The Complainant asserts that its trademark CREDIT AGRICOLE is widely known and highlights that prior panels have confirmed the well known character of the trademark.
The Complainant states that the disputed domain name is confusingly similar to its trademark since it incorporates the trademark CREDIT AGRICOLE in its entirety with the addition of the word "France" (intersected by a hyphen), that does not change the overall impression of the designation as being connected to the trademark CREDIT AGRICOLE.
The Complainant asserts that the Respondent does not have any rights or legitimate interest in the disputed domain name since the Respondent is not affiliated with nor authorized by the Complainant in any way, and does not carry out any activity for, nor has any business with the Complainant. The Complainant also states that the Respondent’s lack of rights or legitimate interests in the disputed domain name is highlighted by the fact that the disputed domain name resolves to an inactive page.
It also highlights that according to established precedents, the complainant is required to make out a prima facie case that a respondent lacks rights or legitimate interests and that, once such prima facie case is made, the respondent carries the burden of demonstrating rights or legitimate interests in the disputed domain name.
With reference to the circumstances evidencing bad faith, the Complainant contends that, given the distinctiveness of the Complainant's trademark and its reputation, it is reasonable to infer that the Respondent has registered the disputed domain name with full knowledge of the Complainant's mark. Further, the complainant contends that the incorporation of a famous mark into a domain name, coupled with an inactive website, may be evidence of bad faith registration and use.
NO ADMINISTRATIVELY COMPLIANT RESPONSE HAS BEEN FILED
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