Charter Communications Holding Company, LLC v. Michael Presley
Claim Number: FA2211002020166
Complainant is Charter Communications Holding Company, LLC (“Complainant”), represented by Craig Beaker of Holland & Hart LLP, Colorado. Respondent is Michael Presley (“Respondent”), US.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <stopspectrum.com> and <spectrumkills.com> registered with NameCheap, Inc..
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 Honorable Neil Anthony Brown KC as Panelist.
Complainant submitted a Complaint to Forum electronically on November 14, 2022; Forum received payment on November 14, 2022.
On November 14, 2022, NameCheap, Inc. confirmed by e-mail to Forum that the <stopspectrum.com>, <spectrumkills.com> domain names are registered with NameCheap, Inc. and that Respondent is the current registrant of the names. NameCheap, Inc. has verified that Respondent is bound by the NameCheap, Inc. 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 November 15, 2022, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of December 5, 2022 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@stopspectrum.com, postmaster@spectrumkills.com. Also on November 15, 2022, 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, Forum transmitted to the parties a Notification of Respondent Default.
On December 8, 2022, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed The Honorable Neil Anthony Brown KC as Panelist.
Having reviewed the communications records, the Administrative Panel (the "Panel") finds that 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, 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,
Charter Communications Holding Company, LLC offers telecommunications services.
Complainant asserts rights in the SPECTRUM mark based upon registration with
the United States Patent and Trademark Office (“USPTO”) (e.g., Reg. no.
6,311,602, registered April 6, 2021). See Compl. Ex. 4. Respondent’s <stopspectrum.com>,
<spectrumkills.com> (Disputed
Domain Names) are confusingly similar to Complainant’s SPECTRUM trademark because it incorporates the mark in its
entirety and adds the generic words “STOP” and “KILLS” and the top-level domain
name (“gTLD”) “.com”.
Respondent does not have rights or legitimate interests
in the disputed domain names. Respondent is not licensed or authorized to use
Complainant’s SPECTRUM
mark and is not commonly known by the
disputed domain name. Respondent’s use of the disputed domain names as
alleged complaint sites do not constitute rights or legitimate interests in the
domain names.
Respondent registered and uses the disputed domain names in bad faith. Respondent uses them as alleged complaint sites. Respondent had actual or constructive knowledge of Complainant’s rights in the SPECTRUM mark.
B. Respondent
Respondent failed to submit a Response in this proceeding.
1. Complainant is a prominent United States company engaged in the telecommunications industry.
2. Complainant has established its rights in the SPECTRUM mark based on registration of the mark with the United States Patent and Trademark Office (“USPTO”) (e.g., Reg. no. 6,311,602, registered April 6, 2021).
3. Respondent registered the disputed domain names on October 11, 2022 and October 19, 2022 respectively.
4. The evidence does not show that Respondent has a right or legitimate interest in either of the disputed domain names.
5. The evidence shows that Respondent registered and has used both of the disputed domain names 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 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”).
The first question that arises is whether Complainant has rights in a trademark or service mark on which it may rely. Complainant has submitted that it has a series of trademarks for SPECTRUM, often together with other words that reflect the diverse nature of Complainant’s business. The Panel’s examination of the extensive records submitted by Complainant shows that Complainant’s submission is correct. One of Complainant’s registered trademarks for SPECTRUM is the SPECTRUM mark registered with the USPTO, no. 6,311,602, registered on April 6, 2021, which was of course prior to the dates on which the Disputed domain names were registered, namely October 11, 2022 and October 19, 2022. See Compl. Ex. 4. Registration of a mark with the USPTO is considered a valid showing of rights under Policy ¶ 4(a)(i). See Liberty Global Logistics, LLC v. damilola emmanuel / tovary services limited, FA 1738536 (Forum Aug. 4, 2017) (stating, “Registration of a mark with the USPTO sufficiently establishes the required rights in the mark for purposes of the Policy.”). As Complainant has provided evidence of registration of the SPECTRUM mark with the USPTO, the Panel finds that Complainant has rights in the mark under Policy ¶ 4(a)(i).
