IETE Apex Forum on Cybercrime and Indian Cyberlaw- An introspection 12 September,2008, IETE HQ. D omain names & Dispute Resolution Karnika Seth Cyberlaw.

IETE Apex Forum on Cybercrime and Indian Cyberlaw-An introspection 12 September,2008, IETE HQ.

Domain names & Dispute Resolution

Karnika Seth Cyberlaw Expert & Managing Partner,

Seth Associates© Seth Associates, 2008 All Rights Reserved

Copyrighted by Seth Associates 2008.

What is a domain name ? The Domain Name System (DNS) is a hierarchical naming system for

computers, services, or any resource participating in the Internet. It associates various information with domain names assigned to such participants. Most importantly, it translates humanly-meaningful domain names to the numerical (binary) identifiers associated with networking equipment for the purpose of locating and addressing these devices world-wide.

An often used analogy to explain the Domain Name System is that it serves as the "phone book" for the Internet by translating human-friendly computer hostnames into IP addresses. For example, www.example.com translates to 208.77.188.166.

Domain names are used in a variety of contexts for identification, reference, and access to Internet resources. They can appear as components of Web sites' Uniform Resource Locators (URL, 'Web-address'), e.g. www.wikipedia.org, electronic mail (e-mail) addresses after the customary '@' separator from the user's name, or as any other part of a syntax that describes an access method to a device or service in an IP network.


Origin Domain names are created out of a naming

space and methodology that was first defined by Paul Mockapetris in IETF publication RFC 882 and RFC 883 (1983) and used in the first expansion of the ARPANET, a predecessor of today's Internet


ICANN & its role The right to use a domain name is delegated by domain name registrars which are

accredited by the Internet Corporation for Assigned Names and Numbers (ICANN), the organization charged with overseeing the name and number systems of the Internet. In addition to ICANN, each top-level domain (TLD) is maintained and serviced technically by a sponsoring organization, the TLD Registry. For India, National Centre for Software Technology is the sponsoring organisation and .in registry is National Internet Exchange of India .

The registry is responsible for maintaining the database of names registered within the TLDs they administer. The registry receives registration information from each domain name registrar authorized to assign names in the corresponding TLD and publishes the information using a special service, the whois protocol.

However, the rules of assignment specify that no legal ownership is conferred with such transactions, only the right of exclusive use and the authority to the name space. Once assigned, a domain name becomes part of the pool of registered domain names and is no longer available for use by anyone else.


A domain name usually consists of two or more parts (technically a label), which is conventionally written separated by dots, such as example.com.

The rightmost label conveys the top-level domain (for example, the address www.example.com has the top-level domain com).

Each label to the left specifies a subdivision, or subdomain of the domain above it. Note: “subdomain” expresses relative dependence, not absolute dependence. For example: example.com is a subdomain of the com domain

A hostname refers to a domain name that has one or more associated IP addresses; ie: the 'www.example.com' and 'example.com' domains are both hostnames, however, the 'com' domain is not. (or “SLD”)

The location of a website, ending in a suffix such as '.com' (for commercial sites), '.org' (non-profit organisations), '.edu' (education), '.gov' (government), '.net' (internet-related), or regionally-specific variants such as '.co.uk' (UK company), '.ac.uk' (UK higher education), '.gouv.fr' (French government) are few examples of TLDs.

Parts of a domain name


Few examples of domain names Generic domains- .biz · .com · .info · .name · .net · .org ·

.pro A country code top-level domain (ccTLD) is an Internet

top-level domain generally used or reserved for a country or a dependent territory. E.g .in, .uk,.eu

geodomain refers to domain names that are the same as those of geographic entities, such as cities and countries. Examples of geodomains are Atlanta.com, LosAngeles.com, Texas.com and Memphis.org.

Sponsored-aero · .asia · .cat · .coop · .edu · .gov · .int · .jobs · .mil · .mobi · .museum · .tel · .travel


Market value of a domain name Various factors influence the

perceived value or market value of a domain name. They include -

1) the natural or "organic" traffic that can be attributed to web surfers typing in a domain name in their web browser as opposed to doing a search for the site through a search engine

2) Branding Opportunity. The ability to have a term recognized and easily recalled as a brand for a company or entity.

3) Re-sale value. The ability to spot trends and predict the value of a name based on its length (short is preferred), clarity, and commercial use.

