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Complainant alleges that the domain names at issue 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 that a “complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.” In support of its argument, Complainant contends that all of the disputed domain names use the same online pharmacy template, and the Canadianpharmac24h.com logo on all of the sites hosted on the Domain Names resolves to the same URL . Complainant also states that all of the disputed domain names are comprised of the CIALIS mark in full. Complainant alleges that many of the Domain Names were registered on the same or within consecutive dates across the registrars, and argues that this is additional evidence that the domain names were registered and are in the control of a common entity. All of the domains registered in 2015 at Nanjing and Vautron were registered on January 16th.

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On May 16, 2014, domains were registered at both Nanjing and Todaynic. On July 17, 2014, domains were registered at both Nanjing and Vautron. On August 8, 2014, domains were registered at both Todaynic and Nanjing. From May 2014 until mid-October 2014, when the Respondent started to use Nanjing and Vautron registrars more frequently, the majority of the Domain Names were registered with Todaynic.com. In arguing for consolidation of Respondents, Complainant relies on Jonathan Matkowsky’s signed affidavit, provided in Complainant’s exhibits. 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.

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Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred: (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 cialis order mastercard 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(e), 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 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.”). 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.

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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.”).

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Forum Sept. 7, 2005) (“[T]he addition of the generic top-level domain (gTLD) “.net” is irrelevant for purposes of determining whether a domain name is identical to a mark.”); see also Sea World, Inc. v. JMXTRADE.com, FA 872052 (Nat. Forum Feb.

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12, 2007) (“[Since] [t]he top-level gTLD is merely a functional element required of every domain name, the domain name is identical to the SHAMU mark under a Policy ¶ 4(a)(i).”). Therefore, the Panel finds that the disputed domain names are confusingly similar to Complainant’s mark under Policy ¶ 4(a)(i). Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii), and then the burden shifts to Respondent to show it does have rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Complainant claims Respondent has no rights or legitimate interests in the disputed domain names.

Complainant contends that Respondent is not commonly known by the disputed domain names, nor has it gained any permission from Complainant to register the CIALIS mark in any way.

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Pursuant to Matkowsky’s Affidavit, Matkowsky is CEO of Maccabim.com Ltd, a corporation which provides cybercrime solutions to protect brand and intellectual property assets, and the disputed domain names are under the control of a criminal network under common control of a rogue online pharmacy network that uses false contact information to register domains, including compromised identities of innocent third persons. This allegation is supported by email correspondence received by the Forum on May 15, 2015, May 19, 2015, May 20, 2015, May 22, 2015, May 26, 2015, May 29, 2015, June 2, 2015, June 3, 2015, and June 5, 2015, from various named registrants of the disputed domain names who denied having registered the domain names. The Panel finds that Complainant has sufficiently presented evidence demonstrating that the disputed domain names are controlled by the same holder using multiple aliases. Complainant requests that the language of this administrative proceeding be in English pursuant to UDRP Rule 11(a). Complainant makes this request in light of the Chinese language Registration Agreement which may be present through registrar Nanjing Imperiosus Technology Co.

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Ltd. 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 the Panel has considered include: 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 included in the Registration Agreement. See The Argento Wine cialis online pharmacy canadian 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). Because Respondent has submitted no additional evidence for the Panel’s consideration, and in light of the available WHOIS information, the Panel finds there is no basis to determine that Respondent is commonly known by the disputed domain names under Policy ¶ 4(c)(ii).

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Panels have agreed the addition of generic or descriptive terms are to a complainant’s unaltered mark does not negate a finding of confusing similarity. 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)). The domains also incorporate gTLD suffixes such as “.com”, “.net”, or “.org.” Panels have agreed that such additions are required in domain name registrations and are therefore irrelevant to a Policy ¶ 4(a)(i) analysis. Global LLC v. Resort Realty, FA 1043061 (Nat.

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Forum Sept. 6, 2007) (“Furthermore, the addition of the generic top-level domain ‘.com’ does nothing to eliminate the confusing similarity, as a top-level domain is a requirement for all domain names.”); see also Katadyn N. Am. v. Black Mountain Stores, FA 520677 (Nat. 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 asserts that 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.

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The Panel has also considered the relative time and expense in enforcing the Chinese language agreement, which may result in prejudice toward Complainant. 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 that persuasive uncontested evidence has been adduced by Complainant to establish that the Respondent is conversant and proficient in the English language. After considering the circumstance of the present case, the Panel decides that the proceeding should be in English.

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The CIALIS mark is used by Complainant and registered with the USPTO (e.g., Reg. Under Policy ¶ 4(a)(i), panels have agreed in determining a complainant’s rights that a USPTO registration is sufficient. 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 argues that Respondent’s disputed domain names are confusingly similar to Complainant’s CIALIS mark as they each incorporate the mark fully and merely add generic or descriptive terms such as: “discount”, “prices”, “online”, “generic”, “buy”, “cheap”, “pills”, and “order”, among others.