WIPO Arbitration and Mediation Center

The Complainants in this proceeding are ISL Worldwide of Zug, Switzerland ("ISL") and The Federation Internationale de Football Association of Zurich, Switzerland ("FIFA").

The Complainants are represented by Tom Heremans and Serge Debrye of the law firm Allen & Overy of Brussels, Belgium.

The Respondent is NETPLUS Communication of Issy-les-Moulineaux, France. The Respondent is represented by Henri Michel Reynaud, European Trademark Attorney of Bloch & Associes of Paris, France.

The domain names at issue are "worldcup.org" registered on March 20, 1997, and "worldcup-tv.com" registered on April 29, 1998.

The domain names are registered with Network Solutions Inc. ("NSI"), of Herndon, Virginia, United States of America.

A Complaint was submitted electronically on January 18, 2001, and by hard copy on January 22, 2001, by the Complainants to the World Intellectual Property Organization Arbitration and Mediation Center ("WIPO Center").

On January 23, 2001, a request for Registrar verification was transmitted by the WIPO Center to NSI, requesting it to:

Confirm that a copy of the Complaint had been sent to it by the Complainant as requested by the WIPO Supplemental Rules for Uniform Dispute Resolution Policy ("Supplemental Rules"), paragraph 4(b).

Confirm that the domain names at issue are registered with NSI.

Confirm that the person identified as the Respondent is the current registrant of the domain names.

Provide full contact details, i.e., postal address(es), telephone number(s), facsimile number(s), email address(es), available in the Registrar’s WHOIS database for the registrant of the disputed domain names, the technical contact, the administrative contact and the building contact for the domain names.

Confirm that the Uniform Domain Dispute Resolution Policy ("UDRP") was in effect.

Indicate the current status of the domain names.

By email dated January 24, 2001, NSI advised the WIPO Center as follows:

NSI had received a copy of the Complaint from the Complainants.

NSI is the Registrar of the domain names.

The Respondent, Netplus Communication is the current registrant with NSI of the said domain names. The technical contact, Laurent Dufour, and the administrative billing contact, Lucas Pedro, have the same address as the Respondent.

NSI’s 5.0 Service Agreement is in effect.

The disputed domain names’ registration is in "Active" status.

With effect from January 1, 2000, NSI adopted the policy for Uniform Domain Name Dispute Resolution adopted by the Internet Corporation for Assigned Names and Numbers ("ICANN"). As can be deduced from the advice of NSI that the domain name in question are "active", the Respondent has not requested that the domain names at issue be deleted from the domain name database, nor sought to terminate the agreement with NSI. Accordingly, the Respondent is bound by the provisions of the Domain Name Dispute Resolution Policy, i.e. the ICANN Policy.

Having verified that the Complaint satisfied the formal requirements of the Uniform Policy and the Uniform Rules, the WIPO Center on January 26, 2001, transmitted by courier, email and facsimile a notification of Complaint and Commencement of Administrative Proceedings to the Respondent. A copy of the notification of Complaint and Commencement of Administrative Proceedings was also emailed to NSI and ICANN.

The Respondent was advised that a Response to the Complaint was required within 20 calendar days. It was also advised that any Response should be communicated, in accordance with the Rules, by four sets of hard copy and by email. The Respondent filed a Response by email on February 14, 2001, and by hard copy on February 14, 2001.

The Complainant elected to have the Complaint resolved by a single Panelist: The Respondent elected a three-person panel. Both parties have paid the requisite amounts to the WIPO Center.

On March 5, 2001, the WIPO Center invited the Honorable Sir Ian Barker QC of Auckland, New Zealand, to chair the Panel in this case. It had earlier invited Dr. Luca Barbero, of Turin, Italy, and Mr. David Heathcote Tatham of London, United Kingdom, to be Panelists. It transmitted to all Panelists a statement of acceptance and requested a declaration of impartiality and independence.

All Panelists duly advised their acceptance and forwarded to the WIPO Center their statements of impartiality and independence. On March 7, 2001, the Complainant and the Respondent were notified of the appointment of the Panel. The Panel finds that the Administrative Panel was properly constituted in accordance with the Rules and the Supplemental Rules.

