Before the:

WORLD INTELLECTUAL PROPERTY ORGANIZATION

ARBITRATION AND MEDIATION CENTER



Pinterest, Inc.
808 Brannan Street,
San Francisco, CA 94103
United States of America

(Complainant)
Case No: D2014-1067




-v-


Disputed Domain Names:
Pin Digital, S.L.
C/ Beethoven 11, 1 4
08021 Barcelona

(Respondent)

<pinsex.com>
<pingay.com>

________________________________



RESPONSE
(Rules, para. 5(b))

I. Introduction

1.1 On 8 July 2014, the Respondent received a Notification of complaint and
Commencement of Administrative Proceeding from the WIPO 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 WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution
Policy (the Supplemental Rules). The Center set 28 July 2014 as the last day
for the submission of a response by the Respondent.

2
II. Respondents Contact Details
(Rules, para. 5(b)(ii) and (iii))

2.1 The Respondents contact details are:

Name: Christian Thorn
Company: Pin Digital, S.L.
Address: C/ Beethoven 11, 1 4
Telephone: +34 629 32 12 65
E-mail: administration@pinsex.com

2.2 The Respondents authorized representative in this administrative proceeding is:

Name: Rosa Maria Abadie Sol
Address: BELLAVISTA LEGAL, S.L.
Avenida Diagonal 463 bis 3r 4a
08036 Barcelona
Telephone: +34 933635471
Fax: +34 934390204
E-mail: rabadie@bellavistalegal.eu

2.3 The Respondents preferred method of communications directed to the
Respondent in this administrative proceeding is:

Electronic-only material
Method: e-mail
Address: rabadie@bellvistalegal.eu
Contact: Rosa Maria Abadie Sol

Material including hardcopy (where applicable)
Method: Fax
Fax: +34 934390204
Contact: Rosa Maria Abadie Sol

3
III. Response to Statements and Allegations Made in complaint
(Policy, paras. 4(a), (b), (c); Rules, para. 5)

3.1 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 names are identical or confusingly similar to a
trademark or service mark in which the Complainant has rights;
(Policy, para. 4(a) (i))

3.2 The contested domain names are composed of the words PINSEX and
PINGAY.

3.3 The word PIN which is included in both domains is a generic word understood
in most languages. It has various meanings among which we can find as a noun
a device used for fastening objects or material together, or as a verb attach
or fasten with a pin or pins in a specified position.

Claim of the Complainant over the term PIN

3.4 Despite the fact that the word PIN is a generic term, PINTEREST, INC.
(hereinafter PINTEREST or the Complainant) claims registered rights over the
word.

3.5 The rights claimed over the word PIN are based on extensive common law use,
on applications pending registration in Canada Chile China, Hong Kong, India
Indonesia, Malaysia, Mexico, the Philippines, Russia, Singapore, South Korea,
Taiwan and Thailand, and registrations in Argentina, Japan, Mexico, New
Zealand, Norway, Saudi Arabia, Switzerland and the United States.

3.6 Regarding the extensive common law use claimed on paragraphs 6.2 and 6.4 of
the complaint, and considering the consensus view adopted by panelists in
various decisions (Alpine Entertainment Group, Inc. v. Walter Alvarez, WIPO
Case No. D2006-1392, <realspanking.com>) the Complainant must show that
the word PIN has become a distinctive identifier associated with the
4
Complainant or its goods/services by providing relevant evidence, and
relevant evidence would be length and amount of sales under the trademark, the
nature and extent of advertising, consumer surveys and media recognition. The
Complainant refers to annex 5 of the complaint which consists merely on prints
of its own web page. This document solely does not prove any acquired right by
the Complainant.

3.7 In fact, the word PIN is also used by many other web pages in this same sense:

GOOGLE MAPS:


WINDOWS:

5





MICROSOFT OFFICE:



6
FACEBOOK:




Also we refer to ANNEX XII.

3.8 Regarding the PIN registered trademarks and applications, the Complainant
only provides a list of references which cannot be contrasted with actual
certificates issued by the national offices, the only certificate included was
issued by the USPTO (United Stated Patent and Trademark Office) for the
registration on June 17
th
2014 of the PIN trademark, and which according to
ANNEX I it was applied for on August 2012, after the contested domain names
were already operative.
7

3.9 The Complainant also claims registered rights over the words PINTEREST
and PIN IT based on extensive common law use and various worldwide
trademark applications and registrations.

