![]() Substantial sales (over $2.37 million dollars since 2006 alone) on orders of Than ten (10) years continuously and without interruption, it achieved it has used THE BIRDSAFE STORE mark for more Publications of its principal, clinic management, and recognition by industry Has established a prominent and leading position in the marketplace as is amplyĭemonstrated by evidence of substantial sales and orders, website visitors,Īdvertising expenditures, links to affiliate rescue organizations, awards, it has actively used and successfully promoted the mark in commerce, and it has common law rights in and to the service mark 5. Related products, and reference materials and programs promoting awareness ofĪnd providing education related to bird health and safety issues through its Its on-line retail store outlet for bird supplies, accessories, toys and ![]() Without interruption, in commerce since 2000 to identify it is the source of it has used the common law service mark THE BIRDSAFE STORE continuously, it acquired the domain names on JanuandĪnd have been continuously so since they were acquired 3. Has operated continuously, without interruption, in commerce since that time 2. it was chartered by the Commonwealth of Virginia on Apand Requests that the domain name be transferred from Respondent to Complainant.Ĭontends that: 1. Single-member Panel, the National Arbitration Forum appointed M. Submissions were received from Complainant on Decemand fromĢ010, pursuant to Complainant’s request to have the dispute decided by a Was received and determined to be complete on December 15, 2010. Registration as technical, administrative and billing contacts. Via post and fax, to all entities and persons listed on Respondent’s Respondent could file a Response to the Complaint, via e-mail to all entitiesĪnd persons listed on Respondent’s registration as technical, administrative, andīilling contacts, and to Also on November 4,Ģ010, the Written Notice of the Complaint, notifying Respondent of the emailĪddresses served and the deadline for a Response, was transmitted to Respondent Notice of the Complaint, setting a deadline of Decemby which Registration agreement and has thereby agreed to resolve domain disputesīrought by third parties in accordance with ICANN’s Uniform Domain Name DisputeĢ010, the Forum served the Complaint and all Annexes, including a Written has verified that Respondent is bound by the, Inc. and that Respondent is the current registrant of the names. confirmed by e-mail to the National Arbitration Forum Octothe National Arbitration Forum received payment on OctoberĢ010,, Inc. Submitted a Complaint to the National Arbitration Forum electronically on His knowledge has no known conflict in serving as Panelist in this proceeding. Represented by Kathie Hahn, Esquire, New Jersey, USA.Īt issue is, registered with ,Ĭertifies that he has acted independently and impartially and to the best of Resp ondent is MY SAFE BIRD STORE (“Respondent”), ![]() Parker,Įsquire of Bowles Rice McDavid Graff & Love LLP, West Virginia, At night he goes into his own room in a sleep, Inc. ![]() That room is basically open to everything else. There is a pass-through to the open concept kitchen living room, so whether he is out and about or in his cage, he can see what’s happening. He also has two climbing nets and his flight cage in that room. He knows it’s there, but I’m a nervous mama. And I am too nervous to leave the glass exposed. I have the shears on the windows because he decided it would be fun to to the blinds. So I sprayed that on my plants as well as the ficus. I got a good tip from a vet, he said bitter apple spray would work. He has not even thought about the other plants. The only one he has gone there is the Jade. My cousin, who is also a bird owner, asked me about the plants. (Ordered from my bird safe store) Now Georgie can happily play while I’m working.
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