The next question that arises is whether the disputed domain names are identical or confusingly similar to Complainant’s SPECTRUM mark. Clearly, neither of them is identical. The question is therefore whether they are confusingly similar to the trademark. Complainant argues that the Disputed Domain Names are confusingly similar to Complainant’s SPECTRUM trademark because they incorporate the mark in its entirety and add the generic words “STOP” and “KILLS” and the gTLD “.com”. Panels have regularly held that the addition of a generic term, a gTLD, and other terms that fall into the category of the “sucks” cases, do not prevent a finding of confusing similarity of a domain name with a trademark under Policy ¶ 4(a)(i). That is because the assessment of this, the first element under the UDRP, is concerned only with a straight comparison between the domain names in question and the relevant trademark. Other issues, such as whether other words added to a trademark can influence decisions made on the second and third elements, must be left until those elements are dealt with. See MTD Products Inc v J Randall Shank, FA 1783050 (Forum June 27, 2018) (“The disputed domain name is confusingly similar to Complainant’s mark as it wholly incorporates the CUB CADET mark before appending the generic terms ‘genuine’ and ‘parts’ as well as the ‘.com’ gTLD.”); see also Chevron Intellectual Property LLC v. andrew toro, FA 1487014 (Forum Apr. 11, 2013) (finding, “The affixation of negative terms does not defeat a finding of confusing similarity” where the respondent registered the domain <chevronthinkswerestupid.com>). Accordingly, on the first issue before the Panel, it finds that the disputed domain names are confusingly similar to Complainant’s SPECTRUM mark under Policy ¶ 4(a)(i). That is so because the two domain names are clearly making the proposition that someone or something, should, respectively, be stopped and that it is engaged in killing. This clearly raises the question of who that might be in each case and the answer is that the domain names are phrased so as to urge the internet user to conclude that the domain names are pointing at the Complainant and only at the Complainant as being the answer to that question. Each of the domain names is therefore confusingly similar to the trademark.
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), then the burden shifts to Respondent to show that 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”).
Having applied that principle, 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 SPECTRUM mark and to use it in its two domain names adding only, respectively, the words “stop” and “kills” to the mark, which do not negate a finding of confusing similarity between the domain names and the mark;
(b) Respondent registered the domain names on October 11, 2022 and October 19, 2022 respectively;
(c) Respondent has used the domain names to resolve to web pages containing derogatory and other pejorative statements about the Complainant, its employees and others;
(d) Respondent has engaged in these activities without the consent or approval of the Complainant;
(e) Complainant argues that Respondent does not have rights or legitimate interests in the Disputed Domain Names because Respondent is not licensed or authorized to use Complainant’s SPECTRUM mark in the domain names and is not commonly known by the disputed domain names. It is clear from the evidence that the Complainant has not licensed or authorized the Respondent to use its trademark in a domain name or anywhere else and could scarcely have done so, due to the unprincipled way in which the domain names have been used by the Respondent to denigrate the Complainant. It is also clear from the evidence that Respondent’s name is Michal Presley and that he is not, in the absence of any evidence to the contrary, commonly known by the domain names. Therefore, the Panel finds that neither of these circumstances gives rise to a right or legitimate interest in the domain names.
All of the foregoing makes it very clear that a prima facie case has been made out that the Respondent does not have a right or legitimate interest in respect of either of the domain names. The Panel must therefore look at whether the Respondent has rebutted that prima facie case. The Panel finds that the Respondent has not done so as it has not filed a Response. But in addition to that, it could not conceivably do so in the light of the evidence, coming in this regard solely from the Respondent.
