(1) the domain names registered by Respondent are 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 names; and (3) the domain names were registered and are being used 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 Complainant prove the following three elements to obtain an order cancelling or transferring a domain name: (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 view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules.� The Panel is entitled to accept all reasonable allegations and inferences set forth in the Complaint as true unless the evidence is clearly contradictory.� See Vertical Solutions Mgmt., Inc.

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29, 2000) (Annex 3, F); and Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (NAF, July 31, 2000). According to LegitScript, a company providing assistance with this proceeding, the Domain Names have been identified as under control of a rogue online pharmacy operator that uses false contact information to register domains.� The Domain Names resolve to websites that advertise and sell generic versions of Complainant�s CIALIS brand product and the sites are part of the same networks, �Rx-Partners,� �Pharmcash� and �Pharmatheke�. [1]� All of the Domain Names are hosted on the same IP address (i.e., 37.187.146.46).� All of the Domain Names that are registered using a name other than Denisov Denis, all link to Denisov Denis via either recent historical WhOIS information or Denisov Denis� email colman662@gmail.com.� Further, each �unique� registrant name uses the email address � ss@ss.ru � at least once in the WHOIS information for each Domain Name.� Other commonalities include, of course, that the Domain Names contain the CIALIS trademark and all of the Domain Names were registered between November 2012 through October 2015.� For all of the foregoing reasons, the Domain Names are likely under common control, notwithstanding that the true identity of the Respondents may be a joint criminal enterprise acting together in concert, rather than a single individual.� Complainant respectfully submits that this satisfies the preponderance of the evidence standard required for consolidation of the Domain Names into a single proceeding.� This Panel generally agrees with Complainant�s claims.� Respondent has done nothing to dispute them.� Complainant has met it burden of proof by a preponderance of the evidence.� The entities which control the disputed domain names 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 a �complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.�� All domains are under control of a single rogue online pharmacy operator, which utilizes false contact information to register domains.� All domain names in dispute resolve to websites which advertise and sell generic versions of Complainant�s products.� All domain names in dispute are hosted on the same IP address.� All domain names in dispute are linked in one way or another to �Denisov Denis.� Each �unique� registrant name uses the email address ss@ss.ru.� All disputed domains contain the CIALIS mark in its entirety.

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Taken in its entirely, this is adequate evidence the listed entities are jointly controlled.� Pursuant to Forum Supplemental Rule 4(c), this Panel also finds all of the domain names are commonly owned.� The named Respondent in this Proceeding shall be Denisov Denis. Complainant requests this administrative proceeding proceed in the English language pursuant to UDRP Rule 11(a). Complainant makes this request even though some of the Registration Agreements are in Russian (most of them are in English). 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. 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. v.

Product	Dosage	Quantity + Bonus	Price
Cialis Generic	5mg	180 + 10 Pills	159.65€ 152.05€
Cialis Generic	20mg	360 + 10 Pills	427.34€ 406.99€
Cialis Generic	40mg	360 + 10 Pills	477.87€ 455.11€
Cialis Generic	60mg	60 + 4 Pills	145.06€ 138.15€
Cialis Soft Tabs	20mg	60 + 4 Pills	159.37€ 151.78€
Cialis Professional	40mg	10 Pills	65.09€ 61.99€
Cialis Soft Tabs	20mg	120 + 6 Pills	248.64€ 236.80€
Cialis Generic	5mg	10 Pills	29.39€ 27.99€
Cialis Generic	10mg	180 + 8 Pills	236.88€ 225.60€
Cialis Original	20mg	64 + 4 Pills	274.18€ 261.12€
Cialis Generic	20mg	10 Pills	31.49€ 29.99€
Cialis Professional	40mg	60 + 2 Pills	262.32€ 249.83€
Cialis Black	80mg	30 + 2 Pills	89.11€ 84.87€

webnet-marketing, inc., FA 95095 (Nat. Forum July 31, 2000) (holding that the respondent�s failure to respond allows all reasonable inferences of fact in the allegations of the complaint to be deemed true); see also Talk City, Inc.

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See Eli Lilly and Company v. Darren K. Headley et al., D2013-1303 (WIPO, Sept. 3, 2013) (finding �[t]here is significant precedent supporting consideration for such consolidation when the disputed domain names are determined to be under common control) (citing Guccio Gucci S.p.A v. Andrea Hubner et al., D2012-2212 (WIPO, Feb.

