Decision for dispute CAC-UDRP-107841

The Panel is not aware of any other legal proceedings which are pending or decided and which relate to the disputed domain name.

Complainant, Chewy Inc., is the owner of various trademark registrations that contain the word CHEWY, registered for online retail pet goods store or goods and services in relation to selling pet food, pet supplies and pet accessories.

Complainant submits several print outs from the US and WIPO trademark database as well as copies of the US Trademark registration certificates as evidence, including e.g.:

US TM number 4346308 CHEWY.COM, registered June 4, 2013, for goods in class 35;

US TM number 6788620 CHEWY, registered July 12, 2022, for goods in class 9;

US TM number 6847058 CHEWY, registered September 13, 2022, for goods in class 18 and 25;

EU TM number 018513701 CHEWY, registered November 16, 2021, for goods in class 9;

EU TM number 016605834 CHEWY, registered August 10, 2017, for services in class 35;

Australia TM number 2060121 CHEWY, registered January 2, 2020, for services in class 35.

The registrations are all in the name of Chewy, inc. though with different addresses.

The Policy does not require though that a trademark owner submits trademark registrations that match with respect to the owner’s address. Therefore, the Panel accepts the submitted trademark registrations as relevant documents in this Complaint.

Chewy Inc, with domicile in Plantation, Florida, United States, was founded in 2011 and operates as one of the largest, as claimed by Complainant, online retail stores in pet supplies and pet wellness-related services including pet food, treats, supplies, and veterinary pharmaceutical products and services. All those products and services are either under the CHEWY trademark or third-party trademarks like PURINA ONE, NEXGARD, SIMPARICA TRIO.

Further, Complainant alleges that Chewy was ranked at number 362 in the Fortune 500 list of the world’s most important companies. In 2024, Chewy was added to the Standard & Poors MidCap 500 list of most valuable midcap stocks. That year, Chewy earned almost $12 billion in net sales, a 6% increase over the previous year. Clearly, Chewy is a very famous and successful global company, according to Complainant. Evidence of the aforesaid is included in the Complaint.

Complainant provides its pet supplies and pet wellness-related services through its <chewy.com> domain name. This domain name is used for the primary website of Complainant. The website includes the CHEWY trademark in blue and white in the top left corner. The <chewy.com> domain name was created on April 18, 2004, as can be seen on the enclosed extract of ICANN Lookup.

According to Complainant, its CHEWY trademark is famous and Complainant substantiates this allegation by mentioning several prior UDRP decisions and citing relevant paragraphs in it:

• Chewy, Inc. v. david almarin, Case No. D2022-3808 (WIPO July 28, 2023) (“The Panel finds it reasonable to conclude that Complainant’s CHEWY mark is “famous” given the evidence provided by Complainant…”);

• Chewy Inc. v. Rostislav Karyi / Ростислав Карый, Case No. DUA2020-0007 (WIPO May 1, 2020) (finding actual knowledge of the Complainant’s mark in light of its fame);

• Chewy, Inc. v. Li Hou Chang, Case No. D2019-1845 (WIPO October 16, 2019) (rejecting Respondent’s argument that the CHEWY mark is not well-known, specifically in China, and finding that “it is inconceivable Respondent was not aware of Complainant and of Complainant’s trademark”).

The UDRP decisions in entirety are not included in the Complaint though.

Complainant continues by stating that the disputed domain name resolves to a website (“Respondent’s website”) showing a replica of the CHEWY logo in the same blue and white color as the website of Complainant and offering pet-related product deals (from various trademarks, including ROYAL CANIN, 4HEALTH, RETRIEVER- as added by the Panel) targeting consumers in the United States.

Complainant alleges that the website under the disputed domain name is exactly the same website as recently resolving at <chewy-outlet.com>, registered by the same Respondent, and subject to Complainant's successful UDRP action just a few months ago. Chewy, Inc. v. Bopan Zack, CAC No. 107505 (April 28, 2025). Complainant did not include the decision in that earlier case, but did submit a copy of the website at stake being <chewy-outlet.com>, on which the Panel could verify that indeed it is about a similar website.

