Before

INTELLECTUAL PROPERTY FOR ALL (IPFA)

Arbitration and Mediation Center

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ROMANCE TV Ltd.
44 200 Suolahti
Finland
358204550697 (Office telephone)
358206020100 (Office FAX)

(Complainant)

-v- Disputed Domain Name:

Restoration SRL
str. L Pasteur nr 78 ap 3
Cluj
Cluj-Napoca 3400 <storyofus-tv.ro>
City xx
RO [ROMANIA]

(Respondent)
________________________________

RESPONSE
(Rules, para. 5(b))

I. Introduction

On April 20. 2014, the Respondent received a Notification of Complaint and Commencement
of Administrative Proceeding from the IPFA Arbitration and Mediation Center (the Center)
by e-mail informing the Respondent that an administrative proceeding had been commenced
by the Complainant in accordance with the Uniform Domain Name Dispute Resolution
Policy (the Policy), approved by the Internet Corporation for Assigned Names and Numbers
(ICANN) on October 24, 1999, the Rules for Uniform Domain Name Dispute Resolution
Policy (the Rules), approved by ICANN on October 30, 2009, and the IPFA Supplemental
Rules for Uniform Domain Name Dispute Resolution Policy (the Supplemental Rules). The
Center set May 11, 2014 as the last day for the submission of a Response by the Respondent.
 II. Respondent’s Contact Details
(Rules, para. 5(b)(ii) and (iii))

The Respondent’s contact details are:

Restoration SRL
str. L Pasteur nr 78 ap 3
Cluj
Cluj-Napoca 3400
City xx
RO [ROMANIA]

The Respondent’s authorized representative in this administrative proceeding is:

Georgy Restoration Aleea George Bacovia
Nr 5A, 400366 Cluj Napoca Romania
narcis@somesfalean. ro +40744256463 (Mobile telephone)
postmaster@restoration.ro

The Respondent’s preferred method of communications directed to the Respondent in this

administrative proceeding is:

Electronic-only material
Method: e-mail
postmaster@restoration.ro

III. Response to Statements and Allegations Made in Complaint

(Policy, paras. 4(a), (b), (c); Rules, para. 5)

The Respondent hereby responds to the statements and allegations in the Complaint and
respectfully requests the Administrative Panel to deny the remedies requested by the
Complainant.

A. Whether the domain name[s] [is/are] identical or confusingly similar to a

trademark or service mark in which the Complainant has rights;
(Policy, para. 4(a)(i))

The domain name is not identical with the service marks owned by Complainant. The
disputed domain name comprises of dictionary descriptive words as “Story” “Of” “Us”

B. Whether the Respondent has rights or legitimate interests in respect of the domain
name[s];
(Policy, para. 4(a)(ii))

The Respondent has registered a domain name made up of confirmed dictionary words which
is genuinely used in connection with the relied-upon meaning.

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The Respondent has been using the disputed domain name in connection to a bona fide
offering of services. The website under which the disputed domain name resolves, offers
information on matrimonial match and fashion for ordinary people with a story as it is
everybody from us.

It is more than evident that the Respondent had proved that it has rights and legitimate
interest in the disputed domain name, which cannot be reserved to a person

IV. Administrative Panel

(Rules, Paragraph 3(b)(iv); Supplemental Rules, Paragraph 8(a))

The Respondent elects to have the dispute decided by a “single-member Administrative

Panel”

V. Mutual Jurisdiction
(Rules, Paragraph 3(b)(xiii))

In accordance with Paragraph 3(b)(xiii) of the Rules, the Complainant will submit, with
respect to any challenges that may be made by the Respondent to a decision by the
Administrative Panel to transfer or cancel the domain name(s) that is/are the subject of this
Complaint, to the jurisdiction of the courts at
“the location of the principal office of the concerned registrar.” or

VI. Other Legal Proceedings

(Rules, Paragraph 3(b)(xi))

No other legal proceedings had been initiated to the best knowledge of the Respondent

VII. Communications
(Rules, paras. 2(b), 5(b)(vii); Supplemental Rules, para. 3, 7, 12)
A copy of this Response, together with the cover sheet as prescribed by the Supplemental
Rules, has been sent or transmitted to the Complainant on 11th of May 2014 via post:

VIII. Payment
(Rules, para. 5(c); Supplemental Rules, Annex D)

IX. Certification
(Rules, para. 5(b)(viii), Supplemental Rules, para. 14)

The Respondent agrees that, except in respect of deliberate wrongdoing, an

Administrative Panel, the World Intellectual Property Organization and the Center shall
not be liable for any act or omission in connection with the administrative proceeding.

The Respondent certifies that the information contained in this Response is to the best
of the Respondent’s knowledge complete and accurate, that this Response is not being
presented for any improper purpose, such as to harass, and that the assertions in this

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 Response are warranted under the Rules and under applicable law, as it now exists or as
it may be extended by a good-faith and reasonable argument.

Respectfully submitted,

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 XIV. List of Annexes
(Rules, Paragraph 3(b)(xv); Supplemental Rules, Paragraphs 4(a), 12(a), Annex E)

1.Printout of the website under the disputed domain name

Georgy Restoration

Date: December 27th, 2014