On March 7, 2001, the WIPO Center forwarded to the Panelists by courier the relevant submissions and the record. These were duly received by them. The Panel was originally to have forwarded its decision by March 21, 2001. However, this date has been extended to March 28, 2001.

The Panel has independently determined and agrees with the assessment of the WIPO Center that the Complaint meets the formal requirements of the Rules for Uniform Domain Name Dispute Resolution Policy as approved by ICANN on October 24, 1999, ("the Rules") and the Supplemental Rules for Uniform Domain Name Dispute Resolution Policy ("the Supplemental Rules").

The language of the administrative proceeding is English, being the language of the registration agreement.

FIFA is the world governing body of the sport of Association Football, commonly known throughout the world as soccer or football. It comprises the National Football Associations of 203 countries. FIFA is the originator and organizer of a number of world and European soccer championships, including, in particular, the WORLD CUP championship. FIFA is the owner of all intellectual property rights in and to the expression "WORLD CUP".

ISL is the exclusive marketing agent for FIFA, charged with the commercial exploitation and protection of FIFA’s intellectual property rights including, in particular, the WORLD CUP trademarks.

FIFA is the legal owner of numerous trademarks worldwide for "WORLD CUP" and variations. Among others, FIFA owns the following trademarks:

International trademark registration No. 487.226 for the verbal mark "WORLD CUP", made on September 10, 1984, for goods falling in international classes: 1, 6, 9, 12, 14, 16, 18, 21, 24, 25, 26, 28, 29, 30, 32, 33, 34, 36, 39, 41 and 42. This trademark covers, amongst others, France (where Respondent is established), Germany, Benelux, Egypt, Spain, Portugal, and Italy;

International trademark registration No. 678511 for the verbal mark "WORLD CUP", made on March 7, 1997, for goods falling in international classes: 3, 4, 6, 8, 9, 11, 12, 14, 16, 18, 20, 21, 24, 25, 26, 28, 29, 30, 32, 33, 36, 38, 39, 40, 41, 42. This trademark covers, amongst others, France (where Respondent is established), Germany, Benelux, China, Egypt, Spain and Poland;

Swiss trademark registration No. 431340 for the verbal mark "WORLD CUP", filed on February 16, 1994, covering goods in the following international classes: 3, 4, 6, 9, 11, 12, 14, 16, 18, 20, 21, 24, 25, 28, 29, 30, 32, 33, 36, 38, 39 and 42;

International trademark registration No. 613159 for the verbal mark "FIFA WORLD CUP", made on October 27, 1993, for goods falling in international classes: 1, 3, 4, 5, 6, 8, 9, 11, 12, 14, 16, 18, 20, 21, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 38, 39, 40, 41 and 42. This trademark also covers, amongst others, France (where Respondent is established), Germany, Benelux, China, Egypt, Spain and Poland;

International trademark registration No. 482138 for the verbal mark "FIFA WORLD CUP" Trophy and Device, made on December 17, 1983, for goods and services in international classes: 6, 14, 25, and 28. This trademark covers, amongst others, France (where Respondent is established), Germany, Benelux, Spain, Italy and Portugal;

In 1998, just before the World Cup France 98 was held, Complainant ISL was involved in a dispute with Respondent regarding its trademarks "WORLD CUP" and "FRANCE 98" which were being used by the Respondent on its website. ISL sued the Respondent before the Tribunal de Grande Instance de Paris on April 22, 1998, for trademark infringement. The case was settled on October 10, 1998. The Respondent agreed to refrain from any use of the mark FRANCE 98, except for selling officially licensed products. The settlement agreement provided that it does not grant the Respondent with any rights to the name "WORLD CUP". Clause III of the Settlement Agreement reads in translation: "This withdrawal by the company ISL Properties does not grant to the company Netplus any ownership right in the denomination "WORLD CUP".

On May 24, 2000, ISL sent a letter by fax and e-mail to Respondent, requesting the transfer of the Domain Name "WORLDCUP.ORG" to FIFA. Respondent never responded to this request.