3.10 As mentioned in paragraph 3.6 of this response, in order for the Complainant to
successfully assert common law or unregistered trademark rights, relevant
evidence must be filed, and the documents referenced by the Complainant are
not enough to considered and acquired right over the word over the GENERIC
term PIN IT.

3.11 Regarding the PINTEREST trademark, the Respondent does not argue the
Complainants rights, however as we explain in paragraph 3.51, the services
distinguished by the PINTEREST trademark are not similar, nor relate to the
services provided by the Respondent, as well as that the word PINTEREST is
not similar to the words PINSEX and/or PINGAY.

3.12 Regarding the trademark registrations and applications, the Complainant only
attaches a list of references that, in the same sense that as mentioned before, this
claims cannot be contrasted due that actual certificates issued by the national
offices have not been provided. The only certificate included was issued by the
USPTO for the registration on May 22
nd
2012 of the PINTEREST trademark.

3.13 On paragraphs 6.5 to 6.10 of the complaint, the Complainant claims further
rights in the PIN mark and reputation in the PIN mark, however all the
arguments and references mentioned on those paragraphs, as well as the annexes
of the complaint to which the arguments refer (annex 11 to 17) clearly mention
the word PINTEREST, not the word PIN, nor the word PIN IT.

3.14 The Complainant is clearly identified in the market with the trademark
PINTEREST, however the word PIN and PIN IT are generic terms
that appear in the dictionary, and if we analyze closely the Complainants
explanation of the use of the words PIN and PIN IT as described in
paragraph 6.7 of the complaint, we can see that these words are not used as
trademarks, they are used as the dictionary definition described on
paragraph 3.3 of this response.
8

3.15 In the comparison of the contested domain names in contrast with the
Complainants claimed rights, we must keep in mind that whole name of the
domain names are PINSEX and PINGAY, and despite that the word PIN
is included within their composition, PIN is a generic term that cannot be
monopolized by one company.

3.16 On the other hand, from the comparison of the PINTEREST trademark with
the registered domain names PINSEX and PINGAY we can clearly see that
there are enough differences in the names and in their conceptual references for
any consumer to differentiate one term from the other.

3.17 The Complainant does not hold universal rights over the word PIN, which is a
generic term included literally in the dictionary, and as we will detail on the next
section, the contested domain names are a clear identical reference to the
Respondents trademark applications and company name.

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

3.18 The Respondent has legitimate rights and interest in respect to the contested
domain names <pinsex.com> and <pingay.com>.

3.19 Considering paragraph 4.c.(i) of the Policy (Uniform Domain Name Dispute
Resolution Policy), and as we will expand further on, the first copy of the
domain names complaint was received by the Respondent on June 20
th
2014, by
this date the contested domain names were fully active and operative, and have
been since the last several years.

3.20 In fact, even the Complainant states in paragraphs 6.17 to 6.20 of the complaint
that the contested domain names are effectively active.

3.21 Considering paragraph 4.c. (ii) of the Policy, since both domain names began
their activity in early 2012 and early 2013 respectively, the Respondent is
9
becoming popular and known within its own sector (sexual and erotic adult
contents industry).

3.22 Currently, <pinsex.com> has had approximately 48,8 Million visits since it
became operative, has almost 70,000 registered users from all over the world. In
the last three months <pinsex.com> has received over 99,000 daily visits,
reaching its highest peak on February 2014 with 550,000 visits in one day.
Please see the detailed information of <pinsex.com> on ANNEX II.

3.23 On the Other hand, <pingay.com> has had approximately 3,4 Million visits since
it became operative, has almost 3,000 registered users from all over the world
and in the last three months <pingay.com> has received over 12,600 daily visits,
reaching its highest peak also on February 2014 with 50,6045 visits in one day.
Please see the detailed information of <pinsex.com> on ANNEX III.

