Another UDRP was filed against a valuable three letter .com domain name at the World Intellectual Property Organization, and the decision was just published on the WIPO website. The three member WIPO panel found in favor of the respondent, and CLH.com will remain with the domain owner.

From my perspective, most UDRP panels have been consistent in finding that valuable LLL .com domain names are fair game for domain investors to own and buy. There are typically many different entities that could conceivably feel entitled to a particular acronym domain name, but that should indicate the generic nature. The panel mentioned this in the decision:

“On the evidence, clearly the acronym CLH, whether as a registered trademark or potentially having common law trademark status by association with the names of companies or other entities, and whether alone or in combination, is in wide use as the identifier of numerous business and other entities. Each of those users of the acronym CLH is a potential customer for a domain name comprising or incorporating CLH, some of which the Respondent has shown to be already in use, including for example <clh.hu>, <clh.com.au> and <clh.org>.”

The panel also noted that the price alone is not evidence of bad faith:

A UDRP was filed at the World Intellectual Property Organization against the seemingly generic Cassandra.com 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 Cassandra.com 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