On September 20, 2000, the Complainants’ representative noticed that the Respondent’s web site had been taken down. Prior to this time, however, both Domain Names referred to the web site.

(a) There can be no doubt that the disputed Domain Names are identical to the "WORLD CUP" trademarks. The relevant part of the Domain Names is in both cases the term "WORLD CUP".

(b) Respondent has no rights or legitimate interests in respect of the Domain Names. Complainant has not licensed or otherwise permitted Respondent to use its trademarks or to apply for or use any domain name incorporating its trademark. Respondent has never been commonly known under the Domain Names, as a legal entity or otherwise, nor has he acquired any trademark or other rights to the Domain Names.

(c) The use made by Respondent of the Domain Names cannot be considered legitimate, because it infringes upon Complainants’ trademark rights and upon the rights of Complainants’ French licensees, who are the only ones licensed in their territory to use Complainants’ trademarks.

(d) The Respondent uses the disputed Domain Names to connect and publish a web page relating to football, which refers to the "World Cup 98", and which exposes the FIFA WORLD CUP Trophy and Device trademark. Respondent never received any license or authorization, explicitly or implicitly, in writing or orally, to use or display these trademarks.

(e) The Respondent is also imitating Complainants’ style by displaying at the bottom of the page an "Our partners’ list.

(f) The Respondent does not have a right nor a legitimate interest in the Domain Names, since its use of the Domain Names is not in connection with a bona fide offering of goods or services.

(g) The following circumstances clearly indicate that Respondent registered and used the Domain Names in bad faith:

(i) When registering the Domain Names, Respondent knew of the trademark ‘WORLD CUP" and the Complainants’ activities because the mark is so famous in France and is promoted by so many and various means;

(ii) The Respondent website was made especially to create the impression to any visitor that it is an official site: use of the terms "Our partners" along the bottom, clearly imitating the ISL/FIFA style of "Official Partners" as well as use of the rectangular logos; prominent display of the ‘WORLD CUP" trophy and device trademark; use of the terms "official products" for Respondent’s on-line shop, etc…when compared to the official website of the France ’98 World Cup;

(iii) Whilst the Complainants do not challenge Respondent’s right to provide alternative information about soccer events, and more particularly about the WORLD CUP, Respondent could have done this without any problem, by using a domain name "adequately reflecting both the object and independent nature of its site, as evidenced today in thousands of domain names." ( Compagnie de Saint Gobain vs. Com-Union Corp, WIPO Case No. D2000-0020).

(iv) Similar behavior was held to constitute bad faith of Respondent in Compagnie de Saint Gobain vs. Com-Union Corp, WIPO Case No. D2000-0020, where the Panelist decided that:

"When registering the Domain Name, Respondent knowingly chose a name which is identical and limited to the trademark of Complainant and which is identical to the domain name registered by Complainant in the .com gTLD. Respondent could have chosen a domain name adequately reflecting both the object and independent nature of its site, as evidenced today in thousands of domain names.

In ISL Marketing AG, and the Union des Associations Europeennes de Football vs. The European Unique Resources Organisation 2000 B.V., (WIPO Case No. D2000-0230), the Panelist considered that:

"Of course, UEFA has not a monopoly of information about the European football Championship. Information on the Euro 2000 event is found in hundreds of different Web sites and is carried by all international media. However, if the primary purpose of Respondent was to provide, in good faith, alternative and unofficial information about the Euro 2000 event, it may have created a Web site under a large variety of domain names, perhaps clearly emphasizing its unofficial and "alternative" nature. The situation, here, is similar to the one decided by a WIPO Panel in Case No. D2000-0034 about the World Cup 2002. While it is perfectly legitimate "to provide alternative news and information about, or even commentary and criticism on a matter of public interest", it is another thing altogether to do it under a domain name strongly suggesting that this information is provided by an entity associated with the organizers of the event (and owner of the corresponding trademarks and service marks).

(v) Respondent refused to transfer the Domain Names for reasonable out of pocket costs, and ignored all attempts made by Complainants to settle the matter amicably, hereby clearly indicating its bad faith.

