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Accordingly, the Panel finds that Complainant has demonstrated its rights in the CIALIS mark pursuant to Policy � 4(a)(i). Complainant argues that all of the domain names identified in this proceeding are confusingly similar to the CIALIS mark through the incorporation of the mark fully, and with the addition of generic/descriptive words like �buy,� �cheap,� and �generic,� geographic terms �Canada� or �Canadian,� along with gTLDs �.com,� �.org,� or �.net.� Neither the addition of generic, descriptive nor geographic terms serve to adequately distinguish a respondent�s domain from a mark in which a complainant has rights. Express Co. v. MustNeed.com, FA 257901 (Forum June 7, 2004) (finding the respondent�s domain name confusingly similar to Complainant�s AMEX mark because the �mere addition of a generic or descriptive word to a registered mark does not negate� a finding of confusing similarity under Policy � 4(a)(i)); see also Trip Network Inc. Alviera, FA 914943 (Forum Mar.

Product	Dosage	Quantity + Bonus	Price
Cialis Generic	10mg	270 + 10 Pills	308.71€ 294.01€	Buy
Cialis Black	80mg	90 + 6 Pills	207.88€ 197.98€	Buy
Cialis Professional	40mg	270 + 6 Pills	898.37€ 855.59€	Buy
Cialis Super Active	20mg	120 + 16 Pills	382.15€ 363.95€	Buy
Cialis Black	80mg	270 + 10 Pills	502.88€ 478.93€	Buy
Cialis Generic	60mg	90 + 6 Pills	196.67€ 187.30€	Buy
Cialis Generic	5mg	60 + 4 Pills	86.02€ 81.92€	Buy
Cialis Generic	20mg	30 + 4 Pills	68.05€ 64.81€	Buy
Cialis Generic	20mg	20 Pills	54.72€ 52.11€	Buy
Cialis Generic	20mg	60 + 6 Pills	117.76€ 112.15€	Buy
Cialis Generic	5mg	180 + 10 Pills	159.65€ 152.05€	Buy
Cialis Generic	2.5mg	360 + 10 Pills	260.03€ 247.65€	Buy
Cialis Soft Tabs	20mg	270 + 10 Pills	471.40€ 448.95€	Buy
Cialis Generic	2.5mg	90 + 6 Pills	112.43€ 107.08€	Buy
Cialis Generic	2.5mg	180 + 10 Pills	154.86€ 147.49€	Buy

27, 2007) (finding that the addition of geograhic terms, such

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Further, all the active websites associated with the domain names resolve to the same online pharmacy, which promotes and allegedly sells �generic� versions of CIALIS brand product, not approved by the U.S. Food and Drug Administration (�FDA�). The attempted sale of counterfeit pharmaceutical products does not represent a bona fide offering of goods or services or any legitimate noncommercial or fair use. Respondents registered and use the domain names in bad faith. First, Respondents have engaged in a pattern of bad faith registration and use through their registration of over 430 domains in the current proceeding.

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Second, Respondents� use of the domains to promote products that compete with Complainant�s business is disruptive. Third, Respondents� use of the domains to sell competing products constitutes bad faith registration and use pursuant to Policy � 4(b)(iv). Fourth, Respondents� use of the domains is potentially harmful to the health of many unsuspecting consumers who may purchase unlawfully sold pharmaceutical products promoted through Respondents� resolving websites. Finally, based on Complainant�s well-known CIALIS trademark, Respondents must have registered the domains with actual or at least constructive knowledge of Complainant�s mark and its rights therein. There are over 400 domain names at issue in this proceeding and over 100 respondents of which only one has submitted a Response to the Complaint. as �cancun� to the end of the CHEAPTICKETS mark in

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Respondent Dr. Adam Joo has informed the Forum he consents to the transfer of the , , and domain names.� Based on the evidence, the remaining Respondents are part of the PharmEmpire, a network that advertises and sells generic versions of Complainant�s CIALIS brand product.� These Respondents are listed in Annex 2 to the Complainant and their identities are part of the record in this proceeding. Complainant holds trademark rights for the CIALIS mark.� Respondents� domain names are confusingly similar to Complainant�s CIALIS mark.� Complainant has established that Respondents lack rights or legitimate interests in the use of the domain names described herein and that the Respondents, with exception of Dr. Adam Joo, registered and use the domain names in bad faith. Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable." Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred: (1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (2) Respondent has no rights or legitimate interests in respect of the domain name; and (3) the domain name has been registered and is being used in bad faith.

