WIPO Arbitration and Mediation Center

ADMINISTRATIVE PANEL DECISION

Facebook Inc. v. Registration Private, Domains By Proxy, LLC / Rochelle Burrell

Case No. D2021-1810

1. The Parties

Complainants are Facebook, Inc., United States of America (“United States”) and Instagram, LLC, United States (together, the “Complainant”), represented by Hogan Lovells (Paris) LLP, France.

Respondent is Registration Private, Domains By Proxy, LLC, United States / Rochelle Burrell, United States

2. The Domain Names and Registrar

The disputed domain names <facebookliveadulttoys.com>, <facebookliveappliance.com>, <facebookliveautoinsurane.com>, <facebooklivebasketball.com>, <facebooklivebedding.com>, <facebookliveboots.com>, <facebookliveboxing.com>, <facebookliveburgers.com>, <facebooklivecandy.com>, <facebooklivecaps.com>, <facebooklivecarsforsale.com>, <facebooklivecellphones.com>, <facebooklivechocolate.com>, <facebooklivechocolateforsale.com>, <facebooklivechristmas.com>,<facebooklivechristmasdecor.com>, <facebookliveclothing.com>, <facebooklivecoffee.com>, <facebooklivecomputers.com>, <facebooklivediamonds.com>, <facebooklivedining.com>, <facebooklivedishes.com>, <facebooklivedresses.com>, <facebookliveelectrician.com>, <facebookliveexperiences.com>, <facebooklivefirsttimehomebuyer.com>, <facebooklivefishing.com>, <facebookliveflatware.com>, <facebooklivefootball.com>, <facebooklivegaming.com>, <facebooklivegamingconsoles.com>, <facebooklivegold.com>, <facebooklivehamburgers.com>, <facebooklivehardmoneylender.com>, <facebookliveheatingandairconditioning.com>, <facebooklivehomeloans.com>, <facebooklivehomesforsale.com>, <facebooklivehometour.com>, <facebooklivehvac.com>, <facebookliveicecream.com>, <facebooklivejerseys.com>, <facebooklivejewelry.com>, <facebooklivekentuckyderby.com>, <facebooklivelaptops.com>, <facebooklivelender.com>, <facebooklivelingerie.com>, <facebooklivelosangeleslakers.com>, <facebooklivemarchmadness.com>, <facebooklivemardigras.com>, <facebooklivemarijuana.com>, <facebooklivemask.com>, <facebooklivemensclothing.com>, <facebooklivemlb.com>, <facebooklivemortgagelender.com>, <facebooklivemortgagerates.com>, <facebooklivemortgages.com>, <facebooklivemovies.com>, <facebooklivemovietickets.com>, <facebooklivenba.com>, <facebooklivenbafinals.com>, <facebooklivenevadaraiders.com>, <facebooklivenevadaraidersrs.com>, <facebooklivenewhometours.com>, <facebooklivenewyearseve.com>, <facebooklivenfl.com>, <facebookliveofficialfanwear.com>, facebookliveolympics.com>, <facebookliveopenhouse.com>, <facebookliveplumber.com>, <facebooklivepurses.com>, <facebookliverealtor.com>, <facebookliverefinancemortgage.com>, <facebookliverosebowl.com>, <facebookliveseasontickets.com>, <facebooklivesextoys.com>, <facebookliveshoes.com>, <facebooklivespirits.com>, <facebooklivestadiumtickets.com>, <facebooklivestanleycup.com>, <facebooklivesuperbowl.com>, <facebooklivetablets.com>, <facebooklivetableware.com>, <facebooklivethecuddly.com>, <facebooklivethemasters.com>, <facebookliveticketsales.com>, <facebooklivetickets.com>, <facebookliveundergarments.com>, <facebooklivewine.com>, <facebooklivewomensclothing.com>, <facebookliveworldcup.com>, <facebookliveworldseries.com>, <facebooklivezonemask.com>, <instagramadulttoys.com>, <instagramcandy.com>, <instagramchristmasdeor.com>, <instagramdallascowboys.com>, <instagramgold.com>, <instagramicecream.com>, <instagramlosangeleslakers.com>, <instagrammarijuana.com>, <instagrammovietickets.com>, <instagramnevadaraiders.com>, <instagramseasontickets.com>, <instagramsextoys.com>, <instagramstadiumtickets.com> are registered with Wild West Domains, LLC (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 8, 2021. On June 9, 2021, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On June 9, 2021, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to Complainant on June 18, 2021 providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on June 18, 2021.

