Domain names newsletter, May 2022 | Hogan Lovells

[co-authors: Laëtitia Arrault, Sean Kelly, Cindy Mikul, Maria Rozylo, and Tony Vitali]

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For earlier Anchovy News publications, please go to our Domain Names practice page. Learn extra about Anchovy® – Global Domain Name and Internet Governance here.

Domain title business information

TMCH decommissions TREx service

The Trademark Clearinghouse (TMCH) announced a couple of weeks in the past that it was suspending its model safety service known as TREx (Trademark Registry Exchange) as a result of present low curiosity in such a service.

TREx is a service developed by the TMCH enabling commerce mark holders to limit the registration of their manufacturers as area names throughout 40 Top Level Domains (TLDs). It is price noting that the service won’t be interrupted instantly, as all of the manufacturers, or “labels”, that are presently lined by it is going to proceed to be protected till their respective expiration dates.

Subscribers to the service have their labels protected in two alternative ways relying on the TLDs, specifically by way of “Registration Track” (for instance .DE, .LA, .LONDON, .VIP or .WORK) and by way of “List Track” (for instance .CAT, .COLOGNE, .JOBURG, .QUEBEC or .SCOT).

Labels which might be protected by way of Registration Track have been registered as area names. Therefore, as soon as the TREx service expires for these labels, the corresponding area names will enter a Grace Period earlier than being deleted.

Labels which might be protected by way of List Track weren’t registered as area names, reasonably the area names have been blocked for registration. Thus as soon as the TREx service expires for these labels, the corresponding area names will likely be out there for registration instantly, and by anybody. Subscribers to the TREx service won’t have precedence to register these area names.

However, the TMCH has put into place an “override course of” with a purpose to allow TREx subscribers to safe their area names. The override course of must be actioned previous to the expiry of the TREx service and works as follows:

  • For Registration Track protected labels: the TREx subscriber liaises with the TMCH with a purpose to receive the auth codes for the area names they want to preserve, then they organize the switch of the area names to a registrar.
  • For List Track protected labels: the TREx subscriber liaises with a registrar and supplies them with the checklist of area names to safe together with the related SMD information for the varied labels. The registrar then liaises with the related Registries which is able to launch the area names to them after checking the SMD information.

The TMCH said that they’d “probably revive the TREx service” when the second spherical of latest gTLDs begins, as they “do consider {that a} blocking product might be efficient when there may be extra motion throughout the area title business”. They additionally mentioned that they’re “presently taking a look at a broader, simpler and environment friendly portfolio of brand name safety companies which is able to embrace extra functionalities.” We will in fact hold our Anchovy News readers knowledgeable of any developments.

For extra data, please contact David Taylor or Jane Seager.

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WIPO quickly suspends Ukrainian UA-DRP

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Hostmaster, the Ukrainian area title Registry, not too long ago introduced that the World Intellectual Property Organization (WIPO) had quickly suspended its area title dispute decision companies underneath the .UA Domain-Name Dispute-Resolution Policy (UA-DRP) and that it could not settle for any new .UA area title registration requests till additional discover.

WIPO introduced the choice by including a observe to its internet web page that details the UA-DRP procedure stating that: “In session with the .UA Registry, the Center has decided that it’s not able to simply accept new .UA filings underneath the .UA Policy till additional discover.”

In its announcement made on 27 April 2022, Hostmaster said that “the choice is because of the truth that Ukrainian registrars and registrars could now be disadvantaged of the chance to completely take part in arbitration proceedings.” It added that the out-of-court dispute decision process will likely be resumed after the tip of martial legislation in Ukraine.

WIPO has been dealing with .UA disputes since 2019 and about 60 instances have been determined to this point.

This transfer follows the latest announcement by Hostmaster that it was pausing area title deletions on account of the continued battle in Ukraine. As reported in Anchovy News last month, the redemption interval, which often lasts for a interval of 30 days following the expiry of a .UA area title, will now run till the tip of the present interval of martial legislation.

For extra details about this, please contact David Taylor or Jane Seager

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International recognition of .DE area names reaches all-time excessive

DENIC, the Registry liable for operating Germany’s .DE nation code Top Level Domain (ccTLD), has not too long ago revealed .DE area title statistics, which show the worldwide recognition of the .DE area title house.

