Date: 27 September 2014
1. Screenshot of the commercial IT company website located at www.MixSoftware PHP developers-Mix Software PHP developerss.com. This indicates that domains containing "MixSoftware PHP developers" are not exclusive to the Complainant nor to commercial entities in the same industry as the Complainant.
2. List of other active websites with "MixSoftware PHP developers" in the domain name.
3. Examples of "MixSoftware PHP developers" marks registered in the United States. A mark that Complainant has not registered in the United States. . Unlike these entities, Complainant has not made any attempt to protect its mark in the US by registering the mark.
4. A URL link to an online copy of Respondent's 50 plus page written Complaint against Complainant and a URL link to supporting evidence (over 100 individual items) corresponding to the footnotes in Respondent's Complaint.
The complaint, substantiated by vast evidence supports Respondent's legitimate reason for and use of the disputed domains.
5. Screenshot of email received by Respondent from Yuriy Zaytev attempting to sell a domain confusingly similar to Complainant's domain.
The screenshot contains Mr. Zaytev's email address, phone number, and address.
6. Screenshot of an email Complainant sent to Respondent threatening Respondent with legal action.
7. Screenshot of Complainant's company profile on Elance.com (an escrow site for developers where Respondent obtained Complainant's services).
Indicates the ominous size of Complainant's (over 500 employees) in comparison to the Respondent, who is a private vulnerable to potential retribution.
X. List of Annexes
1. Screenshot of the commercial IT company website located at www.MixSoftware PHP developers-Mix Software PHP developerss.com. This indicates that domains containing "MixSoftware PHP developers" are not exclusive to the Complainant nor to commercial entities in the same industry as the Complainant.
2. List of other active websites with "MixSoftware PHP developers" in the domain name.
3. Examples of "MixSoftware PHP developers" marks registered in the United States. A mark that Complainant has not registered in the United States. . Unlike these entities, Complainant has not made any attempt to protect its mark in the US by registering the mark.
4. A URL link to an online copy of Respondent's 50 plus page written Complaint against Complainant and a URL link to supporting evidence (over 100 individual items) corresponding to the footnotes in Respondent's Complaint.
The complaint, substantiated by vast evidence supports Respondent's legitimate reason for and use of the disputed domains.
5. Screenshot of email received by Respondent from Yuriy Zaytev attempting to sell a domain confusingly similar to Complainant's domain.
The screenshot contains Mr. Zaytev's email address, phone number, and address.
6. Screenshot of an email Complainant sent to Respondent threatening Respondent with legal action.
7. Screenshot of Complainant's company profile on Elance.com (an escrow site for developers where Respondent obtained Complainant's services).
Indicates the ominous size of Complainant's (over 500 employees) in comparison to the Respondent, who is a private vulnerable to potential retribution.
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