Complainant continues with the allegation that Respondent demonstrates a pattern of abusive registration and use of domain names and that is a further factor supporting this Complaint.

Respondent registered the domain name <chewy-sale.com> on June 6, 2025.    

The Complainant contends that the requirements of the Policy have been met and that the disputed domain name should be transferred to it.
No administratively compliant Response has been filed.

According to the Policy paragraph 4(a)(i) it needs first to be established that:

(i) The domain name is identical or confusingly similar to a trademark or service mark in which complainant has rights;

Complainant starts by stating that the disputed domain name fully incorporates Complainant’s CHEWY mark, adding only the hyphenated word “sale”, and thus is confusingly similar to the CHEWY trademark.

Complainant substantiates this by citing WIPO Overview 3.0 section 1.7:

“[I]n cases where a domain name incorporates the entirety of a trademark, or where at least a dominant feature of the relevant mark is recognizable in the domain name, the domain name will normally be considered confusingly similar to that mark for purposes of UDRP standing,”

and continues that Complainant’s CHEWY mark is incorporated in the disputed domain name in its entirety, which is therefore sufficient to find confusing similarity between the disputed domain name and CHEWY mark.

Moreover, it is established under the Policy that the addition of descriptive terms or a TLD extension to an identical mark is insufficient to escape a finding of such similarity: 

• WIPO Overview 3.0, Section 1.8 (“Where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element.”); 
• Chewy, Inc. v. Bopan Zack, CAC-UDRP-107505 (Apr. 28, 2025) (“The disputed domain name [chewy-outlet.com] incorporates the CHEWY mark in its entirety. The addition of the generic term “outlet” and the hyphen does not prevent a finding of confusing similarity. On the contrary, the term “outlet” may even increase the likelihood of confusion by suggesting an official retail outlet or clearance branch associated with the Complainant.”).

Furthermore, it is established practice to disregard the TLD extension in a domain name since it is seen as a customary registration requirement: 

• WIPO Overview 3.0, Section 1.11 (“The applicable Top Level Domain [“TLD”] in a domain name [e.g., “.com”, “.club”, “.nyc”] is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test.

Accordingly to Complainant, the addition of “sale” and “.COM” does not mitigate the confusing similarity.

That Panel firstly establishes that Complainant’s trademark registrations predate the registration of the disputed domain name and thus the trademark rights prevail.

Further, the Panel agrees with these assertions of Complainant that the disputed domain name is confusingly similar to the CHEWY trademark based on the above mentions allegations which are supported by relevant case law.

Complainant has, to the satisfaction of the Panel, shown the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights (within the meaning of paragraph 4(a)(i) of the Policy).

According to the Policy paragraph 4(a)(ii) it needs further to be established that:

(ii) Respondent has no rights or legitimate interests in respect of the domain name.

Paragraph 4 (c) of the Policy provides circumstances that could demonstrate that Respondent has no rights to and legitimate interests in the disputed domain name. These circumstances are not exclusive. Circumstance that are providing rights or legitimate interests to the disputed domain name are:

(i) before any notice to the Respondent of the dispute, the use of, or demonstrable preparations to use, the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services; or

(ii) Respondent (as an individual, business, or other organization) has been commonly known by the disputed domain name, even if though it has acquired no trademark or service mark rights; or

(iii) Respondent is making a legitimate noncommercial or fair use of the disputed domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.

Further, according to the WIPO Case No. D2003-0455, Croatia Airlines d. d. v. Modern Empire Internet Ltd., Complainant is required to make out a prima facie case that Respondent lacks rights or legitimate interests. Once such prima facie case is made, Respondent carries the burden of demonstrating rights or legitimate interests in the disputed domain name. If Respondent fails to do so, Complainant is deemed to have satisfied paragraph 4(a) (ii) of the Policy.

Complainant alleges that Respondent has no rights on the disputed domain name and substantiate this allegation with a few arguments.

Firstly, Respondent has never been authorized by Complainant to use the CHEWY mark in any manner, much less as part of the disputed domain name.

Further, the disputed domain name was registered long after Complainant registered the CHEWY mark and established extensive goodwill.

