On June 4, 2024, sixty-five (65) days after Plaintiff Prime paid-for the
Butane.com Domain Name, and just one day short of two (2) months after Plaintiff
Crisby paid-for and took ownership of the Calor.com Domain Name, and more than
one hundred (100) days after the Domain Names expired for the previous registrant,
the Plaintiffs each received an e-mail from Defendant’s “CEO Team” stating that
“[D]ue to an unexpected error, the domain calor.com/butane.com should not have been
available for your purchase. To correct this error, we have removed the domain from
your account and are taking proactive steps to prevent this error from happening again
in the future. We have refunded your original purchase and have added an . . . in-store
credit to your account for the inconvenience.” See Ex. K and 11. Plaintiff Thorin was
offered an in-store credit of $350. Ex. K. Plaintiff Prime was offered an instore credit
of $7,350 to offset the cost of the Butane.net and Butane.org. See Ex. 11. On the same
date, Plaintiff Prime received a refund for the nine (9) additional renewal years for
Butane.com, as well as for the Full Domain Protection fees associated with the
Butane.com domain name. See Ex. 12. However, no mention was made, nor were any
refunds provided, for the additional domain names or services purchased in connection
with the development of the Butane.com brand
