WIPO Arbitration and Mediation Center

ADMINISTRATIVE PANEL DECISION

Guccio Gucci S.p.A. v. Zhiyuan Zou, Zouzhi Zhou , Fujian Anfu

Case No. D2012-0888

1. The Parties

The Complainant is Guccio Gucci S.p.A. of Florence, Italy represented by Studio Barbero, Italy.

The Respondents are Zhiyuan Zou, Zouzhi Zhou, and Fujian Anfu of China.

2. The Domain Names and Registrar

2.1 The disputed domain names <cheapguccionsale.com>, <cheapguccishoes-us.com>, <discountguccioutlet.org>, <guccibagsoutletonline.com>, <guccibagssalecheap.com>, <guccibagssalegucci.com>, <guccihandbagscheap.org>, <guccioutletdiscount.com>, <guccisalebyme.com>, <replicaguccibagssale.com>, <thecheapguccishoes.com>, <usagaccioutlet.com> (the “Domain Names”) are registered with GoDaddy.com, LLC (the “Registrar”).

3. Procedural History

3.1 The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 26, 2012. On April 26, 2012, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Names. On April 26, 2012, the Registrar transmitted by email to the Center its verification response confirming that the Respondents are listed as the registrant(s) and providing the contact details.

3.2 The Center verified that the Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”).

3.3 In accordance with the Rules, paragraphs 2(a) and 4(a), the Center formally notified the Respondent(s) of the Complaint, and the proceedings commenced on May 1, 2012. In accordance with the Rules, paragraph 5(a), the due date for Response was May 21, 2012. The Respondent(s) did not submit any response. Accordingly, the Center notified the Respondent’s default on May 22, 2012.

3.4 The Center appointed Matthew S. Harris as the sole panelist in this matter on May 25, 2012. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7.

4. Factual Background

4.1 The Complainant is an Italian public limited company and is part of the Gucci group of companies. The Gucci fashion house was founded in 1921 and since then has become one of the worlds leading manufacturers of fashion products.

4.2 The Complainant is the owner of a large number of trade marks around the world that comprise or incorporate the term GUCCI. They include:

(i) Community Trade Mark no. 121988 filed on April 1, 1996 for the word mark GUCCI in each of classes 1 to 42; and

(ii) Six Chinese Trade Marks no. 177030 to 177035 with a registration date of May 15, 1983 for the word mark GUCCI in classes 6, 3, 18, 25, 14, 34

4.3 The Complainant is also the owner of over five hundred domain names that incorporate the term “gucci”.

4.4 A table setting out the registration dates, current registrant and other details taken from the WhoIs Records for the Domain Names is at Annex A to this Decision. Of the twelve Domain Names, ten were registered on the same day; i.e., July 26, 2011 (the “July Domains”). All of these domain names are currently registered in the name of “zhiyuan zou”, for whom an address is provided in Fuijan province China. Of the remaining two domain names, <cheapguccishoes-us.com> was registered on September 29, 2011 (the “September Domain”) and is currently registered in the name of “zouzhi zhou”. However, the address for the registrant of that Domain Name contains the same province and post code details as the July Domains.

4.5 The remaining Domain Name <usagaccioutlet.com> was registered on November 4, 2011 (the “November Domain”). The current registrant is named as “Fuijan” and gives an address in China. The administrative and technical contacts details for this Domain Name appear to be a meaningless jumble of letters.

4.6 The Registrar for all of the Domain Names is the same. The Domain Servers for all of the Domain Names are also identical; i.e., F1G1NS1.DNSPOD.NET, and F1G1NS2.DNSPOD.NET.

4.7 In its Registrar response to the Center, the Registrar informed that the Domain Names were “registered to this registrant on “7/26/2011, 9/29/2011, 11/5/2011”. Presumably (although this is not yet entirely clear) the first date refers to the July Domains, the second to the September Domain and the third to the November Domain.

4.8 As at (or shortly prior to) the filing of the Complaint the Domain Names were used for websites purporting to sell Gucci products. Each of these websites are very similar if not identical in content, sharing photographs, branding and text. The overall impression of these sites is of a “Gucci online store”, with the Gucci name appearing at the top of the home page, and with various links leading to separate “Home”, “New Products”, “Specials”, “Features Products”, “My Account” and “View Cart2 pages.