(vi) By registering the Domain Names, Respondent places Complainant in a situation where Complainant is unable to reflect its trademark "WORLD CUP" in the corresponding domain names. This is especially true since FIFA is a non-commercial organization. Therefore, since the extension ".org" is intended for organizations, many people will type "worldcup.org" in their browser’s address bar and not necessarily "worldcup.com".

(vii) Respondent has proceeded in a pattern of such conduct, since it registered both "WORLDCUP-TV.COM" and ‘WORLDCUP.ORG", thereby focusing on Complainants’ trademarks in registering its domain names.

(viii) The domain name "WORLDCUP-TV.COM" was registered on April 29, 1998, one week after the Respondent was sued by ISL regarding the use of the trademarks WORLDCUP and FRANCE 98 on Respondent’s web site. The parties amicably entered into a settlement agreement on October 11, 1998, providing that the settlement does not confer any rights to the name '‘WORLD CUP" to the Respondent. The litigation in Paris and the settlement agreement did not concern the domain names at issue in this Complaint.

(ix) The secret registration of the domain name ‘WORLDCUP-TV.COM" one week after being sued in court confirms the Respondent’s bad faith. Bad faith also results from not mentioning anything about this or the earlier domain name ‘WORLDCUP.ORG" while negotiating the settlement agreement with ISL.

(x) There is no doubt that by using the Domain Names, Respondent has intentionally attempted to attract, for commercial gain, Internet users to its web site or other on-line location, by creating a likelihood of confusion with Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of its web site or location or of a product or service on its web site or location (paragraph 4, b., (iv) of the Policy), and that Respondent has registered the Domain Names in order to prevent Complainant from reflecting his mark in the corresponding domain name (paragraph 4, b., (ii) of the Policy). The ‘WORLD CUP" trademark and associated marks enjoy unquestionable fame and notoriety. This has been confirmed in two prior decisions, namely ISL Marketing AG, and The Federation Internationale de Football Association vs. J.Y. Chung, Wordcup2002.com, W Co., and Worldcup 2002, (WIPO, Case No. D2000-0034), stating in relevant part that "FIFA’s registered trademark ,WORLD CUP" is widely known, at least in relation to the provision of services and goods related to and associated with the conduct of the quadrennial association football world championship organized by it." and ISL Marketing and Federation Internationale de Football Association vs. Jonathan Nutt, (WIPO, Case No. D2000-0363), according to which "Complainant has a number of registrations in different countries and also international registrations of the marks FIFA and WORLD CUP and FIFA WORLD CUP and variations of those marks.

(a) FIFA has only two trademark registrations able to be opposed in France:

(i) the International trademark N o. 487226; and

(ii) the International trademark N o. 678 511.

No. 487226 "world cup" has been totally refused in Germany, in Slovakia, in the Russian Federation, and in the Czech Republic. It has been partially refused in Spain, Ukraine and Egypt. This trademark does not designate services in class 38, which is the class related to telecommunication and Internet services, i.e. the relevant class as regards the disputed domain names and Respondent’s Internet activity and website.

The French part of this trademark was challenged before a Paris Court as shown in the Complaint.

(b) The Respondent adopts arguments approved by the WIPO Panel in D2000-0034 "ISL Marketing and FIFA vs. J.Y. Chung" viz: "According to the Encyclopedia Britannica CD 98 Standard Edition, there are at least 16 sports in addition to association football which have a World Cup competition. It may be, therefore, that any number of sporting organizations who conduct a competition under the name "World Cup" could argue that they have a right or legitimate interest in respect of domain names containing those words".

(c) At the filing date of the international trademark, the Complainant did not have any trademark right on the wording "World Cup", which is entirely and solely included in the disputed domain names, which exclude any other FIFA’s properties such as the "FIFA" or "CUP design" trademarks. The wording "world cup" has been brought into common language, by a common use since 1938, a common use by another organization and a total lack of defense as trademark through Court actions.

