Managing Intellectual Property

Literal view of UDRP wins out

10 September 2010

James Nurton, London

An expansive interpretation of the UDRP, which could provide stronger protection for brand owners, looks set to be rejected following a decision this week

For a complaint to succeed, the UDRP requires a finding that a domain name was both registered and used in bad faith. Panellists have traditionally interpreted this language literally, but in a series of well-argued recent decisions some have set out an alternative view - that use or registration in bad faith is sufficient.

This argument has become known as the Octogen line, after three early decisions in which it was put forward. It has been applied by panellists such as Scott Donahey and Andrew Christie.

The Octogen interpretation makes it easier for complainants to establish bad faith, and would sometimes lead to a different finding.

In this week's decision, over domain name ferrlicit.com, Donahey found himself dissenting after two other experienced panellists denied the complaint. They found that while the domain had been used in bad faith, there was no evidence that it had been registered in bad faith.



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