According to LegitScript, a company providing assistance with this proceeding, the Domain Names have been identified as under control of a rogue online pharmacy operator that uses false contact information to register domains.� The Domain Names resolve to websites that advertise and sell generic versions of Complainant�s CIALIS brand product and the sites are part of the same networks, �Rx-Partners,� �Pharmcash� and �Pharmatheke�. [1]� All of the Domain Names are hosted on the same IP address (i.e., 37.187.146.46).� All of the Domain Names that are registered using a name other than Denisov Denis, all link to Denisov Denis via either recent historical WhOIS information or Denisov Denis� email colman662@gmail.com.� Further, each �unique� registrant name uses the email address � ss@ss.ru � at least once in the WHOIS information for each Domain Name.� Other commonalities include, of course, that the Domain Names contain the CIALIS trademark and all of the Domain Names were registered between November 2012 through October 2015.� For all of the foregoing reasons, the Domain Names are likely under common control, notwithstanding that the true identity of the Respondents may be a joint criminal enterprise acting together in concert, rather than indian cialis generic a single individual.� Complainant respectfully submits that this satisfies the preponderance of the evidence standard required for consolidation of the Domain Names into a single proceeding.� This Panel generally agrees with Complainant�s claims.� Respondent has done nothing to dispute them.� Complainant has met it burden of proof by a preponderance of the evidence.� The entities which control the disputed domain names are effectively controlled by the same person and/or entity, which is operating under several aliases.� Paragraph 3(c) of the Rules for Uniform Domain Name Dispute Resolution Policy (the �Rules�) provides a �complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.�� All domains are under control of a single rogue online pharmacy operator, which utilizes false contact information to register domains.� All domain names in dispute resolve to websites which advertise and sell generic versions of Complainant�s products.� All domain names in dispute are hosted on the same IP address.� All domain names in dispute are linked in one way or another to �Denisov Denis.� Each �unique� registrant name uses the email address ss@ss.ru.� All disputed domains contain the CIALIS mark in its entirety. Taken in its entirely, this is adequate evidence the listed entities are jointly controlled.� Pursuant to Forum Supplemental Rule 4(c), this Panel also finds all of the domain names are commonly owned.� The named Respondent in this Proceeding shall be Denisov Denis.

Continent	Countries with Access	Mode of Purchase	Common Brands
North America	USA, Canada	Prescription, OTC (Canada)	Cialis, Adcirca
Europe	UK, Germany, France	Prescription	Cialis, Generics
Asia	Japan, India, China	Prescription & Online	Cialis, Tadalafil Paste
Australia	Australia	Prescription	Cialis, Generic Tadalafil

Complainant requests this administrative proceeding proceed in the English language pursuant to UDRP Rule 11(a). Complainant makes this request even though some of the Registration Agreements are in Russian (most of them are in English). 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. Factors which previous panels have seen as particularly compelling are: WHOIS information which establishes Respondent in a country which would evince a familiarity with the English language, filing of a trademark registration with an entity which evinces an understanding of the English language, and any evidence (or lack thereof) evincing Respondent�s understanding of the English language in the Registration Agreements. 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). In this case, a number of the commonly controlled domain names� websites are in the English language.

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Market Demand Trends

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. Factors which previous panels have seen as particularly compelling are: WHOIS information which establishes Respondent in a country which would evince a familiarity with the English language, filing of a trademark registration with an entity which evinces an understanding of the English language, and any evidence (or lack thereof) evincing Respondent�s understanding of the English language in the Registration Agreements. 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). In this case, a number of the commonly controlled domain names� websites are in the English language. The Panel shall also weigh the relative time and expense in enforcing the Russian language agreements, which would result in prejudice toward either party. See Finter Bank Zurich v. Shumin Peng, D2006-0432 (WIPO June 12, 2006) (deciding that the proceeding should be in English, stating, �It is important that the language finally decided by the Panel for the proceeding is not prejudicial to either one of the parties in his or her ability to articulate the arguments for the case.�).

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Pursuant to UDRP Rule 11(a), the Panel finds sufficient persuasive evidence has been shown by the Complainant that Respondent is sufficiently conversant in the English language. After considering the circumstance of the present case, the Panel decides the Proceeding should be in English. There is nothing to be gained by buy cialis 60mg either translating the documents into Russian or by having a parallel set of proceedings.

Product	Dosage	Quantity + Bonus	Price
Cialis Black	80mg	360 + 20 Pills	639.78€ 609.31€
Cialis Soft Tabs	20mg	90 + 6 Pills	216.71€ 206.39€
Cialis Generic	60mg	60 + 4 Pills	145.06€ 138.15€
Cialis Soft Tabs	20mg	120 + 6 Pills	248.64€ 236.80€
Cialis Generic	60mg	360 + 10 Pills	570.52€ 543.35€
Cialis Professional	40mg	30 Pills	148.94€ 141.85€
Cialis Original	20mg	48 + 4 Pills	224.69€ 213.99€
Cialis Generic	10mg	180 + 8 Pills	236.88€ 225.60€
Cialis Generic	40mg	180 + 10 Pills	277.29€ 264.09€
Cialis Soft Tabs	20mg	20 + 2 Pills	66.98€ 63.79€
Cialis Original	20mg	34 + 2 Pills	183.99€ 175.23€
Cialis Generic	5mg	10 Pills	29.39€ 27.99€
Cialis Soft Tabs	20mg	10 Pills	39.03€ 37.17€
Cialis Generic	20mg	270 + 10 Pills	335.21€ 319.25€

The CIALIS mark is used by Complainant and was registered with the United States Patent & Trademark Office (�USPTO�) (e.g., Reg.

