Igor Palchikov, FA 1105001388612 (NAF, June 15, 2011) (Annex 3, P).� Moreover, prior NAF Panels have found, �that the offer of counterfeit and competing products constitutes bad faith attraction for commercial gain under Policy �4(b)(iv).�� See Eli Lilly and Company v. Grace Beaumont et. One may argue that the Respondents� conduct with respect to 10 of the Domain Names that currently don�t have active websites cannot be said to come squarely within any of the examples of bad faith registration and use set out in �4(b) of the Policy. However, the examples in �4(b) are intended to be illustrative, rather than exclusive. See Telstra Corporation Limited v. Nuclear Marshmallows, D2000-0003 (WIPO, February 18, 2000) (Annex 3, R). As discussed in detail above, the Telstra decision established that "inaction" can constitute bad faith use, and the decision has since been cited for that proposition and followed by many subsequent Panels. See Staples, Inc. v. Ryan Conrad, D2003-0713 (WIPO, October 27, 2003) (Annex 3, V).

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Andrea Hubner et al., D2012-2212 (WIPO, Feb. 8, 2013) (�UDRP jurisprudence suggests consolidation of multiple respondents may be appropriate, under paragraphs 3(c) and 10(e) of the Rules, even where differently named domain name registrants are involved, where the particular circumstances of a given case indicate that common control is being exercised over the disputed domain names or the websites to which the domain names resolve�); and Speedo Holdings B.V. v. Programmer, Miss Kathy Beckerson et al., D2010-0281 (WIPO, May 18, 2010); see also HLT Domestic IP LLC v. Boris Chevkov / Macky Tong, Claim No.

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FA1405001558971 (NAF, June 23, 2014) (�Previous Panels have also found multiple respondents to be commonly controlled where the content of their websites were substantially identical and referred Internet visitors to a common homepage.�) The burden of proof for establishing that the disputed domain names are subject to common control is a preponderance of the evidence. See Seiko Holdings Kabushiki Kaisha v. L. Collins Travis, C. Turner Jose, et al., D2013-0994 (WIPO, Aug.

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6, 2013) (�In this instance, the Panel finds that the Complainant has established more likely than not that the disputed domain names are subject to common ownership or control��); and Lanc�me Parfums Et Beaut Et Compagnie v. You Ge, Jean Buding, Kang Tianhuan, Zongkaili, Leigeng, D2013-1559 (WIPO, Nov. 20, 2013) (��the Panel infers that on the balance of probabilities, the disputed domain names are all controlled or under the common ownership of the same person or entity��).� Where consolidation will permit multiple domain name disputes arising from a common nucleus of facts and involving common legal issues to be heard and resolved in a single administrative proceeding, the shared interests of the parties are promoted in avoiding unnecessary duplication of time, effort and expense, and generally furthers the fundamental objectives of the Policy. All reasonable allegations and inferences set forth in the complaint may be accepted as true unless the evidence is clearly contradictory.� See Talk City, Inc. v. As a result, Respondents' passive and misleading use of 10 of the Domain Names constitutes bad faith registration and use. "It is further important to state that the mere holding of a domain name that is identical or confusingly similar to a trademark belonging to someone else, prevents the holder of the said mark to be present on the Internet under a domain name that reflects the trademark, which in itself can be considered disrupting to his business.

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Cialis Soft Tabs	20mg	180 + 8 Pills	353.17€ 336.35€
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Cialis Generic	40mg	360 + 10 Pills	477.87€ 455.11€

"� See Healthy Back LLC v. Ivo Somoza, D2003-0276 (WIPO, June 3, 2003).� Respondents' registration and misleading use of the Domain Names is disrupting to Complainant's business.� Finally, Respondents� use of Complainant's CIALIS mark in the Domain Names is potentially harmful to the health of many unsuspecting consumers who may purchase unlawfully sold pharmaceutical products promoted through the websites associated with the Domain Names under the mistaken impression that they are dealing with Complainant and, therefore, are receiving information on safe and effective drugs approved by the FDA or other health authorities around the world.� As discussed above, �Generic� CIALIS brand product has neither been developed by the Complainant nor approved by the FDA or any other health authority.� Complainant's CIALIS brand product is only available on a physician's prescription and is manufactured, labeled, and sold in strict compliance with the FDA and other health authority laws and regulations.� A prior panel has noted that the obvious danger of consumers being afforded inaccurate, incomplete or misleading information about medical products may further demonstrate a Respondent's bad faith.� See Eli Lilly and Company v.

