To: From: Cc: Date: Re:

Whois Privacy Protection Service, Inc. Whois Agent (), Respondent SelectQuote Insurance Services, Complainant National Arbitration Forum July 23, 2012 selectquotereview.com

Complaint Transmittal Cover Sheet

The attached Complaint is being filed against you with the National Arbitration Forum (the "Forum") pursuant to the Uniform Domain Name Dispute Resolution Policy (the "Policy") adopted by the Internet Corporation for Assigned Names and Numbers ("ICANN") on October 24, 1999 and incorporated in your Registration Agreement with the Registrar of your domain name(s). By submitting this Complaint to the Forum, the Complainant agrees to abide and be bound by the provisions of the Policy, the ICANN Rules, and the Forum's Supplemental Rules. Until you are notified by the Forum that a proceeding has commenced, you have no duty to act with regard to this Complaint. The Forum will examine the Complaint to determine whether it conforms to the ICANN Policy, Rules, and the Supplemental Rules. If the Complaint conforms to those standards, the Forum will forward an official copy of the Complaint to you. Once the official Complaint is forwarded to you, you will have twenty (20) calendar days to submit a Response to both the Forum and the Complainant in accordance with the Policy, Rules, and Supplemental Rules. You may seek legal assistance to represent you in this administrative proceeding. The Policy and Rules governing this proceeding can be found at: ICANN UDRP Policy http://www.icann.org/udrp/udrp-policy-24oct99.htm ICANN UDRP Rules http://www.icann.org/udrp/udrp-rules-24oct99.htm Forum Supplemental Rules http://domains.adrforum.com/main.aspx?itemID=631&hideBar=False&navID=237&news=26 Complainant has opted to file this complaint entirely electronically as provided in the UDRP Rules as effective March 1, 2010. Respondent may also choose to take advantage of the new Rules. ICANN New UDRP Rules Forum New Supplemental Rules http://www.icann.org/en/dndr/udrp/uniform-rules.htm http://domains.adrforum.com/resource.aspx?id=1540

Alternatively, you may contact the Forum to obtain any of the above documents. Telephone: (800) 474-2371 or (952) 516-6400 E-mail: domaindispute@adrforum.com Please provide the Forum with the email address where the official Complaint and other communications in the administrative proceeding should be sent.

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Domain Names In Dispute SelectQuote Insurance Services 595 MARKET STREET 10th Floor SAN FRANCISCO, CA 94105 United States (Complainant) v. Whois Privacy Protection Service, Inc. Whois Agent (pkvqmbcg@whoisprivacyprotect.com) PMB 368, 14150 NE 20th St - F1 C/O selectquotereview.com Bellevue, WA 98007 United States (Respondent) COMPLAINT IN ACCORDANCE WITH THE UNIFORM DOMAIN NAME DISPUTE RESOLUTION POLICY 1. This Complaint is hereby submitted for decision in accordance with the Uniform Domain Name Dispute Resolution Policy (UDRP), adopted by the Internet Corporation for Assigned Names and Numbers (ICANN) on August 26, 1999 and approved by ICANN on October 24, 1999, and the Rules for Uniform Domain Name Dispute Resolution Policy (UDRP Rules), with an effective date of March 1, 2010, and the National Arbitration Forum (FORUM) Supplemental Rules (Supp. Rules). UDRP Rule 3(b)(i). 2. COMPLAINANT INFORMATION [a.] Name: [b.] Address: [c.] Telephone: [d.] Fax: [e.] E-Mail:
SelectQuote Insurance Services 595 MARKET STREET 10th Floor SAN FRANCISCO, CA 94105 United States (415) 543-7338 (415) 882-4681 netadmin@SELECTQUOTE.COM

selectquotereview.com

Complainant's authorized representative in the administrative proceeding is: [a.] Name:

ISCRS Inc

[b.] Address:

ISCRS Inc Suite 191161 Boise, Idaho 83719 (208)340-5866 (914)931-4622 DBusmann@iscrs.com

[c.] Telephone: [d.] Fax: [e.] E-Mail:

Complainant's preferred method for communications directed to Complainant in the administrative proceeding: Electronic-Only Material [a.] Method: [b.] Address: [c.] Contact: Representative Email DBusmann@iscrs.com UDRP Consultant

Material Including Hard Copy [a.] Method: Representative's Fax [b.] Address/Fax: (914)931.4622 [c.] Contact: UDRP Consultant Complainant chooses to have this dispute heard before a single-member administrative panel. 3. RESPONDENT INFORMATION [a.] Name: [b.] Address: Whois Privacy Protection Service, Inc. Whois Agent () PMB 368, 14150 NE 20th St - F1 C/O selectquotereview.com Bellevue, WA 98007 United States (425)274-0657 (425)974-4730 pkvqmbcg@whoisprivacyprotect.com

