The Complainants are Darkside Productions, Inc. Severo Ochoa No. Embajada esc. On January 30, , the Center transmitted by email to Go Daddy Software a request for registrar verification in connection with the domain names at issue. On the same day, Go Daddy Software transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details for the administrative, billing, and technical contact.
In accordance with the Rules, paragraphs 2 a and 4 a , the Center formally notified the Respondent of the Complaint, and the proceedings commenced on February 4, In accordance with the Rules, paragraph 5 a , the due date for Response was February 24, The Response was filed with the Center on February 24, The Panel finds that it was properly constituted.
The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. The application for registration was filed on June 26, , claiming a date of first use in commerce of August The registration is for "dissemination of advertising for the goods and services of others via the global computer network.
The Respondent also claims rights to the mark EROS and has filed applications for registration of that mark for various services, most of them in the area of "adult-themed services. The services provided by the Complainant are provided by way of websites at "www. Sometimes the domain names are hyphenated and sometimes they are not. Examples are "www. The Domain Names were registered in December , to a Mr.
Shortly thereafter the Complainants became aware of the Domain Names and sent a cease and desist letter to Mr. On January 22, , the Complainants responded clarifying their rights and reiterating their demands.