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Nuclear Marshmallows, D2000-0003 (WIPO, February 18, 2000) (Annex 3, R). As discussed in detail above, the Telstra decision established that "inaction" can constitute bad faith use, and the decision has since been cited for that proposition and followed by many subsequent Panels. See Staples, Inc. v. Ryan Conrad, D2003-0713 (WIPO, October 27, 2003) (Annex 3, V).

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As a result, Respondents' passive and misleading use of 10 of the Domain Names constitutes bad faith registration and use. "It is further important to state that the mere holding of a domain name that is identical or confusingly similar to a trademark belonging to someone else, prevents the holder of the said mark to be present on the Internet under a domain name that reflects the trademark, which in itself can be considered disrupting to his business. "� See Healthy Back LLC v. Ivo Somoza, D2003-0276 (WIPO, June 3, 2003).� Respondents' registration and misleading use of the Domain Names is disrupting to Complainant's business.� Finally, Respondents� use of Complainant's CIALIS mark in the Domain Names is potentially harmful to the health of many unsuspecting consumers who may purchase unlawfully sold pharmaceutical products promoted through the websites associated with the Domain Names under the mistaken impression that they are dealing with Complainant and, therefore, are receiving information on safe and effective drugs approved by the FDA or other health authorities around the world.� As discussed above, �Generic� CIALIS brand product has neither been developed by the Complainant nor approved by the FDA or any other health authority.� Complainant's CIALIS brand product is only available on a physician's prescription and is manufactured, labeled, and sold in strict compliance with the FDA and other health authority laws and regulations.� A prior panel has noted that the obvious danger of consumers being afforded inaccurate, incomplete or misleading information about medical products may further demonstrate a Respondent's bad faith.� See Eli Lilly and Company v. Ryma Nynyore/Domain Directors Pty. Ryma Nynyore/Domain Directors Pty. Ltd., D2011-0478 (WIPO, April 29, 2011).� In light of all of these factors, it is apparent that the Respondents have clearly registered and are using the Domain Names in bad faith.� Respondent failed to submit a Response in this proceeding. (1) the domain names registered by Respondent are identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (2) Respondent has no rights or legitimate interests in respect of the domain names; and (3) the domain names were registered and are being used in bad faith.

Side Effect	Severity	Possible Cause	Recommendations
Headache	Mild	Vasodilation effects	Hydration, OTC pain relievers
Flushing	Mild	Blood vessel dilation	Cooling measures
Nasal Congestion	Mild	Vasodilation	Decongestants
Muscle Pain	Mild	Muscle blood flow changes	Rest, OTC pain relief

Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable." Paragraph 4(a) of the Policy requires Complainant prove the following three elements to obtain an order cancelling or transferring a domain name: (1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (2) Respondent has no rights or legitimate interests in respect of the domain name; and (3) the domain name has been registered and is being used in bad faith. In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules.� The Panel is entitled to accept all reasonable allegations and inferences set forth in the Complaint as true unless the evidence is clearly contradictory.� See Vertical Solutions Mgmt., Inc. v.

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webnet-marketing, inc., FA 95095 (Nat. Forum July 31, 2000) (holding that the respondent�s failure to respond allows all reasonable inferences of fact in the allegations of the complaint to be deemed true); see also Talk cialis buy cheap City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (�In the absence of a response, it is appropriate to accept as true all allegations of the Complaint.�).

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See Eli Lilly and Company v.

