The number of decisions under the Uniform Domain Name Dispute Resolution Policy (UDRP) rose 9.89 percent in the third quarter of 2025, from the same period a year ago, according to data in the newest issue of GigaLaw’s Domain Dispute Digest.
If the trend continues until the end of 2025, the total number of cybersquatting cases at WIPO (the largest of the five UDRP service providers and a barometer of overall trends) will remain almost unchanged from 2023 and 2024.
The Digest tracks data from all of the UDRP providers, as well as for the Uniform Rapid Suspension System (URS), which saw a significant drop in decisions of almost 27% — an indication that the the URS remains an unpopular way to resolve domain name disputes while the UDRP is to go-to choice for trademark owners to deal with cybersquatters.
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In my Foreword to this issue of the Digest, I also discuss the problem of “serial cybersquatters,” that is, domain name registrants that show up again and again in UDRP cases.
On the one hand, such repetitive activity by domain name registrants usually makes a UDRP case relatively easy to win. That’s because one way for a trademark owner to establish bad faith (one of the three required elements in every UDRP complaint) is to provide evidence showing that the registrant has “engaged in a pattern of such conduct.” As the WIPO Overview says, “UDRP panels have held that establishing a pattern of bad faith conduct requires more than one, but as few as two instances of abusive domain name registration.”
On the other hand, the UDRP provides no tools for trademark owners to deal with such repeat cybersquatters other than to repeatedly file UDRP complaints.
Here are just a few examples of recent UDRP decisions involving serial cybersquatters:
In CBOCS Properties, Inc. v. Kas Is, WIPO Case No. D2025-1419, the respondent registered the domain name <crackerbarrelemployee.org> and used it in connection with a website that appeared to be a website for the complainant. “Two prior panels under the Policy have found the Respondent to have committed cybersquatting…” the panel wrote. “In both of those cases the Respondent was shown to have engaged in very similar conduct as it has exhibited in this case, specifically, impersonating well-known brands by masquerading as their employee portals.”
In LinkedIn Corporation v. Stacken Schneider, WIPO Case No. D2025-1102, the panel wrote: “The record… shows that Respondent has a history of being a serial cyber squatter, and previously registered numerous domain names that have been found by other panelists to be confusingly similar to well-known trademarks.” (Disclosure: I represented the complainant in the LinkedIn case.)
In Equifax Inc. v. Shi Lei, WIPO Case No. D2025-0382, the panel said “the Complainant notes that the Respondent is a serial cybersquatter who has lost numerous proceedings under the Policy.” Indeed, the respondent appears to have been named in at least 57 decisions at WIPO, 33 decisions at the Forum and five decisions at CAC. (Disclosure: I represented the complainant in the Equifax case.)
Unfortunately, the issue of serial cybersquatting shows no signs of dissipating. Fortunately, the UDRP remains an effective way for trademark owners to repeatedly defeat these repeat offenders.
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For all of the detailed data on UDRP and URS cases for the third quarter of 2025, download a copy of GigaLaw’s Domain Dispute Digest — and subscribe to get an email when the next quarterly issue is published.