The Respondent has not filed a Response in this proceeding or even written to the Forum setting out its views, as is often done by registrants in the position of Respondent. However, what is clear from the extensive evidence submitted by Complainant is that Respondent as a matter of fact is using the domain names to support webpages in which Respondent has made a series of derogatory and other pejorative statements about Complainant and its employees. A page that is exhibited comes from the website to which <stopspectrum.com> resolves and it contains the assertion that Charter Spectrum is sending violent criminals into homes to install Wi Fi, cable and phones; that is has engaged in a cover-up; that there is an “overwhelming number of thefts, assaults, rapes and other criminal behavior that Charter Spectrum’s employees commit”; that some or all of this information is alleged to have come from a particular court case that is said to have taken place; that Complainant had committed “ felony forgery”; that the information in question raised the question whether this was an inside job; asks the question why Spectrum consumers are not told that “ the techs are possible criminals” and makes other assertions of the same genre. A second page or site, which is in essence of the same genre presented over several pages, is also exhibited and this comes from the site to which the domain name <spectrumkills.com> resolves, and consists of “lorem ipsum” text, meaning “all the facts” and used to fill empty space prior to the publication of a printed product. It therefore does not, in words, contain the same content as the material from <stopspectrum.com>, but its meaning and intention are very clear because each page is headed “Spectrum Kills”, which does not leave much scope for doubt as to what it is meant to convey. It is an assertion that the Complainant kills.
The question therefore arises, although it has not been submitted by Respondent, as it has not defended the proceeding, whether the contents of each of the two exhibits is a form of free speech presented in a criticism site which is protected by virtue of the First Amendment to the United States Constitution and/or that it is “ a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue” within the meaning of paragraph 4( c) (iii) of the Policy”.
That argument, whether the Respondent were to advance it or not, has no merit and could not succeed. It overlooks a fundamental point which is sometimes overlooked when this issue arises for discussion or decision. The point is that if it is to be said that a criticism site is protected as free speech, it must first be shown that it actually is a criticism site, the emphasis being on the word “is”, as opposed to “is not”. If and when that conclusion is reached, the panel or a court can then decide if it also passes muster as an exercise in free speech and is protected for that reason. Here, the issue is what is the substance of the site or other content? Is it a criticism site?
In the present context, it is clear that “criticism“ means the presentation of an opinion with enough substance in it to enable the recipient to understand what is being said against it so that it can reply to it. In the present case the substance of the content of the two webpages in question shows to the panel that its substance, intention and purpose is not to stimulate criticism or debate but to abuse and denigrate the Complainant and its employees and possibly others as well. That is made clear by the inherent absurdity of the allegations, their extraordinary width, the absence of any invitation to reply or debate and the absence of any content that could rationally call for a reply or a defence. Likewise, an alleged fan site must be a real fan site and not a platform serving an entirely different function, but under the guise of a fan site. Thus, if a website to which the domain name resolves asserts that its substance is to give homage as a fan, but it then goes on to say that the subject of the fan’s adulation is a serial criminal or a profligate, that cannot accurately be said to be a fan site. Moreover, the substance of the present allegations, like its purpose and intention, is clearly to inflict pain and denigration on the Complainant and its employees and others, rather than to present a subject of criticism to which the Complainant can and should be able to reply.
Thus, the webpages are not, in substance, criticism but abuse. More to the point, the content of the two webpages show that it would be impossible on the evidence to show that the Respondent has a right or legitimate interest in using the Complainant’s trademark to register the domain names and use them for a sustained attack on the Complainant and others who must be presumed innocent of the charges levelled against them.
There are also some other factors that make it entirely inappropriate to give the contents of the two webpages any free speech protection at all.
First, as noted, the Respondent could have, but did not, set out a rational defence of its conduct in a Response.
Secondly, the Panel’s decision does not affect the Respondent’s free speech rights in any way at all, as it retains all of its rights to sue in the courts under whatever cause of action it may wish to pursue.
Thirdly, as also noted, the Respondent has made a series of wild allegations without any evidence to which the Complainant could reasonably be expected to reply.
Fourthly, although the allegations attack the commercial propriety of the Complainant, they go far beyond that ambit and trespass into allegations about innocent employees of the Complainant that have no connection with the commercial activities of the Complainant, with no evidence and no reasonable mechanism or opportunity to reply, going as far as to describe them as being “violent criminals” engaged in theft, assault, rape, forgery and “other criminal behavior”.
Fifthly, it does this by using the Complainant’s trademark without any permission to do so.