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Ltd., D2011-0478 (WIPO, April 29, 2011).� In light of all of these factors, it is apparent that the Respondents have clearly registered and are using the Domain Names in bad faith.� Respondent failed to submit a Response in this proceeding. (1) the domain names registered by Respondent are identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (2) Respondent has no rights or legitimate interests in respect of the domain names; and (3) the domain names were registered and are being used in bad faith. Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable." Paragraph 4(a) of the Policy requires Complainant prove the following three elements to obtain an order cancelling or transferring a domain name: (1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (2) Respondent has no rights or legitimate interests in respect of the domain name; and (3) the domain name has been registered and is being used in bad faith. In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules.� The Panel is entitled to accept all reasonable allegations and inferences set forth in the Complaint as true unless the evidence is clearly contradictory.� See Vertical Solutions Mgmt., Inc. v.

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Complainant has requested these proceedings be consolidated.� For the purposes of clarity and to insure the Panel�s ruling is understandable to readers who are not parties, Complaint�s request will be set out in full:� Complainant hereby requests permission to proceed against multiple respondents in this single administrative proceeding pursuant to �3(c) or 10(e) of the UDRP Rules.� The consolidation of multiple registrants as respondents in a single administrative proceeding is appropriate under �3(c) or 10(e) of the UDRP Rules provided the complainant can demonstrate that the disputed domain names or the websites to which they resolve are subject to common control, and the Panel, having regard to all of the relevant circumstances, determines that consolidation would be procedurally efficient and fair and equitable to all parties. See Eli Lilly and Company v. Darren K. Headley et al., D2013-1303 (WIPO, Sept. 3, 2013) (finding �[t]here is significant precedent supporting consideration for such consolidation when the disputed domain names are determined to be under common control) (citing Guccio Gucci S.p.A v. Darren K. Headley et al., D2013-1303 (WIPO, Sept. 3, 2013) (finding �[t]here is significant precedent supporting consideration for such consolidation when the disputed domain names are determined to be under common control) (citing Guccio Gucci S.p.A v. Andrea Hubner et al., D2012-2212 (WIPO, Feb. 8, 2013) (�UDRP jurisprudence suggests consolidation of multiple respondents may be appropriate, under paragraphs 3(c) and 10(e) of the Rules, even where differently named domain name registrants are involved, where the particular circumstances of a given case indicate that common control is being exercised over the disputed domain names or the websites to which the domain names resolve�); and Speedo Holdings B.V.

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v. Programmer, Miss Kathy Beckerson et al., D2010-0281 (WIPO, May 18, 2010); see also HLT Domestic IP LLC v.

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Robertson, D2000-0009 (WIPO Feb. 29, 2000) (Annex 3, F); and Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (NAF, July 31, 2000). 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�.

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[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 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.

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Boris Chevkov / Macky Tong, Claim No. FA1405001558971 (NAF, June 23, 2014) (�Previous Panels have also found multiple respondents to be commonly controlled where the content of their websites were substantially identical and referred Internet visitors to a common homepage.�) The burden of proof for establishing that the disputed domain names are subject to common control is a preponderance of the evidence.

Drug Class	Interaction Effect	Advice
Nitrates	Severe hypotension	Avoid use altogether
Alpha-blockers	Increased blood pressure effects	Consult doctor for dosage adjustments
CYP3A4 inhibitors	Increased Cialis levels, risk of side effects	Dose adjustment necessary

See Seiko Holdings Kabushiki Kaisha v. L. Collins Travis, C. Turner Jose, et al., D2013-0994 (WIPO, Aug. 6, 2013) (�In this instance, the Panel finds that the Complainant has established more likely than not that the disputed domain names are subject to common ownership or control��); and Lanc�me Parfums Et Beaut Et Compagnie v. You Ge, Jean Buding, Kang Tianhuan, Zongkaili, Leigeng, D2013-1559 (WIPO, Nov. 20, 2013) (��the Panel infers that on the balance of probabilities, the disputed domain names are all controlled or under the common ownership of the same person or entity��).� Where consolidation will permit multiple domain name disputes arising from a common nucleus of facts and involving common legal issues to be heard and resolved in a single administrative proceeding, the shared interests of the parties are promoted in avoiding unnecessary duplication of time, effort and expense, and generally furthers the fundamental objectives of the Policy.

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All reasonable allegations and inferences set forth in the complaint may be accepted as true unless the evidence is clearly contradictory.� See Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (Annex 3, F); and Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (NAF, July 31, 2000). 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 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.

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