eResolution Dream Island - page 1 and page 2

Category 1 – Copy or Similarity

Background

1.The Complaint company, Daydream Island Resort Investments Pty Ltd CAN 089 615 136 (“ the Complaint”), is a Queensland, Australia resident private company incorporated on 20^th September 1999. Share subscriptions issued 7^th October 1999: Exhibit 4a

2.The related entity, “Cruising On” International Investments Pty Ltd CAN 087 762 525 is also a Queensland, Australia resident private company incorporated on 26^th May 1999: Exhibit 4b

3. The Complaint purchased a 50% share in an Australian territorial island on 1^st November 1999. The Complaint’s interest was derived from a Joint Venture and the related entity purchased the remaining 50% share in 31^st March 2000.

4. The domain name in contention “daydreamisland.com” (“disputed domain name”) was registered with Network Solutions Inc on 18^th December 1999: Exhibit 6

5. The registrant of the domain name, and the Respondent to the complaint, is Alessandro Sorbello, a resident of Queensland, Australia. Alessandro Sorbello is a company director with extensive business experience both in real estate and the telecommunications industry as well as other interests in Brisbane and throughout Queensland. More recently his interests have extended to the nascent but developing ecommerce industry both through entities in which he is a participant or with which he is otherwise affiliated and in his private capacity.

6. The Complainant has lodged a complaint with ICANN (AF00586) seeking to have the disputed domain name transferred from the Respondent to the Complainant or its nominee.

7. The Respondent is required to respond to the allegations raised by the Complainant, In doing so the Respondent is not required to and does not relinquish any rights whatsoever to later seek to have this dispute dealt with by a Court of competent jurisdiction.