The Center verified that the Complaint together with the amended 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”).

In accordance with the Rules, paragraphs 2 and 4, the Center formally notified Respondent of the Complaint, and the proceedings commenced on June 25, 2021. In accordance with the Rules, paragraph 5, the due date for Response was July 15, 2021. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on July 16, 2021.

The Center appointed Brian J. Winterfeldt as the sole panelist in this matter on August 3, 2021. 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

Complainant Facebook, Inc. (“Facebook”) is a leading online social media and social networking service that has been in operation since 2004. As of December 2020, Facebook has approximately 2.8 billion monthly and 1.84 billion daily active users worldwide. Its main website, “www.facebook.com”, is ranked as the 7th most visited website in the world and its services are provided in over 70 languages. Facebook also operates on mobile devices. In 2015, Facebook launched its “Facebook Live” livestreaming service.

Facebook owns numerous trademarks in various global jurisdictions for its FACEBOOK trademark, some examples of which are as follows:

- United States Trademark Registration No. 3041791, FACEBOOK, registered January 10, 2006.
- European Union Trade Mark No. 002483857, FACEBOOK, registered June 13, 2003.
- International Registration No. 1280043, FACEBOOK, registered December 23, 2014.

Complainant Instagram, LLC (“Instagram”), which is a wholly-owned subsidiary of Facebook, is an online photo- and video-sharing social networking platform. Instagram has operated since 2010 and currently has over 1 billion active monthly users. Its website, “www.instagram.com”, is currently the 24th most visited website in the world, and Instagram is also available on mobile apps.

Instagram also owns numerous trademarks in various global jurisdictions for its INSTAGRAM trademark, some examples of which are as follows:

- United States Trademark No. 4146057, INSTAGRAM, registered May 22, 2012 (first use in commerce on October 6, 2010);
- European Union Trade Mark No.014493886, INSTAGRAM, registered December 24, 2015;
- International Registration No. 1129314, INSTAGRAM, registered March 15, 2012,

Complainant operates exclusively online due to the nature of its business, and has registered numerous domain names in both generic Top-Level Domains (“gTLDs”) and country code Top-Level Domains (“ccTLDs”) incorporating its FACEBOOK and INSTAGRAM trademarks. Complainant also has an extensive online presence across a variety of social media platforms, at the following websites:

- “www.facebook.com/facebook”
- “www.twitter.com/facebook”
- “www.youtube.com/facebook”
- “www.linkedin.com/company/facebook”
- “www.instagram.com/instagram”
- “www.facebook.com/instagram”
- “www.twitter.com/instagram”
- “www.linkedin.com/company/instagram”

The disputed domain names have the following registration dates:

At the time of the filing of the Complaint, all of the disputed domain names redirected to the “Domains Priced Right” home page. The disputed domain names all now direct to parked pages that provide advertising links and a link to a domain broker that is part of the same corporate group as the Registrar.

5. Parties’ Contentions

A. Complainant

Complainant asserts that its trademark rights in the FACEBOOK and INSTAGRAM trademarks are established through its numerous trademark registrations for these marks in various jurisdictions, and thus it has standing to file a UDRP based on these rights. Complainant also states that each of the disputed domain names incorporate either the FACEBOOK or INSTAGRAM trademark in its entirety as the leading element, and the disputed domain names remain confusingly similar to Complainant’s trademarks despite the addition of other terms. According to Complainant, the incorporation of the term “live” following the FACEBOOK element of each of the FACEBOOK-formative disputed domain names also creates confusing similarity with Complainant’s Facebook Live brand service. Complainant cites decisions of prior UDRP panels involving use of Complainant’s trademarks in a similar manner (incorporation of Complainant’s trademark as a leading element, followed by other terms) that have found such domain names to be confusingly similar to Complainant’s trademarks. Finally, Complainant contends that the disputed domain names remain confusingly similar despite the addition of the “.com” suffix to each disputed domain name.

