The Panel finds that the Disputed Domain Names are confusingly similar to the Complainant’s TAOBAO trademarks. The test for confusing similarity under the UDRP “involves a comparison between the mark and the domain name…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 …typically being regarded as insufficient to prevent threshold Internet user confusion.”4 The Disputed Domain Names <open-taobao.com>, <tao-0.com>, <tao-api.info>, <taoimagine.com>, <tao-mama.com>, <tao-sp.org> and <taobao-sp.org> incorporate the Complainant’s TAOBAO trademarks in their entirety. Adding merely generic or descriptive wording to the Complainant’s trademark, like the prefix “open,” or suffixes “0”, “api,” “imagine,” “mama,” “sp” or a hyphen where the mark constitutes the dominant part of the domain name, cannot avoid finding of confusing similarity. It a consensus among the UDRP panelists that adding the gTLD “.com” or equivalent should be disregarded under the confusing similarity test, as it is a technical requirement of registration5. The Disputed Domain Names <тао-бао.com> and <таобао-форум.com> incorporate the Complainant’s TAOBAO trademark in its entirety. The only differences between the TAOBAO trademark and the Disputed Domain Names are the use of the Cyrillic characters "т" and "б" instead of the English letters "t" and "b"; the addition of the hyphen ("-"); and, with regard to <таобао-форум.com> and the addition of the generic Russian word "форум" (which means "forum" in English). The Russified spellings of the <таобао.com> and <таобао-форум.com> Disputed Domain Names are confusingly similar to the TAOBAO trademark because the TAOBAO trademark remains the dominant component of the Disputed Domain Name.6 Therefore, the Panel finds that the Complainant satisfied the first UDRP element by proving that the Disputed Domain Names are identical to the Complainant’s TAOBAO trademarks in which the Complainant has rights. B) Rights and Legitimate Interests To satisfy the second UDRP element, he Complainant must make out a prima facie case showing that the Respondent has no rights or legitimate interests in the Domain Name. It is a consensus view of the UDRP panelists that the general “standard of proof under the UDRP is "on balance" - often expressed as the "balance of probabilities" or "preponderance of the evidence" standard. Under this standard, an asserting party would typically need to establish that it is more likely than not that the claimed fact is true.”7 The Panel finds it is more likely that the Respondent does not have rights or legitimate interests in the Disputed Domain Names because: First, the Respondent probably has not been commonly known by the <tao-0.com>, <opentaobao.com> or <tao-api.info> Disputed Domain Names because neither the his nameAlexey Gurov, nor his Organization’s name – Merchant Global Enterprise Ltd, 4 Paragraph 1.2., WIPO Overview 2.0. Paragraph 1.2. of WIPO Overview 2.0. 6 See, generally, Paragraph 1.20 of WIPO Overview 2.0. 7 Paragraph 4.7 of WIPO Overview 2.0. 5 Page 8