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8, 2013) (�UDRP jurisprudence suggests consolidation of multiple respondents may be appropriate, under paragraphs 3(c) and 10(e) of the Rules, even where differently named domain name registrants are involved, where the particular circumstances of a given case indicate that common control is being exercised over the disputed domain names or the websites to which the domain names resolve�); and Speedo Holdings B.V. v. Programmer, Miss Kathy Beckerson et al., D2010-0281 (WIPO, May 18, 2010); see also HLT Domestic IP LLC v. Boris Chevkov / Macky Tong, Claim No. FA1405001558971 (NAF, June 23, 2014) (�Previous Panels have also found multiple respondents to be commonly controlled where the content of their websites were substantially identical and referred Internet visitors to a common homepage.�) The burden of proof for establishing that the disputed domain names are subject to common control is a preponderance of the evidence. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (�In the absence of a response, it is appropriate to accept as true all allegations of the Complaint.�). Complainant has requested these proceedings be consolidated.� For the purposes of clarity and to insure the Panel�s ruling is understandable to readers who are not parties, Complaint�s request will be set out in full:� Complainant hereby requests permission to proceed against multiple respondents in this single administrative proceeding pursuant to �3(c) or 10(e) of the UDRP Rules.� The consolidation of multiple registrants as respondents in a single administrative proceeding is appropriate under �3(c) or 10(e) of the UDRP Rules provided the complainant can demonstrate that the disputed domain names or the websites to which they resolve are subject to common control, and the Panel, having regard to all of the relevant circumstances, determines that consolidation would be procedurally efficient and fair and equitable to all parties. See Eli Lilly and Company v. Darren K. Headley et al., D2013-1303 (WIPO, Sept. 3, 2013) (finding �[t]here is significant precedent supporting consideration for such consolidation when the disputed domain names are determined to be under common control) (citing Guccio Gucci S.p.A v. Andrea Hubner et al., D2012-2212 (WIPO, Feb. 8, 2013) (�UDRP jurisprudence suggests consolidation of multiple respondents may be appropriate, under paragraphs 3(c) and 10(e) of the Rules, even where differently named domain name registrants are involved, where the particular circumstances of a given case indicate that common control is being exercised over the disputed domain names or the websites to which the domain names resolve�); and Speedo Holdings B.V. v.

Step	Action	Notes
1	Take with water	On an empty or full stomach
2	Avoid high-fat meals before	May delay absorption
3	Do not exceed prescribed dose	Risk of side effects
4	Engage in sexual activity after 1 hour	For best results

Programmer, Miss Kathy Beckerson et al., D2010-0281 (WIPO, May 18, 2010); see also HLT Domestic IP LLC v. Boris Chevkov / Macky Tong, Claim No. FA1405001558971 (NAF, June 23, 2014) (�Previous Panels have also found multiple respondents to be commonly controlled where the content of their websites were substantially identical and referred Internet visitors to a common homepage.�) The burden of proof for establishing that the disputed domain names are subject to common control is a preponderance of the evidence. See Seiko Holdings Kabushiki Kaisha v. L. Collins Travis, C.

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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. See Finter Bank Zurich v.

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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. Turner Jose, et al., D2013-0994 (WIPO, Aug. 6, 2013) (�In this instance, the Panel finds that the Complainant has established more likely than not that the disputed domain names are subject to common ownership or control��); and Lanc�me Parfums Et Beaut Et Compagnie v.

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See Seiko Holdings Kabushiki Kaisha v. L. Collins Travis, C. Turner Jose, et al., D2013-0994 (WIPO, Aug. 6, 2013) (�In this instance, the Panel finds that the Complainant has established more likely than not that the disputed domain names are subject to common ownership or control��); and Lanc�me Parfums Et Beaut Et Compagnie v.

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You Ge, Jean Buding, Kang Tianhuan, Zongkaili, Leigeng, D2013-1559 (WIPO, Nov. 20, 2013) (��the Panel infers that on the balance of probabilities, the disputed domain names are all controlled or under the common ownership of the same person or entity��).� Where consolidation will permit multiple domain name disputes arising from a common nucleus of facts and involving common legal issues to be heard and resolved in a single administrative proceeding, the shared interests of the parties are promoted in avoiding unnecessary duplication of time, effort and expense, and generally furthers the fundamental objectives of the Policy. All reasonable allegations and inferences set forth in the complaint may be accepted as true unless the evidence is clearly contradictory.� See cialis without a doctor prescription Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. You Ge, Jean Buding, Kang Tianhuan, Zongkaili, Leigeng, D2013-1559 (WIPO, Nov. 20, 2013) (��the Panel infers that on the balance of probabilities, the disputed domain names are all controlled or under the common ownership of the same person or entity��).� Where consolidation will permit multiple domain name disputes arising from a common nucleus of facts and involving common legal issues to be heard and resolved in a single administrative proceeding, the shared interests of the parties are promoted in avoiding unnecessary duplication of time, effort and expense, and generally furthers the fundamental objectives of the Policy. All reasonable allegations and inferences set forth in the complaint may be accepted as true unless the evidence is clearly contradictory.� See cialis without a doctor prescription Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb.