According to DENIC, on the finish of 2021 there have been a complete of 17,160,504 .DE area names held in DENIC’s database, of which practically 1.7 million had registrants positioned outdoors of Germany. This determine represents a rise of 244,000 area names, or virtually 50%, as DENIC recorded 128,000 worldwide registrations in 2020. The 1.7 million worldwide .DE registrations additionally symbolize 9.88% of all .DE registrations, in comparison with 8.7% in 2020.

A breakdown of the worldwide .DE registrations exhibits that the United States had the most important share with 21% of the overseas .DE inventory. This is sort of half of the whole share of the six international locations of Netherlands, Austria, Switzerland, Great Britain, Portugal and France, which represents 38.7%. This latter determine elevated by 3.6% in comparison with 2020, while the share of non-European international locations was comparatively unchanged and accounted for 16%.

Even with the numerous enhance in internationally registered .DE area names, greater than 90% of .DE area names are registered domestically in Germany, which represents virtually 15.5 million area names. According to DENIC, this determine accounts for 60% of all area names registered in Germany and thus .DE clearly stays “the market chief within the nationwide area market”.

Nonetheless, the variety of worldwide registrants does show the recognition of the .DE area title house, with the share frequently rising over time and spreading out internationally.

To go to DENIC, please click on here.

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Domain title recuperation information

Complainant loses Bette

In a latest choice underneath the Uniform Domain Name Dispute Resolution Policy (UDRP) earlier than the World Intellectual Property Organization (WIPO), a Panel denied the switch of the Domain Name at problem because it was registered earlier than the Complainant was capable of show that it had commerce mark rights, and the Respondent’s rationalization that it was registered as a result of it was a typical feminine title was “believable”.

The Complainant was Bette GmbH & Co. KG, a German firm based in 1952 and specialised in manufacturing and promoting lavatory furnishings and merchandise. It held a number of commerce marks for BETTE, together with an International commerce mark (designating United Kingdom) registered in 2003. It additionally owned a site title my-bette.com, which was registered in 2019 and pointed to its official web site out there in seven languages.

The Domain Name was bette.com, registered in 1998 by way of a privateness registration service. It beforehand pointed to a parking web page with pay-per-click (“PPC”) hyperlinks to 3rd events providing bath-related merchandise, together with the Complainant’s rivals. The parking web page additionally contained a hyperlink to the Sedo area title public sale web site, stating that the Domain Name “could also be on the market” for “35000 GBP”.

The Respondent, Anthony Stewart, was based mostly within the United Kingdom. He said that he was the unique registrant and that, in 2015, he was approached by the Complainant and declined its provide to buy the Domain Name for EUR 1,000.

To achieve success in a grievance underneath the UDRP, a complainant should fulfill the next three necessities:

(a) The area title registered by the respondent is an identical or confusingly much like a commerce mark or service mark wherein the complainant has rights; and

(b) The respondent has no rights or reputable pursuits in respect of the area title; and

(c) The area title has been registered and is being utilized in unhealthy religion.

With respect to the first limb, the Complainant contended that the Domain Name was an identical to its BETTE commerce marks, no matter the truth that its commerce marks have been registered after the Domain Name was created. This assertion was accepted by the Panel. The first limb was subsequently glad.

Regarding the second limb, the Complainant argued that the Respondent had no permission to utilize its commerce marks whereas the Respondent claimed that he registered the Domain Name to determine a feminine dealing with on-line betting web site, with none intent to focus on the Complainant and its enterprise. The Respondent added that the title Bette was a typical spinoff of the title Elisabeth and said that, as first title area names have been extremely wanted, he had refused quite a few provides from potential patrons over time.

The Panel thought-about that the Respondent, regardless of his holding of the Domain Name for twenty-four years, had failed to offer any proof of demonstrable preparations to make use of it in connection together with his said undertaking. Furthermore, the Respondent’s use of the Domain Name to level to a parking web page with PPC hyperlinks and provide to promote the Domain Name couldn’t be considered a bona fide providing of excellent and companies underneath the UDRP. For these causes, the Panel discovered that the Respondent had not established rights or reputable pursuits within the Domain Name and so the second limb was additionally glad.