Complainant, in this respect, cites WIPO Overview 3.0, Section 2.5.1:

“[W]here a domain name consists of a trademark plus an additional term (at the second- or top-level), UDRP panels have largely held that such composition cannot constitute fair use if it effectively impersonates or suggests sponsorship or endorsement by the trademark owner….”.

Moreover, the disputed domain name does not reflect Respondent’s common name.

Rather, Respondent is using the disputed domain name to infringe and cybersquat upon Complainant’s rights in its globally famous and well-known CHEWY mark, including in the United States, where Complainant has owned valid, subsisting, and well-known trademark rights and federal trademark registrations since at least 2013, long predating Respondent’s registration of the disputed domain name on March 31, 2025, as Complainant continues. 

The disputed domain name currently resolves to an imitative website offering pet-related products under the CHEWY mark. Accordingly, Respondent is monetizing the disputed domain name by trading on the goodwill associated with the CHEWY mark used in the disputed domain name, via advertising and otherwise, to confuse Internet users into visiting Respondent’s website where Respondent purports to offer deals for competing retail goods. 

Such use of the disputed domain name does not constitute any legitimate bona fide sale of goods or services or legitimate non-commercial or fair use.

Complainant cites here:

•  WIPO Overview 3.0, Section 2.5.3 (“[A] Respondent’s use of a Complainant’s mark to redirect users (e.g., to a competing site) would not support a claim to rights or legitimate interests.”);

• Chewy, Inc. v. Bopan Zack, CAC-UDRP-107505 (April 28, 2025). (“Respondent has used the disputed domain name in connection with a website that mimics the appearance and branding of the Complainant’s official website, offering goods under the CHEWY name and logo without authorization. Such use is clearly misleading and does not constitute a legitimate or fair use under the Policy.”); Chewy, Inc. v. Anne Dudley, CAC-UDRP-107614 (July 17, 2025) (same).

Indeed, Respondent cannot make any claim to be a reseller with a right or legitimate interest in the disputed domain name, for Respondent does not accurately disclose Respondent’s lack of a relationship or affiliation with the trademark owner, namely, Complainant. Here Complainant cites:

• Oki Data Americas, Inc. v. ASD, Inc., Case No. D2001-0903 (WIPO Nov. 6, 2001) (noting cases where Respondents were found to lack rights and legitimate interests in disputed domain names, including cases where websites falsely suggest they are official sites such as via use of a complainant’s logo and lack of a disclaimer).

Instead, Respondent falsely holds out Respondent’s Website to be an official Chewy online shop for pet-related products. Thus, Respondent falsely declares it is Chewy itself, which can never be deemed a legitimate interest under the Policy.

And here Complainant cites:

• WIPO Overview 3.0, Section 2.8.1; see, e.g., Chewy, Inc. v. Yinfeng Yin, Xi Gong, Dongkun Wang, Case No. D2023-2493 (WIPO Aug. 9, 2023) (“[T]he websites to which the disputed domain names resolved did not disclose the relationship or lack of relationship with the trademark owner… [T]he Panel considers that the above-mentioned [Oki Data] criteria are not met in this case and the disputed domain names have not been used for a bona fide offering of goods in the meaning of the Policy.”);

• WIPO Overview 3.0, Section 2.10.2. For a Respondent to have rights or legitimate interests in a domain name, the Respondent’s evidence supporting its explanation for its registration (and any use) of the domain name should indicate a credible and legitimate intent which does not capitalize on the reputation and goodwill inherent in the Complainant’s mark.

Here, the “CHEWY” that is used in the disputed domain name, and the retail goods featured on Respondent’s website, are so closely and uniquely associated with Complainant that there can be no credible and legitimate intent that would not capitalize on the reputation and goodwill inherent in Complainant’s famous CHEWY marks, as Complainant contends.

