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30, 2007) (concluding that the sale of counterfeit products is evidence that the respondent does not make a bona fide offering of goods or services or a legitimate noncommercial or fair use of a disputed domain name); see also Eli Lilly and Company v.

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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.� 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.�). Complainant claims Respondent has no rights or legitimate interests in the disputed domain names.� Respondent is not commonly known by the disputed domain names, nor has Complainant given Respondent permission to register the CIALIS mark in any way.� Because Respondent has submitted no additional evidence for the Panel�s consideration, the Panel finds there is no basis for finding Respondent is �commonly known by� the domain names under Policy �4(c)(ii) in light of the available WHOIS information.� See IndyMac Bank F.S.B. Forum Dec. 7, 2006) cialis without prescription in canada (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 claims 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.� All pages resolve to the same networks which promote and sell �Generic� CIALIS brand products.� This is an unlawful sale of a counterfeit pharmaceutical product which has not been approved by the FDA.� Marketing of illegal products does not create any rights or legitimate interests.� As in Nycomed Danmark ApS v.

Common Alternatives

Diaz, D2006-0779 (WIPO Aug. 15, 2006), the panel concluded that �the respondent�s use of a disputed domain name to operate a website promoting an illegal food supplement was not a bona fide offering of goods or services under Policy �4(c)(i) or a legitimate noncommercial or fair use under Policy �4(c)(iii).�� Such products also compete with Complainant even if they weren�t illegal, so Respondent has not demonstrated any Policy �4(c)(i) and (iii) rights.� See eLuxury.com Inc. v. WangJunJie, FA 1075554 (Nat. Forum Nov. Igor Palchikov, FA 1105001388612 (NAF, June 15, 2011) (finding that using the disputed domain names to redirect to websites advertising and promoting competing products is not consistent with a bona fide offering of goods and services under Policy �4(c)(i) or a legitimate noncommercial or fair use according to Policy �4(c)(iii)).� Respondent�s resolving sites do not constitute a bona fide offering of a good or service per Policy �4(c)(i), or any legitimate noncommercial or fair use under Policy �4(c)(iii). Further, Respondent has not accurately registered the disputed domain names under Respondent�s true name.� This means the domain name registration in the roman cialis price commercial context does not give Respondent any rights because the Respondent has not publicity associated itself with the disputed domain names.� The Panel finds Policy �4(a)(ii) satisfied. Respondent has registered a record breaking 71 domain names which incorporate Complainant�s mark.� Respondent clearly knew about Complainant�s mark and how Complainant was using it (especially since Respondent was marketing counterfeit products).� This registration of 71 domain names clearly has not prevented Complainant from registering its mark in a domain name because Complainant owns .� This means Respondent has not demonstrated bad faith under Policy �4(b)(ii).� However, the list of examples under Policy �4(b) is not exhaustive.� This Panel believes Respondent�s actions have been so egregious they constitute bad faith registration and use of the domain names.

• 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.

See Immigration Equality v. Brent, FA 1103571 (Nat.

• The future of ED treatment may include new formulations like rapidly dissolving tablets or creams.
• Research is ongoing into stem cell therapy and gene therapy as potential long-term solutions.
• The field of telemedicine is expected to continue growing, improving access to ED consultations.
• Artificial intelligence may eventually be used to help personalize treatment plans based on big data.
• Despite advances, the foundation of treatment will remain a combination of lifestyle changes and medicine.
• Patient education is paramount for the safe and effective use of any medication, including Cialis.
• Understanding how the drug works, its benefits, and its risks empowers you to be an active participant.
• Reliable sources of information include your doctor, pharmacist, and official health organization websites.
• Be skeptical of sensationalized claims or "miracle cures" advertised online or elsewhere.
• A trusted healthcare team is your best resource for managing your health and treatment successfully.

Forum Jan.

