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Adam Joo for the domain names
| Retailer Type | Price Range per Tablet | Purchase Options |
|---|---|---|
| Online Pharmacy | $10 - $20 | Single orders, subscriptions |
| Local Clinic | $15 - $25 | Prescription required |
| Discount Retailers | $8 - $15 | Bulk purchase discounts |
| Price Trend (2023) | Slight decrease over year | Market competition influences prices |
Complainant requests that the domain names be transferred from the Respondents to Complainant. Complainant has registered the CIALIS trademark with the United States Patent and Trademark Office (�USPTO�) (Reg. The mark is used in connection with the sale of pharmaceutical and medical treatment for sexual dysfunction.
- Canadian pharmacies may offer patient support services, including medication reminders.
- It is important to distinguish between legitimate online pharmacies and illegal "rogue" sites.
- The medication may cause dizziness, which can be exacerbated by alcohol or other medications.
- Its use is not recommended in patients with a recent history of myocardial infarction.
- The tablet's film coating helps make it easier to swallow and may mask a bitter taste.
- It is often packaged in bottles of 30 or 90 tablets for daily therapy convenience.
- Patients with sickle cell anemia or multiple myeloma have a theoretical increased priapism risk.
- It does not require dose adjustment based on race or ethnicity.
- The medication should be taken as part of a overall healthy lifestyle for best results.
- It is not a cure for underlying vascular disease that may contribute to ED.
- Disposal in household trash should involve mixing with an undesirable substance (e.g., coffee grounds).
Respondents� domain names are confusingly similar to the CIALIS mark through the incorporation of the mark fully, with the addition of generic/descriptive words like �buy,� �cheap,� and �generic,� geographic terms �Canada� or �Canadian,� along with generic top-level domains (�gTLDs�) �.com,� �.org,� or �.net.� Respondents have no rights or legitimate interests with respect to the domain names.� No evidence exists that Respondents are commonly known by the term CIALIS or any of the domain names. Further, all the active websites associated with the domain names resolve to the same online pharmacy, which promotes and allegedly sells �generic� versions of CIALIS brand product, not approved by the U.S. Food and Drug Administration (�FDA�). The attempted sale of counterfeit pharmaceutical products does not represent a bona fide offering of goods or services or any legitimate noncommercial or fair use. Respondents registered and use the domain names in bad faith. First, Respondents have engaged in a pattern of bad faith registration and use through their registration of over 430 domains in the current proceeding. Second, Respondents� use of the domains to promote products that compete with Complainant�s business is disruptive. Third, Respondents� use of the domains to sell competing products constitutes bad faith registration and use pursuant to Policy � 4(b)(iv). Fourth, Respondents� use of the domains is potentially harmful to the health of many unsuspecting consumers who may purchase unlawfully sold pharmaceutical products promoted through Respondents� resolving websites. Finally, based on Complainant�s well-known CIALIS trademark, Respondents must have registered the domains with actual or at least constructive knowledge of Complainant�s mark and its rights therein. There are over 400 domain names at issue in this proceeding and over 100 respondents of which only one has submitted a Response to the Complaint.
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Finally, based on Complainant�s well-known CIALIS trademark, Respondents must have registered the domains with actual or at least constructive knowledge of Complainant�s mark and its rights therein. There are over 400 domain names at issue in this proceeding and over 100 respondents of which only one has submitted a Response to the Complaint. Respondent Dr. Adam Joo has informed the Forum he consents to the transfer of the
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Adam Joo, cialis cheapest registered and use the domain names 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 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 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 this proceeding, Complainant has alleged the entities which control 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.� Complainant has set forth the following information in support of its argument that all of the domain names at issue in this proceeding are under common control: According to LegitScript, a company providing assistance with this proceeding, the Domain Names have been identified as under control of single criminal enterprise.� The active websites associated with the Domain Names are part of the PharmEmpire network that advertises and sells generic versions of Complainant�s CIALIS brand product.� Further, all of the websites associated with the Domain Names use the same template on the landing pages and redirect customers to trustedpharmacy24.com once a product is selected.� �Additionally, all of the websites associated with the Domain Names use the dedicated payment portal secure-bill.net to collect payment information from users. In each case, the Domain Names were registered using the contact information for a US-based medical practitioner or practice and it is likely that the Domain Names have been registered without the knowledge or consent of the individuals named in the Whois records. Moreover, the Domain Names were registered at both Nanjing Imperious Technology, Co.
