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22, 2014) (�As mentioned above, Respondent uses the domain name to promote counterfeit goods like those offered by Complainant.� Doing so disrupts Complainant�s business and demonstrates Respondent�s bad faith under Policy � 4(b)(iii).�).

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Joo. Complainant contends that Respondents� use of the domains to promote counterfeit products that compete with Complainant�s business is disruptive. A respondent�s use of a domain to sell counterfeit products that are directly competitive with a complainant�s business constitutes bad faith registration and use. See H-D U.S.A., LLC v. Linchunming / linchunming, FA1411001589214 (Forum Dec. For this reason, the Panel finds that Respondents have engaged in bad faith registration and use per Policy � 4(b)(iii). Complainant argues that Respondents� use of the domains to sell competing products constitutes bad faith registration and use.

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A respondent engages in bad faith where it uses a domain to sell counterfeit products that are directly competitive with a complainant�s business. 23, 2009) (determining that the respondent�s selling of counterfeit products creates the likelihood of confusion as to the complainant�s affiliation with the disputed domain name and allows the respondent to profit from that confusion).

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Thus, the Panel finds that Respondents have registered and are using the domains in bad faith per Policy � 4(b)(iv).

Product	Dosage	Quantity + Bonus	Price
Cialis Generic	20mg	30 + 4 Pills	68.05€ 64.81€
Cialis Generic	20mg	180 + 10 Pills	254.09€ 241.99€
Cialis Generic	2.5mg	20 Pills	40.73€ 38.79€
Cialis Generic	5mg	90 + 6 Pills	115.91€ 110.39€
Cialis Generic	40mg	120 + 8 Pills	206.98€ 197.12€
Cialis Professional	20mg	90 + 2 Pills	241.49€ 229.99€
Cialis Original	20mg	64 + 4 Pills	274.18€ 261.12€
Cialis Generic	10mg	30 + 4 Pills	63.32€ 60.30€
Cialis Soft Tabs	20mg	60 + 4 Pills	159.37€ 151.78€
Cialis Generic	40mg	10 Pills	37.79€ 35.99€
Cialis Soft Tabs	20mg	180 + 8 Pills	353.17€ 336.35€

Next, Complainant argues that the Respondents� use of their domains is potentially harmful to the health of many unsuspecting consumers who may purchase unlawfully sold pharmaceutical products promoted through Respondents� resolving websites.

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27, 2007) (finding that the addition of geograhic terms, such as �cancun� to the end of the CHEAPTICKETS mark in the , , , and domain names, does not overcome a finding of confusing similarity under Policy � 4(a)(i)). ��Furthermore, the affixation of a gTLD is irrelevant to a Policy � 4(a)(i) analysis. See Trip Network Inc. v. Alviera, (concluding that the affixation of a gTLD to a domain name is irrelevant to a Policy � 4(a)(i) analysis).

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For these reasons, the Panel finds that Respondents� domain names are confusingly similar to Complainant�s mark pursuant to Policy � 4(a)(i). The Panel finds Complainant has satisfied Policy � 4(a)(i). Complainant contends the Respondents are not commonly known by the domain names identified herein.� �Further, Complainant argues that none of the Respondents have a license or authorization to use Complainant�s mark. The �WHOIS information provided by Complainant supports this assertion.� Moreover, no Respondent has come forward asserting it is commonly known by the domain names set forth herein.� As such, the Panel finds there is nothing in the record to establish that the Respondents are commonly known by the domain names pursuant to Policy � 4(c)(ii). See Tercent Inc. The Panel agrees that Respondents have registered and are using the domains in bad faith pursuant to Policy � 4(a)(iii).� See Eli Lilly and Company v. Ryma Nynyore / Domain Directors Pty.

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v. Lee Yi, FA 139720 (Forum Feb. 10, 2003) (stating �nothing in [the respondent�s] WHOIS information implies that [the respondent] is �commonly known by� the disputed domain name� as one factor in determining that Policy � 4(c)(ii) does not apply).� Further, Complainant has shown that all of 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 FDA. See Wolverine World Wide, Inc. v.

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Fergus Knox, FA 1627751 (Forum Aug. 19, 2015) (finding no bona fide offering of goods or legitimate noncommercial or fair use existed where Respondent used the resolving website to sell products branded with Complainant�s MERRELL mark, and were either counterfeit products or legitimate products of Complainant being resold without authorization). Therefore, cialis plus priligy the Panel finds that the Respondents are not using the domain names in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use under Policy � 4(c)(i) and Policy � 4(c)(iii). The Panel finds Complainant has satisfied Policy � 4(a)(ii). The discussion in this section does not apply to the domain names registered to Dr. 29, 2011) (�The obvious danger of consumers being afforded inaccurate, incomplete, or misleading� contact information about medical products and the probable diversion of actual sales reinforces the Respondent�s bad faith.�). Finally, based on its well-known CIALIS trademark, Complainant argues Respondents must have registered the domains with actual knowledge of Complainant�s mark and its rights therein.� The Panel finds that due to the notoriety of Complainant�s mark, Respondents most certainly had actual knowledge of the mark and Complainant�s rights.

Country	Price per 20mg Tablet	Average Shipping Cost	Total Cost (including shipping)	Notes
Canada	$50	$10	$60	Competitive price
US	$55	$15	$70	Slightly higher shipping
UK	£40 (~$50)	£5 (~$6)	~$56	Good deal from UK pharmacies
India	$20	$5	$25	Cheapest, but longer delivery

Thus, the Panel holds that Respondents registered and use the domains in bad faith.

