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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.�).

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. 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.

International Nonproprietary Name And Brand Names

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.

Pricing Information

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. 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. 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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[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. 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. 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.

Special Precautions

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. 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.

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

ATC Code And Dosage Forms

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.�).

Subjective Insights

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. 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. 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. 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).

• Cialis is a medication used to treat erectile dysfunction.
• Cialis contains the active ingredient tadalafil.
• It is available by prescription at pharmacies.
• Cialis helps improve blood flow to the penis.
• The usual dose is 10mg or 20mg before activity.
• Cialis can be taken with or without food.
• The effects of Cialis last up to 36 hours.
• Common side effects include headache and flushing.
• Cialis is not suitable for everyone; consult a doctor first.
• It may interact with nitrates and other medications.
• Cialis can be purchased online with a valid prescription.
• Always follow the dosage instructions given by your pharmacist.

In this case, a number of the commonly controlled domain names� websites are in the English language.

How and Where to Buy Cialis Online?

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. There is nothing to be gained by either translating the documents into Russian or by having a parallel set of proceedings.

Payment Methods

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. 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). 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.

Experimental Uses of Cialis

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.

Black Box Warnings

Robertson, D2000-0009 (WIPO Feb. 29, 2000) (Annex 3, F); and Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 brand cialis canadian pharmacy (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�. After considering the circumstance of the present case, the Panel decides the Proceeding should be in English. There is nothing to be gained by 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. 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.

• Cialis is often prescribed for erectile dysfunction.
• It is also used to treat benign prostatic hyperplasia.
• The medication helps achieve and maintain an erection.
• Cialis is effective for up to 36 hours.
• The drug is taken 30 minutes before activity.
• It’s important to follow the prescribed dose.
• Report any allergic reactions to your doctor.
• Use Cialis responsibly to avoid side effects.
• Cialis may cause back pain or muscle aches.
• Avoid alcohol when taking Cialis.
• Share your medication history with your pharmacist.
• Cialis should not be mixed with certain medications.

v.

• Cialis can help men regain sexual function.
• It is a long-acting ED medication.
• Side effects are usually mild and temporary.
• Serious reactions require immediate medical attention.
• Discuss all health conditions with your doctor.
• Follow dosing guidelines strictly.
• Cialis is available in various formulations.
• Check if your pharmacy offers consultations.
• Use Cialis as part of a comprehensive treatment plan.
• Avoid using Cialis with certain heart medications.
• Inform your healthcare provider of all supplements used.
• Use caution if you experience vision or hearing changes.

Cologne Zone, D2000-1809 (WIPO Feb.

• Cialis may be prescribed for both ED and BPH.
• It works by inhibiting PDE5 enzymes.
• Taking Cialis 30 minutes before sex is typical.
• Consult a doctor if you experience chest pain.
• Do not take Cialis with fatty meals if sensitive.
• Alcohol consumption can reduce efficacy.
• Be aware of potential headache side effects.
• Use Cialis responsibly to prevent misuse.
• Always complete your full course as prescribed.
• Report any sudden vision loss immediately.
• Cialis can be part of a healthy lifestyle.
• Follow up with your doctor regularly.

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.