Finally, Complainant alleges that it is well-established that, where the Complainant contends the Respondent has no rights or legitimate interests in a disputed domain name, the burden of proof shifts to Respondent to come forward with proof to the contrary:

• LACOSTE and LACOSTE ALLIGATOR SA v. Domain Manager, Case No. D2016-2181 (WIPO December 20, 2016) (“Complainants have provided prima facie evidence of Respondent’s lack of rights or legitimate interests in the disputed domain name, and the burden of production therefore shifts to Respondent to come forward with evidence demonstrating the rights or legitimate interests it may have.”);

• De Beers Intangibles Limited v. Domain Admin, Whois Privacy Corp., Case No. D2016-1465 (WIPO September 14, 2016) (“[I]t is sufficient for a Complainant to raise a prima facie case against Respondent under this head and an evidential burden will shift to the respondent to rebut that prima facie case.”); Chewy, Inc. v. Anne Dudley, CAC-UDRP-107614 (July 17, 2025) (same).

Absent any showing to the contrary by Respondent, Complainant has therefore established that Respondent has no rights or legitimate interests in the Disputed Domain Name, concludes Complainant.

Respondent has not responded to this Complaint.

The Panel finds that the Oki Data Criteria, (recently updated in the Lost Mary Direct case CAC-UDRP-107605 - Lost Mary criteria), as cited by Complainant cannot be applied here one on one. In the previous cases, Oki Data and Lost Mary Direct, the parties were a trademark owner (Complainant) on one side and an authorized dealer (Oki Data) or reseller (Lost Mary Direct) on the other side. Both parties were commercializing the same goods under the same trademark. The present case is about the use of a retailer’s service mark at both Parties' sides though to commercialize the sale of pet products under multiple trademarks. This is a different situation.

Further, the Panel follows the reasoning of Complainant that Respondent has no rights or legitimate interest in the disputed domain name according to the Policy.

The Panel could verify, based on the attached copies of the website of both Complainant and Respondent that Respondent in fact, is a simple copier with respect to:

• the disputed domain name, containing Complainant’s trademark in whole and only adding a descriptive term <sale> which enhances the emphasis on the trademark CHEWY;
• the features of the website to which it resolves, which includes an almost identical CHEWY logo in blue and white and a similar website composition.

This fact is not counterargued by Respondent.

Complainant has, to the satisfaction of the Panel, shown Respondent to have no rights or legitimate interests in respect of the disputed domain name (within the meaning of paragraph 4(a)(ii) of the Policy).

According to the Policy paragraph 4(a)(iii) it finally needs to be established that:

(iii) the domain name has been registered and is being used in bad faith.

Paragraph 4 (b) of the Policy provides circumstances on that demonstrate that Respondent has registered and used the domain name in bad faith. These circumstances are not exclusive.

Those circumstances are for example:

(i) circumstances indicating that respondent has registered or has acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the domain name; or

(ii) respondent has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that respondent has engaged in a pattern of such conduct; or

(iii) respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or

(iv) by using the domain name, respondent has intentionally attempted to attract, for commercial gain, Internet users to its web site or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of your web site or location or of a product or service on your web site or location.

Complainant states that article 4 (b) (iii) is at stake here:

(iii) Respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or

And Complainant substantiates this allegation by citing case law:

• WIPO Overview 3.0, Section 3.1.3 (“Noting that the scenarios enumerated in UDRP paragraph 4(b) are non-exhaustive, panels have applied the notion of a ‘competitor’ beyond the concept of an ordinary commercial or business competitor to also include the concept of “a person who acts in opposition to another” for some means of commercial gain, direct or otherwise.”); 
• Chewy, Inc. v. Anne Dudley, CAC-UDRP-107614 (July 17, 2025) (finding bad faith where “the disputed domain name resolves to a website that advertises goods and services in direct competition with those of the Complainant”); 
• Chewy, Inc. v. Bopan Zack, CAC-UDRP-107505 (“Complainant also argues that the Respondent’s use of the disputed domain name is disruptive to its business under paragraph 4(b) (iii) of the Policy. Given that the website directly targets the Complainant’s customers and offers competing goods, the Panel accepts this contention.”); 
• Chewy, Inc. v. david almarin, Case No. D2022-3808 (WIPO Jul. 28, 2023) (“Respondent, having intentionally configured the disputed domain name to enhance confusing similarity to Complainant’s CHEWY mark, is using the disputed domain name to direct Internet users to an imitation website claiming to offer pet-related goods for sale at a discounted price, thus unfairly trading on the goodwill associated with Complainant’s CHEWY mark. Accordingly, Respondent’s conduct was undertaken in opposition to Complainant and disruptive to Complainant’s business, which prior UDRP panels have found to be evidence of bad faith use under paragraph 4(b)(iii) of the Policy.”); 