Branding

Resale value

Organic traffic


Most expensive domain name sales To date, and according to

Guinness World Records and MSNBC, the most expensive domain name sales on record as of 2004 were:

Business.com for $7.5 million in December 1999

AsSeenOnTv.com for $5.1 million in January 2000

Altavista.com for $3.3 million in August 1998

Wine.com for $2.9 million in September 1999

CreditCards.com for $2.75 million in July 2004

Autos.com for $2.2 million in December 1999

Business.com$7.5 million

Asseenontv.com$5.1 million

Altavista.com$ 3.3 Million


Kinds of domain name disputes

Cyber squatting

Trademark infringement/passing offDilution


DND- Cybersquatting The popularity of domain names also led to uses which were regarded as

abusive by established companies with trademark rights; this has become known as cybersquatting, in which a person registers a domain name that resembles a trademark in order to profit from visitors looking for that address. To combat this, various laws and policies were enacted to allow abusive registrations to be forcibly transferred, but these were sometimes themselves abused by overzealous companies committing reverse domain hijacking against domain users who had legitimate grounds to hold their names.

One of the famous cases on cyber squatting is the One in a million case[1]. In this case the court in United kingdom granted an injunction to prevent the cyber squatting of domain names involving well-known brands such as Sainsbury, Mark and Spencer and British Telecom. [1] Marks & Spencer plc vs. One in a Million, 1998 FSR 265

India case- Tata Tea vs Gem lifts lts- see detailed case study hereinafter..


Attributes of Passing OffLord diplock in Erven Warnink v J Townend 1979 (2)AllER 927-To Succeed in an action for passing off, a claimant should establish that:

The claimant has a goodwill

The misrepresentation damages or is likely to damage the goodwill of the claimant.

Passing off is made in the course of trade.

The defendant made a misrepresentation that is likely to deceive the public.


Passing off action & TM infringement under the Trade Marks Act, 1999

A registered Trademark has the backing of infringement and passing off remedies under the TMA Act.

The Act does not provide for infringement action in respect of unregistered Trademarks.-section 27 TMA

Only Passing off remedy is available in case of unregistered Trademarks.

(Section 27 of TMA Act, 1999).


Dilution Dilution is a trademark law concept

forbidding the use of a famous trademark in a way that would lessen its uniqueness.

In most cases, trademark dilution involves an unauthorized use of another's trademark on products that do not compete with, and have little connection with, those of the trademark owner( Section 29(4) TMA)


Case on dilution Toys "R" Us, Inc. v. Feinberg and Guns are We, 1998 WL 760219, Oct.

28, 1998, (SDNY). Plaintiff Toys "R" Us sued defendant Guns are We for use of the domain

name gunsareus.com. The court granted the defendant's motion for summary judgment after concluding that the plaintiff had not demonstrated any evidence of likelihood of confusion or dilution. In determining that there is no likelihood of confusion the court indicated that it is unlikely that a prudent consumer would be misled into thinking that Toys "R" Us had sponsored a small gun shop web site targeting primarily gun dealers. Additionally the court emphasized that the gunsareus.com domain name did not use the infamous "r" but instead spelled out the word "are." Additionally, in its dilution analysis, the court noted that the title of the web page was not "Guns Are US" or "Guns ‘R’ Us," but instead "Guns Are We." Thus the distinctiveness of the "R" Us family of marks was not likely to be blurred.


Trade Mark Infringement The taking of any essential feature of the mark or

taking the whole of the mark and then making a few additions and alterations would constitute infringement.

The infringing mark must be used in the course of trade, i.e, in a regular trade wherein the proprietor of the mark is engaged.

The use of the infringing mark must be printed or usual representation of the mark in advertisements, invoices or bills. Any oral use of the trade mark is not infringement.

Advertising with the unauthorized use of the registered trade mark is also an act of infringement.

Any or all of the above acts would constitute infringement if the same is done in such a manner as to sender the use of the mark likely to be taken as being used as a trade mark. (See Section 29 TMA)

Sec 135 Relief in suits for infringement or for

passing off, includes injunction and at the option of the plaintiff, either damages or an account of profits.

In brief, the relief to which a plaintiff is entitled are- An injunction restraining further

use of the infringing mark. Damages or an account of profits. An order for delivery-up of

infringing labels and marks for destruction or erasure.