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Forum July 31, 2000) (holding that the respondent�s failure to respond allows all reasonable inferences of fact in the allegations of the complaint to be deemed true); see also Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (�In the absence of a response, it is appropriate to accept as true all allegations of the Complaint.�). Complainant has requested these proceedings be consolidated.� For the purposes of clarity and to insure the Panel�s ruling is understandable to readers who are not parties, Complaint�s request will be set out in full:� Complainant hereby requests permission to proceed against multiple respondents in this single administrative proceeding pursuant to �3(c) or 10(e) of the UDRP Rules.� The consolidation of multiple registrants as respondents in a single administrative proceeding is appropriate under �3(c) or 10(e) of the UDRP Rules provided the complainant can demonstrate that the disputed domain names or the websites to which they resolve are subject to common control, and the Panel, having regard to all of the relevant circumstances, determines that consolidation would be procedurally efficient and fair and equitable to all parties. 29, 2000) (Annex 3, F); and Vertical Solutions Mgmt., Inc. v. webnet-marketing, inc., FA 95095 (NAF, July 31, 2000). According to LegitScript, a company providing assistance with this proceeding, the Domain Names have been identified as under control of a rogue online pharmacy operator that uses false contact information to register domains.� The Domain Names resolve to websites that advertise and sell generic versions of Complainant�s CIALIS brand product and the sites are part of the same networks, �Rx-Partners,� �Pharmcash� and �Pharmatheke�. [1]� All of the Domain Names are hosted on the same IP address (i.e., 37.187.146.46).� All of the Domain Names that are registered using a name other than Denisov Denis, all link to Denisov Denis via either recent historical WhOIS information or Denisov Denis� email colman662@gmail.com.� Further, each �unique� registrant name uses the email address � ss@ss.ru � at least once in the WHOIS information for each Domain Name.� Other commonalities include, of course, that the Domain Names contain the CIALIS trademark and all of the Domain Names were registered between November 2012 through October 2015.� For all of the foregoing reasons, the Domain Names are likely under common control, notwithstanding that the true identity of the Respondents may be a joint criminal enterprise acting together in concert, rather than a single individual.� Complainant respectfully submits that this satisfies the preponderance of the evidence standard required for consolidation of the Domain Names into a single proceeding.� This Panel generally agrees with Complainant�s claims.� Respondent has done nothing to dispute them.� Complainant has met it burden of proof by a preponderance of the evidence.� The entities which control the disputed domain names 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 a �complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.�� All domains are under control of a single rogue online pharmacy operator, which utilizes false contact information to register domains.� All domain names in dispute resolve to websites which advertise and sell generic versions of Complainant�s products.� All domain names in dispute are hosted on the same IP address.� All domain names in dispute are linked in one way or another to �Denisov Denis.� Each �unique� registrant name uses the email address ss@ss.ru.� All disputed domains contain the CIALIS mark in its entirety. Taken in its entirely, this is adequate evidence the listed entities are jointly controlled.� Pursuant to Forum Supplemental Rule 4(c), this Panel also finds all of the domain names are commonly owned.� The named Respondent in this Proceeding shall be Denisov Denis. Complainant requests this administrative proceeding proceed in the English language pursuant to UDRP Rule 11(a).

Cialis’s onset is typically within 30 minutes.
The drug’s effects can last up to 36 hours.
Do not take more than the prescribed dose.
Missed doses should not be doubled.
Consult your doctor if you miss a dose.
Cialis is not an instant solution; arousal is needed.
Overuse can increase side effect risk.
Ensure your doctor is aware of all health conditions.
Cialis is used worldwide for ED treatment.
Pharmacists provide guidance on safe use.
Be mindful of expiration dates.
Do not use expired medication.

Complainant makes this request even though some of the Registration Agreements are in Russian (most of them are in English). 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.

Country	Prescription Requirement	Sale Restrictions	Age Limit
USA	Prescription mandatory	Online and pharmacy	18+
Germany	Prescription required	In pharmacies only	18+
Australia	Prescription needed	Only in pharmacies	18+

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. See Finter Bank Zurich v.

Adherence to the prescribed regimen is critical for achieving the best results with treatment.
For daily dosing, taking the pill at the same time each day helps maintain steady drug levels.
Setting a daily reminder or using a pill organizer can help prevent missed doses.
Do not increase your dose without talking to your doctor, even if you feel the medication isn't working.
It may take a few attempts or dosage adjustments to find what works best for you.
Keeping a log of your responses can help your doctor fine-tune your treatment plan.
Note the timing of the dose, presence of sexual stimulation, and the quality of the erection.
Also record any side effects you experience and their severity.
This data provides valuable objective information for your healthcare provider.
Be patient; finding the right treatment approach is often a process of adjustment.