According to Complainant, Respondent has no rights or legitimate interests in the disputed domain names. Respondent is not a licensee of Complainant, has not been authorized by Complainant to use Complainant’s FACEBOOK or INSTAGRAM trademarks in domain names or in any other context, and is not affiliated with Complainant in any way. Complainant asserts that Respondent does not appear to have any legitimate business interest in the disputed domain names, is not making legitimate noncommercial or fair use of the disputed domain names and is passively holding the disputed domain names in a manner that does not demonstrate any rights or legitimate interests. Complainant contends that there is no bona fide offering of goods or services associated with the disputed domain names. Complainant also contends that Respondent is not commonly known by the disputed domain names and that Respondent’s personal name bears no resemblance to the disputed domain names.

Complainant contends that its FACEBOOK and INSTAGRAM trademarks are distinctive and well-known globally, and that it is thus very unlikely that a domain name registrant would not be aware of Complainant and Complainant’s trademark rights. According to Complainant, the FACEBOOK and INSTAGRAM trademarks have an exclusive association with Complainant, as demonstrated by results from the Google Internet search engine. Furthermore, Complainant emphasizes that Respondent registered a large number (105) of domain names incorporating exact matches of the FACEBOOK or INSTAGRAM trademarks, which actions demonstrate a pattern of bad faith conduct according to Complainant. Finally, Complainant asserts that redirection of the disputed domain names to registrar-provided websites is compatible with a finding of bad faith.

B. Respondent

Respondent did not reply to Complainant’s contentions.

6. Discussion and Findings

Under paragraphs 5(e) and 14(a) of the Rules, the effect of a default by a respondent is that, in the absence of exceptional circumstances, the Panel shall proceed to a decision on the basis of the Complaint.

Under paragraph 4(a) of the Policy, to succeed Complainant must satisfy the Panel that:

(i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights;

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

(iii) the disputed domain name was registered and is being used in bad faith.

A respondent’s default does not by itself satisfy a complainant’s burden of proof and is not necessarily an admission that the complainant’s allegations are true. See paragraph 4.3 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”). Thus, even though Respondent has failed to address Complainant’s contentions, the burden remains with Complainant to establish the three elements of paragraph 4(a) of the Policy by a preponderance of the evidence. See, e.g., The Knot, Inc. v. In Knot We Trust LTD, WIPO Case No. D2006-0340.

6.1 Consolidation of Proceedings

Paragraph 3(c) of the Rules indicates that more than one domain name may be addressed in a complaint, provided that the domain names have a single registrant. In the case of multiple complainants, the panel should assess whether there is a common grievance against the respondent or if the respondent’s conduct has had a similar impact on the complainants, and whether consolidation is fair and efficient.

In connection with this Complaint, Complainant Instagram, LLC is a wholly-owned subsidiary of Complainant Facebook, Inc., and thus the Complainants ultimately have common ownership. Each Complainant’s concerns regarding the disputed domain names are identical (i.e., each disputed domain name contains either the FACEBOOK or INSTAGRAM trademark as a leading element followed by other terms). As such, there is a common grievance against Respondent; Respondent’s conduct has had a similar impact on each Complainant; and consolidation is fair and efficient. See WIPO Overview 3.0, Section 4.11.1. The Panel will therefore proceed to a decision on the merits.

