Las Vegas Sands Corp. (Sands) filed a federal lawsuit on Friday in the United States District Court for the District Of Nevada against the owners of 35 websites/domain names including 368.COM, 8227.COM and 9770.COM.

The suit alleges that the unknown registrants of thirty-five Internet domain names who are using Las Vegas Sands Corp.’s world famous “Sands” trademark, “Jinsha” Chinese characters ( 金沙, meaning roughly, “golden sand” and which is the Chinese equivalent of the “Sands” trademark,) on websites to falsely affiliate themselves with Las Vegas Sands Corp., to lure prospective gamblers to overseas online casinos, and to unlawfully and in bad faith advertise, promote, and provide online casino services and gambling services.

Las Vegas Sands Corp. sued for trademark infringement, false designation of origin, and dilution under the Lanham Act, as well as claims for common law trademark infringement, and common law unfair competition.

The Las Vegas Sands Corp. seeks temporary, preliminary, and permanent injunctive relief, as well as damages, attorneys’ fees, and costs.

Here are the relevant allegations from the lawsuit

Defendants have set up a network of Chinese language Internet websites (all of which are accessible to U.S. citizens) designed to drive Internet users to one or more online casinos. These websites are located at thirty-five Internet domains:

368.com

8227.com

9770.com

22v.com

vns000.com

vns002.com

vns003.com

vns004.com

vns005.com

vns006.com

vns007.com

vns008.com

vns009.com

vn008.com

666cp.com

xjs00.com

xjs11.com

xjs22.com

xjs33.com

xjs44.com

xjs55.com

xjs66.com

xjs77.com

xjs88.com

xjs99.com

vns95500.com

vns95511.com

vns95522.com

vns95533.com

vns95544.com

vns95555.com

vns95566.com

vns95577.com

vns95588.com

vns95599.com

The Sands Alleges their identities are unknown because the domain names were registered using a “privacy protection” service offered by eNom, Inc. or Name.com, Inc., through Whois Privacy Protection Service, Inc. or by GoDaddy.com, Inc. through its affiliate DomainsByProxy, LLC.

These companies register domain names without listing the registrant’s true name, email address, or contact information in the publicly available “WHOIS” database of domain name registrants.

The extent of the Defendants’ network of domain names and gambling websites is presently unknown.

To date, however, Las Vegas Sands Corp. has discovered two “directory sites.” These sites are located at 368.com and vns000.com (or 22v.com).

The use of Plaintiff’s marks was no accident. The website is clearly intended to refer to Plaintiff’s world famous resort hotel, as it shows a skyline view of Marina Bay Sands Hotel in Singapore.

The SANDS Marks are embodiments of the substantial goodwill and excellent reputation Las Vegas Sands Corp. and its predecessors have developed since 1952 as a premierprovider of entertainment and casino services. Asa result of the Defendants’ blatant exploitation of Las Vegas Sands Corp.’s trademarks without Las Vegas Sands Corp.’s consent, Las Vegas Sands Corp. has lost control over the SANDS Mark

This loss of control over its goodwill and reputation is irreparable and Las Vegas Sands Corp. cannot be adequately compensated by an award of money damages alone.

As just one example makes clear, while Las Vegas Sands Corp. is a strong supporter of the Coalition to Stop Internet Gambling, and is presently engaged in publicity and lobbying campaigns aimed at defeating measures that would legalize Internet gambling in the United States and elsewhere,the Defendants’ use of the SANDS Marks on the homepages of online casinos, even though unauthorized by Las Vegas Sands Corp., threatens to dilute and detract from Las Vegas Sands Corp.’s message and its efforts to stop the proliferation of online gambling.

Accordingly, the Defendants’ actions have caused and are likely to continue to cause Las Vegas Sands Corp. to suffer irreparable harm and injury unless temporarily, preliminarily, and permanently enjoined by the Court.

The Sands is asking the Court for A temporary, preliminary, and permanent injunction prohibiting the Defendants and their respective officers, agents, servants, employees, and/or all ot her persons acting in concert or participation with Defendants, from:

(1) using the SANDS Marks, or any confusingly similar variations thereof, alone or in combination with any other letters, words, letter string, phrases or designs in commerce, including, without limitation,on any website, in any domain name, in any social network user name, in any hidden website text, or in any website metatag;

and

(2) engaging in false or misleading advertising or commercial activities likely to deceive consumers into believing that any Defendant is the Plaintiff or that any Defendant’s services are associated or affiliated with, connected to, or approved sponsored by the Plaintiff;

An order requiring domain name registrars eNom, Inc., Name.com, Inc., GoDaddy.com, Inc., and/or VeriSign, Inc. (the.com domain name registry) to immediately remove or disable the current domain name server information for each of the domain names and place the domain names on hold and lock pending further order of the Court.

Award of compensatory, consequential, statutory, and/or punitive damages to Plaintiff in an amount to be determined at trial;

An award of interest, costs, and attorneys’ fees incurred by Plaintiff in prosecuting this action; and

All other relief to which Plaintiff is entitled

The case number is  2:14-cv-01049.
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