Injunction may be of the following types:- Anton Piller Order Mareva Injunction Interlocutory Injunction Perpetual injunction.

Kind of Infringement Relief


Trademark Infringement under TMA A registered trademark is infringed by a person if he

uses a registered mark as his trade mark, as his trade name,or part of his tradename, or name of his business concern,or part of the name, of his business concern dealing in goods or services in respect of which the trademark is registered. Section 29(5)TMA-

Applies equally in the cyberspace with respect to adopting a trademark that is registered by another person as his own domain name .


Criminal remedies-TM infringement Section 103 TMA. Penalty for applying false trade marks, trade descriptions, etc.Any person who-(a) falsifies any trade mark; or(b) falsely applies to goods or services any trade mark; or(c) makes, disposes of, or has in his possession, any die, block, machine, plateor other instrument for the purpose of falsifying or of being used for falsifying, atrade mark; or(d) applies any false trade description to goods or services; or(e) applies to any goods to which an indication of the country or place in whichthey were made or produced or the name and address of the manufacturer orperson for whom the goods are manufactured is required to be applied undersection 139, a false indication of such country, place, name or address; or(f) tampers with, alters or effaces an indication of origin which has been appliedto any goods to which it is required to be applied under section 139; or(g) causes any of things above-mentioned in this section to be done,shall, unless he proves that he acted, without intent to defraud, be punishable withimprisonment for a term which shall not be less than six months but which mayextend to three years and with fine which shall not be less than fifty thousandrupees but which may extend to two lakh rupees:PROVIDED that the court may, for adequate and special reasons to be mentionedin the judgement, impose a sentence of imprisonment for a term of less than sixmonths or a fine of less than fifty thousand rupees.


Criminal remedies-TM infringementSection 104. Penalty for selling goods or providing services to whichfalse trade mark or false trade description is appliedAny person who sells, lets for hire or exposes for sale, or hires or has in hispossession for sale, goods or things, or provides or hires services, to which anyfalse trade mark or false trade description is applied or which, being requiredunder section 139 to have applied to them an indication of the country or place inwhich they were made or produced or the name and address of the manufacturer,or person for whom the goods are manufactured or services provided, as the casemay be, are without the indications so required, shall, unless he proves,-(a) that, having taken all reasonable precautions against committing an offenceagainst this section, he had at the time of commission of the alleged offence noreason to suspect the genuineness of the trade mark or trade description or thatany offence had been committed in respect of the goods or services; or(b) that, on demand by or on behalf of the prosecutor, he gave all theinformation in his power with respect to the person from whom he obtained suchgoods or things or services; or(c) that otherwise he had acted innocently,be punishable with imprisonment for a term which shall not be less than sixmonths but which may extend to three years and with fine which shall not be lessthan fifty thousand rupees but which may extend to two lakh rupees:PROVIDED that the court may, for adequate and special reasons to be mentionedin the judgement, impose a sentence of imprisonment for a term of less than sixmonths or a fine of less than fifty thousand rupees.


Indian cases-The Yahoo v Akash arora Case One of the most important cases in this regard has been the yahoo case[1]

wherein the internet search engine, yahooinc sued and internet pirate who had copied the domain name yahooindia.com and also used yahooindia as a trade mark with similar literary work on its website and offered directory services with information specific to India and was passing itself off as the extension of yahoo. The defendant further copied the content of the plaintiffs webpage and the HTML code associated with the webpage. The high court of Delhi granted an injunction restraining him from using yahoo either as a part of his domain name or as a trade mark or from copying any of the contents of the plaintiffs website that infringe yahoo’s copyrights.

The court categorically ruled that trade mark applies with equal force on internet as it does in a physical world .

The potentiality of harm is far greater on the internet because of his wide access and reach and therefore trademark protection principles equally apply to online world [1] Yahooinc. V. Akash Arora (1999) PTC 201.


The Rediff case In Rediff Communication Ltd Vs. Cyberbooth

and anr. 2000 PTC 209, the plaintiff had the domain name rediff. com and the defendant had the mark Radiffcom. The high Court held that the only reason the defendant had adopted the Address Radiff was to trade upon the Plaintiffs position. They said that a first time user would be confused and furthermore as both the sites offered similar features the confusion would be compounded


Other Indian precedents Acqua Minerals Limited vs. Pramod Bose and Ors 2001 PTC 619,

where the defendant had registered bisleri.com as a domain name. The plaintiffs were the registered proprietors of the mark Bisleri. The Hon’ble Court injuncted the defendant on the ground that the domain name service functions as the trademarks and is not a mere address or like finding the number on the internet and therefore is entitled to equal protection as trademark for it also identifies the internet site to those who reach it much like a persons name identifies a specific company.