4.9 The websites are in English, although the language would appear to have been written by a non-native English speaker. For example, the “contact_us” page of the website operating from the <usagaccioutlet.com> includes the following text:

“Your trustful choice and degree of satisfaction are our best presents. We will insist on devoting ourselves to establishing a topping and comfortable online shopping surrounding for all the customers. If you have any questions or suggests, do not hesitate to contact us via e-mail.”

4.11 In the case of at least one of the goods on offer, they are described as “Gucci handbags replica”.

4.12 The website operating from the Domain Name <usagaccioutlet.com> continues to operate as at the date of this decision. The Domain Name <guccioutletdiscount.com> also redirects to that website. None of the other websites are operational at this time.

5. Parties’ Contentions

A. Complainant

5.1 The Complaint recognises that prima facie there appear to be three different registrants for the Domain Names. Accordingly, the Complaint includes a “request for consolidation of multiple registrant and domain names.” It refers to numerous cases decided under the Policy that are said to be authority for the proposition that a case can proceed against multiple registrants where there are “circumstances indicating that a single person or entity has registered multiple domain names using fictitious names”.

5.2 So far as the facts of this case are concerned, the Complainant refers to the fact that ten of the twelve Domain Names are registered in the name of “Zhiyuan Zhou” (i.e., the July Domains). It also contends:

(i) that (a) one of the July Domain Names (i.e., <thecheapguccishoes.com>) redirects to the website operating from the <cheapguiccishoes-us.com> Domain Name registered in the name of zouzhi zhou (i.e., the September Domain); and (b) the website operating from the September Domain provides a contact email address that incorporates one of the July Domain (i.e., <thecheapguccishoes.com>); and

(ii) that (a) another one of the July Domains (i.e., <guccioutletdiscount.com>) redirects to the website operating from the <usagaccioutlet.com> Domain Name registered in the name of fujan (i.e., the November Domain) (b) the website operating from the November Domain provides a contact email address that incorporates one of the July Domains (i.e., <guccioutletdiscount.com>).

5.3 The Complainant also states that in the case of the September Domain and the November Domain, it arranged for someone to register with the website stores operating from those Domain Names as well as one of the July Domains. Each resulted in an email reply containing identical text save that they provided a contact email address corresponding to the relevant Domain Name.

5.4 From these facts the Complainant asserts that “it can be inferred that the Registrants of all the disputed Domain Names are either a single person or entity which has registered multiple domain names using different possibly fictitious names, or reflective of a small group of individuals acting in concert”.

5.5 It also relies upon the fact that the Domain Names are registered with the same domain name servers and through the same Registrar and the fact that each of the Domain Names incorporates the Complainant’s GUCCI mark in combination with similarly descriptive text.

5.6 So far as the requirements of the Policy are concerned, the Complainant relies upon its GUCCI registered trade marks and contends that it is a “well-established principle that domain names that wholly incorporate a trade[ ]mark, in particular one as famous as GUCCI, are found to be confusingly similar for the purposes of the Policy, despite the fact that the disputed Domain Names may also contain a descriptive or generic term”. It also contends this to be so “regardless of the other terms in the domain name”, this is also said to be so where the domain name incorporates a “confusingly similar approximation”, referring in this respect to the November Domain Name, <usagaccioutlet.com>.

5.7 The Complainant contends that the Respondent is not a licensee, authorized agent of the Complainant, or in any other way authorised to use the Complainant’s GUCCI mark. It denies that the Domain Names are being used in connection with any bona fide offering of goods or services, claiming that the websites operating from the Domain Names prima facie offer counterfeit products.

5.8 It further contends that it is inconceivable that the Respondent was not aware of the Complainant’s trade mark rights at the time of the registration of the Domain Names and that the use in relation to counterfeit goods falls within the scope of paragraph 4(b)(iv) of the Policy which provides an example of circumstances indicating bad faith use. The sale of counterfeit goods is said to show that the Domain Names have been registered and used with the purpose of disrupting the Complainant’s business within the scope of paragraph 4(b)(iii) of the Policy.

5.9 The Complainant finally contends that the registrations themselves indicate that the Complainant has registered the Domain Names (or at least the September Domain and the November Domain) in using false contact information and that this of itself provides a further indication of bad faith.

