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Some Complaint claims and accusations:
* The domain name is confusingly similar to UPS, UPS.COM & UPS ONLINE (section A para 13)
*The domain name has not been used for bona fide offering of service (section B para 22-24)
*The domain name was registered to divert and mislead consumers (section B para 26)
*Pick Ups Online is not commonly known by the domain name and is seeking a free ride on the goodwill of UPS (section B para 28-30)
*The use of the domain name is neither legitimate or fair...the use of the domain name is intended to deceive and confuse for the soul purpose of commercial gain (section B para 31-32)
*We are using the domain name in Bad faith (section C)
AND SO ON ...
**UPS requests that the domain name be trasferred to them (para 34)
Our Response in brief:
It will be necessary for us to respond to WIPO with evidence that will support our valid use of the domain name as well as discredit claims and accusations made regarding our motives and use of the domain name. We will be asking for letters from customers to assist us in this support. An email with details will be sent in due course.
*Pick Ups Online is a bona fide business that has been trading for four years
*The name Pick Ups Online was used because we take pick up bookings online. It had or has nothing to do with UPS.
*We have never and will probably not in the future compete directly with UPS.
*Pick Ups Online's method of generating business have been primarily through referral and Yellow Pages advertising. It has in no way ever expected a spin off from UPS's reputation.
Click here for link to Complaint document
United Parcel Service of America has FAILED in its attempt on ALL grounds to acquire pickupsonline.com.au domain name. The action was a deliberate attempt to BULLY a small business in Australia seriously compromising the ethics and integrity of UPS as a company. Below is a link to the Administrative decision Document.
Click here for Administrative Panel Decision
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