In Dr. Reddy’s Laboratories Limited vs. Monu Kosuri & others 2001 PTC859 it was held that the plaintiff’s trademark Dr. REDDY’s was deceptively similar to drredddy’slab.com. It was pointed out that there was every possibility of an Internet user being confused and deceived in believing that both the names belong to the plaintiff although the two domain names belong to two different concerns.


New Hybrid DNS disputes

Domain theft Domain wahehousing

Doamain Highjacking

Hybrids of DN disputes


Domain hijacking Domain hijacking is the process by which internet

domain names are stolen from the rightful registrant. Many people confuse domain hijacking with the re-

registration of an expired domain by a new party. One is a legal process and one is not. Domain hijacking is theft, while if a name owner does not renew a name he or she is no longer the owner and it is available for someone else to register.


Domain theft Domain theft is an aggressive form of domain hijacking that

usually involves an illegal act. In most cases, identity theft is used to trick the domain registrar into allowing the hijacker to change the registration information to steal control of a domain from the legitimate owner.

Some registrars are quick to set things right when these cases are discovered. However, it is well documented that some registrars will admit no fault in accepting the forged credentials and will refuse to correct the record until forced by legal action. In many of these cases, justice is not done and the hijacker retains control of the domain.


Domain name warehousing Domain name warehousing is the common practice

of registrars obtaining control of domain names with the intent to hold or “warehouse” names for their use and/or profit.

Typically this practice occurs after a domain name has expired and the previous owner (registrant) has not exercised his/her right to renew that name within the allotted time frame (approximately 45 days following expiration). Domain's expiration date and time are easily calculated based on the expiration date in the whois and the redemption process.


Why Use the Uniform Policy?

options

Conflict Trademark - Domain Name

Courts Uniform Policy

1. Fast (1 to 2 months)2. Cheap (US$ 1000)3. Directly enforceable: transfer or cancellation


UDRP vs Resolution through Courts A UDRP complaint may be initiated at

UDRP proceeding with an approved dispute resolution service provider. A victim of cybersquatting may also file an InterNIC Registrar Problem Report regarding a cybersquatter posing as a registrar.

Jurisdiction issue- Court systems can also be used to sort out claims of cybersquatting, but jurisdiction is often a problem, as different courts have ruled that the proper location for a trial is that of the plaintiff, the defendant, or the location of the server through which the name is registered.

Substantive law different approaches- Countries such as China and Russia do not view cybersquatting in the same way or degree that US law does. Some countries have specific laws against cybersquatting beyond the normal rules of trademark law. The United States, for example, has the U.S. Anticybersquatting Consumer Protection Act (ACPA) of 1999. India – TM Act 1999 deals with remedies for passing off, dilution and trademark infringement -equally applicable to domain names as decided by courts in India through cases such as yahoo.com case, siffy.com case etc. As opposed to it, UDRP has a uniform policy and rules

Quick and cost effective- People often choose the UDRP (Uniform Dispute Resolution Process) created by ICANN because it is usually quicker and cheaper than going to court, but courts can and often do overrule UDRP decisions.

Accredited DNR service providers are neutral bodies such as WIPO (World Intellectual Property Organization - Geneva], NAF (The National Arbitration Forum – Minneapolis, USA), ADNDRC (Asian Domain Name Dispute Resolution Centre – Beijing and Hong Kong, China


Salient documents for Domain name dispute

Resolution under ICANN Policy

Domain Names dispute Resolution

Basic documents

Uniform UDRP policy UDRP RulesSupplemental Rules of accredited service

Provider


WIPO website highlights essential features of UDRP policy

WIPO domain name dispute resolution statistics

Year 2007- 2156cases Year 2008-1573 cases


The UDRP Policy The Uniform Domain-Name Dispute-Resolution Policy (UDRP) ( adopted in 1999) is a

process established by the Internet Corporation for Assigned Names and Numbers (ICANN) for the resolution of disputes regarding the registration of internet domain names. The UDRP policy currently applies to all .biz, .com, .info, .name, .net, and .org top-level domains, and some country code top-level domains.