[c.] Telephone: [d.] Fax: [e.] E-Mail:

4. DISPUTED DOMAIN NAME(S) The following domain names, ordered by registrar, is the subject of this Complaint and is [a.] hereafter referred to as "the Disputed Domain Name":
selectquotereview.com

[b.] Registrar Information:

[i] Registrar Name: [ii] Registrar Address:

ENOM, INC PMB 368, 14150 NE 20th St - F1 C/O enom.com Bellevue, WA 98007 United States qxjstwqcqp@whoisprivacyprotect.com

[iii] Telephone Number: (425)274-0657 [iv] E-Mail Address:

[c.] Trademark/Service Mark Information Complainant selectquotereview.com mark [i.] SELECTQUOTE for goods and services in the field of Life Insurance. (U.S. Reg. No. 2653112); FIRST USE IN COMMERCE: 19850222 5. FACTUAL AND LEGAL GROUNDS Complainant is a private company Headquartered in San Francisco, California,that pioneered the direct marketing of Term Life Insurance In 1985. Complainant provides its customers with comprehensive unbiased price comparisons of insurance rates from highly-rated Term Life Insurance companies. SelectQuote accomplishes this service via breakthrough technology which has helped streamline what can normally be a lengthy and involved insurance application process. Prior to the launch of selectquote insurance, purchasing a term life policy was a lengthy and manual process; where comparison of pricing and service was an exhaustive undertaking involving many documents, agents and entities. Much of the analysis and comparison was left to the consumer to organize and implement. Now, selectquote enjoys more of a partnership relationship with its customers; answering all client questions, offering all the information needed to be an informed buyer, and even lobbying for a better rate and policy for its clients.
Selectquote.com has a well-known presence in both printed, television, radio and online media; for example, Selectquote has several radio ads including dialogue with well known TV and radio personality Suze Orman. Online resources include unbiased articles on internet sites such as Technorati, and Google. As a result of this reputation, SelectQuote is Americas #1 Term Life sales agency.

In short, Complainant enjoys wide consumer recognition and acceptance of its brand. Furthermore, Complainant owns the selectquote.com mark cited in Section 4(c) above for which it has obtained federal trademark registrations. The federal mark registration has not been abandoned, cancelled or revoked.Complainant has spent several thousands of dollars in advertisement and promotion of the selectquote.com mark on the Internet through its website located at <selectquote.com>.

Based on its federal trademark registrations and extensive use, Complainant owns the exclusive right to use the selectquote.com mark in connection with its online insurance services. [a.] The Disputed Domain Name(s) are nearly identical and confusingly similar to Complainant's Marks. [i.] The Disputed Domain Name(s) contains Complainant's entire Mark(s)or mark, with an added generic term, and adds the generic top-level domain ("gTLD") ".com." Previous panels have found that the addition of a generic term to a mark may render said domain confusingly similar to the complainant's famous mark. See Am. Int'l Group, Inc. v. Domain Admin. Ltd., FA1106369 (Nat. Arb. Forum Dec. 31, 2007) (finding that "spaces are impermissible and a generic top-level domain, such as '.com,' '.net,' '.biz,' or '.org,' is required in domain names. Therefore, the panel finds that the disputed domain name [<americangenerallifeinsurance.com>] is confusingly similar to the complainant's [AMERICAN GENERAL] mark."); see also Warner Bros. Entm't Inc. v. Rana, FA 304696 (Nat. Arb. Forum Sept. 21, 2004) (finding that the addition of the generic term "collection" to Complainant's HARRY POTTER mark failed to distinguish the domain name from the mark).

[ii.] The Disputed Domain Name(s)contains the term "review" paired with the Complainant's entire Mark(s)or mark, in a configuration that the casual observer is bound to mistake for a name related to the Complainant. The likelihood of confusion is the obvious association with the trademark of the Complainant. With reference to the reputation of the trademark SELECTQUOTE there is a considerable risk that the trade public will perceive the Domain Name either as owned by the Complainant or as commercially related the Complainant. By using the trademark SELECTQUOTE as a dominant part of the Domain Name, the Respondent exploits the goodwill and the image of the trademark, which may result in dilution and other damage for the Complainants trademark. See Aktiebolaget Electrolux v. Protected Domain Services - Customer ID: NCR-3460652 / Edmund Lee., D2011-2005 (WIPO Mar. 6, 2012) (finding that "the addition of the non-distinctive term "refrigeratorreviews" does not detract from the distinctiveness of the mark")

[b.] Respondent has no rights or legitimate interests in respect of the Disputed Domain Name(s) for the following reasons:
[i.] Respondent has not been commonly known by the Disputed Domain Names. See Policy, 4(c)(ii). See WHOIS record for the Disputed Domain Names set forth in Exhibit G. Where, as here, "the WHOIS information suggests Respondent is known as" an entity other than the trademark associated with Complainant, and Complainant has not "licensed, authorized, or permitted Respondent to register domain names incorporating Complainant's... mark," a Panel should find that the Respondent is not commonly known by the Disputed Domain Name. United Way of America v. Alex Zingaus, NAF Claim No. FA0707001036202.

