<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. Page 3

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