Respondent submits that it has been using the Domain Name to offer bona fide services in the online dating industry and has been active on this . Based on its popularity, Respondent claims it is commonly known by its Domain Name within the online dating industry. The homepage of the website linked to the Domain Name makes clear that the website is owned and operated by Linking Lovers Ltd and that there is no affiliation with any of the competing online dating websites owned by Complainant. Consequently, Respondent urges that it is making a legitimate commercial use of the Domain Name, thus demonstrating that Respondent has rights and legitimate interests in it.
With regard to Complainant’s allegation that Linking Lovers Ltd was incorporated on , and that this allegedly proves that Respondent’s use of the Domain Name is calculated to falsely suggest to Internet users that Complainant is affiliated with Respondent’s website, Respondent emphasizes that the fact that Linking Lovers Ltd was incorporated on does not tiny chat change the fact that the Domain Name has been legitimately used since 2014, nor does this have anything to do with the allegations made by Complainant. Consequently, Respondent asks the Panel to disregard this claim in determining the legitimate use of the Domain Name.
In response to Complainant’s claim that Respondent is using the Domain Name to intentionally attract, for commercial gain, Internet users to Respondent’s website by creating a likelihood of confusion with Complainant’s mark, Respondent states that Complainant and Respondent are two distinct operators in the online dating industry.