claims it has not licensed or otherwise authorized the Respondent to use its TAO or TAOBAO trademarks with the Disputed Domain Names. The Complainant further claims there is no evidence to suggest that the Respondent has been commonly known by the Disputed Domain Names because neither the Respondent’s name- Alexey Gurov, nor his Organization’s name – Merchant Global Enterprise Ltd, do not correspond to the Disputed Domain Names. The Complainant contends that in the registration information for the Disputed Domain Names <tao-imagine.com>; <tao-mama.com>; <tao-sp.org>; <taobaosp.org>, <тао-бао.com> and <таобао-форум.com> the Respondent identified as his organization Taobao Ltd, an organization with an address in China. The Complainant claims that the Respondent’s use of the Taobao Ltd attempts to frustrate the Complainant’s efforts to recover the Disputed Domain Names and it doesn’t afford the Respondent with any rights or legitimate interests in the Domain Names. The Respondent asserts that passive holding of the Disputed Domain Names <tao-0.com>, <tao-api.info>, <tao-mama.com>, <tao-sp.org>, <taobao-sp.org>, <тао-бао.com> and <таобао-форум.com> (the “Inactive Domains”) confers no rights or legitimate interests on the Respondent in the abovementioned Disputed Domain Names. According to the Complainant, the Respondent is using the <open-taobao.com> and <tao-imagine.com> domain names to unfairly capitalize on the confusing similarity between the Complainant’s TAOBAO and TAO trademarks and the Disputed Domain Names by attracting and redirecting Internet users to its websites associated with the Disputed Domain Names. iii. The Complainant assets that the Disputed Domain Names have been registered and are being used by the Respondent in bad faith because the Respondent has no rights or legitimate interested in the Disputed Domain Names. The Complainant claims that the Respondent has engaged in a pattern of bad faith because 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. The Complainant alleges that the Respondent is also connected with respondent in a previous domain name dispute involving <Taobao.com> domain name because websites associated with the <Taobao.com> domain name and the <open-taobao.com> Disputed Domain Name, and the registrant company’s name, address and banking information were virtually identical. The Complainant alleges that the Respondent knew about the Complainant’s trademarks when he registered the Disputed Domain Names, because the Complainant registered the TAO and TAOBAO trademarks eight years before the Respondent registered the first of the Disputed Domain Names, the Complainant’s TAO and TAOBAO trademarks are well-known and because neither TAO, nor TAOBAO terms has meaning in English or Russian. The Complainant asserts that the Respondent must have known about the Complainant’s rights because his “www.open-taobao.com” website falsely claims that the Respondent is an official partner of the Complainant’s Taobao marketplace. Further, the Complainant alleges that the Respondent’s registration and use of the Disputed Domain Names must involve mala fides where the registration and use of it was and continues to be made in the full knowledge of the Complainant's prior rights in the TAO and TAOBAO trademarks. The Complainant claims that the Respondent’s use of “Taobao Ltd" is further Page 5