3.24 The domain name <pinsex.com> was created in 2008, and has been active since
June 2012, in the same sense <pingay.com> was created in 2011, and has been
active since May 2013, please see ANNEX XVIII. It is important to remark that
the contested domain names are and have been completely fully operative for
various years, providing a service of sexual and erotic contents to for adult users.

3.25 Additionally, the web page <pinsex.com> was nominated for Progressive Web
Company of the Year award at the Xbiz awards, one of the most important
recognition awards in the adult industry, for more information please see
www.xbizawards.xbiz.com and ANNEX VII, and in the year 2013 the web page
<pinsex.com> was nominated for Best Emerging Site at the YNOT Awards,
please see ANNEX VIII.

3.26 The Respondent is a Spanish company legally set up with the name PIN
DIGITAL, S.L. (hereinafter PIN DIGITAL) since June 2012, and its main
activity is aimed to providing sexual and erotic contents through internet for
adult users. Please see ANNEX IV for the Respondents company details.

3.27 Having the name of the company as a reference (PIN DIGITAL) and as the
Respondent is a Spanish company, the legitimate right over the domain names
<pinsex.com> and <pingay.com> are recognized by the Spanish trademark Law
10
(Law 17/2001 of December 7), which acknowledges a trade name as an acquired
right. Article 9: Other Prior Rights (d) the trade name, name or business
name of a legal person

3.28 Further on July 2012 the Respondent applied for the registration of Community
trademark (CTM) n 11058195 PINSEX your daily dose of sexpiration
(ANNEX V), and on May 2013 the Respondent applied for the registration of
CTM n 11856309 PINGAY (ANNEX VI). Both trademark applications have
been opposed by the Complainant and are currently in procedure.

3.29 The Respondent began the preparations for the activation of <pinsex.com> in
June 2012 and the domain name was fully operative by the end of that same
month, please see ANNEX IX which includes the documents that show the
preparation for the activation of the domain names, the company and timings.

3.30 According to paragraph 6.16 of the complaint, the Complainant indicates that
they launched their activity <pinterest.com> in 2010 and became known in
2012, however, all the documents filed to prove this well known claimed by
the Complainant are in relation to the word PINTEREST and mostly within
the United States. Lets not forget that the Respondent is a small Spanish
company and that the fact that a web page becomes popular in Unites States,
does not mean it is well known worldwide.

3.31 The Respondents activity began on June 2012, time in which the web page
<pinterest.com> was not known in the European Community. Most of Spanish
and European users were not aware of its existence, and the Complainant had
not even applied for a trademark registration. ANNEX X includes a list of
community trademark applications/registrations filed by the Complainant, please
notice that most of PINTEREST and PIN trademark application have been
opposed.

3.32 Regarding the allegations on paragraphs 6.17 and 6.18 of the complaint, it is
important to keep in mind that the domain names were created in 2008 and 2011
respectively, and despite that they were later transferred and activated in 2012
and 2013, the important issue regarding legitimacy is that they have been active
for various years with a very busy traffic. (ANNEX II and ANNEX III).
11

3.33 The complaint indicates in paragraph 6.19 that the contested domains are not
commonly known, however, as ANNEX II, III, VII and VIII show, since the
domains began their activity they have been very successful in their sector (adult
contents industry), reaching a traffic peaks of 550,000 and 50,000 visits in one
day. Additionally, please see ANNEX XI which includes details from Alexa
on how popular is the domain name <pinsex.com>, and a detail from Similar
Web on how popular is <pingay.com>.

3.34 Paragraph 6.20 of the complaint states that the concept of the contested
domain names mimics the Complainants business concept, however we
consider that this claim is not relevant on whether PIN DIGITAL has a
legitimate right over the contested domain names, as well as the fact that the
Complainant has not proven to have any registered right over the layout, or how
the information is provided in a web page.

3.35 The contested domain names provide sexual and erotic contents for adult users
by providing a wide selection at the homepage, with direct links to specific
video/photos the user may want to see. This system, layout, form of presentation
is commonly used by websites that provide sexual and erotic contents please see
the following examples:

YOUJIZZ.COM

12
PORNHUB.COM




YOUPORN.COM





13
And almost in the same sense, <pinsex.com> and <pingay.com>



3.36 We completely disagree with the Complainant's statement in paragraph 6.21 of
the complaint, which indicates that the use of the PIN word by the Respondent
infringes its registered rights and tarnishes the Complainant's trademark due that
the contested domains provide sexual and erotic contents. Firstly, we have
clearly stated (paragraph 3.3 of this response) that the word PIN is a generic
term that it is used by a great number of companies and web pages, as an
additional example please see ANNEX XII.