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v. Bonds, FA 873143 (Forum Feb. 16, 2007) (finding that a USPTO trademark registration adequately demonstrates a complainant�s rights in a mark under Policy � 4(a)(i)). 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.

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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. v. Alviera, FA 914943 (Forum Mar. v.

Brand Name	Dosage Forms	Active Ingredient	Strengths Available	Notes
Cialis Original	Tablets	Tadalafil	5mg, 10mg, 20mg	Trademarked; pharmaceutical grade
Tadalafil Generic	Tablets	Tadalafil	5mg, 10mg, 20mg	Cheaper alternative
Cialis Softgel	Softgel Capsules	Tadalafil	10mg, 20mg	Easier to swallow

Butler, FA 744444 (Forum Aug.

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� 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. Morales, FA 475191 (Forum June 24, 2005) (�[U]nder such circumstances, where Respondent has agreed to comply with Complainant�s request, the Panel felt it to be expedient and judicial to forego the traditional UDRP analysis and order the transfer of the domain names.�). Preliminary Issue C: Language of the Proceedings Complainant requests that the language of this administrative proceeding proceed in the English language pursuant to UDRP Rule 11(a).� Complainant makes this request in light of the Chinese language Registration Agreements.� It is established practice to take UDRP Rules 10(b) and (c) into consideration for the purpose of determining the language of the proceeding to ensure fairness and justice to both parties.

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Complainant argues that the domain names at issue resolve to hosted websites in English and all of the domain names were registered incorporating the Complainant�s CIALIS mark and English words such as �buy,� �cheap� and �generic.� �Pursuant to UDRP Rule 11(a), the Panel finds that persuasive evidence has been produced by Complainant to show that is most probable that the Respondents are conversant and proficient in the English language. �Accordingly, the Panel holds that the proceeding should be in English.� See The Argento Wine Company Limited v. Argento Beijing Trading Company, D2009-0610 (WIPO July 1, 2009) (panel exercising discretion in deciding that the language of the proceedings advance in English, contrary to the Registration Agreement, based on evidence that respondent has command of the language).� Complainant has registered the CIALIS trademark with the United States Patent and Trademark Office (�USPTO�) (Reg. The trademark registrations with the USPTO demonstrate Complainant�s rights in its mark for the purposes of Policy � 4(a)(i). Co. 17, 2006) (finding bad faith where the respondent was �well-aware� of the complainant�s YAHOO! The Panel finds Complainant has satisfied Policy � 4(a)(iii). Click Here to return to the main Domain Decisions Page. Click Here to return to our Home Page BrandCialis 10 mgAs low as $176.228 Tablet (India) $176.228 Tablet (Canada) $179.9932 Tablet (India) $445.32 GenericTadalafil 10 mgAs low as $28.988 Tablet (Canada) $28.9812 Tablet (Canada) $42.5220 Tablet (Canada) $62.6124 Tablet (Canada) $72.1432 Tablet (United Kingdom) $73.9128 (Megalis-Macleods) (India) $74.3730 Tablet (Canada) $82.9544 Tablet (United Kingdom) $83.9932 Tablet (Canada) $88.2436 Tablet (Canada) $98.4788 Tablet(Megalis-Macleods) (India) $114.4960 Tablet (Canada) $120.0288 (Megalis-Macleods) (India) $138.6288 Tablet (United cialis oral strips Kingdom) $142.2380 Tablet (Canada) $158.7390 Tablet (Canada) $175.08 Cialis (Tadalafil) 2.5 mg Check Price BrandCialis 2.5 mgAs low as $277.9928 Tablet (Canada) $277.99 GenericTadalafil 2.5 mgAs low as $65.1430 Tablet (Canada) $65.1460 Tablet (Canada) $96.3890 Tablet (Canada) $125.62 BrandCialis 20 mgAs low as $229.998 Tablet (Canada) $229.9912 Tablet (Canada) $259.9920 Tablet (Canada) $379.9932 Tablet (Australia) $449.9932 Tablet (Turkey) $503.2232 Tablet (Canada) $599.99 GenericTadalafil 20 mgAs low as $37.4124 Tablet(Tadacip-Cipla) (India) $37.4164 Tablet(Tadacip-Cipla) (India) $43.1188 Tablet(Tadacip-Cipla) (India) $48.5324 Tablet (United Kingdom) $67.1988 (Tadalis-Ajanta) (India) $69.9936 Tablet (United Kingdom) $89.5988 Tablet (United Kingdom) $111.9928 Tablet(Blister Packs) (Canada) $133.8330 Tablet (Canada) $153.3640 Tablet(Blister Packs) (Canada) $160.5160 Tablet (Canada) $202.3188 Tablet(Blister Packs) (Canada) $254.2490 Tablet (Canada) $256.69 BrandCialis 5 mgAs low as $239.9928 Tablet (Canada) $239.9928 Tablet (Turkey) $281.2856 Tablet (Canada) $393.9984 Tablet(ON BACKORDER) (Turkey) $433.3484 Tablet (Canada) $539.9984 Tablet (Turkey) $603.54 GenericTadalafil 5 mgAs low as $34.7128 Tablet (United Kingdom) $34.7130 Tablet (Canada) $49.1430 Tablet(Modula-Sun Pharma) (India) $71.3484 Tablet (United Kingdom) $72.7960 Tablet (Canada) $74.3890 Tablet(Exilar-SAVA Healthcare) (India) $74.9790 Tablet (Canada) $105.62 TALADAFIL IS A PRESCRIPTION MEDICATION - A DOCTOR'S PRESCRIPTION IS MANDATORYTaladafil tablets are PDE-5 inhibitors which work in the same way as Viagra.