B. Respondent

5.10 The Respondents did not reply to the Complainant’s contentions.

6. Discussion and Findings

6.1 There are no exceptional circumstances within paragraph 5(e) of the Rules so as to prevent this Panel from determining the dispute based upon the Complaint, notwithstanding the failure of any Respondent to lodge a Response.

6.2 Notwithstanding that default, it remains incumbent on the Complainant to make out its case in all respects under the Rules as set out in paragraph 4(a) of the Policy. Namely the Complainant must prove that:

(i) the Domain Names are identical or confusingly similar to a trade mark or service mark in which the Complainant has rights (paragraph 4(a)(i)); and

(ii) the Respondent has no rights or legitimate interests in respect of the Domain Names (paragraph 4(a)(ii)); and

(iii) the Domain Names have been registered and are being used in bad faith (paragraph 4(a)(iii)).

6.3 However, under paragraph 14 of the Rules, where a party does not comply with any provision of the Rules, the Panel shall “draw such inferences therefrom as it considers appropriate”.

6.4 The Panel will address each of these requirements of the Policy in turn, but before it does so it is necessary to deal with the Complainant’s request that there be “consolidation” of its complaints in respect of domain names registered in the name of more than one person or entity.

A. Request for “Consolidation”

6.5 The Complainant refers to a large number of cases under the Policy which, it correctly records, allowed a single set of proceedings to continue in respect of domain names nominally at least registered in more than one name where the panel was satisfied that the domain names were under common control.

6.6 The position is addressed in the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Second Edition (“WIPO Overview 2.0”), which at paragraph 4.16 states as follows:

“WIPO panels have articulated principles governing the question of whether a complaint filed with WIPO by multiple complainants may be brought against (one or more) respondents. These criteria encompass situations in which (i) the complainants either have a specific common grievance against the respondent, or the respondent has engaged in common conduct that has affected the complainants' individual rights in a similar fashion; (ii) it would be equitable and procedurally efficient to permit the consolidation; or in the case of complaints brought (whether or not filed by multiple complainants) against more than one respondent, where (i) the domain names or the websites to which they resolve are subject to common control, and (ii) the consolidation would be fair and equitable to all parties.

In order for the filing of a single complaint brought by multiple complainants or against multiple respondents which meets the above criteria to be accepted, such complaint would typically need to be accompanied by a request for consolidation which establishes that the relevant criteria have been met. The onus of establishing this falls on the filing party/parties, and where the relevant criteria have not been met, the complaint in its filed form would not be accepted.”

6.7 The issue of bringing proceedings against multiple respondents was also addressed by this Panel in Accor v. Jose Garcia, Jan Cerny, N/A, Dopici Nasrat, WIPO Case No. D2010-0471. In that case it was stated:

“4.2 The starting point is that normally it is not possible to commence a single UDRP proceeding in relation to domain names registered in the name of more than one person. Paragraph 3(c) of the Rules state that ‘The complaint may relate to more than one domain name, provided that the domain names are registered by the same domain-name holder’, and although this is permissive rather than a proscriptive provision, the intent of the drafters of the Rules seems reasonably clear. So in a case where a complaint is filed against multiple unconnected respondents, a panel may continue that case against one of the respondents and dismiss it against the others (see for example The Cartoon Network LP, LLLP v. Mike Morgan, WIPO Case No. D2005-1132).

4.3 However, in considering whether there are multiple respondents, what is important is the identity of the registrants at the date that the complaint became ‘pending’. […]

4.4 Further, if a panel considers that notwithstanding any change in registration details the relevant domain names are in fact controlled by the same person or persons, the proceedings can still continue (see, for example, General Electric Company v. Marketing Total S.A, WIPO Case No. D2007-1834 and Western Union Holdings, Inc. v. Private Whois Escrow Domains Private Limited / Comdot Internet Services PVT. LTD., Laksh Internet Solutions Private Limited., Pluto Domain Services Private LTD., Compsys Domain Solutions Private Limited, [ WIPO Case No. D2008-1675]’.”

6.8 Given the wording of WIPO Overview 2.0, the Complainant unsurprisingly puts its case as one of “consolidation”. This Panel would suggest that this may not necessarily be the best terminology to use in such a case. The term “consolidation” is used in paragraph 4(f) of the Policy to refer to multiple distinct disputes, and when read in conjunction with paragraph 4(d) of the Policy, it seems reasonably clear that the situation envisaged by this paragraph of the Policy is a request to consolidate what are or may otherwise be separately commenced proceedings. The situation in part envisaged by paragraph 4.16 of the WIPO Overview 2.0 and faced in the present case is not so much a consolidation of separate proceedings, but whether a single set of proceedings commenced against prima facie more than one respondent can continue in light of the wording of paragraph 3(c) of the Rules.

