar to the complainant’s AMEX mark because the “mere addition of a generic or descriptive word to a registered mark does not negate” a finding of confusing similarity); see also Victoria’s Secret et al. v. Zuccarini, FA 95762 (Forum Nov. 18, 2000) (finding that misspelling words and adding letters does not create a distinct mark but is nevertheless confusingly similar to the complainant’s marks); see also TripAdvisor, LLC v. Above.com Domain Privacy / Above.com, FA 1623514 (Forum July 22, 2015) (“The addition of letters to a mark does not adequately distinguish the domain name from a mark.”) see also 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.”). Therefore, the Panel finds that the disputed domain names are confusingly similar to Complainant’s mark under Policy ¶ 4(a)(i).
Complainant has not licensed or otherwise authorized Complainant to use its mark. Respondent is not commonly known by the disputed domain names: in the absence of a response, WHOIS information may be used to determine whether a respondent is has rights or legitimate interest in a disputed domain name under Policy ¶ 4(c)(ii). See Amazon Technologies, Inc. v. LY Ta, FA 1789106 (Forum June 21, 2018) (concluding a respondent has no rights or legitimate interests in a disputed domain name where the complainant asserted it did not authorize the respondent to use the mark, and the relevant WHOIS information indicated the respondent is not commonly known by the domain name). Here, the WHOIS information for the disputed domain names identifies a variety of registrants, none of which correspond with any of the disputed domain names. Therefore, the Panel finds that Respondent is not commonly known by the disputed domain names per Policy ¶ 4(c)(ii).
Some of the disputed domain names are used in connection with an illegal phishing scheme, whereas others are not used. Use of a domain name in connection with phishing is not considered a bona fide offering of goods or services or legitimate noncommercial or fair use per Policy ¶¶ 4(c)(i) or (iii). See DaVita Inc. v. Cynthia Rochelo, FA 1738034 (Forum July 20, 2017) (”Passing off in furtherance of a phishing scheme is not considered a bona fide offering of goods or services or legitimate noncommercial or fair use.”). Similarly, inactively holding a disputed domain name does not show rights and legitimate interests in the domain name. See CrossFirst Bankshares, Inc. v. Yu-Hsien Huang, FA 1785415 (Forum June 6, 2018) (“Complainant demonstrates that Respondent fails to actively use the disputed domain name as it resolves to an inactive website. Therefore, the Panel finds that Respondent fails to actively use the disputed domain name for a bona fide offering of goods or services or legitimate noncommercial or fair use under Policy ¶ 4(c)(i) or (iii).”). Thus, the Panel finds that Respondent is not using the disputed domain names to make a bona fide offering of goods or services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii). And the Panel finds that Respondent does not have rights or legitimate interests in the disputed domain name.
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 names.
Indeed, as already noted, some of the disputed domain names are used in connection with a phishing scheme. Use of a disputed domain name to further a phishing scheme or other fraudulent behavior supports a finding of bad faith under Policy ¶ 4(b)(iv). See Juno Online Servs., Inc. v. Nelson, FA 241972 (Forum Mar. 29, 2004) (“The domain name <billing-juno.com> was registered and used in bad faith by using the name for fraudulent purposes.”). Thus the Panel finds bad faith registration and use per Policy ¶ 4(b)(iv).
Further, also as already noted, the other disputed domain names are not used. According to paragraph 3.3 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (WIPO Jurisprudential Overview 3.0): “From the inception of the UDRP, panelists have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. While panelists will look at the totality of the circumstances in each case, factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent’s concealing its identity or use of false contact details (noted to be in breach of its registration agreement), and (iv) the implausibility of any good faith use to which the domain name may be put.”
In the present case, it is difficult to envisage any use of the disputed domain name that would not violate the Policy, see Morgan Stanley v. TONY / shentony, FA 1637186 (Forum Oct. 10, 2015) (“Respondent registered the disputed domain name [MORGANSTANLEY.ONLINE] in bad faith because . . . it is difficult to envisage any use of the disputed domain name that would not violate the Policy”); see also Singapore Airlines Ltd. v. European Travel Network, D2000-0641 (WIPO Aug. 29, 2000) (where selection of disputed domain name is so obviously connected to complainant’s well-known trademark, use by someone with no connection with complainant suggests opportunistic bad faith); see also Starwood Hotels & Resorts Worldwide, Inc., Sheraton Int’l IP, LLC, Westin Hotel Mgmt., L.P. v. Jingjing Tang, D2014-1040 (WIPO Aug. 19, 2014) (“The Panel finds that the [WESTIN] Marks are not such that could legitimately be adopted by traders other than for the purpose of creating an impression of an association with Complainant. Thus, the Panel concludes that the disputed domain names were registered in bad faith”).