As far because the third limb was involved, the Complainant argued that the Respondent’s use of the Domain Name to level to a parking web page with PPC hyperlinks redirecting to competitor web sites and his provide to promote the Domain Name for an quantity largely exceeding out-of-pocket prices clearly indicated unhealthy religion. The Respondent denied having management over the content material of the parking web page to which the Domain Name resolved, claiming that each the PPC hyperlinks and provide to promote the Domain Name have been robotically generated. He additional argued that he registered the Domain Name in good religion because it was created 5 years earlier than the Complainant registered its earliest commerce mark for BETTE and 21 years earlier than the Complainant registered its area title my-bette.com.

Given the early registration date of the Domain Name, the Complainant filed a supplemental submitting with further proof to determine its frequent legislation commerce mark rights on the time of registration of the Domain Name, together with an earlier German design commerce mark (subsequently deserted) and its historic gross sales volumes within the interval 1996-98.

With regard to the Complainant’s supplemental submitting, the Panel thought-about that this submitting didn’t handle any newly found proof and the Complainant ought to have anticipated that it could be required to determine its frequent legislation commerce mark rights for the needs of the third limb when submitting the Complaint. In spite of this, the Panel nonetheless determined to consider the extra proof for the restricted functions of addressing the Respondent’s unhealthy religion on the time of registration of the Domain Name. In the Panel’s opinion, the extra proof offered by the Complainant was not adequate to assist its frequent legislation commerce mark rights in gentle of the standards laid out in WIPO Overview 3.0, part 1.3, which supplies:

“To set up unregistered or frequent legislation trademark rights for functions of the UDRP, the complainant should present that its mark has turn into a particular identifier which shoppers affiliate with the complainant’s items and/or companies.

Relevant proof demonstrating such acquired distinctiveness (additionally known as secondary which means) features a vary of things resembling (i) the length and nature of use of the mark, (ii) the quantity of gross sales underneath the mark, (iii) the character and extent of promoting utilizing the mark, (iv) the diploma of precise public (e.g., client, business, media) recognition, and (v) client surveys.”

Despite the Complainant’s lengthy historical past (based in 1952) and its continued use of the title Bette, the Panel thought-about that the Complainant had didn’t substantiate its frequent legislation commerce mark rights in 1998, even with the unsupported statements of gross sales within the interval 1996-98 submitted in its supplemental submitting.

In any occasion, the Panel discovered that the Respondent’s motive for registering the Domain Name based mostly on a typical feminine title was believable, and there was no compelling motive to conclude that he had prior information of the Complainant or meant to focus on it when registering the Domain Name in 1998. The proven fact that the Respondent by no means contacted the Complainant to promote the Domain Name and held it for years with out itemizing it on the market additional indicated the shortage of unhealthy religion.

In view of the above, the third limb was not glad and the Complaint was denied.

Comment

This case illustrates, as soon as once more, that to achieve success underneath the UDRP complainants should show each unhealthy religion registration AND use. In instances resembling this, the place the Complainant’s registered commerce marks post-date registration of the Domain Name, it’s usually tough to show unhealthy religion registration and procure a switch order. In such instances, complainants have an uphill battle to determine not solely the existence of unregistered commerce mark rights on the time of the registration of the area title, but additionally that the respondent was conscious of those rights and was concentrating on them.

The choice is offered here.

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Complainant loses to a “gripe web site”

In a latest choice underneath the Uniform Domain Name Dispute Resolution Policy (UDRP) earlier than the World Intellectual Property Organization (WIPO), a three-member Panel denied a Complaint for the Domain Name doesryankavanaughlooklikeharveyweinstein.com, discovering that the Respondent’s use for a non-commercial criticism web site was protected underneath the UDRP.

The Complainant was a United States movie financier and movie and tv producer whose title appeared within the Internet Movie Database in reference to various movies and TV sequence for which he was a producer. The Complainant’s area title rkavanaugh.com resolved to his private web site. On 15 November 2021, the Complainant filed a United States commerce software for RYAN KAVANAUGH underneath Serial No. 97125566, with an alleged first use in commerce date of 18 May 2004.

The Respondent was a Swedish entity and agent for Ted Entertainment, Inc. (“TEI”), based mostly within the United States. TEI produced the H3 Podcast, which had criticised the Complainant.