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16, 2007) (finding that a USPTO trademark registration adequately demonstrates a complainant�s rights in a mark under Policy �4(a)(i)).� Complainant has sufficiently demonstrated its rights in the CIALIS mark under Policy �4(a)(i). Respondent�s disputed domain names each incorporate the CIALIS mark fully and merely add generic/descriptive/geographic terms, as well as the generic top-level domains (�gTLDs�) �.com,� or �.net.�� Adding generic/descriptive/geographic terms do not adequately differentiate a domain name from a mark under Policy �4(a)(i).� See, e.g., Chanel, Inc. v. Cologne Zone, D2000-1809 (WIPO Feb. 22, 2001) (�CHANEL, the salient feature of the Domain Names, is identical to a mark in which Complainant has shown prior rights.� The addition of the generic term, �perfumes� is not a distinguishing feature, and in this case seems to increase the likelihood of confusion because it is an apt term for Complainant�s business.�); see also Trip Network Inc.

Common Alternatives

v. Alviera, FA 914943 (Nat. 27, 2007) (finding that the addition of geographic 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, every domain name requires a TLD, whether it is a gTLD or a ccTLD.� Such TLDs must be disregarded when doing a Policy �4(a)(i) analysis.� Respondent�s disputed domains are confusing similar to the CIALIS mark pursuant to Policy �4(a)(i). The Panel finds Policy �4(a)(i) satisfied. Complainant must first make a prima facie case Respondent lacks rights and legitimate interests in the disputed domain name under Policy �4(a)(ii).� Then the burden shifts to Respondent to show it has rights or legitimate interests.� See Hanna-Barbera Prods., Inc. 2,724,589, registered June 10, 2003) to identify its rights in a pharmaceutical product intended for the treatment of erectile dysfunction and benign prostatic hyperplasia.

International Nonproprietary Name And Brand Names

Complainant claims Respondent is not making use of the disputed domain names for any bona fide offering of goods or services or for any legitimate noncommercial or fair use.� All pages resolve to the same networks which promote and sell �Generic� CIALIS brand products.� This is an unlawful sale of a counterfeit pharmaceutical product which has not been approved by the FDA.� Marketing of illegal products does not create any rights or legitimate interests.� As in Nycomed Danmark ApS v. Diaz, D2006-0779 (WIPO Aug. 15, 2006), the panel concluded that �the respondent�s use of a disputed domain name to operate a website promoting an illegal food supplement was not a bona fide offering of goods or services under Policy �4(c)(i) or a legitimate noncommercial or fair use under Policy �4(c)(iii).�� Such products also compete with Complainant even if they weren�t illegal, so Respondent has not demonstrated any Policy �4(c)(i) and (iii) rights.� See eLuxury.com Inc. v. WangJunJie, FA 1075554 (Nat. A complainant may prove its rights under Policy �4(a)(i) by proving a trademark registration with a governmental authority, such as the USPTO.� See Metro. Forum Feb. 16, 2007) (finding that a USPTO trademark registration adequately demonstrates a complainant�s rights in a mark under Policy �4(a)(i)).� Complainant has sufficiently demonstrated its rights in the CIALIS mark under Policy �4(a)(i). Respondent�s disputed domain names each incorporate the CIALIS mark fully and merely add generic/descriptive/geographic terms, as well as the generic top-level domains (�gTLDs�) �.com,� or �.net.�� Adding generic/descriptive/geographic terms do not adequately differentiate a domain name from a mark under Policy �4(a)(i).� See, e.g., Chanel, Inc.

Prescription Refills

The Panel shall also weigh the relative time and expense in enforcing the Russian language agreements, which would result in prejudice toward either party. See Finter Bank Zurich v. Shumin Peng, D2006-0432 (WIPO June 12, 2006) (deciding that the proceeding should be in English, stating, �It is important that the language finally decided by the Panel for the proceeding is not prejudicial to either one of the parties in his or her ability to articulate the arguments for the case.�). Pursuant to UDRP Rule 11(a), the Panel finds sufficient persuasive evidence has been shown by the Complainant that Respondent is sufficiently conversant in the English language. After considering the circumstance of the present case, the Panel decides the Proceeding should be in English.