Sixthly, although UDRP decisions are not precedents, the view now being expressed by this panel is one that is consistent with established views expressed by other panelists. The Panel particularly relies on the decision cited by the Complainant in TM Web Properties, Ltd. v. dlp / donald seoane, Forum. FA1909001861963 (October 15, 2019). Here, on facts not dissimilar to those of the present case, the distinguished panelist who wrote the decision observed:
“The real question is whether the site offers fair comment on the one hand or whether it is intended to tarnish Complainant’s mark within the meaning of Policy ¶ 4(c)(iii). Tarnishing in this context refers to linking unrelated pornographic, violent or other inherently evil behavior to the mark at issue. Britannia Building Society v. Britannia Fraud Prevention, Case No. D2001-0505 (WIPO July 6, 2001), Nicole Kidman v. John Zuccarini d/b/a/ Cupcake Party, Case No D-2000-1415 (WIPO January 23, 2000) (“Likewise, the sexual implications of the domain name <nicolekidmannude.com> and the sexually explicit advertisements to which it was connected threaten to tarnish Kidman’s mark.”). Criticism, even if defamatory, does not constitute tarnishing and is not prohibited by the Policy. Britannia Building Society v. Britannia Fraud Prevention, Ibid., Wal-Mart Stores, Inc. v. Richard MacLeod d/b/a For Sale, Case No. 2000-0662 (WIPO September 19, 2000) (protection for genuine criticism sites is provided by the Policy’s legitimate interest and bad faith prongs).
Commentary on Respondent’s web site to the effect that Complainant engages in predatory business practices is related to the business of Complainant but the references to hacking, raping children, scamming and evading justice in foreign countries are not. They plainly link vile criminal acts to Complainant and its mark. They also are made in an intemperate and provocative manner, using terms such as “child rapist scammer” and provide no evidence or explanation in support. This type of expression cannot rationally be regarded as honest, genuine criticism entitled to protection as fair use under the Policy. Jody Kriss and East River Partners, LLC v. Felix Sater / Larissa Yudina, FA160200 1660728 (Forum Mar. 22, 2016) (“In the Panel’s view the present case is not one of criticism but one where the site is clearly intended for denigration and disparagement, and probably as Complainant submits, revenge, by means of using extreme language, up to and including an allegation of murder. . . . The only conclusion the Panel can draw from an examination of this material, none of which is covered by a qualification, is that it is not legitimate criticism, but abuse and that it was devised to damage Complainant and its business and personal interests.”). The Panel finds that Respondent’s intent in posting the personal references to the former CEO of Complainant’s holding company and linking that alleged misconduct to Complainant was to tarnish the Complainant and its mark. Respondent is not making a legitimate non-commercial or fair use of the Domain Name within the meaning of Policy ¶ 4(c)(iii).”
That is not said to diminish the importance of free speech in domain name cases, but to emphasize that it will only be recognised and applied in a case where the facts and the essential principle that the disputed content is a real exercise in free speech justify it. The present case is not such a case, as it shows that in substance the content was not an exercise in free speech but an exercise in indefensible and unproven abuse that makes it impossible for innocent people to defend themselves.
The evidence therefore shows that the webpage at <stopspectrum.com> is not a criticism site, where, by definition there must be an opinion that is capable of being resolved by argument and where there is some sort of invitation to the reader to join in, on one side or the other, of whatever the contentious opinion may be. For the same reason, the webpage at <spectrumkills.com> is also not a criticism site. It may have confined itself to the assertion that the trademark owner kills, but that is more than enough to enable the Panel to say that the <spectrumkills.com> domain name also does not give rise to a criticism site.
Apart from all of the foregoing, it must seriously be doubted whether the Respondent has any right to the domain names at all. It must also be surely the case that the Respondent is in breach of the terms of its registration agreement with Namecheap, its registrar, potentially negating any entitlement it has to the domain names.
Paragraph 4 of the agreement prohibit “…abuse of the Services ( provided by Namecheap), (and) material allegations of illegal conduct,…” or if your use of the Services involves us in a violation of any Internet Service Provider's ("ISP's") acceptable use policies, including the transmission of unsolicited bulk email in violation of the law.
Paragraph 6 prohibits the use of services under the agreement for “illegal or improper purposes”
Paragraph 6 also prohibits the use of the domain names for “fraudulent or deceptive practices, counterfeiting or otherwise engaging in activity contrary to applicable law.”
