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Which predates the Respondent’s registration of the disputed domain name. See CBS Broadcasting, Inc. v. LA-Twilight-Zone, D2000-0397 (WIPO June 19, 2000) (finding that the Respondent has not demonstrated any rights or legitimate interests in the domain name "TWILIGHT-ZONE.NET" since the Complainant had been using the mark TWILIGHT ZONE since 1959). The Respondent cannot prevail on the argument that the mark is generic. The Complainant’s trademark registration is "conclusive evidence" of the Complainant’s exclusive right to use the mark (subject to certain enumerated defenses not relevant to the defense of genericness). 15 U.S.C. § 1115(b). Park ‘N Fly, Inc. v. Dollar Park and Fly, Inc., 469 U.S. 189, 198, 105 S.Ct. 658, 663, 83 L.Ed.2d 582 (1985). Registration and Use in Bad Faith The Respondent registered and is using the domain name in bad faith. The Respondent as a competitor, knew or should have known of the Complainant’s famous mark prior to registering the disputed domain name. See Samsonite Corp. v. Colony Holding, FA 94313 (Nat. Arb. Forum, Apr. 17, 2000) (evidence of bad faith includes actual or constructive knowledge of commonly known mark at the time of registration); see also Reuters Ltd. v. Teletrust IPR Ltd., D2000-0471 (WIPO Sept. 8, 2000) (finding that the Respondent demonstrated bad faith where the Respondent was aware of the Complainant’s famous mark when registering the domain name as well as aware of the deception and confusion that would inevitably follow if he used the domain names). Also, the Respondent registered the disputed doma

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