The disputed Domain Name was registered on 16 October 2021, and resolved to an internet site that featured pejorative, essential statements concerning the Complainant and in contrast him to Harvey Weinstein. The web site on the disputed Domain Name included banners asking “Does Ryan Kavanaugh Look Like Harvey Weinstein?”, statements detailing elements of the Complainant’s private {and professional} historical past, together with his private {and professional} affiliation with Harvey Weinstein, and statements on and hyperlinks to information articles detailing his purported arrest for drunk driving, his purported involvement in a Ponzi scheme, and different incidents purportedly involving him. The web site additionally included a hyperlink to a YouTube video, which was an episode of the H3 Podcast that includes criticism of the Complainant, and dialogue of stories articles that includes him.

To achieve success in a grievance underneath the UDRP, a Complainant should fulfill the necessities of paragraph 4(a) of the UDRP, specifically that:

(i) The area title registered by the respondent is an identical or confusingly much like a commerce mark or service mark wherein the complainant has rights; and

(ii) The respondent has no rights or reputable pursuits in respect of the area title; and

(iii) The disputed area title has been registered and is being utilized in unhealthy religion.

As far because the first limb was involved, the Complainant contended that the Domain Name was confusingly much like his RYAN KAVANAUGH commerce mark, in that it reproduced the commerce mark in its entirety together with quite a few adverse phrases. The Respondent argued that the Domain Name posed a query for dialogue and commentary, specifically “Does Ryan Kavanaugh Look Like Harvey Weinstein?” and that the added phrases created a unique impression from the Complainant’s commerce mark, and have been unlikely to create confusion with the commerce mark.

In this regard, two Panel members discovered that the extra parts (“does” earlier than and “look”, “like”, and “Harvey Weinstein” after) resulted in a really completely different total impression that was not confusingly much like the Complainant’s commerce mark, whereas the third Panel member was of the opinion that the addition of those different phrases wouldn’t negate a discovering of complicated similarity as a result of the Complainant’s commerce mark was recognisable throughout the Domain Name. However, given the Panel’s unanimous discovering underneath the second and third limbs, this distinction of opinion amongst the Panel members with regard to the primary limb didn’t have an effect on the result.

With regard to the second limb, the Panel famous that the disputed Domain Name truly posed an implied query, specifically “Does [the Complainant] resemble [a former film producer convicted of sex crimes]?”, and that Internet customers viewing the corresponding web site wouldn’t be misled as to its supply or sponsorship. The Panel discovered that the web site was by all appearances a real “gripe web site” rife with non-commercial criticism of the Complainant in numerous types, together with photographic composites of the Complainant and Harvey Weinstein, accompanied by statements that they have been visually related people, which implied that, within the Respondent’s view, the Complainant was as objectionable as Harvey Weinstein. Regarding the Complainant’s allegation that the Respondent competed with him based mostly on the hyperlink to the YouTube video of the H3 Podcast on the Respondent’s web site, the Panel held that the YouTube video hyperlink evinced solely a minimal, incidental diploma of economic exercise, and that the Respondent’s web site was primarily devoted to non-commercial criticism. The Panel additional rejected the Complainant’s declare that similarities between the Respondent’s web site and the Complainant’s web site conveyed an affiliation together with his commerce mark, discovering that the similarities cited by the Complainant have been superficial, and will feasibly be shared by many web sites criticising or commenting on the Complainant. The Panel concluded that the Complainant had subsequently didn’t fulfill the necessities of the second limb.

Regarding the third limb, the Panel dismissed the Complainant’s assertion that the Respondent’s web site was one in every of a number of competitor web sites getting used to explain the Complainant’s companies, discovering that the Respondent and the Complainant weren’t rivals and that the Respondent’s web site was getting used for non-commercial, reputable criticism of the Complainant. The Panel was unconvinced by the Complainant’s argument that redirecting site visitors to web sites that offered “lies for the aim of economic acquire” violated the UDRP, in that the Complainant had didn’t show that Internet site visitors flowing to the Respondent’s web site had resulted from unhealthy religion on the Respondent’s half. The Panel concluded that it was past its means and the scope of the UDRP to evaluate whether or not the Respondent’s web site was defamatory, noting that the Complainant had not recognized which statements made by the Respondent on the web site have been “lies”. The Panel subsequently discovered that the Respondent’s registration and use of the Domain Name was not in unhealthy religion.