There has been no response to the Complaint. Respondent used a privacy service, that is, it attempted to conceal its identity. Several of the disputed domain names were registered using false WHOIS information, that is false contact details were used (see below). Given these circumstances, the Panel finds that, in this particular case, a finding of bad faith use can be inferred even though the disputed domain name is not being actively used. See Telstra Corporation Limited v. Nuclear Marshmallows, D2000-0003 (WIPO Feb. 18, 2000).
As stated above, the WHOS information for several of the disputed domain names is false: for example, Registrant provided conflicting address information for all but three of the disputed domain names, using the zip code” 85014” in combination with a variety of cities like “Vandiver, AL,” “New York, NY,” and “Randleman, NC” that are not affiliated with that zipcode; in addition, for at least 25 of the disputed domain names, Respondent identified itself using a nonsensical string of letters that are clearly fraudulent, such as “gdhfgj,” “yfgs,” or “dfdfdfd fdfdf.” In many cases, a similar jumble of letters was provided for Respondent’s address. Many of the other cities identified in connection with Respondent’s registration of the disputed domain names do not exist at all, such as “Culver, Alabama,” “MacyBeverly, Massachusetts,” “New York, Colorado,” and “New York, Kentucky.
Using false WHOIS contact information can evince bad faith registration and use under Policy ¶ 4(a)(iii). See CNU ONLINE Holdings, LLC v. Domain Admin / Whois Privacy Corp., FA1504001614972 (Forum May 29, 2015) (“As the Panel sees that Respondent has provided false or misleading WHOIS information, the Panel finds bad faith in Respondent’s registration of the disputed domain name per Policy ¶ 4(a)(iii).”); see also ABB Asea Brown Boveri Ltd v. Global Mgr, FA 1702001716963 (Forum Mar. 30, 2017) (“Complainant contends that Respondent provided false contact information while registering the disputed domain. Registering a confusingly similar domain name using false contact information can evince bad faith registration.”); see also j2 Global Canada, Inc. and Landslide Technologies, Inc. v. Vijay S Kumar/Strategic Outsourcing Services Pvt Ltd, FA 1411001647718 (Forum Jan. 4, 2016) (“False or misleading contact information indicates bad faith registration and use.”); see also Chevron Intellectual Property LLC v. Phillip Thomas/Chevron Pacific, FA 1504001615524 (Forum May 29, 2015) (“Complainant’s use of false registration data and its unexplained redirection of the disputed domain name to Complainant’s own website are further indications of such bad faith.”); see also McDonald’s Corp. v. Holy See, FA 0304000155458 (Forum June 27, 2003) (“The Panel finds that Respondent provided false contact information in the registration certificates and that such actions, even though not specifically enumerated in the Policy, may form the basis for a finding of bad faith registration and use.”); see also Mars, Incorporated v. RaveClub Berlin, FA 0106000097361 (Forum July 16, 2001) (providing false registration and contact information for infringing domain names evidenced Respondent’s bad faith). Accordingly, the Panel finds that Respondent registered and is using the disputed domain names in bad faith 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 <dealsxeroshoess.today>, <outletxeroshoess.today>, <pusbllmallxeroshoes.shop>, <storexeroshoes.today>, <xeroshoes.shop>, <xeroshoes.today>, <xeroshoesdeals.shop>, <xeroshoesdeals.today>, <xeroshoesmalldeals.shop>, <xeroshoesmalloutlet.today>, <xeroshoesmalls.shop>, <xeroshoesmallss.shop>, <xeroshoesmallsus.shop>, <xeroshoesnewmall.shop>, <xeroshoesnews.shop>, <xeroshoesnewus.shop>, <xeroshoesonline.shop>, <xeroshoesonlineus.shop>, <xeroshoesooutletqsxus.shop>, <xeroshoesoutlet.co>, <xeroshoesoutlet.shop>, <xeroshoesoutlet.today>, <xeroshoesoutlets.best>, <xeroshoesoutlets.today>, <xeroshoesqmallkyus.shop>, <xeroshoesshopoutlet.shop>, <xeroshoesshops.shop>, <xeroshoesshops.today>, <xeroshoesstores.shop>, <xeroshoestoday.co>, <xeroshoesus.shop>, <xeroshoesus.today>, <xeroshoesusdeals.shop>, <xeroshoesusoutlet.shop>, and <xeroshoesye.shop> domain names be TRANSFERRED from Respondent to Complainant.
Richard Hill, Panelist
Dated: September 14, 2021
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