6.9 Nevertheless, regardless of the terminology used, the Complainant’s case when it comes to allowing a single set of proceedings to continue in relation to all of the Domain Names is compelling. So far as the July Domains are concerned, which comprise ten out of the twelve Domain Names in these proceedings, no question arises of the proceedings not being allowed to continue. They have all been commenced against a single named respondent.

6.10 The question only arises in relation to the September Domain and the November Domain that have prima facie been registered in different names. In the case of the September Domain, the address provided for the Registrant, as well as the Technical and Administrative contacts is in large part the same as that provided in relation to the July Domains. Further, there is the fact that the content and form of the websites operating from the September Domain and the November Domain suggests that they are being operated by the same person or persons who is or are operating the website operating from the July Domains. Next there is the fact that the websites operating from the September Domain and the November Domain incorporate email addresses incorporating one of the July Domains. Then there is the Complainant’s evidence that those registering at the “store” operating from the July Domains, the September Domain and the November Domain, received a virtually identical email from the operators of those websites on registration.

6.11 In short, the Panel is persuaded by the Complainant’s evidence and arguments that all the Domain Names are under the control of a single person or entity and that it is therefore appropriate for these proceedings to continue in respect of all of the Domain Names. So far as the rest of this Decision refers to the “Respondent”, this is intended as a reference to that single person or entity.

B. Identical or Confusingly Similar

6.12 Eleven of the twelve Domain Names can only sensibly be read as comprising the Complainant’s GUCCI mark in its entirety together with various other English words that primarily either describe certain types of products (such as “bags” or “shoes”) and/or which are suggestive of the price at which the products are being sold (such as “sale”, “discount” or “cheap”). The only Domain Name that does not quite follow that pattern is <usagaccioutlet.com>. It is not easy to give a sensible reading to that combination of letters, but the Panel accepts that a sensible (if not the most sensible) reading is as the terms “usa”, “gacci” and “outlet” in combination. When read this way the term “gacci” appears to be a misspelling of the Complainant’s GUCCI mark.

6.13 The Complainant refers to a large number of decisions under the UDRP on the question of confusing similarity. The test for confusing similarity is also addressed in paragraph 1.2 of the WIPO Overview 2.0 which states:

“The first element of the UDRP serves essentially as a standing requirement. The threshold test for confusing similarity under the UDRP involves a comparison between the trademark and the domain name itself to determine likelihood of Internet user confusion. In order to satisfy this test, the relevant trademark would generally need to be recognizable as such within the domain name, with the addition of common, dictionary, descriptive, or negative terms [regarding the latter see further paragraph 1.3 below] typically being regarded as insufficient to prevent threshold Internet user confusion. Application of the confusing similarity test under the UDRP would typically involve a straightforward visual or aural comparison of the trademark with the alphanumeric string in the domain name. While each case must be judged on its own merits, circumstances in which a trademark may not be recognizable as such within a domain name may include where the relied-upon mark corresponds to a common term or phrase, itself contained or subsumed within another common term or phrase in the domain name (e.g. trademark HEAT within domain name theatre.com)”

6.14 One of the relevant cases then cited in the Overview is this Panel’s decision in Research in Motion Limited v. One Star Global LLC, WIPO Case No. D2009-0227. In that decision it was stated as follows:

“6.6 It is necessary to recognise that the term of confusing similarity is a low threshold test the purpose of which is effectively to assess whether a complainant has sufficient rights so as to give it standing to bring a complaint (see, for example, Aubert International SAS and Aubert France SA v. Tucows.com Co., WIPO Case No. D2008-1986). It involves a simple comparison of the mark relied upon with the domain name in issue. The geographical location of that mark is not important and normally neither is the degree of fame or reputation that a registered mark has achieved. Similarly, reference to local case law on confusing similarity or likelihood of confusion, is also unlikely to be that helpful.

