Although it sometimes seems like it receives a lot of attention, Reverse Domain Name Hijacking (RDNH) is a very uncommon finding in domain name dispute cases. Across all service providers under the Uniform Domain Name Dispute Resolution Policy (UDRP), panels in only 1.3 percent of decisions issued a finding of RDNH in the second quarter of 2025.
That’s the conclusion of RDNH data that was included for the first time ever in GigaLaw’s Domain Dispute Digest.
The UDRP Rules define RDNH as “using the Policy in bad faith to attempt to deprive a registered domain-name holder of a domain name.” The Rules state that a panel “shall declare in its decision that the complaint was brought in bad faith and constitutes an abuse of the administrative proceeding” if “after considering the submissions the Panel finds that the complaint was brought in bad faith, for example in an attempt at Reverse Domain Name Hijacking or was brought primarily to harass the domain-name holder.”
Although there are no express consequences for a complainant if a panel issues a finding of RDNH, many domain name registrants see it as a way to publicly shame or reprimand those who file inappropriate UDRP complaints, perhaps discouraging future improper complaints from being filed in the first place.
As the Digest data shows, RDNH findings vary by provider — from a low of no such findings at the Asian Domain Name Dispute Resolution Centre (ADNRC) to a high of 9.1 percent at the Canadian International Internet Dispute Resolution Centre (CIIDRC), although the CIIDRC’s small caseload skews the results. But across the the three largest UDRP providers — the World Intellectual Property Organization (WIPO), the Forum and the Czech Arbitration Court (CAC) — the results were similar, ranging only from 1.19 percent to 1.76 percent.
The Digest includes a list of all decisions in the quarter in which panels issued a finding of RDNH.
Indeed, as some of the decisions finding RDNH last quarter make clear, these complaints probably should not have been filed in the first place. For example, in a UDRP decision involving the domain name <ks.com> (WIPO Case No. D2025-0756), the panel wrote:
This is a compelling case for a finding that the Complaint was brought in bad faith and constitutes an abuse of the UDRP. This Complaint is replete with material omissions and outright lies, such as assuming the identity of nonexistent and defunct corporations, submitting a copy of the Respondent’s (cancelled) trademark certificate, and claiming continuous use of a domain name, website, and social media site without proof that the Complainant ever controlled them. Moreover, it appears that the Complainant fabricated a document to make a spurious case for bad faith against the Respondent. A valuable and apparently dormant domain name makes a tempting target, and it is lamentable that a legitimate registrant should be put to the burden of defending against such an abuse of the administrative proceeding.
And in another decision, for the domain name <watertimer.com> (WIPO Case No. D2025-1642), the panel wrote:
Complainant… knew or should have known that there was no evidence of the Respondent’s bad faith directed towards the Complainant, making highly unlikely if not impossible that the Respondent had been targeting the Complainant. Finally, as it has been stated in previous decisions, a complainant is at risk of a RDNH declaration when its attempt to try and buy a domain name is not successful, and it tries to obtain it by using, or rather “abusing”, the UDRP.
While cases like these are shocking, the data on RDNH makes clear that these types of bad faith disputes are incredibly uncommon.
* * *
As usual, the Digest also contains detailed data about the number of decisions at each of the five UDRP service providers, including:
Number of UDRP decisions and domain names
Outcome of UDRP decisions
UDRP case size
Largest UDRP cases
Number of UDRP decisions by provider
Transfer/cancellation rate by provider
Most common gTLDs in UDRP cases
Most common ccTLDs in UDRP cases
Most active trademark owners (UDRP cases)
Number of URS decisions and domain names
URS outcome
Most active trademark owners (URS domain names)
Most common gTLDs (URS cases)
This issue of the Digest also includes details about ICANN’s “New gTLD Program,” which is expected to launch next year, 13 years after its initial round attracted 1,930 applications for new top-level domains. As before, the process will include opportunities for trademark owners and applicants to file objections to specific applications.
Download a copy of the 17-page Digest
See previous issues of the Digest
Subscribe to be notified when future issues are published