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In this proceeding, Complainant has alleged the entities which control the domain names at buy cialis uk cheap issue are effectively controlled by the same person and/or entity, which is operating under several aliases.� Paragraph 3(c) of the Rules for Uniform Domain Name Dispute Resolution Policy (the �Rules�) provides that a �complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.� Complainant has set forth the following information in support of its argument that all of the domain names at issue in this proceeding are under common control: According to LegitScript, a company providing assistance with this proceeding, the Domain Names have been identified as under control of single criminal enterprise.� The active websites associated with the Domain Names are part of the PharmEmpire network that advertises and sells generic versions of Complainant�s CIALIS brand product.� Further, all of the websites associated with the Domain Names use the same template on the landing pages and redirect customers to trustedpharmacy24.com once a product is selected.� �Additionally, all of the websites associated with the Domain Names use the dedicated payment portal secure-bill.net to collect payment information from users. In each case, the Domain Names were registered using the contact information for a US-based medical practitioner or practice and it is likely that the Domain Names have been registered without the knowledge or consent of the individuals named in the Whois records. Moreover, the Domain Names were registered at both Nanjing Imperious Technology, Co. Ltd., and Vautron Rechenzentrum AG using the same identities on the same dates.� For example, on May 2, 2016, Domain Names were registered at both registrars using the names Marian Garcia, Evan Swanson, Bridgette Latimer, and Alison Stocks.� Other commonalities include, of course, that the Domain Names contain the CIALIS trademark and all of the Domain Names were registered in 2015 and 2016. (citations to the record omitted).� Based on the foregoing uncontradicted evidence in the record, the Panel concludes the Complainant has established that the all of the domain names described in this proceeding are under common control within the meaning of Paragraph 3(c).� One exception concerns Respondent Dr. the , , , and

• Ensure that the Canadian pharmacy requires a valid prescription.
• Look for pharmacies with positive customer feedback.
• Confirm if they ship to your country and shipping costs.
• Check for pharmacy certifications and associations.
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domain names, does not

Method	Delivery Time	Cost	Countries Served	Notes
Standard Postal	10–21 days	Low	Worldwide	No tracking, slower
Express DHL/UPS	3–7 days	Higher	US, Canada, EU	Trackable, fast
Courier Service	5–10 days	Moderate	North America, Europe	Reliable, insured

overcome a finding of confusing similarity under Policy � 4(a)(i)).

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Adam Joo, which is discussed below. Preliminary Issue B: Consent to Transfer / Identity Theft One of the many Respondents, Dr. Adam Joo, has submitted a formal Response stating he has not registered or authorized registration of the , , and domain names.� Respondent Joo has stated he �does not object to transfer or cancellation of the domain names and is willing to execute a transfer agreement of said domain names.�� Implicit in his Response is a claim of stolen identity as he disclaims any knowledge of the registration of the foregoing domains. After the initiation of this proceeding, Nanjing Imperiosus Technology Co. Ltd.

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and Vautron Rechenzentrum AG placed holds on Respondent Joo�s accounts and therefore he cannot transfer these domain names while this proceeding is still pending.� Accordingly, because Respondent Joo has not contested the transfer of the three domain names but instead agrees to transfer the domain names in question to Complainant, the Panel chooses to forego the traditional UDRP analysis and order an immediate transfer of the , , and domain names.� See Boehringer Ingelheim Int�l GmbH v. Modern Ltd. � Cayman Web Dev., FA 133625 (Forum Jan. 9, 2003) (transferring the domain name registration where the respondent stipulated to the transfer); see also Disney Enters., Inc. v.