Black Box Warnings

There is nothing to be gained by buy cialis 60mg either translating the documents into Russian or by having a parallel set of proceedings. The CIALIS mark is used by Complainant and was registered with the United States Patent & Trademark Office (�USPTO�) (e.g., Reg. 2,724,589, registered June 10, 2003) to identify its rights in a pharmaceutical product intended for the treatment of erectile dysfunction and benign prostatic hyperplasia. A complainant may prove its rights under Policy �4(a)(i) by proving a trademark registration with a governmental authority, such as the USPTO.� See Metro. Forum Feb. v. Cologne Zone, D2000-1809 (WIPO Feb. 22, 2001) (�CHANEL, the salient feature of the Domain Names, is identical to a mark in which Complainant has shown prior rights.� The addition of the generic term, �perfumes� is not a distinguishing feature, and in this case seems to increase the likelihood of confusion because it is an apt term for Complainant�s business.�); see also Trip Network Inc. v. Alviera, FA 914943 (Nat. 27, 2007) (finding that the addition of geographic 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, every domain name requires a TLD, whether it is a gTLD or a ccTLD.� Such TLDs must be disregarded when doing a Policy �4(a)(i) analysis.� Respondent�s disputed domains are confusing similar to the CIALIS mark pursuant to Policy �4(a)(i). The Panel finds Policy �4(a)(i) satisfied. Complainant must first make a prima facie case Respondent lacks rights and legitimate interests in the disputed domain name under Policy �4(a)(ii).� Then the burden shifts to Respondent to show it has rights or legitimate interests.� See Hanna-Barbera Prods., Inc. v. Entm�t Commentaries, FA 741828 (Nat. Forum Aug.

Brand Name	Dosage Forms	Strengths (mg)	Availability (Country)
Cialis	Tablets	5, 10, 20	Worldwide
Adcirca	Capsules	20	North America, Europe
Tadalafil	Generic Tablets	2.5, 5, 10, 20	Worldwide

18, 2006) (holding that the complainant must first make a prima facie case that the respondent lacks rights and legitimate interests in the disputed domain name under UDRP �4(a)(ii) before the burden shifts to the respondent to show that it does have rights or legitimate interests in a domain name); see also AOL LLC v. Gerberg, FA 780200 (Nat. Forum Sept. 25, 2006) (�Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light.� If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names.�). Complainant claims Respondent has no rights or legitimate interests in the disputed domain names.� Respondent is not commonly known by the disputed domain names, nor has Complainant given Respondent permission to register the CIALIS mark in any way.� Because Respondent has submitted no additional evidence for the Panel�s consideration, the Panel finds there is no basis for finding Respondent is �commonly known by� the domain names under Policy �4(c)(ii) in light of the available WHOIS information.� See IndyMac Bank F.S.B. Forum Dec. 7, 2006) (finding that the respondent failed to establish rights and legitimate interests in the domain name as the respondent was not authorized to register domain names featuring the complainant�s mark and failed to submit evidence that it is commonly known by the domain name). Complainant claims Respondent is not making use of the disputed domain names for any bona fide offering of goods or services or for any legitimate noncommercial or fair use.� All pages resolve to the same networks which promote and sell �Generic� CIALIS brand products.� This is an unlawful sale of a counterfeit pharmaceutical product which has not been approved by the FDA.� Marketing of illegal products does not create any rights or legitimate interests.� As in Nycomed Danmark ApS v.

Manufacturers And Registration

v. Entm�t Commentaries, FA 741828 (Nat. Forum Aug. 18, 2006) (holding that the complainant must first make a prima facie case that the respondent lacks rights and legitimate interests in the disputed domain name under UDRP �4(a)(ii) before the burden shifts to the respondent to show that it does have rights or legitimate interests in a domain name); see also AOL LLC v. Gerberg, FA 780200 (Nat.

Payment Methods

Forum Sept. 25, 2006) (�Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light.� If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names.�). Complainant claims Respondent has no rights or legitimate interests in the disputed domain names.� Respondent is not commonly known by the disputed domain names, nor has Complainant given Respondent permission to register the CIALIS mark in any way.� Because Respondent has submitted no additional evidence for the Panel�s consideration, the Panel finds there is no basis for finding Respondent is �commonly known by� the domain names under Policy �4(c)(ii) in light of the available WHOIS information.� See IndyMac Bank F.S.B. Forum Dec. 7, 2006) (finding that the respondent failed to establish rights and legitimate interests in the domain name as the respondent was not authorized to register domain names featuring the complainant�s mark and failed to submit evidence that it is commonly known by the domain name). Diaz, D2006-0779 (WIPO Aug. 15, 2006), the panel concluded that �the respondent�s use of a disputed domain name to operate a website promoting an illegal food supplement was not a bona fide offering of goods or services under Policy �4(c)(i) or a legitimate noncommercial or fair use under Policy �4(c)(iii).�� Such products also compete with Complainant even if they weren�t illegal, so Respondent has not demonstrated any Policy �4(c)(i) and (iii) rights.� See eLuxury.com Inc. v.

How it works

Forum Nov. 30, 2007) (concluding that the sale of counterfeit products is evidence that the respondent does not make a bona fide offering of goods or services or a legitimate noncommercial or fair use of a disputed domain name); see also Eli Lilly and Company v. WangJunJie, FA 1075554 (Nat.

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Cialis is contraindicated with certain medications.
Do not exceed the prescribed dosage.
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Consult your doctor for proper usage guidance.