the results of its search at google.com as an annexure to its Complaint A Respondent a The domain name is identical or confusingly similar to a trade mark or service mark in which the Complainant has rights The Respondents acknowledge that the

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

a business index and Google searches both show results for the Respondent Nishan Limited The Kellysearch shows two business addresses for the Respondent one in Watford and one in Harrow The telephone and facsimile numbers given for the

de una búsqueda realizada en Google que arroja 27000 páginas como resultado al introducir las palabras inter law Cita la Demandada algunos casos anteriores en los cuales no se ha encontrado mala fe debido al uso de términos genéricos como marca

Respondent claims that a Google search revealed over 495000 references to chevron Many U.S companies operate under the mark CHEVRON either alone or combined with other terms Respondent claims that his privately owned company Lagna Medallion

to the address returned by a Google search are those contained in the previous domain name decisions against the Respondent The Complainant submits that the Respondent has provided false identification and contact information and that the address

on the Internet search engine Google.com for the word windows yields innumerable third-party web pages The Israeli address referred to by the Complainant is in fact the address of Respondent s business activities The Respondent maintains offices

sense On the search engine google.com the word Scuderia yields 66.800 hits scuderia.com is a site for motorcycles But also in other fields of sport the term Scuderia is used as a description of a team such as in the field of wrestling The

of this Respondent introduced Google search results that found 6230000 matches for xbox while Google search results found only 674 matches for xobx Response Annexes C.1 and C.2 Respondent acknowledged that the vast majority of the 674 matches

from an established mark see Google v Namerental.com D2001-0060 Finding that the domain name ggoogle.com was confusingly similar to the Complainant s GOOGLE mark see also American Airlines Inc v Zuccarini FA0009000095695 finding that the domain

10 different searches on Google regarded as the most complete search engine on the Internet Most key word phrases used were taken directly by the Complainants own descriptions Florida Real Estate Developers Florida Real Estate Florida Real

standard and the online Google Glossary a well-respected lexicon of technology phrases and standards fails to list mmode The evidence of use of mmode by one supplier and two other domain name registrants prior to December 28 2001 is

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

most common search engines Google Virgilio and Yahoo The Complainant commented that the Respondent proved to be familiar with the use of Internet since it has registered a domain name and therefore a search in the above mentioned search engines

from an established mark see Google v Namerental.com D2001-0060 Finding that the domain name ggoogle.com was confusingly similar to the Complainant s GOOGLE mark see also American Airlines Inc v Zuccarini FA0009000095695 finding that the domain

two Internet search engines Google and Yahoo each return the familymeds.com website as the first choice The Respondent easily could have determined that family meds was already associated with the Complainant even assuming that he did not know

registered as a trademark A Google search of the phrase We Are Sports led to 610 instances of the phrase used by organizations engaged in various facets of sports and sports commerce Complainant never uses the phrase on its own but generally on

carried out a worldwide Google search on the internet on August 19 2002 using Aspreys and casino and no casino or similar business using the name Aspreys was revealed It is submitted that the Respondent does not operate a business called

substantial third party use A google.com search for the word MADRID yielded over 8.4 million web pages containing the term Exhibit l Response There are over 2000 registered domain names com net and org which incorporate madrid Exhibit 3 Response

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