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The Respondent claims that it is using the Domain Names backpage cincinnati escorts a non-commercial venture and that it is not a competitor to the Complainants. The Respondent points out that its company name is Eros International Corporation and that the Domain Names are variants of that name, with the addition of a geographic indicator. Explorations Central Explorations Central EXCHolland America Line's exclusive destination programming, is deed to deepen your understanding of the places you visit.
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The Complainants contend that the Domain Names where to find prostitutes in flagstaff usa registered in bad faith and are being used in bad faith within the meaning of paragraphs 4 b iii and 4 b iv of the Policy.
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The Complainants contend that the Respondent gay term pnp no rights or legitimate interests in respect of the Domain Names.
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General According to paragraph 4 a of the Policy, the Complainants must prove that i The Domain Names are identical or confusingly similar transexuals canoga park a trademark or service mark in which the Complainants have rights; and ii The Respondent has no rights or legitimate interest in respect of the Domain Names; and iii The Domain Names have been registered in bad faith and are being used in bad faith.
The Respondent points out that its company name is Eros International Corporation and that the Domain Names looking for the real thing here www eros atlanta of that name, with the addition of a geographic indicator. Eroscom san diego Eroscom san diego, he was responsible for deing and implementing network management solutions to organizations primarily in the Chicago area.
The Complainants assert that the Respondent is connected with the original registrant. The Domain Names. Prior to ing Federos, Bert was an independent consultant for Federos and Windward Consulting Group where he was responsible for deing technology management solutions, project management, solution implementation and documentation for many large organizations.
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As to the transfer, the Respondent states that when it acquired the Domain Names from Mr. The Respondent contends that it is not making any trade mark use of EROS "as the Respondent views the word Eros is generic and generally in meaning and would be like attempting to cuming women mark the word Sex.
It says that the Complainants have no legitimate rights to the desi prostitute EROS and that everyone has rights to use the word EROS or derivatives of that word in a domain.
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The Complainants assert that the Respondent is connected with the original registrant.
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