[ii.] Respondent is not sponsored by or legitimately affiliated with Complainant in any way. [iii.] Complainant has not given Respondent permission to use Complainant's Mark in a domain name. [iv.] The earliest date on which Respondent registered the Disputed Domain Name was Jan 27, 2012, which is significantly after Complainant's first use in commerce, Feb. 22, 1985 as specified in their relevant registration with the USPTO. See Exhibit H for the relevant trademark and/or service mark registration information. Also, see Exhibit G for WHOIS data for the Disputed Domain Names, which includes the registration dates in question. [v.] The earliest date on which Respondent registered the Disputed Domain Name was Jan 27, 2012, which is significantly after Complainant's registration of selectquote.com on Feb 14, 1996. See Exhibit D for WHOIS data for the Complainant's registration information. Also, see Exhibit G for WHOIS data for the Disputed Domain Name, which includes the registration dates in question.

[c.] The Domain Name(s) should be considered as having been registered and being used in bad faith for the following reasons: [i.] Respondent's typosquatting behavior is, in and of itself, evidence of bad faith. See Canadian Tire Corp. v. domain adm'r no.valid.email@worldnic.net 1111111111, D20030232 (WIPO May 22, 2003) (finding the respondent registered and used the domain name in bad faith because the respondent "created 'a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of the Respondent's web site or location'.. . through Respondent's persistent practice of 'typosquatting'"); see also Nat'l Ass'n of Prof'l Baseball League, Inc. v. Zuccarini, D20021011 (WIPO Jan. 21, 2003) ("Typosquatting ... is the intentional misspelling of words with [the] intent to intercept and siphon off traffic from its intended destination, by preying on Internauts who make common typing errors. Typosquatting is inherently parasitic and of itself evidence of bad faith."). [ii.] Respondent has caused the websites reachable by (some or all of) the domain names to display Complainant's Mark spelled correctly (even though the domain name is a variant version of the same mark). This serves as further evidence of bad faith intent because it removes any doubt as to whether or not the spelling was intentionally designed to improperly capitalize on Complainant's famous Mark. See Exhibit F for screenshots of the websites reachable through the Disputed Domain Names, which show the usage of the correctly spelled Mark.

[iii.] The content of the selectquotereview.com is not free speech commentary protected under the First Amendment, but rather a bad faith website carefully designed and intended to hurt or disrupt Selectquote business. Under the legal definition of defamation, the elements that must be proved to establish defamation are: the use of a publication to someone other than the person or entity defamed; the use of a false statement or fact; which is understood as being of and concerning the complainant; and which is understood in such a way as to tend to harm the reputation of complainant. Selectquotereview.com meets all the criteria for defamation and certainly is being used in bad faith. See Exhibit I for examples of bad faith content.

6. REMEDY SOUGHT Complainant requests that the Panel issue a decision that the domain-name registration be transferred. 7. OTHER LEGAL PROCEEDINGS There are no other legal proceedings that have been commenced or terminated in connection with or relating to the Disputed Domain Name that are the subject of the complaint. 8. COMPLAINT TRANSMISSION Complainant asserts that a copy of this Complaint, together with the cover sheet as prescribed by NAF's Supplemental Rules, has been sent or transmitted to Respondent (domain-name holder), in accordance with ICANN Rule 2(b) and to the Registrar(s) of the Disputed Domain Name(s), in accordance with NAF Supp. Rule 4(d). 9. MUTUAL JURISDICTION Complainant will submit, with respect to any challenges to a decision in the administrative proceeding canceling or transferring the domain name, to the location of the principal office of the concerned Registrar. 10.CERTIFICATION Complainant agrees that its claims and remedies concerning the registration of the Disputed Domain Name, the dispute, or the dispute's resolution shall be solely against the domain-name holder and waives all such claims and remedies against (a) the National Arbitration Forum and panelists, except in the case of deliberate wrongdoing, (b) the registrar, (c) the registry administrator, and (d) the Internet Corporation for Assigned Names and Numbers, as well as their directors, officers, employees, and agents. Complainant certifies that the information contained in this Complaint is to the best of Complainant's knowledge complete and accurate, that this Complaint is not being presented for any improper purpose, such as to harass, and that the assertions in this Complaint are warranted under these Rules and under applicable law, as it now exists or as it may be extended by a good-faith and reasonable argument. Respectfully Submitted,