(d) International trademark No. 678511 "world cup" was registered on March 7, 1997, and, for the first time, claims protection for services in class 38, Respondent had registered a domain name "worldcup.fr" prior to this date, on May 6, 1996. Therefore, Respondent acquired rights to the domain name "worldcup" before the date at which FIFA acquired its trademark rights in France, regarding the class 38 services and particularly the Internet activity. Therefore the Complainant has sought to acquire and oppose some trademark rights to the Respondent whereas he knew that this trademark was filed after the Respondent domain name registration date in France for the ".fr" ccTLD. This trademark is then somehow non-opposable to the Respondent, as far as the class 38 services and the wording "world cup" are concerned.

(e) Respondent has rights or legitimate interest in the disputed domain names as follows:

(i) On May 27, 1998, the Respondent was sued before the Tribunal of Paris for having infringed some ISL "world cup" trademarks when registering the domain name "worldcup.fr". Respondent filed a counterclaim in order to have the "worldcup" ISL trademarks cancelled for lack of distinctive character.

(ii) ISL and the Respondent signed an agreement as a result of which the Respondent kept the domain name "worldcup.fr" and only waived from the corresponding website every mention to "France 98".

(iii) ISL has never requested the Respondent to limit, transfer or amend the domain name in dispute, or the corresponding website in that it also referred to the World Cup, whereas ISL’s claim was precisely directed against this domain name and the alleged fraudulent use of the "world cup" trademarks.

(iv) One company (BHO) listed as an "official retailer of licensed products" and worked with the Respondent during the France ’98 world cup, in order to sell and promote, through the Respondent’s website, official licensed products. Thus, ISL wanted to do some business with the Respondent related to the World Cup, but also requested him to avoid reprinting on his website any mention related to "France ‘98" only, which is also a registered trademark of FIFA.

(v) Accordingly, ISL and FIFA "unofficially" authorized the Respondent’s domain name "world cup.fr" and the corresponding website, and have made some profit with it. Otherwise, if ISL never knew that one of the Official licensee made some business with the Respondent, it would never have signed the October 1998, agreement which states that "NETPLUS (the Respondent) has the right to sell and promote the official licensed products from the catalogue "France ‘98" in the same way to that of his current catalogue".

(vi) If ISL had wanted to limit the Respondent’s business to one operation, ISL should have restricted the access to the Respondent website to one single domain name in the 1998 agreement, and should have asked the Respondent to give this domain name back to it, after the competition, but it had not.

Indeed, in page2-II-I it is said that "NET PLUS gives up to using … the wording France 98, notably on his web site identified by the address www.worldcup.fr". ISL thus never asked the Respondent to limit the access to his website to one domain name.

(vii) As a result, the Respondent has legitimately sought to develop his website’s access to non-French residents by registering the two other "worldcup" domain names, currently in dispute before this Panel.

(f) The domain names have been registered and are being used in good faith because:

(i) No sale price was mentioned in the Communication in which the domain names were offered for sale, and it is not established that the Respondent acquired the disputed domain names primarily for the purpose of selling them to the Complainant.

(ii) The Respondent’s website has always indicated that it is a "Non Official website, in force since 1996.

(iii) The press media has published numerous articles about the Respondent’s website and corresponding activity, which recognize that the Respondent’s website is unofficial, of good quality and non-conforming.

(iv) The Complainant has filed the instant complaint three years and 10 months after the reservation of the Respondent’s domain name "worldcup.org" and two years and 8 months after the reservation of the Respondent’s domain name "worldcup-tv.com".

(v) The respondent has not warehoused a large number of domain names using the word "world cup".

(vi) The Respondent has not therefore sought to mislead the public or create any likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation or endorsement of his website and has used the disputed domain names in good faith.

Paragraph 15(a) of the Rules instructs the 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".

The burden for the Complainant, under paragraph 4(a) of the ICANN Policy, is to show:

- That the domain name registered by the Respondent is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and

- That the Respondent has no legitimate interests in respect of the domain name; and

- The domain name has been registered and used in bad faith.