3.37 Lets not forget that the word PIN is a dictionary word and it is used by the
domain name in connection with a purpose directly related to its meaning. We
refer to the decision Porto Chico Stores, Inc. v. Otavio Zambon, WIPO Case
No.D2000-1270, <lovelygirls.com>.

3.38 Regarding the claim that the activity of the Respondent could tarnish the
Complainants trademark, we refer to ANNEX XIII which shows, from what
websites do the users of the contested trademarks come from, and where do they
go to after visiting <pinsex.com> and <pingay.com>. Please notice that not even
one user comes from the Complainant's web page.

3.39 Considering the services provided by the Complainant in contrast with the
services provided by the Respondent, it is clear that they are addressed to very
different users, and as the Complainant does not allow any sexual or erotic
content in its web page, both companies will surely never coincide in the market.
It is impossible to consider that a user with the intention to access PINTEREST,
will be confused and in the contrary access <pinsex.com > or <pingay.com>, in
the same sense that the Respondent is sure that the internet users with the
14
intention to access a adult content website will not confusingly access
PINTEREST.COM.

3.40 The Complainant cannot expect to have a UNIVELSAL right over a generic
term, an even worse use this claim to shut down the activity of a legitimate
company, with legitimated rights, that has been active for various years.

3.41 Finally, considering paragraph 4.c. (iii) of the Policy it is important to remark
that the Respondent is making a legitimate fair use of the domain names, as the
details in ANNEX XIII show PIN DIGITAL has no gain from the
Complainants activity. The use of the contested domain names is not
misleading in any way, in the contrary; their names make it very clear for the
consumer to be aware of the type of web page they are entering.

C. Whether the domain names have been registered and are being used in bad
faith.
(Policy, para. 4(a)(iii))

3.42 In regard to this section, and as mentioned in previous sections we insist that the
commercial activity carried out by PIN DIGITAL has no relation with the
services and internet activity of PINTEREST, INC. They are both clearly
addressed to different users.

3.43 The legally established name of the Respondents company is PIN DIGITAL
and the domain names chosen by the Respondent are a clear referenced to the
registered company name <pinsex.com> for general sexual and erotic contents
and <pingay.com> for general gay contents. It is impossible to consider that
there is bad faith in the registration and/or use of contested domain names; they
are both the results of a commercial activity developed the last years by a legally
constituted Spanish company.

3.44 The Complainant indicates in paragraph 6.22 that the contested domain name
<pinsex.com> began its activity between September 2012 and April 2013, when
actually the relevant information regarding this domain name is that it was
created in June 2008, and as mentioned on paragraph 3.29 of this response, the
15
preparations for the launching the web page began in early 2012 resulting the
page to be fully active by the end of June 2012.

3.45 Regarding the referenced made by the Complainant in paragraph 6.22, to
paragraph 3.7 of the WIPO overview, we must keep in mind that Panels have
tended to the view that formal changes in registration data are not necessarily
deemed to constitute a new registration where evidence clearly establishes an
unbroken chain of underlying ownership by a single entity or within a genuine
conglomerate, and it is clear that any change in WhoIs registrant data is not
being made to conceal an underlying owner's identity for the purpose of
frustrating assessment of liability in relation to registration or use of the domain
name. As the complaint indicates in paragraph 6.18, the former owner of the
contested domain name is directly related with the Respondent, BEREPUBLIC
NETWORKS, S.L. is part of PIN DIGITAL. BEREPUBLIC NETWORKS, S.L.
handled the entire project's preparation and launching, this is why they were the
initial holders of the contested domain names. ANNNEX XVII includes various
documents that prove the relation between BEREPUBLIC NETWORKS, S.L.
and PIN DIGITAL.