• Fitbit, Inc. v. WhoisGuard Protected, WhoisGuard, Inc. / Wei Zhang, Case No. D2020-0317 (WIPO Apr. 13, 2020) (“[T]he Respondent has used the disputed domain name to impersonate the Complainant. The Respondent’s only or prime interest in the disputed domain name would appear to be illegitimate… In all the circumstances, the Panel finds that, for the purposes of the Policy, there is evidence of both registration and use of the Domain Name in bad faith”).

Complainant illustrates that article 4 (b)(iv) of the Policy:

(iv) by using the domain name, the respondent has intentionally attempted to attract, for commercial gain, Internet users to its website or other on-line location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location or of a product or service on the respondent’s website or location.

Is applicable as well by alleging that Respondent has intentionally attracted Internet users for commercial gain, offering pet-related products through its competing imitative website, creating a likelihood of confusion with Complainant’s CHEWY mark as to the source, sponsorship, affiliation, or endorsement of the disputed domain name. Accordingly, the disputed domain name has been intentionally registered and used to attract Internet users for commercial gain by creating a likelihood of confusion with the CHEWY mark. There is no evidence of any other conceivable good faith use.

Further, Complainant cites case law:

• WIPO Overview 3.0, Section 3.1.4 (“Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names… incorporating the mark plus a descriptive term) to a famous or widely known trademark by an unaffiliated entity can by itself create a presumption of bad faith.

And Complainant continues that Panels have found the following types of evidence to support a finding that a Respondent has registered a domain name to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s mark:

(i) actual confusion;

(ii) seeking to cause confusion (including by technical means beyond the domain name itself) for the respondent’s commercial benefit, even if unsuccessful;

(iii) the lack of a respondent’s own rights to or legitimate interests in a domain name;

(iv) redirecting the domain name to a different respondent-owned website, even where such website contains a disclaimer;

(v) redirecting the domain name to the complainant’s (or a competitor’s) website,  and

(vi) absence of any conceivable good faith use.

• Chewy, Inc. v. Bopan Zack, CAC-UDRP-107505 (“Complainant has submitted uncontested evidence that the disputed domain name resolves to a website that imitates the Complainant’s official site, using its name and logo without authorization and purporting to offer similar goods and services. … The Panel finds that the Respondent’s conduct is intended to mislead consumers and divert traffic for commercial gain, by creating a likelihood of confusion with the Complainant’s trademark. This conduct falls within the circumstances of bad faith outlined in paragraph 4(b)(iv) of the Policy….”); 

• Chewy, Inc. v. Anne Dudley, CAC-UDRP-107614 (July 17, 2025) (same); Chewy, Inc. v. david almarin, Case No. D2022-3808 (WIPO July 28, 2023) (finding bad faith under paragraph 4(b)(iv) of the Policy where Complainant evidenced Respondent’s use of a domain name to redirect to an imitation website offering competing goods); Walgreen Co. v. Registration Private, Domains By Proxy LLC / Nitish Maheshwari, Case No. D2017-1601 (WIPO Sep. 28, 2017) (“[T]he website to which the Disputed Domain Name resolves shows the Complainant's logo and products of the type associated with it. This demonstrates that the Respondent knew of the Complainant and was using the Disputed Domain Name to exploit the Complainant’s trademark in order to sell products to customers who would have assumed that they were dealing with the Complainant.”).

