hyperlinks some sponsored by Google but others not some related to motorcycles and cycling but others not One such other advertisement includes a link to a site apparently run by Respondent that sells electronic greeting cards another is about and

term hydroboost from the Google search engine substantiates the use of the term hydroboost as a hydraulically actuated brake component and is not specifically referencing the Robert Bosch Corporation /p p o p /o p /p p There was a motion put

a secondary meaning a quick Google search reveals that hundreds if not thousands of breeders clubs exist in the United States alone The vast majority of these clubs are involved in breeding dogs or cats as this is the business associated with

common term An advanced Google search for �gold medal � excluding �goldmedal.co.uk � and �travel � yielded 1.94 million results The first 100 Google search results annexed include Gold Medal Models Gold Medal Fishing Gold Medal Schools Gold

conducted through the GOOGLE YAHOO and MSN search engines revealed the Complainant �s web site as the number one search result for the term �MYSPACE � a copy of the abbreviated search results appear in Exhibit R to the Complaint According

�loreal color of hope � on Google.de allows the searcher to identify the Complainant Therefore taking into consideration these arguments as well as the fact that in this day and age of Internet and advancement in information technology it is

assertions Respondent s googlead.com domain name is confusingly similar to Complainant s GOOGLE mark Respondent does not have any rights or legitimate interests in the googlead.com domain name Respondent registered and used the googlead.com

Paragraph 4 a i See also Google Inc v Jon G FA 106084 Nat Arb Forum Apr 26 2002 finding googel.com to be confusingly similar to a complainant s GOOGLE mark and noting that t he transposition of two letters does not create a distinct mark

provided through the Google Adsense program The links in question are provided pursuant to Google s terms and are triggered by search requests entered by computer users Respondent has no control over what terms advertisers bid on at Google

assertions Respondent s googleadwords.com domain name is confusingly similar to Complainant s GOOGLE and ADWORDS marks Respondent does not have any rights or legitimate interests in the googleadwords.com domain name Respondent registered and

are provided pursuant to Google �s terms and are triggered by search requests entered by computer users There is allegedly no intent on Respondent �s part to target Complainant Respondent claims that it has no control over what terms

the issue of bad faith only A Google search for the word �usborne � reveals in excess of 2.5 million entries all of which in the book publishing context appear to the Panel to relate to the Complainant The Complaint annexes vast amounts of evidence

and that a simple search via Google using the keyword �danone � demonstrates that all first results relate to the Complainant �s products or news iii The mere addition of the word �food � being a generic term linked with the Complainant �s main

relate to Complainant The Google results demonstrate that the average user on the Internet would associate the word zero with something entirely different from Complainant s PZERO line of tires Because of the vast gulf in usages of zero and the

assertions Respondent s googlesky.com and googlecomputer.com domain names are confusingly similar to Complainant s GOOGLE mark Respondent does not have any rights or legitimate interests in the googlesky.com and googlecomputer.com domain name

and net or without running a Google or other Internet search engine search on �gals4free � Any such checks would have quickly led the Respondent to the Complainant �s website 4 Since the Domain Name has been registered it has simply been linked to

likely derived revenue from Google for impressions and click-throughs Moreover the website prominently featured the name �John Barrett � thereby diverting both current and prospective Elementage and John Barrett customers to Respondent �s

a mailing list to host ads by Google and to provide product endorsements The TRUE VALUE mark and domain were well established and in long use by Complainant when Respondent registered the domain Respondent is not entitled to continued registration

mark are inconsequential See Google Inc v DktBot.org FA 286993 Nat Arb Forum Aug 4 2004 The mere addition of a single letter to the complainant s mark does not remove the respondent s domain names from the realm of confusing similarity in relation

sedoparking �www groupemornay google co kr e g F D C InfoSpace � 6 9 d o sedo �mornay archive org �www nnn nushu leaflets fliers and or www.sedoparking.com www.groupemornay.com d b