3.46 The Complainant indicates in paragraph 6.23 that its rights were extremely well
known, however fails to consider that the Respondent is not an American
company located at San Francisco where in 2012 the Complainant may have
been extremely well known. The Respondent is a small Spanish company that
began its activity in 2012, when PINTEREST was barely known in the European
Community, in fact, as we can see from ANNEX XIV there are even articles
that specify that PINTEREST has not been granted its rights in the European
Community and that the company PREMIUM INTEREST LTD holds prior
rights to the name. Consequently, apart from the fact that the services provided
by the Complainant and the Respondent have NOTHING in common, the
Complainants activity was not extremely known in the European Community
when the contested domain names began their activity.

3.47 In paragraphs 6.24 of the complaint, the Complainant insists that the domain
names are similar to the word PIN, however, as already established in
previous paragraphs PIN is a generic word used by the Respondent as a
16
reference to its own company name and a reference to the Dictionary term
PIN.

3.48 Regarding the arguments of the Complainant in paragraph 6.25 of the complaint,
as previously mentioned the Complainant has not provided any document that
proves any prior right over a web page format, a form of displaying the
information that is and will continue to be commonly used by a very large
number of websites. Please see as ANNEX XV a large number of websites that
use similar information displays.

3.49 Considering paragraph 4.b.(i) of the Policy, it is clear that the contested domain
names have not been registered or acquired for the purpose of selling, renting, or
otherwise transferring the domain name registrations to the Complainant. The
Respondent has been active for various years now and has never had the
intention to interfere, nor transfer its activity or domain names to PINTEREST.

3.50 Regarding paragraph 4.b.(ii) of the Policy, the contested domain names are
clearly registered and active to provide the services of PIN DIGITAL, these
domain names do not prevent at all the Complainant from reflecting the mark in
a corresponding domain name and, in connection therewith, the Respondent has
not engaged in a pattern of such conduct. The Respondent does not wish to
interfere with the Complainants activity, in fact, as we will mention on the next
section, it could be even considered the other way around.

3.51 Regarding paragraph 4.b. (iii) of the Policy, it is clear that the Complainant and
the Respondent are NOT competitors; both provide very different activities
addressed to very different internet users. In fact, the adult contents of the
Respondents web sites are completely prohibited in the Complainants web
pages.







17
<PINTEREST.COM>:




<PINSEX.COM>:






18
<PINGAY.COM>:



3.52 From the previous comparison it is clear that the Complainants and the
Respondents activity are very different and that they are not competitors in any
way.

3.53 Finally, regarding paragraph 4.b.(iv) of the Policy the Respondents services and
activity has no relation with the Complainants activity, the contested domain
names are NOT an intentional attempt to attract for commercial gain, internet
users to the Respondents web site, in fact as ANNEX XIII shows none of the
users that access the contested domain names are redirected from the
Complainant, nor go to the Complainants web page after visiting <pinsex.com>
and/or <pingay.com>. The services provided by each company are so dissimilar,
that it is impossible to consider that any consumer could make a mistake based
on likelihood of confusion with the Complainants trademark.

D. Reverse domain name Hijacking or abuse of process;
(Rules, para. 15(e))

3.54 In addition to the previous defense arguments, the Respondent hereby request
the Panel to make a finding regarding reverse domain name hijacking and abuse
of process based on paragraph 15(e)) of the Rules.
19
3.55 As mentioned in the previous sections of this response, the Respondents activity
has been in preparation since early 2012 and was officially active on June 2012
and May 2013 respectively; also, the Respondent applied for the registration of
Community Trademarks n 11058195 and n 11856309 in the years 2012 and
2013 which as explained have been opposed by the complainant. Please see
ANNEX V and ANNEX VI.

3.56 As the articles provided in ANNEX XVI mention, the Complainant has initiated
a campaign against any company or internet web page that uses the generic term
PIN, claiming a UNIVERSAL right over a dictionary word that cannot be
monopolized by a sole company.

3.57 Considering the public strategy followed by the Complainant that appears in the
news, the oppositions filed at the Office for Harmonization in the Internal
Market (OHIM) and the complaint against the domain names <pinsex.com> and
<pingay.com> filed at the WIPO, the Respondent is specially affected by the
campaign followed by the Complainant, which has continued despite that they
know that the Respondents activity is legal, legitimate and has been active for
various years.