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Ltd., and Vautron Rechenzentrum AG using the same identities on the same dates.� For example, on May 2, 2016, Domain Names were registered at both registrars using the names Marian Garcia, Evan Swanson, Bridgette Latimer, and Alison Stocks.� Other commonalities include, of course, that the Domain Names contain the CIALIS trademark and all of the Domain Names were registered in 2015 and 2016. (citations to the record omitted).� Based on the foregoing uncontradicted evidence in the record, the Panel concludes the Complainant has established that the all of the domain names described in this proceeding are under common control within the meaning of Paragraph 3(c).� One exception concerns Respondent Dr. Adam Joo, which is discussed below. Preliminary Issue B: Consent to Transfer / Identity Theft One of the many Respondents, Dr. Adam Joo, has submitted a formal Response stating he has not registered or authorized registration of the
| Product | Dosage | Quantity + Bonus | Price | |
|---|---|---|---|---|
| Cialis Professional | 40mg | 10 Pills | 65.09€ 61.99€ | |
| Cialis Original | 20mg | 4 Pills | 41.99€ 39.99€ | |
| Cialis Professional | 20mg | 20 Pills | 78.33€ 74.60€ | |
| Cialis Generic | 2.5mg | 60 + 4 Pills | 83.43€ 79.46€ | |
| Cialis Soft Tabs | 20mg | 60 + 4 Pills | 159.37€ 151.78€ | |
| Cialis Generic | 10mg | 30 + 4 Pills | 63.32€ 60.30€ | |
| Cialis Generic | 20mg | 180 + 10 Pills | 254.09€ 241.99€ | |
| Cialis Generic | 60mg | 30 + 2 Pills | 85.33€ 81.27€ | |
| Cialis Original | 20mg | 76 + 4 Pills | 319.19€ 303.99€ | |
| Cialis Generic | 2.5mg | 120 + 6 Pills | 128.93€ 122.79€ | |
| Cialis Professional | 40mg | 60 + 2 Pills | 262.32€ 249.83€ | |
| Cialis Black | 80mg | 180 + 10 Pills | 356.64€ 339.66€ | |
| Cialis Generic | 20mg | 120 + 8 Pills | 188.15€ 179.19€ | |
| Cialis Super Active | 20mg | 30 + 6 Pills | 128.09€ 121.99€ | |
| Cialis Professional | 20mg | 10 Pills | 48.29€ 45.99€ |
Complainant holds trademark rights for the CIALIS mark.� Respondents� domain names are confusingly similar to Complainant�s CIALIS mark.� Complainant has established that Respondents lack rights or legitimate interests in the use of the domain names described herein and that the Respondents, with exception of Dr. Adam Joo, cialis cheapest registered and use the domain names 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 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 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 this proceeding, Complainant has alleged the entities which control 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.� Complainant has set forth the following information in support of its argument that all of the domain names at issue in this proceeding are under common control: According to LegitScript, a company providing assistance with this proceeding, the Domain Names have been identified as under control of single criminal enterprise.� The active websites associated with the Domain Names are part of the PharmEmpire network that advertises and sells generic versions of Complainant�s CIALIS brand product.� Further, all of the websites associated with the Domain Names use the same template on the landing pages and redirect customers to trustedpharmacy24.com once a product is selected.� �Additionally, all of the websites associated with the Domain Names use the dedicated payment portal secure-bill.net to collect payment information from users. In each case, the Domain Names were registered using the contact information for a US-based medical practitioner or practice and it is likely that the Domain Names have been registered without the knowledge or consent of the individuals named in the Whois records.
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Moreover, the Domain Names were registered at both Nanjing Imperious Technology, Co.
- Buying Canadian Cialis 5mg online can be cost-effective.
- Always verify the pharmacy’s legitimacy.
- Beware of counterfeit Cialis products.
- Follow dosing instructions carefully.
- Avoid combining Cialis with recreational drugs.
- Regular use may improve overall sexual health.
- Patients should inform doctors of other health concerns.
- Cialis 5mg can be part of a healthy lifestyle.
- Ensure proper disposal of expired medication.
Ltd., and Vautron Rechenzentrum AG using the same identities on the same dates.� For example, on May 2, 2016, Domain Names were registered at both registrars using the names Marian Garcia, Evan Swanson, Bridgette Latimer, and Alison Stocks.� Other commonalities include, of course, that the Domain Names contain the CIALIS trademark and all of the Domain Names were registered in 2015 and 2016. (citations to the record omitted).� Based on the foregoing uncontradicted evidence in the record, the Panel concludes the Complainant has established that the all of the domain names described in this proceeding are under common control within the meaning of Paragraph 3(c).� One exception concerns Respondent Dr. Adam Joo, which is discussed below.
- Canadian Cialis 5mg offers a discreet solution for ED.
- It is a trusted name in erectile dysfunction treatment.
- The medication should be used consistently for best results.
- It’s important to follow the prescribed dosage.
- Cialis 5mg can be effective for up to 36 hours.
- Always consult a healthcare professional if unsure.
- Canadian pharmacies often provide secure payment options.
- Avoid using Cialis with certain nitrates or medications.
- Maintaining a healthy lifestyle enhances treatment success.
Preliminary Issue B: Consent to Transfer / Identity Theft One of the many Respondents, Dr.
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Adam Joo for the domain names
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The mark is used in connection with the sale of pharmaceutical and medical treatment for sexual dysfunction. Respondents� domain names are confusingly similar to the CIALIS mark through the incorporation of the mark fully, with the addition of generic/descriptive words like �buy,� �cheap,� and �generic,� geographic terms �Canada� or �Canadian,� along with generic top-level domains (�gTLDs�) �.com,� �.org,� or �.net.� Respondents have no rights or legitimate interests with respect to the domain names.� No evidence exists that Respondents are commonly known by the term CIALIS or any of the domain names. Further, all the active websites associated with the domain names resolve to the same online pharmacy, which promotes and allegedly sells �generic� versions of CIALIS brand product, not approved by the U.S. Food and Drug Administration (�FDA�). The attempted sale of counterfeit pharmaceutical products does not represent a bona fide offering of goods or services or any legitimate noncommercial or fair use.
