Complainant claims you to definitely Respondent brings customers into the Domain names that have confusingly equivalent web addresses and you can websites. This new obtaining users of the Domains are comparable, and purport to own same functions. This site during the
Website name conspicuously screens the text “Really Fish Matchmaking” and you may proclaims: “Sign up among the best free online dating site among other online dating sites and you may see attractive american singles from one part of Business.” Additionally, the fresh new squeeze page provides links so you can fighting dating websites, together with “theseniordating”, “singlecougar”, and you will “filipinocupid”.
Domain name furthermore screens what “POF 100 % free 100% Online Relationship”, and you can “Register Free of charge 100% Free Singles Dating site”. Concurrently, which landing page alsoprovides backlinks to help you contending internet dating other sites, like the “filipinocupid” web site.
Complainant states so it hasn’t subscribed Respondent to utilize any of one’s PLENTYOFFISH Scratches, neither people mark confusingly comparable thereto, given that a great elizabeth. On pointers and faith, Complainant means that Respondent possess inserted and you will will continue to make use of the Domains so you can mislead users and you will prospective profiles regarding Complainant’s relationships qualities, within Complainant’s debts as well as for Respondent’s profit.
Participants entered the newest Domains over ten yearsafter Complainant’s first use of PLENTYOFFISH Scratches and you may Complainant’s membership of the authoritative