Paragraph 8 prohibits any use of the domain names that “infringes legal rights of others.”
The Panel also notes that paragraph 5 provides that:
“If we have grounds to terminate or suspend Service(s) with respect to one domain name or in relation to other Service(s) provided through your account, we may terminate or suspend all Service(s) provided through your account, including Service(s) to other domain names maintained by you with us.” Thus, the foregoing comments apply both to <stopspectrum.com> and <spectrumkills.com>.
Accordingly, the conduct of the Respondent, as asserted by its own contribution to the two webpages, is in breach of all of those provisions, giving Namecheap the right to terminate the agreement. Such conduct therefore also strengthens the panel’s conclusion that the Respondent’s registration and use of the domain names shows that it has no right to or legitimate interest in either of them.
For all of those reasons, the Panel finds that the Respondent does not have a right or legitimate interest in the 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.
The provisions of Policy ¶ 4(b) sets forth a nonexclusive list of four circumstances, any one of which if proven would be evidence of bad faith use and registration of a domain name. They are as follows:
(i) circumstances indicating that you have registered or you have acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant which is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the domain name; or
(ii) you (the registrant) have registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or
(iii) you have registered the domain name primarily for the purpose of disrupting the business of a competitor; or
(iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your web site or other on-line location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation or endorsement of your web site or location or of a product of service on your web site or location
The facts that have already been analysed of Respondent’s conduct discussed above in the rights or legitimate interests section of this decision also support a finding of bad faith registration and use of both domain names.
First, the Respondent has brought itself within several of the specific criteria listed in paragraph 4 (b). In particular, the Respondent has clearly brought itself within paragraph 4 (b)(iii) for, on any test, the Respondent was aiming at the Complainant with the sole objective of damaging it and disrupting its business by lessening public confidence in the Complainant and its employees and branding it as some sort of criminal enterprise. Nothing could be more calculated to disrupt the Complainant’s business. Moreover, the Respondent has set out to compete with the Complainant in the use of its trademark, reputation and brand and in particular by using Complainant’s trademark in the domain names without permission.
In any event and apart from the specific criteria in paragraph 4 (b), the Respondent’s conduct shows bad faith registration and use. There is no need to set out again how its conduct was motivated by bad faith both in the registration and use of the domain names. Again, the decision in TM Web Properties, Ltd. v. dlp / donald seoane (supra) is instructive on this issue as being a decision on analogous facts. The Panel in that decision observed on the issue of bad faith:
“Finally, it is evident from the long-standing notoriety of Complainant’s WEBZILLA mark, from Respondent’s copying that mark verbatim into the Domain Name, and from the vitriolic content directed at and about Complainant on Respondent’s web site, that Respondent had actual knowledge of Complainant and its mark when he registered the Domain Name in August 2019 (WHOIS report submitted as Complaint Exhibit 1 shows registration date). Given the non-exclusive nature of Policy ¶ 4(b), registering a confusingly similar domain name with actual knowledge of a complainant’s rights in its mark has often been held to be evidence of bad faith registration and use for the purposes of Policy ¶ 4(a)(iii). Univision Comm'cns Inc. v. Norte, FA 1000079 (Forum Aug. 16, 2007) (rejecting the respondent's contention that it did not register the disputed domain name in bad faith since the panel found that the respondent had knowledge of the complainant's rights in the UNIVISION mark when registering the disputed domain name).”
In addition, the Respondent had actual knowledge of the Complainant’s SPECTRUM trademark as is seen from the fact that it incorporated the whole of the Trademark in each of the domain names.
Those observations are applicable to the present case and, when applied, show how the Respondent registered and used the domain names in bad faith.
For all of those reasons, the Panel finds that the Respondent registered and used the disputed domain names in bad faith.
Complainant has thus made out the third of the three elements that it must establish and has thus made out all of the elements that it must prove.
Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <stopspectrum.com> and <spectrumkills.com> domain names be TRANSFERRED from Respondent to Complainant.
The Honorable Neil Anthony Brown KC
Panelist
Dated: December 12, 2022
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