Despite their completely different opinions relating to the primary limb, finally the Panel unanimously held that the Respondent was utilizing the Domain Name for real non-commercial free speech, and never as a pretext for cybersquatting or business exercise to misleadingly divert the Complainant’s prospects. The Complaint was subsequently dismissed.

The choice is offered here.

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Unsubstantiated chain of occasions for biking firm

In a latest choice underneath the Uniform Domain Name Dispute Resolution Policy (UDRP) earlier than the World Intellectual Property Organization (WIPO), a three-member Panel refused to switch the disputed area title protanium.com, discovering that the Complainant had didn’t show that the Domain Name had been registered in unhealthy religion.

The Complainant was Protanium B.V., a Dutch firm integrated in 2008 and wholly owned by Accell Global B.V., a European chief in e-bikes, bicycle components and equipment. The Complainant was the proprietor of a number of commerce mark registrations for PROTANIUM, together with in Denmark (figurative mark registered in 1995), the European Union (phrase mark registered in 2008) and the United Kingdom (phrase mark registered in 2008).

The Respondent was Lars Munskoe, positioned in Denmark. He was one of many shareholders (holding 20% of the shares) and a member of the board of the Complainant from 2008 to October 2015, when he left the corporate after executing a settlement settlement with the Complainant. The Respondent registered the Domain Name in 2006. It resolved to an internet site offering details about PROTANIUM merchandise and historical past, with the final updates courting again to 2014.

The Complainant initiated proceedings underneath the UDRP for a switch of possession of the Domain Name. To achieve success underneath the UDRP, a complainant should fulfill the necessities of paragraph 4(a) of the UDRP, specifically that:

(i) the disputed area title is an identical or confusingly much like a commerce mark or service mark wherein the complainant has rights;

(ii) the respondent has no rights or reputable pursuits within the disputed area title; and

(iii) the disputed area title was registered and is being utilized in unhealthy religion.

Under the first ingredient of paragraph 4(a) of the UDRP, the Complainant argued that the Domain Name was an identical to its commerce mark PROTANIUM because it reproduced the commerce mark in its entirety. The Panel thought-about, after establishing that the commerce marks have been nonetheless registered on the time of the drafting of the choice, that the Complainant had confirmed that the Domain Name was an identical to the commerce mark, as PROTANIUM was solely reproduced within the Domain Name.

With regard to the second ingredient of paragraph 4(a) of the UDRP, the Complainant claimed that the Respondent had no rights within the Domain Name, arguing that:

(i) the commerce mark PROTANIUM was registered in 1995 whereas the Respondent registered the Domain Name in 2011,

(ii) the Respondent had full information of the Complainant’s mental property portfolio, together with patent rights registered by the Complainant however invented by the Respondent when he was a board member and shareholder of the Complainant;

(iii) pursuant to the 2015 settlement settlement between the Complainant and the Respondent, all rights and obligations between the events had ended and the Respondent now not owned shares within the Complainant and was not licensed by it to make use of its mental property rights in any manner;

(iv) the Respondent was not generally recognized by the Domain Name and didn’t make honest use of it as a result of, by registering the Domain Name and pointing it to an internet site offering data on the Complainant’s historical past, philosophy, services, the Respondent had tried to falsely recommend an affiliation with the Complainant; and

(v) the web site to which the Doman Name resolved additionally offered data on different manufacturers owned by the Accell Group and wherein the Respondent had no rights.

The Respondent countered that he had all the time been the reputable proprietor of the Domain Name since 2006 and that he had quickly, between 2008 and 2015, granted the Complainant use of the Domain Name when he was a supervisor and shareholder of the Complainant. The Respondent additionally argued that the Domain Name had all the time been maintained and paid for by him and never by the Complainant, that it had been greater than 6 years since he stopped working for the Complainant and that the Complainant owned its personal official area title protanium.nl registered in 2016, however by no means used. The Respondent rejected the Complainant’s declare to unique rights in PROTANIUM based mostly on commerce mark registrations in a couple of international locations and identified that many different individuals or corporations in different international locations had registered PROTANIUM as a commerce mark. The Respondent additional indicated that, to his information, the Complainant had stopped promoting PROTANIUM-branded merchandise shortly after he left the corporate and that subsequently the commerce marks weren’t in use. In addition, the Respondent knowledgeable the Panel that as a result of non-use of the commerce mark by the Complainant, the Respondent had filed, in January 2022, a European Union commerce mark software for PROTANIUM, within the title of his firm Lynx ApS, in addition to revocation functions in opposition to the Complainant’s European Union and Danish commerce mark registrations for PROTANIUM.