When a registrant chooses a domain name, the registrant must “represent and warrant,” among other things, that registering the name “will not infringe upon or otherwise violate the rights of any third party,” and agree to participate in an arbitration-like proceeding should any third party assert such a claim.

A complainant in a UDRP proceeding must establish three elements to succeed: The domain name is identical or confusingly similar to a trademark or service mark in which

the complainant has rights; The registrant does not have any rights or legitimate interests in the domain name; and The registrant registered the domain name and is using it in "bad faith." Procedure is fast-within 45 days proceedings are over –fees is stipulated by different service

providers and depends on number of panelists and domains involved in dispute


The Panelists

Intellectual property and Internet specialists Published list- +100 members and growing +30 countries and growing

Germany Egypt Ireland Republic of Korea

Argentina Spain Israel United Kingdom

Australia United States Italy Sweden

Bahrain Finland Japan Switzerland

Belgium France Malaysia

Brazil Ghana New Zealand

Canada Greece Uganda

Chile Hungary Netherlands

China India Czech Republic


Scope of a review or challenge? If a trademark holder loses a UDRP proceeding, it

may still bring a lawsuit against the domain name registrant, for example, under the Anticybersquatting Consumer Protection Act, a U.S. federal law. In this situation the administrative panel's UDRP decision is not binding to the extent that it can be challenged and overturned in a court of law.

Conversely, if a domain name registrant loses a UDRP proceeding, it must file a lawsuit against the trademark holder within ten days to prevent ICANN from transferring the domain name.


.in domain name disputes Dispute Resolution Process The registry has published the .IN Dispute Resolution Policy (INDRP). It

has been formulated in line with internationally accepted guidelines, and with the relevant provisions of the Indian IT Act 2000. There are two documents that all parties in a dispute should read carefully:

The .IN Domain Name Dispute Resolution Policy (INDRP). This document explains what types of disputes can be brought, and the criteria that will be considered by the arbitrators.

The INDRP Rules of Procedure. These Rules describe how to file a complaint, how to respond to a complaint, the fees, communications, and the other procedures that will be used.

To file a complaint, one needs to follow the instructions in the INDRP Rules of Procedure. Once NIXI has received a request, and filing fee, it will assign an arbitrator and will send additional communications.

All disputes are subject to the jurisdiction of Delhi courts only.


Detailed case study#1-Tata Tea vs Gem lifts ltd- (decided by WIPO using UDRP ) Tata Tea vs Gem lifts ltd ( company based in scotland) The domain name upon which this complaint is based is <tata-tea.com> The Complaint was received by the WIPO Arbitration and Mediation Center The Complainant has operated a tea cultivation, producing, manufacturing, processing,

blending and marketing business in India since 1962 and has been known as Tata Tea Limited since 1983. The Complainant is one division of a much larger conglomerate known as the "House of Tatas".

The Complainant stated that its trademark is known internationally and has acquired significant goodwill both inside and outside India. The Complainant referred to two other domain name arbitrations in which the arbitrators had found significant goodwill in the Tata trademark –WIPO Case No. D2000-0479 (Tata Sons Limited v. D & V Enterprises) and WIPO Case D2000-0049 (Tata Sons Ltd. v. The Advanced Information Technology Asssociation). The Complainant registered its trademark in class 30 in India on 28 November 1988 "in respect of tea for sale in India and for export". The Complainant has sold tea around the world under the name "Tata Tea" for almost forty years.

The Respondent is the operator of a lift sale and repair business in Scotland and has no links with the tea industry in any country


Tata Tea vs Gem lifts ltd-A case study. Complainant’s assertions-

4(a)(i) of the Policy -domain name in dispute is identical or confusingly similar to its registered mark Tata Tea, and the domain name in dispute incorporates the whole of the Complainant’s registered mark Tata Tea, with the sole addition of a hyphen between the two words.

paragraph 4(a)(ii) of the Policy, the Complainant asserts that the Respondent has no rights or legitimate interest in the domain name in dispute. In particular, the Complainant submits that the Respondent has registered the domain name with the ulterior intention of furthering their business activities in an unauthorised manner.

