is registered with Google LLC the Registrar 3 Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center the Center on December 29 2020 On December 29 2020 the Center transmitted by email to the Registrar a

UDRP case as a respondent see Google LLC v Mitra Haman and Samaneh Latifi WIPO Case No D2019-12331 Such circumstances may indicate that the Respondent registered the disputed domain name in order to prevent the owner of the trademark from

under Policy ¶ 4 a i   See Google LLC v Bhawana Chandel / Admission Virus FA 1799694 Forum Sept 4 2018 Complainant has rights in the GMAIL mark based upon its registration of the mark with numerous trademark agencies around the world      The

¶ 4 c ii   See for example Google LLC v Bhawana Chandel / Admission Virus FA 1799694 Forum September 4 2018 concluding that a respondent was not commonly known by a disputed domain name incorporating the GOOGLE mark where the relevant WHOIS

Complainant emphasizes that a Google or similar online search would have undoubtedly demonstrated that all the results would have led to the Complainant s websites and business thus the Complainant contends that it was highly unlikely that the

had carried even a basic Google search in respect of the wordings INTESA SANPAOLO and INTESA the same would have yielded obvious references to the Complainant The Complainant submits an extract of a Google search in support of its allegation

search engines such as Google.com Bing.com and Yahoo.com the vast majority of the results relate to the Complainant s official websites and also third parties websites directly referring to the Complainant s products sold under the ARLA

versions however search in Google Play and AppStore again pointed to the Complainant It is impossible that the Respondent was still not aware of the Complainant and its trademark Novartis after it spent hours analyzing the market Rights The

by a disputed domain name See Google LLC v Bhawana Chandel / Admission Virus FA 1799694 Forum Sept 4 2018 concluding that Respondent was not commonly known by the disputed domain name where the WHOIS of record identifies the Respondent as Bhawana

and save content from Google's YouTube service in violation of Google's YouTube Terms of Services see also Google Inc v Onur Koycegiz FA1741705 Forum Aug 25 2017 the disputed domain name resolves to a website featuring 10YOUTUBE in a

over 500 million users in the Google Play store The Complainant is the owner of many registered trademarks in relation to TIKTOK worldwide including but not limited to the international registration word mark TIK TOK with registration number

had carried even a basic Google search in respect of the wordings INTESA SANPAOLO and INTESA it would have identified the Complainant The disputed domain name is connected to a website sponsoring among others banking and financial services for

and services under its GOOGLE mark Complainant is the owner of numerous domestic and international registrations for its GOOGLE mark and variations thereof constituting the family of GOOGLE marks Complainant's primary website is located at

the term arcelorrmttal via Google all results triggered relate to the trade mark ARCELORMITTAL Then there is the addition of the gTLD com As is generally accepted the addition of a gTLD such as com is merely a technical registration requirement

to a safety warning from Google A cease and desist letter was sent to the Respondent by email on October 30 2020 to request the transfer of the disputed domain name to the Complainant It remained unanswered 5 Parties Contentions A Complainant

to a safety warning from Google A cease and desist letter was sent to the Respondent by email on October 30 2020 to request the transfer of the disputed domain name to the Complainant It remained unanswered 5 Parties Contentions A Complainant

search engines such as Google.com the very first results relate to the Complainant s official website and the remaining results relate to the Disputed Domain Name and pages connected to the same according to the WHOIS records the Respondent

13 2021   On January 14 2021 Google LLC confirmed by e-mail to the Forum that the subzero.rip domain name is registered with Google LLC and that Respondent is the current registrant of the name Google LLC has verified that Respondent is bound by

word fxcm on the Baidu and Google search engines direct Internet users to the Complainant and its services which indicates that an exclusive connection between the FXCM trade mark and the Complainant has been established As such the Respondent

is registered with Google LLC the Registrar 3 Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center the Center on November 27 2020 On November 27 2020 the Center transmitted by email to the Registrar a