UDRP: Reverse Domain Name Hijacking

A UDRP was filed at the World Intellectual Property Organization against the seemingly generic domain name. The decision was published this morning, and the three member panel ruled in favor of the domain registrant. In addition, the panel found that this was a case of Reverse Domain Name Hijacking (RDNH).

As an observer, it seems pretty clear to me that Cassandra is a women’s name and is generic considering how many people there are named Cassandra. As a domain name, a first name .com domain name like holds considerable value, and the registrant shared a couple of public first name .com domain name sales to support this. In the discussion section of the UDRP, the panel offers some good language for domain investors who own first name domain names like this one:

“The Panel accepts that, where a party legitimately registers a domain name comprising commonplace or dictionary elements for sale, without intent to target the trademark of an existing trademark owner, then that offer for sale can give rise to rights or legitimate interests in the domain name as a bona fide offering of goods or services for the purposes of paragraph 4(c)(i) of the Policy (see e.g. Allocation Network GmbH v. Steve Gregory, WIPO Case No. D2000-0016; and Voys B.V., Voys United B.V. v. Thomas Zou, WIPO Case No. D2017-2136). The Panel finds that the same considerations are applicable to the registration of a personal first name. The question in this case, therefore, is whether the Respondent registered the disputed domain name in the knowledge of the Complainant’s trademark and with the intention of taking unfair advantage of the goodwill attaching to that trademark, or legitimately in the circumstances described above.

Based on the parties’ submissions in this case, the Panel can find no evidence upon which to conclude that the Respondent was aware of the Complainant’s United States trademark THE CASSANDRA REPORT at the date it registered the disputed domain name, or that it registered the disputed domain name with the intention of taking unfair advantage of that trademark.”

In the discussion about RDNH, the panel seems to have felt that the complainant brought the UDRP complaint as a means of getting the domain name for less than it is worth. According to the decision, the complainant offered a measly $2,500 to try and buy The RDNH discussion had some good language for domain investors and the asking prices of their domain names ($200,000 in the case of

“In the view of the Panel, the Complainant has disclosed no reasonable grounds for believing that the Respondent registered the disputed domain name with the Complainant or its trademark THE CASSANDRA REPORT in mind or with the intention of taking unfair advantage of the Complainant’s trademark. Nor, for the reasons set out above, has it disclosed reasonable grounds for believing that the Respondent has used the disputed domain name in bad faith. On the contrary, the Panel infers on balance that the Complainant commenced the current proceeding in the hope of acquiring the disputed domain name without paying the full price legitimately demanded by the Respondent for the sale of the disputed domain name. Noting also that the Complainant is legally represented in this proceeding, the Panel finds that that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding.”

If the goal of the UDRP filing was to get for less than the domain name is worth, that plan backfired. The price likely increased (if the registrant would even consider selling it to the complainant) because there is a substantial cost to a UDRP defense and the UDRP panel backed the registrant’s right to have this domain name.

The UDRP was defended by Zak Muscovitch of Muscovitch Law.

Elliot Silver
Elliot Silver
About The Author: Elliot Silver is an Internet entrepreneur and publisher of Elliot is also the founder and President of Top Notch Domains, LLC, a company that has closed eight figures in deals. Please read the Terms of Use page for additional information about the publisher, website comment policy, disclosures, and conflicts of interest. Reach out to Elliot: Twitter | Facebook | LinkedIn


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