“www.open-taobao.com” website and is virtually identical to the “www.open-taobao.com” website. The Russian Website has the same Hong Kong and China address and the same HSBC bank account details as stated in the “www.open-taobao.com” website. The both websites are allegedly operated by the same company Merchant Global Enterprise Ltd. The Russian Website also incorporates the Complainant's Taobao Trade Marks and an orange mascot owned by the Complainant (the “Tao Doll”). Under no circumstances may such use confer rights or legitimate interests in the Disputed Domain Names on the Respondent. The Panel, therefore, finds that the Complainant made out the 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 “[o]nce the prima facie case is made, the burden of production shifts to the respondent to come forward with appropriate allegations or evidence demonstrating rights or legitimate interests in the domain name. If the respondent fails to come forward with such appropriate allegations or evidence, a complainant is generally deemed to have satisfied paragraph 4(a)(ii) of the UDRP.” By defaulting, the Respondent failed to satisfy its burden of production. Therefore, the Panel finds that the Complainant satisfied the second UDRP element. C) Bad Faith To satisfy the third UDRP element, the Complainant must prove that the domain names were registered and are being used in bad faith. The Panel finds that the Respondent registered and is using the Disputed Domain Names in bad faith. First, evidence on record shows the Respondent has engaged into a pattern of registering domain names that bear resemblance to the Complainants TAOBAO trademarks, a pattern of conduct forbidden by paragraph 4(b)(ii) of the UDRP13. As of today, the Respondent has registered 19 domain names that incorporate the Complainant’s TAOBAO trademarks. 14 Besides the Disputed Domain Names the Respondent also registered <tao.email>, <taobao.email>, <taobao.website>, <taobao.domains>, <taobao.ink>, <taobao.expert>, <taobao.ninja>, <taobao.partners>, <taobao.today>, <tao.land> and <tao.zone> that incorporated the Complainant’s TAO or TAOBAO trademarks. Second, the Complainant claims that during the last three years, its rights in the TAOBAO trademarks have been violated 76 times. In the Panel’s view, the existence of multiple attempts by third parties to trade on the Complainant’s goodwill indicates its fame. In addition, the Complainant provided evidence of its significant transaction volume and number of Internet users that use the Taobao Marketplace. This confirms that the TAOBAO trademarks have become well-known to consumers. The Panel shares the view that “opportunistic bad faith” is shown when a domain name incorporating a well-known mark is registered “by someone with no connection with the product.” Because, the Respondent registered the Disputed Domain Names, which incorporate the Complainant’s well-known TAOBAO trademarks, and the Respondent has no connection with the TAOBAO or TAO products, the Panel finds that the Disputed Domain Names were registered in bad faith. 13 14 Paragraph 3.3. of WIPO Overview, 2.0. This includes the Disputed Domain Names and the domain names that were subject of dispute in the URS Cases. Page 10