Medication Quality Concerns
Respondents registered and use the domain names in bad faith. First, Respondents have engaged in a pattern of bad faith registration and use through their registration of over 430 domains in the current proceeding. Second, Respondents� use of the domains to promote products that compete with Complainant�s business is disruptive. Third, Respondents� use of the domains to sell competing products constitutes bad faith registration and use pursuant to Policy � 4(b)(iv). Fourth, Respondents� use of the domains is potentially harmful to the health of many unsuspecting consumers who may purchase unlawfully sold pharmaceutical products promoted through Respondents� resolving websites. Adam Joo, has submitted a formal Response stating he has not registered or authorized registration of the
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Bonds, FA 873143 (Forum Feb. 16, 2007) (finding that a USPTO trademark registration adequately demonstrates a complainant�s rights in a mark under Policy � 4(a)(i)).
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v. Morales, FA 475191 (Forum June 24, 2005) (�[U]nder such circumstances, where Respondent has agreed to comply with Complainant�s request, the Panel felt it to be expedient and judicial to forego the traditional UDRP analysis and order the transfer of the domain names.�).
| Temperature Environment | Recommended Range | Additional Tips |
|---|---|---|
| Room Temperature | 20°C - 25°C (68°F - 77°F) | Keep in a dry, cool place |
| Light Exposure | Keep away from direct sunlight | Protect packaging from light |
| Humidity | Low humidity | Use airtight containers if needed |
| Child Safety | Keep out of reach | Store in a secure location |
Preliminary Issue C: Language of the Proceedings Complainant requests that the language of this administrative proceeding proceed in the English language pursuant to UDRP Rule 11(a).� Complainant makes this request in light of the Chinese language Registration Agreements.� 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. Complainant argues that the domain names at issue resolve to hosted websites in English and all of the domain names were registered incorporating the Complainant�s CIALIS mark and English words such as �buy,� �cheap� and �generic.� �Pursuant to UDRP Rule 11(a), the Panel finds that persuasive evidence has been produced by Complainant to show that is most probable that the Respondents are conversant and proficient in the English language.
| Attribute | Description | Notes |
|---|---|---|
| Active Ingredient | Tadalafil | Main component |
| Dosage Form | Oral tablets | |
| Package Size | 30 tablets per bottle | Typical pack size |
| Price Range | $10 - $20 per tablet | Depending on supplier |
| Availability | Online pharmacies, Canadian clinics | Legal purchase options |
�Accordingly, the Panel holds that the proceeding should be in English.� See The Argento Wine Company Limited v.
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After the initiation of this proceeding, Nanjing Imperiosus Technology Co. Ltd. and Vautron Rechenzentrum AG placed holds on Respondent Joo�s accounts and therefore he cannot transfer these domain names while this proceeding is still pending.� Accordingly, because Respondent Joo has not contested the transfer of the three domain names but instead agrees to transfer the domain names in question to Complainant, the Panel chooses to forego the traditional UDRP analysis and order an immediate transfer of the
Other Interactions
9, 2003) (transferring the domain name registration where the respondent stipulated to the transfer); see also Disney Enters., Inc. v. Morales, FA 475191 (Forum June 24, 2005) (�[U]nder such circumstances, where Respondent has agreed to comply with Complainant�s request, the Panel felt it to be expedient and judicial to forego the traditional UDRP analysis and order the transfer of the domain names.�). Preliminary Issue C: Language of the Proceedings Complainant requests that the language of this administrative proceeding proceed in the English language pursuant to UDRP Rule 11(a).� Complainant makes this request in light of the Chinese language Registration Agreements.� 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. Complainant argues that the domain names at issue resolve to hosted websites in English and all of the domain names were registered incorporating the Complainant�s CIALIS mark and English words such as �buy,� �cheap� and �generic.� �Pursuant to UDRP Rule 11(a), the Panel finds that persuasive evidence has been produced by Complainant to show that is most probable that the Respondents are conversant and proficient in the English language.
Cost Disparity Factors
�Accordingly, the Panel holds that the proceeding should be in English.� 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).� Complainant has registered the CIALIS trademark with the United States Patent and Trademark Office (�USPTO�) (Reg. The trademark registrations with the USPTO demonstrate Complainant�s rights in its mark for the purposes of Policy � 4(a)(i). Co. 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).� Complainant has registered the CIALIS trademark with the United States Patent and Trademark Office (�USPTO�) (Reg. The trademark registrations with the USPTO demonstrate Complainant�s rights in its mark for the purposes of Policy � 4(a)(i).
Brand Name
Co. v. Bonds, FA 873143 (Forum Feb. 16, 2007) (finding that a USPTO trademark registration adequately demonstrates a complainant�s rights in a mark under Policy � 4(a)(i)).
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