A. Identical or Confusingly Similar

A national or international trademark registration is prima facie evidence that the holder has the requisite rights in the registered mark for purposes of paragraph 4(a)(i) of the Policy. WIPO Overview 3.0, section 1.2.1. Complainant has provided evidence that it owns multiple registrations in the United States and other jurisdictions for the FACEBOOK and INSTAGRAM trademarks. Therefore, Complainant has established that it has rights in the FACEBOOK and INSTAGRAM trademarks.

The remaining question under the first element of the Policy is whether the disputed domain name (typically disregarding the gTLD in which the domain name is registered) is identical or confusingly similar to Complainant’s mark. It is well accepted that the first element functions primarily as a standing requirement and that the threshold test for confusing similarity involves a “reasoned but relatively straightforward comparison between the complainant’s trademark and the disputed domain name”. WIPO Overview 3.0, section 1.7. This test typically involves a side-by-side comparison of the domain name and the textual components of the relevant trademark to assess whether the mark is recognizable within the disputed domain name. Id.

Here, the disputed domain names each incorporate either the FACEBOOK or the INSTAGRAM trademark on their entirety as the leading and dominant element, followed by assorted other terms. In most of the disputed domain names, the additional terms are descriptive of goods or services. Prior panels have held that the addition of a descriptive term to a domain name containing a trademark does not prevent a finding of confusing similarity between the disputed domain name and the mark. See eBay Inc. v. ebayMoving / Izik Apo, WIPO Case No. D2006-1307, <ebaymoving.com>.

Some of the disputed domain names incorporate geographic terms with the FACEBOOK or INSTAGRAM trademarks. These terms include:

- “kentucky”
- “losangeles”
- “nevada”
- “dallas”

Prior UDRP panels have found that the addition of a geographic term to a trademark does not prevent a finding of confusing similarity. See Playboy Enterprises International, Inc. v. Zeynel Demirtas, WIPO Case No. D2007-0768, <playboyturkey.com>

Finally, some of the disputed domain names incorporate terms that may be considered third parties’ trademarks, as follows:

- “kentuckyderby”
- “losangeleslakers”
- “marchmadness”
- “nba”
- “nevadaraiders”
- “nfl”
- “olympics”
- “rosebowl”
- “stanleycup”
- “superbowl”
- “themasters”
- “worldcup”
- “worldseries”
- “dallascowboys”

Prior UDRP panels have held that the incorporation of third-party trademarks with a complainant’s trademarks does not prevent a finding of confusing similarity between a disputed domain name and a complainant’s trademark. See Guccio Gucci S.p.A. v. Brenda Hawkins, WIPO Case No. D2013-0603, <gucciipadcase.net>.

The Panel therefore finds that Complainant has satisfied the requirements of paragraph 4(a)(i) of the Policy in establishing its trademark rights and showing that each of the disputed domain names is confusingly similar to its FACEBOOK or INSTAGRAM trademarks.

B. Rights or Legitimate Interests

Under paragraph 4(a)(ii) of the Policy, Complainant must make at least a prima facie showing that Respondent possesses no rights or legitimate interests in each disputed domain name. See, e.g., Malayan Banking Berhad v. Beauty, Success & Truth International, WIPO Case No. D2008-1393. Once Complainant makes such a prima facie showing, the burden of production shifts to Respondent, though the burden of proof always remains on Complainant. If Respondent fails to come forward with evidence showing rights or legitimate interests, Complainant will have sustained its burden under the second element of the UDRP.

Paragraph 4(c) of the Policy lists the ways that Respondent may demonstrate rights or legitimate interests in the disputed domain name:

(i) before any notice of the dispute, respondent’s use of, or demonstrable preparations to use, the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services; or

(ii) the respondent (as an individual, business or other organization) has been commonly known by the disputed domain name, even if it has acquired no trade mark or service mark rights; or

(iii) the respondent is making a legitimate noncommercial or fair use of the disputed domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trade mark or service mark at issue.

