<taobao.website>, <taobao.domains>, <taobao.ink>, <taobao.expert>, <taobao.ninja>,
<taobao.partners>, <taobao.today>, <tao.land>, <tao.zone> (the "URS Cases").
The WhoIS search result for <tao-0.com> domain names reveals that that the Respondent
identified "Merchant Global Enterprise Ltd" as his organization and stated the same
address in Russia as his contact address stated in his registration information for the <opentaobao.com> and <tao-api.info>. The WhoIS search results for six of the Disputed Domain
Names (<tao-imagine.com>, <tao-mama.com>, <tao-sp.org>, <taobao-sp.org>, <таобао.com> and <таобао-форум.com>) reveals that the Respondent identified "Taobao Ltd"
as his organization and stated an address in China.
The Respondent registered <open-taobao.com> domain name on 18 August 2011. The
"www.open-taobao.com" website is an online marketplace, which incorporates the
Complainant's Taobao Trade Marks and allegedly sells products from China and Hong
Kong.
The Respondent registered <tao-imagine.com> domain name on 6 November 2012. The
"www.tao-imagine.com" website is a website that allegedly assists users to help search for
and purchase products from the Complainant's Taobao Marketplace. It also links to the
Russian online shopping website “www.выгоднокупи.рф,” which incorporates
Complainant's Taobao Trade Marks. “выгоднокупи” consists of two Russian words:
“выгодно” and “купи”, which means “buy at competitive prices.”
On August 15, 2012, the Respondent registered <tao-api.info> domain name. The
Respondent registered <тао-бао.com> and <таобао-форум.com> domain names on 5 May
2013. The Respondent registered <tao-mama.com> domain name on 22 February 2013.
The next day, the Respondent registered <tao-sp.org> and <taobao-sp.org>. Finally, the
Respondent registered <tao-0.com> on July 12, 2014. The Disputed domain names <tao0.com>, <tao-api.info>, <tao-mama.com>, <tao-sp.org>, <тао-бао.com>, <таобаофорум.com>, <taobao-sp.org> revert to parking pages (the “Inactive Domains”).
On December 2, 2014, the law firm representing the Complainant emailed to the
Respondent copies of the Complaint and annexes (the “Complainant’s December 2, 2014
communication”). The next day, a person identifying herself as “Diana” sent the following
email to an attorney representing the Complainant: “Dear Karen, Can you please inform
when our domains will be taken away? And what can we do to keep them? Is there any
way to solution? Waiting for your replay. Thank you!” (the “December 3 Respondent’s
email”). The December 3, 2014 Respondent’s e-mail string showed the forwarded
Complainant’s December 2, 2014 communication. On the same day, an attorney
representing the Complainant wrote to the Respondent that its “client is not interested in
entering into negotiations. Our client’s rights have been infringed multiple times by Mr.
Alexey Gurov, and, it therefore intends to let the current proceedings continue
accordingly.”
On December 22, 2014, the Respondent sent an e-mail to the Center with the following
text: “Hello, tell me why you are interested only in these domains? There are still such as
"vivatao.com", "kupunatao.com", "taobao.ru"” (the “December 22 Respondent’s email”).
The December 22 Respondent email’s string showed the December 22, 2014 e-mail from
the Center to the parties indicating that the Respondent submitted no response to the
Complaint.
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