6.7 It is against this ‘standing’ requirement that the word ‘confusing’ is to be understood. So for example, even in cases where the domain name in issue takes the form of a trade mark combined with the pejorative term such as ‘sucks’, there is still likely to be confusing similarity (see for example, Sermo, Inc. v. CatalystMD, LLC, WIPO Case No. D2008-0647). There are cases where a domain name combining the term ‘sucks’ with a mark has not been held to be confusingly similar to that mark where the domain name has been used for a criticism site (see the case[s] listed in The Royal Bank of Scotland Group plc, National Westminster Bank plc A/K/A NatWest Bank v. Personal and Pedro Lopez, WIPO Case No. D2003-0166), but the Panel would suggest that the real rationale of those cases may rather be found in an assessment of whether the operation of a criticism site from such a domain name provides rights or legitimate interests and/or is in bad faith.

6.8 This low threshold approach in cases where the pejorative or the alleged distinguishing term is incorporated in a Domain Name is sometimes said to be justified by the fact that the domain name might be seen by persons who are not familiar with the language from which the additional word is taken. It is claimed that such persons will be confused by the mark element of the domain name and that this confusion will not be dispelled by the additional word or words in the domain name. There may be some force in this argument, but regardless of its exact justification, the advantages of the low threshold approach are clear. Take for example, a company that registers the domain name <[name of competitor]sucks.com> for a website that does nothing more than sell its own goods. In the opinion of this Panel the question of whether or not such use should be allowed is best addressed in the context of an assessment of rights or legitimate interests and bad faith. To interpret paragraph 4(a)(i) as setting a low threshold test permits this to happen.

6.9 It is also an approach that means that in most cases where a domain name incorporates the entirety of a trade mark, then the domain name will for the purposes of the Policy be confusingly similar to the mark. The Complainant has cited a number of cases that are said to support that proposition. However, this Panel would prefer not to endorse this as a hard and fast rule. Are the domain names <theatre.com> or (to adopt American spelling) <theater.com> really confusingly similar to a mark for the word “heat”? Each case must be judged on its own facts, and the assessment will always depend on the specific mark and the specific domain name.”

6.15 In the circumstances, it is clear that each of the eleven Domain Names that incorporate the Complainant’s GUCCI trade mark in its entirety are confusingly similar (as that term is understood by the Policy) to the Complainant’s marks. None of the additional text in any of the Domain Names so detracts from the mark element that it would prevent such a finding. This is so even in the case of the Domain Name that incorporates the term “replica”, even if (as is the case with “sucks” domain names) that addition signals to some Internet users that this might not be a domain name that the Complainant would ordinarily control.

6.16 Further, in the case of the remaining <usagaccioutlet.com> Domain Name, the fact that a plausible (and perhaps the most plausible) reading of the Domain Name is one that contains a misspelling of the GUCCI mark, is also sufficient to justify a finding of confusing similarity. In this respect, the Panel takes into account that it is clear from the content of the website operating from the Domain Name that the registrant of the Domain Name intended the Domain Name to be read in that way. As was stated in RapidShare AG and Christian Schmid v. majeed randi, WIPO Case No. D2010-1089:

“6.9 In short, an obvious inference from this content is that the Respondent intended the Domain Name to be understood as alluding to the Complainants’ mark. Of course, the test of “confusing similarity” is an objective one and not one of the Respondent’s subjective intent. But that does not mean that in an appropriate case evidence of what a Respondent’s subjectively intended cannot be evidence of how the mark is objectively understood.

6.10 The Panel is not in any way suggesting that the general rule recorded in paragraph 1.2 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions that ‘the content of a website (whether it is similar or different to the business of a trademark owner) is irrelevant in the finding of confusing similarity’ is wrong. The test is not of similarity between businesses or websites. It involves a comparison between mark and domain name only. However, that does not mean that the content of the website cannot in some cases provide a pointer as to how Internet users will perceive a domain name that in turn might inform the relevant comparison.”

6.17 In summary, the Complainant has made out the requirements of paragraph 4(a)(i) of the Policy in relation to all twelve of the Domain Names.

C. Rights or Legitimate Interests

6.18 There is also no suggestion that the Respondent is the owner of any registered right in the term GUCCI and the Complainant contends that the Respondent has not been authorised to use the GUCCI term in any domain name or for the purposes of operating of websites that purport to sell GUCCI products. It also refers to certain cases which are said to be authority for the proposition that where a complainant has put forward prima facie evidence of a lack of rights or legitimate interests the burden of proof on this issue passes to the respondent.

