The number of decisions under the Uniform Domain Name Dispute Resolution Policy (UDRP) jumped nearly 15 percent in the first quarter of 2026 – and, the number of domain names in those decisions skyrocketed more than 41 percent, the biggest increase since GigaLaw started tracking UDRP cases six years ago.
I suspect that the increase in the number of decisions is simply due to the usual trend that has been occurring regularly since 2013: a rise in the number of domain name registrations; the ongoing ease with which cybersquatters can engage in their activities, along with few deterrents; growing awareness of domain name disputes in general; and the continued effectiveness of the UDRP itself.
What accounts for the spike in the total number of domain names in those UDRP cases is easier to pinpoint: Two cases alone accounted for 1,242 of the 4,766 disputed domain names, or more than 26% of the total. Those two cases (filed by cosmetics company L’Oréal for 705 domain names; and financial services company Empower for 537 domain names) are unusually large. By comparison, the largest cases in the first quarter of 2025 (each of which was filed by pharmaceutical company Novartis) included “only” 228 and 122 domain names.
Such outsized UDRP cases are rare because of Rule 3(c):
The complaint may relate to more than one domain name, provided that the domain names are registered by the same domain-name holder.
The common use of privacy and proxy services in recent years, as well registrars’ redaction practices following the European Union’s General Data Protection Regulation (GDPR) in 2018, often makes it difficult for trademark owners to know whether multiple domains are actually registered by a single person or entity.
(This has not always been the case. When I filed the largest UDRP complaint that has ever been filed, in 2009 – which resulted in a decision ordering the transfer of 1,519 domain names – privacy and proxy services were far less common, and the GDPR was still nine years away. As a result, many, if not most, Whois records disclosed the names of domain name registrants, making it easier to file consolidated complaints.)
In both the L’Oréal and Empower decisions, the panels addressed the issue of multiple domain names, and each concluded that it would be proper to allow consolidation. In the Empower case, for example, the panel noted
the common patterns in the composition of the disputed domain names, the registration of hundreds of similar disputed domain names with the same Registrar over the course of a few specific days in a short span of time, and their use in precisely the same way as part of a relatively complex fraudulent phishing scheme using session-hijacking to target account-holders of one of the largest retirement plan providers in the United States.
As a result, the panel concluded that “whoever is behind the registration and use of the disputed domain names exercises common control over them.”
Although both L’Oréal and Empower obtained favorable decisions for all of the domain names in their large UDRP cases, they interestingly sought different remedies. While the Empower domain names were ordered to be transferred, the panel in the L’Oréal case ordered all of the domain names cancelled, presumably at L’Oréal’s request. (Why any trademark owner would ever request cancellation as a remedy instead of transfer is something I have never understood, because a domain name cancelled in a UDRP proceeding is not made permanently unavailable and could be registered by another – or even the same – cybersquatter again.)
For extensive data on UDRP decisions in Q1 2026, download the 16-page issue of GigaLaw’s Domain Dispute Digest
