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.] RESPONSE TO FACTUAL AND LEGAL ALLEGATIONS MADE IN COMPLAINTS

This Response specifically responds to the statements and allegations contained in the Complaint and includes any and all bases for the Respondent to retain registration and use of the disputed domain names. ICANN Rule 5(b)(i). [The analysis in this section may require more space than provided, but the entire Complaint shall not exceed ten (10) pages. NAF Supp. Rule 5(a).]

[Elements of the UDRP are as follows:]

[a.] [Specify in the space below the manner in which the domain name(s) is not/are not identical or confusingly similar to a trademark or service mark in which the Complainant has rights.] ICANN Rule 3(b)(ix)(1); ICANN Policy  4(a)(i).



Aol.com - America Online
www.Aol.com
and Microsoft - so far have accomplished what Reverse Domain Name Hijackers do to Registrants - make domains un-available to use




Aol.tv - www.Cityfarmer.tv
www.Aol.tv



[b] [Specify in the space below why the Respondent (domain-name holder) should be considered as having rights or legitimate interests in respect of the domain name(s) that is/are the subject of the complaint.] ICANN Rule 3(b)(ix)(2); ICANN Policy  4(a)(ii).

Respondent believes
1.) He registered domain name because it was available.
2.) He purchased domain name at 10 times the regular price of regular .tv domains for 3 year term. Complainant says their host inadvertently sold domain name, was the price inadvertently raised also?
3.) He purchased domain as an investment for family's future.
4.) Many Possibilities. A______ Online Live
5.) www.Entrepreneur.tv

[The Panel may consider any relevant aspects included in, but not limited to ICANN Policy 4(c):

(i.) Whether, before any notice to the Respondent of the dispute, Respondent's use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name is in connection with a bona fide offering of goods or services; or

----- Original Message -----
From: Edward Tapia
To: adsense-support@google.com ; info@google.com ; contactmanager ; Ed Tapia ;
Sent: Saturday, May 01, 2004 7:17 AM
Subject: Possibilities