Here, Complainant has alleged that Respondent has no rights or legitimate interests in any of the disputed domain names. Respondent has not submitted any arguments or evidence to rebut Complainant’s contention that Respondent is not a licensee of Complainant and that Respondent has no other business relationship with Complainant. As all of the disputed domain names resolve to parked pages and not to active websites, Respondent also does not appear to be using the disputed domain names in connection with any legitimate noncommercial or fair use of the disputed domain names, and Respondent’s use of the disputed domain names also cannot be considered a bona fide offering of goods or services.

Therefore, the Panel concludes that Respondent does not have rights or a legitimate interest in the disputed domain name within the meaning of Policy, paragraph 4(a)(ii).

C. Registered and Used in Bad Faith

The registration and use of the disputed domain names was in bad faith. Complainant provided evidence of its registration and widespread use of the FACEBOOK and INSTAGRAM trademarks, sufficient to conclude that they were well-known prior to Respondent’s registration of the disputed domain names. Therefore, Respondent was likely aware of Complainant and its rights in the FACEBOOK and INSTAGRAM trademarks at the time of registration of the disputed domain names. See WIPO Overview 3.0, section 3.2.1; see also TTT Moneycorp Limited v. Privacy Gods / Privacy Gods Limited, WIPO Case No. D2016-1973.

Bad faith in connection with registration of domain names may also be found through a pattern of conduct. Specifically, UDRP panels have held that a pattern of bad faith conduct requires more than one, but as few as two instances of abusive domain name registration. See WIPO Overview 3.0, section 3.1.2; see also Arla Foods Amba and Mejeriforeningen Danish Dairy Board v. Mohammad Alkurdi, WIPO Case No. D2017-0391. In connection with the disputed domain names, Respondent, on several dates between November 2, 2020 and November 14, 2020, registered 105 different domain names incorporating Complainant’s FACEBOOK or INSTAGRAM trademarks, thus demonstrating a pattern of bad faith registration.

Respondent is currently holding the disputed domain names passively, as all of the disputed domain names currently resolve to parked pages that offer links to topics related to terms in each disputed domain name, along with links to contact a domain broker that is part of the Registrar’s corporate organization in order to purchase the domain name. From the inception of the UDRP, panelists have found that the non-use of a domain name, including the domain name resolving to a parked page, would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3; see also Virgin Enterprises Limited v. Cesar Alvarez, WIPO Case No. D2016-2140. While panelists will look at the totality of the circumstances in each case, factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the concealment of the respondent’s identity or use of false contact details (noted to be in breach of its registration agreement), and (iv) the implausibility of any good faith use to which the domain name may be put. Id. The passive holding doctrine applies in this case because Complainant’s marks are highly distinctive, Respondent failed to come forward with any evidence of a conceivable good faith use for the disputed domain names, and it is implausible that Respondent can put the disputed domain names to any conceivable good faith use without infringing upon Complainant’s rights in its FACEBOOK and INSTAGRAM mark. The Panel finds it more likely that Respondent selected the disputed domain names with the intention of taking advantage of Complainant’s reputation by registering domain names containing Complainant’s FACEBOOK and INSTAGRAM trademarks in their entirety with the intent to ultimately use the disputed domain names for an illegitimate purpose, such as misleading Internet users for Respondent’s commercial gain.

For these reasons, this Panel finds that Respondent’s registration and use of the disputed domain names was in bad faith.