3.58 The oppositions against the Respondents trademark applications, were filed in
in the years 2012 and 2013, time at which the Complainant was very aware of
the legitimate activity of the Respondent; further on the complaint at the WIPO
was not filed until June 2014, which responds to a harassing campaign of the
Complainant against PIN DIGITAL.

3.59 The Complainant knew at the time the complaint was filed, that the Respondent
is the legitimate owner of the contested domain names and that their use cannot,
under any fair interpretation of the reasonably available facts, constitute bad
faith, as well as that the Respondent uses the contested domain name as part of a
bona fide business. In this sense, we refer to the decision issued in Case No. D
2000-1202 Deutsche Welle v. Diamond Ware Limited which says: The Policy
is only designed to deal with a very narrow category of case, namely
cybersquatting. It was never intended to be a substitute for trade mark
infringement litigation. Manifestly, in their view, this was never a case of
cybersquatting. The Policy is clear. To succeed in the complaint, the
20
Complainant has to prove, at the very least, that the Domain Name was
registered in bad faith. When the Complainant conducted its Whois search and
found that the Domain Name registration dated back nearly 6 years, it was
alerted to the fact that registration of the Domain Name was most unlikely to
have been undertaken "primarily" for any bad faith purpose directed at the
Complainant. The Complainant has not produced one shred of evidence to
suggest why the Respondent, a company in the United States, should have been
aware of the existence of the Complainant, a German broadcasting service, back
in 1994 when it registered the Domain Name. When the Complainant visited the
Respondents website (its letter of July 13, 2000 makes it clear that it was aware
of the website) any doubts it may have had were removed. The Domain Name
connects to an active website through which the Respondent conducts a bona
fide business and in relation to which the acronym "DW" is apt.

3.60 In light of the above, we request the Panel to declare that the complaint was
brought in bad faith and constitutes an abuse of the administrative
proceeding

IV. Administrative Panel
(Rules, paras. 5(b)(iv) and (b)(v) and para. 6; Supplemental Rules, para. 7)

4.1 The Respondent elects to have the dispute decided by a single-member
Administrative Panel.

V. Other Legal Proceedings
(Rules, para. 5(b)(vi))

5.1 As far as the Respondent is aware, no legal proceedings have been issued or
terminated in connection with the contested Domain names.

VI. Communications
(Rules, paras. 2(b), 5(b)(vii); Supplemental Rules, para. 3, 7, 12)

6.1 A copy of this Response has been sent or transmitted to the Complainant on 28
July 2014 by email.

21
6.2 This Response is submitted to the Center in electronic form, including any
annexes, in the appropriate format.

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

7.1 As the Respondent has decided in section IV to have the dispute decided by a
single-member Administrative Panel no payment is required.

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

8.1 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.

8.2 The Respondent certifies that the information contained in this Response is to
the best of the Respondents 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 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,


___________________
Rosa Maria Abadie


Date: 28 July 2014

22

X. List of Annexes


ANNEX I: USPTO PIN trademark registration details.
ANNEX II: Google Analytics <pinsex.com> details.
ANNEX III: Google Analytics <pingay.com> details.
ANNEX IV: PIN DIGITAL, S.L. Company general information.
ANNEX V: CTM n 11058195 PINSEX your daily dose of sexpiration
ANNEX VI: CTM n 11856309 PINGAY
ANNEX VII: Progressive Web Company of the Year - Xbiz awards
ANNEX VIIII: Best Emerging Site - YNOT Awards
ANNEX IX: Preparation for the activation of the domain names.
ANNEX X: List of the Community trademark applied by the Complainant.
ANNEX XI: Alexa and SimilarWeb detail on how popular are the domains
ANNEX XII: Examples of web pages that include the word PIN.
ANNEX XIII: Detail of where users come from and where they go after.
ANNEX XIV: Articles regarding PINTEREST trademark in the European Union.
ANNEX XV: Examples of web pages with the layout as PINTEREST.
ANNEX XVI: Articles on PINTEREST.
ANNEX XVII: Documents that link BEREPUBLIC and PINDIGITAL.
ANNEX XVIII: <pinsex.com> and <pingay.com> registration details.