FACTS ASSERTED BY THE COMPLAINANT AND NOT CONTESTED BY THE RESPONDENT:
The Complainant is a French multinational mass media conglomerate headquartered in Paris. The company has activities in music, television, film, video games, telecommunications, tickets and video hosting service. With 44,142 employees in 78 countries, the Complainant’s total revenues amounted to €13,932 million worldwide in 2018.
The Complainant also owns and communicates on Internet through various domain names, such as the domain name <vivendi.com> registered on 12 November 1997.
The disputed domain name <vivendiclassaction.com> (the "Domain Name") was registered on 20 January 2020 and redirects to a parking page with commercial links. It has also been offered for sale on the afternic website for USD 9,888.
The Respondent has been involved in numerous UDRP proceedings as the Registrant of third-party trade marks. Examples include WIPO Case No. D2019-2781, BAZARCHIC v. Milen Radumilo; WIPO Case No. D2019-2541 Association des Centres and Lec v. Perfect Privacy, LLC / Milen Radumilo and CAC Case No. 102693, Piriform Software Limited v. Milen Radumilo.
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