7. Decision

For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain names <facebookliveadulttoys.com>, <facebookliveappliance.com>, <facebookliveautoinsurane.com>, <facebooklivebasketball.com>, <facebooklivebedding.com>, <facebookliveboots.com>, <facebookliveboxing.com>, <facebookliveburgers.com>, <facebooklivecandy.com>, <facebooklivecaps.com>, <facebooklivecarsforsale.com>, <facebooklivecellphones.com>, <facebooklivechocolate.com>, <facebooklivechocolateforsale.com>, <facebooklivechristmas.com>,<facebooklivechristmasdecor.com>, <facebookliveclothing.com>, <facebooklivecoffee.com>, <facebooklivecomputers.com>, <facebooklivediamonds.com>, <facebooklivedining.com>, <facebooklivedishes.com>, <facebooklivedresses.com>, <facebookliveelectrician.com>, <facebookliveexperiences.com>, <facebooklivefirsttimehomebuyer.com>, <facebooklivefishing.com>, <facebookliveflatware.com>, <facebooklivefootball.com>, <facebooklivegaming.com>, <facebooklivegamingconsoles.com>, <facebooklivegold.com>, <facebooklivehamburgers.com>, <facebooklivehardmoneylender.com>, <facebookliveheatingandairconditioning.com>, <facebooklivehomeloans.com>, <facebooklivehomesforsale.com>, <facebooklivehometour.com>, <facebooklivehvac.com>, <facebookliveicecream.com>, <facebooklivejerseys.com>, <facebooklivejewelry.com>, <facebooklivekentuckyderby.com>, <facebooklivelaptops.com>, <facebooklivelender.com>, <facebooklivelingerie.com>, <facebooklivelosangeleslakers.com>, <facebooklivemarchmadness.com>, <facebooklivemardigras.com>, <facebooklivemarijuana.com>, <facebooklivemask.com>, <facebooklivemensclothing.com>, <facebooklivemlb.com>, <facebooklivemortgagelender.com>, <facebooklivemortgagerates.com>, <facebooklivemortgages.com>, <facebooklivemovies.com>, <facebooklivemovietickets.com>, <facebooklivenba.com>, <facebooklivenbafinals.com>, <facebooklivenevadaraiders.com>, <facebooklivenevadaraidersrs.com>, <facebooklivenewhometours.com>, <facebooklivenewyearseve.com>, <facebooklivenfl.com>, <facebookliveofficialfanwear.com>, <facebookliveolympics.com>, <facebookliveopenhouse.com>, <facebookliveplumber.com>, <facebooklivepurses.com>, <facebookliverealtor.com>, <facebookliverefinancemortgage.com>, <facebookliverosebowl.com>, <facebookliveseasontickets.com>, <facebooklivesextoys.com>, <facebookliveshoes.com>, <facebooklivespirits.com>, <facebooklivestadiumtickets.com>, <facebooklivestanleycup.com>, <facebooklivesuperbowl.com>, <facebooklivetablets.com>, <facebooklivetableware.com>, <facebooklivethecuddly.com>, <facebooklivethemasters.com>, <facebookliveticketsales.com>, <facebooklivetickets.com>, <facebookliveundergarments.com>, <facebooklivewine.com>, <facebooklivewomensclothing.com>, <facebookliveworldcup.com>, <facebookliveworldseries.com>, <facebooklivezonemask.com> be transferred to Complainant, Facebook, Inc.

In accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain names, <instagramadulttoys.com>, <instagramcandy.com>, <instagramchristmasdeor.com>, <instagramdallascowboys.com>, <instagramgold.com>, <instagramicecream.com>, <instagramlosangeleslakers.com>, <instagrammarijuana.com>, <instagrammovietickets.com>, <instagramnevadaraiders.com>, <instagramseasontickets.com>, <instagramsextoys.com>, <instagramstadiumtickets.com> be transferred to Complainant, Instagram, LLC.

These transfers are ordered without prejudice to any rights that might be asserted by third-party trademark owners with regard to the following domain names: <facebooklivekentuckyderby.com>, <facebooklivelosangeleslakers.com>, <facebooklivemarchmadness.com>, <facebooklivemlb.com>, <facebooklivenba.com>, <facebooklivenbafinals.com>, <facebooklivenevadaraiders.com>, <facebooklivenevadaraidersrs.com>, <facebooklivenfl.com>, <facebookliveolympics.com>, <facebookliverosebowl.com>, <facebooklivestanleycup.com>, <facebooklivesuperbowl.com>, <facebooklivethemasters.com>, <facebookliveworldcup.com>, <facebookliveworldseries.com>, <instagramdallascowboys.com>, <instagramlosangeleslakers.com>, <instagramnevadaraiders.com>.

Brian J. Winterfeldt
Sole Panelist
Date: August 27, 2021