The Panel didn’t choose it obligatory to deal with the query of the Respondent’s rights and bonafide pursuits as a result of it concluded that the Complaint had failed on the third ingredient.

Under the third ingredient of paragraph 4(a) of the UDRP, the Complainant contended that the Respondent had registered and used the Domain Name in unhealthy religion and that he was actively stopping it from reflecting its commerce mark within the Domain Name.

With regard to unhealthy religion registration, the Complainant argued that the Respondent, in his capability as former board member and shareholder of the Complainant, had registered the Domain Name with out the Complainant’s consent, however with full information of its mental property rights, as highlighted by the content material of the web site which included data on the Complainant’s historical past, philosophy, services in addition to patent rights owned by the Complainant reasonably than the Respondent himself. The Complainant thought-about that the Respondent couldn’t have ignored the Complainant’s commerce mark rights given his former place as shareholder and board member and the prior relationship between the events. The Complainant additionally identified that the Respondent’s former place couldn’t justify using the commerce mark PROTANIUM with out the Complainant’s consent.

With regard to unhealthy religion use, the Complainant claimed that, in violation of the settlement settlement which requested disclosure by the Respondent of the required data relating to the affairs of the corporate, together with on mental property issues, the Respondent had by no means notified the Complainant of the possession of the Domain Name, and had not handed over any related knowledge on the subject. The Complainant added that the Respondent had been utilizing a privateness defend to cowl his identification, excluding himself from the necessity to adjust to the abovementioned obligation.

The Respondent denied the allegation of unhealthy religion registration and use and identified that (i) the Complainant was integrated in 2008, two years after he registered the Domain Name and, subsequently he had not registered the Domain Name with the Complainant in thoughts, (ii) to one of the best of his information, the Complainant had ceased to be in enterprise for a few years and the inactive firm was offered in 2019 to concentrate on a unique model title and now not on PROTANIUM branded items, and (iii) contemplating the Complainant was now not an energetic enterprise and had not been for a few years, it was extremely unlikely that the Complainant would want the Domain Name to conduct enterprise, certainly it was extra doubtless that the Complainant’s intention was to promote the Domain Name for revenue to the proprietor of its remaining actions, i.e. the useful proprietor Protanium GmbH, based mostly in Switzerland.

The Panel held that the Complainant had didn’t show that the Respondent had registered the Domain Name in unhealthy religion. First, within the absence of substantiating proof, the Panel rejected the Complainant’s assertion that the Domain Name had been registered by the Respondent in 2011, and relied on information indicating that the Domain Name was registered in 2006, i.e. two years earlier than the Complainant’s incorporation. Then, with regard to the Danish commerce mark registered in 1995, the Panel identified that public information indicated that the commerce mark was acquired by the Complainant in 2008 by way of a switch from a predecessor in rights. The Panel additionally famous, as indicated by the Respondent, that the Domain Name resolved to an internet site offering data on the Complainant, its merchandise, patent rights and historical past, together with the inspiration of Protanium in 2006 by the Respondent and one other particular person and that such web site was up to date till 2014, the Respondent having left the Complainant in 2015. Therefore, in view of the circumstances of the case, the Panel discovered that, on stability of possibilities, the Respondent had maintained and used the Domain Name for the aim of selling the PROTANIUM commerce mark and merchandise throughout his time as member and shareholder of the Complainant.

The Panel concluded that, given the registration date of the Domain Name and the character of the dispute between the Parties, there was no clear case of cybersquatting underneath the UDRP, however as a substitute a fancy dispute that ought to be extra correctly addressed in a civil courtroom. The Complaint was subsequently denied.

This choice exhibits the significance and the relevance of the commerce mark and area registration dates in the case of assessing unhealthy religion registration claims underneath the UDRP. It can also be a reminder that UDRP Panels will usually deny instances that transcend the scope of cybersquatting the place there are extra sophisticated points to contemplate, and that is very true when events are concerned in parallel commerce mark disputes (revocation proceedings on this specific case).

The choice is offered here.

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https://www.jdsupra.com/legalnews/domain-names-newsletter-may-2022-6751676/

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