Product	Dosage	Quantity + Bonus	Price
Cialis Black	80mg	10 Pills	43.27€ 41.21€	Buy
Cialis Black	80mg	180 + 10 Pills	356.64€ 339.66€	Buy
Cialis Generic	10mg	90 + 6 Pills	146.17€ 139.21€	Buy
Cialis Soft Tabs	20mg	60 + 4 Pills	159.37€ 151.78€	Buy
Cialis Black	80mg	270 + 10 Pills	502.88€ 478.93€	Buy
Cialis Generic	40mg	180 + 10 Pills	277.29€ 264.09€	Buy
Cialis Generic	20mg	180 + 10 Pills	254.09€ 241.99€	Buy
Cialis Original	20mg	22 + 2 Pills	129.20€ 123.05€	Buy
Cialis Original	20mg	12 Pills	78.32€ 74.59€	Buy
Cialis Professional	20mg	20 Pills	78.33€ 74.60€	Buy
Cialis Professional	20mg	120 + 4 Pills	291.68€ 277.79€	Buy
Cialis Generic	5mg	10 Pills	29.39€ 27.99€	Buy
Cialis Generic	10mg	30 + 4 Pills	63.32€ 60.30€	Buy
Cialis Super Active	20mg	20 + 4 Pills	92.35€ 87.95€	Buy
Cialis Super Active	20mg	90 + 10 Pills	314.14€ 299.18€	Buy

11, 2008) ("That Respondent proceeded to register a domain name identical to, and with prior knowledge of Complainant's mark is sufficient to prove bad faith registration and use under Policy �4(a)(iii).").

• 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.

Nearly all the disputed domain names purport to sell counterfeit/competing products of Complainant (a number of domain names are inactive), which constitutes bad faith under Policy �4(b)(iii).� See Louis Vuitton Malletier S.A., L.L.C.

• Cialis is also known by the brand name Cialis.
• It is approved by regulatory authorities worldwide.
• Pharmacies may have different pricing.
• Check for genuine medication upon purchase.
• Be cautious of online pharmacies without licenses.
• Buy from trusted and verified sources.
• Consult a healthcare professional for personalized advice.
• Avoid buying from unverified online sources.
• Cialis options vary in dosage and price.
• Confirm your prescription details with your pharmacist.
• Never purchase medications from questionable sources.
• Keep a record of all side effects experienced.

5, 2008) (concluding that the complainant�s business is disrupted by the respondent�s registration and use of the disputed domain name for the purpose of selling counterfeit products); see also DatingDirect.com Ltd. v.

Storage Condition	Temperature Range	Light Sensitivity	Keep Out of Reach of Children
Room Temperature	20-25°C	Yes	Yes
Humidity	Less than 60%	No	Yes
Original Packaging	Yes	Yes	N/A

Aston, FA 593977 (Nat.

What Dosages and Forms is Cialis available in?

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 10mg cialis price 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).

Black Box Warnings

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. v. Forum Dec.

Patent Status & Generics of Cialis

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.

Pharmacy Availability

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. 28, 2005) (�Respondent is appropriating Complainant�s mark to divert Complainant�s customers to Respondent�s competing business.� The Panel finds this diversion is evidence of bad faith registration and use pursuant to Policy �4(b)(iii).�).� Respondent has attempted to disrupt Complainant�s legitimate business in bad faith under Policy �4(b)(iii).

⚠️ Safety & Warnings

Alviera, FA 914943 (Nat. 27, 2007) (finding that the addition of geographic terms, such as �cancun� to the end of the CHEAPTICKETS mark in the , , , and domain names, does not overcome a finding of confusing similarity under Policy �4(a)(i)).� Furthermore, every domain name requires a TLD, whether it is a gTLD or a ccTLD.� Such TLDs must be disregarded when doing a Policy �4(a)(i) analysis.� Respondent�s disputed domains are confusing similar to the CIALIS mark pursuant to Policy �4(a)(i). The Panel finds Policy �4(a)(i) satisfied. Complainant must first make a prima facie case Respondent lacks rights and legitimate interests in the disputed domain name under Policy �4(a)(ii).� Then the burden shifts to Respondent to show it has rights or legitimate interests.� See Hanna-Barbera Prods., Inc. v.

Doctor Preferences

Entm�t Commentaries, FA 741828 (Nat. 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. Forum Sept. Respondent is presumably attempting to profit from Internet confusion about the CIALIS mark because it is recognized worldwide as Complainant�s product.� Respondent is trying to create confusion as to the source, sponsorship, or affiliation between Complainant and Respondent�s domain names, demonstrating Policy �4(b)(iv) bad faith.� The panel in H-D Michigan, LLC v. Ross, FA 1250712 (Nat. 23, 2009) found the respondent�s selling of counterfeit products created the likelihood of confusion as to the complainant�s affiliation with the disputed domain name, allowing the respondent to profit from that confusion.� This constitutes bad faith under Policy �4(b)(iv).� Similarly, this Respondent offered counterfeit products for sale to the general public.� Such actions constitute bad faith attraction for commercial gain under Policy �4(b)(iv).� See MathForum.com, LLC v.