In the opinion of the Panel, the domain names registered by the Respondent are in the case of "worldcup.org" identical and in the case of "worldcup-tv.com" confusingly similar to the Complainant’s marks "world cup". It is irrelevant, as Respondent suggests, that the mark is not registered in a particular class or that one out of several international marks may not have an earlier date than the domain name registrations. Nor is it relevant that registration of the marks may have been refused in some countries.

The Policy’s only requirement is that the Complainant should possess rights in a mark, which is identical or confusingly similar to the disputed names. There is no mention in the Policy of goods and services to which the marks may relate.

The Complainant must show that the Respondent has no rights or legitimate interests in respect of the dispute domain name. The Respondent does not assume the burden of proof, but may establish a right or legitimate interest in a disputed domain name by demonstrating in accordance with paragraph 4(c) of the Policy:

(a) He has made preparations to use the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services prior to the dispute;

(b) He is commonly known by the domain name, even if he has not acquired any trademark rights; or

(c) He intends to make a legitimate, non-commercial or fair use of the domain name without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark.

The Panel considers that the Complainant has discharged the onus of proof for this criterion. In the Panel’s view the crucial point is the final sentence of Clause III of the agreement dated October 10, 1998, which settled litigation between the Parties. An English translation is: "This withdrawal (by the company) by ISL Properties does not grant to the company Netplus any ownership right in the denomination WORLD CUP". This clause does not apply solely to the domain name "worldcup.fr" so must have referred to other domain names. Nor do the actions of an official retailer of licensed products have any relevance.

Paragraph 4(b) of the ICANN Policy states:

"For the purposes of paragraph 4(a)(iii), the following circumstances, in particular but without limitation, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith:

(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 the complainant who 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 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 or service on your web site or location."

It should be noted that the circumstances of bad faith are not limited to the above.

The Panel considers that the Respondent has registered and used the domain name "worldcup.org" and "worldcup-tv.com" in "bad faith" for the following reasons:

(a) The Respondent clearly knew at the time it registered the disputed domain names of the Complainant’s interest in the expression "worldcup".

(b) The Respondent’s website "worldcup.org" appears to be a mirror image of its legitimate website "worldcup.fr".

(c) As noted by other WIPO Panelists, (e.g. D2000-020), knowingly to choose a domain name consisting solely of the Complainant’s trademark creates a situation at odds with the legal rights and obligations of the parties. Whilst it is legitimate to provide on a website information about a matter of such intense public interest as the World Cup, it is not legitimate to do so under a domain name suggesting that this information is provided by an entity associated with the organizers of the event and/or the owners of the trademarks.

(d) It is too much of a coincidence that one of the disputed names was registered only a week after the Complainants had initiated action against the Respondent in the French Court.

(e) Although the term "World Cup" is used for other sports, the Respondent has no connection with any of these other sports. It confines its information to Soccer. The Panel takes judicial notice that the term "World Cup" could be taken to refer to Soccer by the vast majority of the population of Europe and Latin America, if not elsewhere.

(f) The casual user of the internet could be led to believe that there was some connection between the owner of the website and the World Cup organization, despite the statement about a "non-official" website which is so insignificant as not to be easily visible to or ready by most visitors to the site.

(g) There is no limitation period in the Policy. Therefore any delay by the Complainant in filing an application under the Policy is not relevant in this case. Delay could be relevant in some circumstances where a respondent had innocently been using a domain name for a lengthy period. Such use could bolster a claim under paragraph 4(c) of the Policy. Here, the situation is that the Respondent knew for the whole of the period since registration of the Complainants’ interest in the name "World Cup".

For the foregoing reasons, the Panel decides:

(a) That the domain names registered by the Respondent are identical or confusingly similar to the trademark to which the Complainants have rights;

(b) That the Respondent has no rights or legitimate interests in respect of the domain name; and

(c) The Respondent’s domain names have been registered and are being used in bad faith.

Accordingly, pursuant to paragraph 4(i) of the Policy, the Panel requires that the registration of the domain names "worldcup.org" and "worldcup-tv.com" be transferred to the Complainant.

Hon. Sir Ian Barker QC
Presiding Panelist

Dr. Luca Barbero
Panelist

Mr. David Heathcote Tatham
Panelist

Dated: March 26, 2001