If you wish, as mentioned to your client, supply our organization the proper trademark papers, we would consider holding a board meeting to discuss this matter. Please do not contact us directly again without showing registered trademark papers. Complainant s attorneys responded to this email by sending Respondent, via email and certified United Stated Postal Service mail, information on Complainant s allowed trademark application. Respondent never replied, and the instant proceeding followed. A. Similarity of the Mark and Domain Name.
Complainant easily satisfies the first factor.
B. Respondent Has No Legitimate Interests in the Domain Name. In the absence of a Response, it is appropriate to accept as true all allegations of the Complaint. Talk City, Inc. v. Robertson, Case No. The record is devoid of any conceivable justification for Respondent s registration of this domain name. Given the lack of a response, it appears that he has elected to remain silent in this proceeding as well.