6.19 However, ultimately the Complainant’s case is far more straightforward. It contends that the Domain Names were all registered and have been used to further a business in the sale of counterfeit products of the Complainant. As is discussed in greater detail under the heading of bad faith below, the Panel accepts that this is factually correct. It also accepts that the sales of counterfeit goods from a domain name that incorporates the mark used for genuine goods to which the counterfeits correspond, does not provide a legitimate interest in that domain name. Indeed, the Panel would go further and say that such use of the trade mark of another in the domain name comprises positive evidence that a right or legitimate interest in the domain name could not exist.

6.20 In the circumstances the Complainant has made out the requirements of paragraph 4(a)(ii) of the Policy.

6.21 The Panel also adds that even had the Panel not been satisfied that the Domain Names were being used to promote and sell counterfeit goods, it is likely that the Panel would have still have found that the Respondent had no right or legitimate interest in these domains. Even if the Respondent was engaged in the sale of genuine goods of the Complainant, this is a case where the Respondent would have had to at least satisfy the conditions of the Oki Data Americas, Inc. v. ASD, Inc., WIPO Case No. D2001-0903. Not only was no Oki Data argument put forward by the Respondent, but given the content of the websites operating from the Domain Names it seems unlikely that the Respondent could satisfy the relevant conditions. Further, even had the Respondent been able to satisfy the Oki Data conditions, for the reasons given by this Panel in paragraphs 6.18 and 6.19 of the Research in Motion Limited case supra it is still questionable whether this would provide a legitimate interest. However, it is not necessary to consider these issues any further in this case.

D. Registered and Used in Bad Faith

6.22 The Complainant contends that the Domain Names in this case have all been registered pursuant to a single scheme in order to offer counterfeit Gucci products to the public. The Panel accepts that this is so.

6.23 Ten of the Domain Names were registered on the same day and have been used in connection with very similar if not identical websites. As has already been described in this Decision, shortly thereafter the remaining two Domain Names were also registered for use with further similar if not identical websites. Given the fame and distinctiveness of the GUCCI mark the only credible explanation of those registrations is that they were registered with the Complainant’s mark in mind. On the websites operating from those Domain Names goods are sold as Gucci products and the only sensible reading of those websites is that the Respondent is offering products that are the same as or which imitate the Complainant’s products. For example, similar pictures of the “Gucci Jackie bag” appear on the Complainant’s own website and on the website operating from the <guccibagsoutletonline.com> Domain Name.

6.24 Further, the fact that the products on sale are more likely than not to be counterfeit products is clear from the reference on some of the websites (and in the text of one of the Domain Names) to the products for sale being “replica” products. The Complainant also points to differences in price between the products on sale on the Respondent’s websites and genuine products. The Panel accepts that this is supportive of the Complainant’s case in the absence of any evidence or argument to the contrary.

6.25 The Complainant contends that such activities fall within the scope of paragraph 4(b)(iii) and 4(b)(iv) of the Policy. This is probably so, but regardless of whether such activities fall within the scope of either or both of these examples of circumstances indicating bad faith, the registration and use of domain names for the purpose of the sale of counterfeit products are themselves clear and obviously examples of bad faith registration and use.

6.26 The Panel also accepts that the Respondent has provided false registration details and that this supports a finding of bad faith. It accepts in the absence of evidence or arguments to the contrary the Complainant’s contention that the address provided in relation to the July Domains is false, but the point is made most compellingly in the case of the November Domain where many of the entries comprise a meaningless jumble of letters.

6.27 In the circumstances, the Complainant has made out the requirements of paragraph 4(a)(iii) of the Policy.

7. Decision

7.1 For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that each of the following Domain Names, be transferred to the Complainant.

<cheapguccionsale.com> <guccibagsoutletonline.com>

<guccibagssalecheap.com> <guccibagssalegucci.com>

<guccihandbagscheap.org> <guccioutletdiscount.com>

<guccisalebyme.com> <replicaguccibagssale.com>

<thecheapguccishoes.com> <discountguccioutlet.org>

<cheapguccishoes-us.com> <usagaccioutlet.com>

Matthew S. Harris
Sole Panelist
Dated: June 7, 2012

ANNEX A