paragraph 4(a)(iii) of the Policy, the Complainant asserts that the Respondent has registered and is using the domain name in dispute in bad faith. In support of this allegation, the Complainant claims that the Respondent does not operate in the tea business and has not used the domain name since registering it

The Complainant asserts that the Respondent acquired the domain name <tata-tea.com> primarily for the purposes of (1) misappropriating the Complainant’s trademark to pass off the Respondent’s products and services and for those of the Complainant; and (2) selling it to the Complainant at a price substantially greater than the Respondent’s out-of-pocket expenses and that when the Complainant notified the Respondent of the Complaint, the Respondent’s Response included an offer to sell the domain name to the Complainant at a premium


Tata Tea vs Gem lifts ltd-A case studyRespondent’s assertions-

The Respondent asserts that the word "tata" is a word commonly used in Scotland to mean good-bye. The Respondent asserts that the word "tea" is a generic word that "cannot be copywrited".

The Respondent denies that the Complainant has any reputation in Scotland, though admits that specialists in the tea industry in that country would likely be aware of the Complainant’s trademark, reputation and goodwill.

The Respondent asserted that it had received offers from third parties interested in acquiring this domain name and that the Respondent would be willing to "accept a reasonable sum commensurate with the stated importance you (the Complainant) seem to place on this domain name"


Tata Tea vs Gem lifts ltd-A case study Findings of the panel- The domain name in dispute is <tata-tea.com>. The Complainant has a registered

trademark in India for the mark TATA TEA. In the Panel’s view the domain name is identical to the trademark owned by the Complainant, the gTLD suffix and the hyphen having no relevant distinguishing function. In any event the domain name is confusingly similar to the trademark and the Panel notes that there is no asserted meaning for the second word by the Respondent.

The Respondent has not asserted that it owns any trademark in Scotland (or any other jurisdiction) for Tata Tea. The Respondent has shown no evidence of operating any business using the disputed domain name. The Respondent has also denied operating or having any intention to operate any business relating to the tea industry. The Panel finds that the Respondent has shown no evidence that it used the contested domain name in connection with bona fide offerings of goods and services prior to notice of this dispute or notice of the Complainant’s registered Indian trademark

The Panel finds that the Complainant has shown that the Respondent has no rights or legitimate interests in respect of the domain name and therefore has proven paragraph 4(a)(ii) of the Policy.


Tata Tea vs Gem lifts ltd-A case study In this case, although the registrar of the disputed domain name has

confirmed that the site is "active", currently the domain name resolves to a message from UK2.net about its domain name registration and hosting services. In such a situation, it is clear that the Respondent is only using the domain name to promote the business that assisted the Respondent to register the disputed domain name in the first place. Although the Panel finds that the Respondent has not "used" the domain name to pass off any goods or services as those of the Complainant, bad faith use of a domain name can arise through having the DNS entry point to another site, and the Panel finds that this has occurred in this situation.

The Complainant states that in offering to sell the domain name to the Complainant, the Respondent has clearly demonstrated that the domain name was registered in bad faith. Paragraph 4(b)(i) of the Policy provides that the following is evidence of bad faith registration

Clear case of cybersquatting and all three parameters being satisfied, the subject domain name was directed to be transferred to Tatas.


SETH ASSOCIATESSETH ASSOCIATES ADVOCATES AND LEGAL CONSULTANTSADVOCATES AND LEGAL CONSULTANTS

New Delhi Law OfficeNew Delhi Law Office:: C-1/16, Daryaganj, New Delhi-110002, IndiaC-1/16, Daryaganj, New Delhi-110002, IndiaTel:+91 (11) 65352272, +91 9868119137Tel:+91 (11) 65352272, +91 9868119137Corporate Law OfficeCorporate Law Office: : B-10, Sector 40, NOIDA-201301, B-10, Sector 40, NOIDA-201301, N.C.R ,IndiaN.C.R ,IndiaTel: +91 (120) 4352846, +91 9810155766Tel: +91 (120) 4352846, +91 9810155766Fax: +91 (120) 4331304Fax: +91 (120) 4331304E-mail: [email protected]: [email protected]

Thank You!Thank You!

IETE Apex Forum on Cybercrime and Indian Cyberlaw- An introspection 12 September,2008, IETE HQ. D omain names & Dispute Resolution Karnika Seth Cyberlaw.

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