Furthermore, as Complainant alleges, the Complainant’s rights in the CHEWY mark is so well established, and its CHEWY brand has achieved a level of recognition and fame such that Respondent has no colorable argument that he is unaware of this brand. The disputed domain name is only valuable because of its association with the CHEWY brand. Next, Complainant cites the following case law:

• Chewy, Inc. v. David Almarin, Case No. D2022-3808 (WIPO July 28, 2023) (finding bad faith because “here, it would be implausible to believe that Respondent selected and was using the disputed domain name for any other purpose than to trade on Complainant’s trademark rights and reputation” in light of the fame of the CHEWY Mark and circumstances of Respondent’s use of a confusingly similar domain name for an imitation website);

• Chewy Inc. v. Rostislav Karyi / Ростислав Карый, Case No. DUA2020-0007 (WIPO May 1, 2020) (“[N]oting Complainant’s rights in the CHEWY Marks, that the disputed domain name is identical to the CHEWY Marks, and the manner the disputed domain name is being used, Respondent has no colorable argument that he is unaware of the CHEWY brand. Respondent sought to capitalize on that goodwill by drawing Internet users to its website for commercial gain by creating a likelihood of confusion with the CHEWY Marks.”);

• Chewy, Inc. v. Li Hou Chang, Case No. D2019-1845 (WIPO October 16, 2019) (finding that “it is inconceivable Respondent was not aware of Complainant and of Complainant’s trade mark when Respondent acquired the disputed domain name”).

Further, Complainant adds that this counterfeit website is exactly the same website as recently resolving at chewy-outlet.com, registered by the same Respondent, and subject to Complainant's successful UDRP action just a few months ago. Chewy, Inc. v. Bopan Zack, CAC No. 107505 (Apr. 28, 2025). Complainant continues by alleging that this pattern of abusive registration and use is a further factor supporting this Complaint and the only conclusion that can be drawn from the evidence is that Respondent registered and used the disputed domain name in bad faith per Section 4(b) of the Policy.

Based on the above the Panel has the following findings.

Bad faith circumstances occur mainly when a Respondent sees financial gain on riding on the coat tails of Complainant’s success. This is mostly profitable when Complainant has a reputation. Therefore, first it needs to be established whether Complainant has such a reputation.

To substantiate its reputation Complainant submits Investors information originating from its own Chewy.com website, as well as a press release from S&P Global and the Full Fortune 500 list on which Chewy Inc is listed. Also, previous case law is cited as evidence.

With respect to the cited case law the Panel finds that it should establish itself whether there is factual evidence of reputation rather than copying other Panel’s findings. On the reputation the Panel concludes that the Complaint lacks evidence on global reputation but concludes that, based on the submitted evidence, the CHEWY trademark could be considered well known in the United States of America. As Respondent is established in the United States of America too, it is likely that Respondent had knowledge about the CHEWY trademark. This proves that the disputed domain name is registered in bad faith.

Further, with respect to the registration and use of the disputed domain name, Complainant cites lots of UDRP case law, that it finds relevant. The Panel accepts these citations prima facie for as far as they are rules of law as established in the WIPO Overview 3.0.

Where Complainant cites other UDRP decisions the Panel would have preferred that the Complaint included the UDRP decisions in the Complaint and moreover, that in those submissions the relevant paragraphs would be marked or highlighted. The Panel finds that it cannot be expected that the Panel has knowledge of all decisions rendered in domain name conflicts. The provision of the relevant – according to Complainant and/or Respondent - marked decisions would facilitate the rendering of a decision in a UDRP case.

For now, the Panel decided to search for those decisions on the internet, itself. This could be done as under WIPO Overview 3.0, 4.5. it is established that a Panel can perform independent research, which to the believe of the Panel, could also be extended to relevant case law.

Having reviewed that, the Panel agrees with the citations of Complainant and its allegations, in short that, the disputed domain name should have been registered with knowledge of Complainant’s trademark and that the website to which it resolves is a copy of that of Complainant’s website concluding that it is used to intentionally attempt to attract, for commercial gain, the internet user by creating a likelihood of confusion.

Complainant has, to the satisfaction of the Panel, shown the disputed domain name has been registered and is being used in bad faith (within the meaning of paragraph 4(a)(iii) of the Policy).

The Panel is satisfied that all procedural requirements under UDRP were met and there is no other reason why it would be inappropriate to provide a decision.