The World Intellectual Property Organization (WIPO) recently announced that it had reached a new milestone in 2025, namely managing over 6,200 Uniform Domain Name Dispute Resolution Policy (UDRP) cases – the highest number on record.

WIPO has resolved over 80,000 cases over the past 25 years, including over 70,000 generic Top-Level Domain (gTLD) cases and nearly 10,000 country-code Top-Level Domain (ccTLD) cases.  According to the information provided by WIPO in its update, the majority of cases originate from the United States, France, and the United Kingdom.

A graph provided by WIPO shows that case numbers have grown steadily since the launch of the UDRP in 1999 with a marked bump in the overall numbers after 2020, when 4,204 cases were examined, as compared with the 6,282 cases handled in 2025. 

Interestingly, the number of ccTLD cases handled has also increased exponentially, from just 51 in 2001, to 819 in 2025.  On a related note, in 2025 WIPO also began accepting cases for .HT (Haiti) and received its first filings and first decisions for .AD (Andorra), .CV (Cabo Verde), and .LV (Latvia). This takes to 87 the total number of ccTLDs for which WIPO now provides dispute resolution services. 

The top 10 ccTLDs in 2025 in terms of domain name case filings were: .CO (Colombia), .AU (Australia), .AI (Anguilla), .CN (China), .IO (British Indian Ocean Territory), .MX (Mexico), .CC (Cocos Islands), .ES (Spain), .NL (Kingdom of the Netherlands), and .SE (Sweden).

WIPO also saw increases in domain name case filings for the ccTLDs of .CO (Colombia), .AU (Australia), .IO (British Indian Ocean Territory), .MX (Mexico), .IE (Ireland), and .UA (Ukraine).

As WIPO states: “[t]hese case filing numbers show the continued importance of the WIPO-administered Uniform Domain Name Dispute Resolution Policy (UDRP) as a vital part of trademark owners' online brand protection toolkit.”

Should you require assistance in relation to UDRPs, please contact David Taylor or Jane Seager, both of whom are WIPO UDRP panellists.

The Tanzania Communications Regulatory Authority (TCRA), which manages the .TZ country-code Top-Level Domain (ccTLD), is reportedly preparing a nationwide campaign to promote its use for websites and email.  The campaign aims to strengthen Tanzania's digital identity, improve cybersecurity, and support the growth of the digital economy.

Speaking in Dar es Salaam recently, TCRA Director General Dr Jabiri Bakari said the authority intends to “educate, motivate and empower” citizens to adopt the .TZ domain as a reliable and trusted digital identity for the country, as reported by this Tanzanian news outlet.  The twelve-month campaign, scheduled to begin this year, will seek to increase Tanzanians' understanding of domain names and their importance as well as to promote their registration.  Tanzanians will be urged to select a .TZ as their official online address.

Dr Bakari added that the programme will also raise awareness about cybersecurity, authenticity and trust associated with the use of official domain names.  Wider adoption of the Tanzanian domain, he asserted, “makes it easier for clients to access an organisation's services, demonstrates professionalism, enhances branding, and builds trust and confidence among users.”

With Tanzania's digital economy expanding rapidly, more individuals, companies and institutions need a visible and secure presence on the internet.  “As more services shift to digital platforms, ranging from e-commerce and digital payments to government services, the importance of owning a verified and secure domain name has become more critical than ever”, Dr Bakari emphasised.

Currently, the use of .TZ domains remains modest compared to the growing number of internet users and businesses.  By September 2025, only 35,621 .TZ domain names had been registered, although this represented quite a significant increase of 24.5% over the same period in 2023.  In Tanzania, many organisations still rely solely on social media pages, free hosting services or shared platforms, which can undermine credibility, weaken security and reduce control over their digital identity.

This situation has reportedly led to problems such as impersonation, misinformation, brand abuse, cybercrime and the limited visibility of Tanzanian content online.  Encouraging companies, start-ups, creators and public institutions to adopt .TZ domain names is said to be in line with national priorities for digital transformation, local content development, data localisation and cybersecurity.

If you would like more information or are interested in registering .TZ domain names, please contact David Taylor or Jane Seager.

DNS Belgium, the organisation responsible for managing the .BE domain name space, recently published an article explaining how it is using a new machine-learning system called RegCheck to identify and block suspicious .BE domain name registrations before they become active on the Internet.

DNS Belgium has stated that keeping the Internet secure is one of its most important objectives and, in practice, this means “striking a balance between the smooth registration of .be domain names and strict control of registrations that appear suspicious.”  To support that effort, the RegCheck tool, which automatically screens new domain name registrations for signs of suspicious activity, was developed and has been in operation since March 2024.  RegCheck analyses historical patterns in order to predict whether a newly registered domain name could be suspicious.

The RegCheck tool grew out of the idea that fraudulent domain name registrations tend to follow recognisable patterns and that machine learning could be used to detect them.  It was first proposed in a thesis submitted to the Department of Computer Science at KU Leuven in 2019/20, then became a collaboration between DNS Belgium and its Dutch counterpart, SIDN, which was pursuing a similar approach to abuse mitigation.  The two organisations decided to collaborate, exchanging code and ideas and jointly defining the features that would serve as input for the machine-learning model.

The two Registries encountered a number of challenges during the training and testing of the model – one being that malicious domain name registrations are not always obvious at the moment they are created.  A domain name that appears legitimate initially may later be used for fraudulent activity, which means that the model must be designed to consider broader patterns beyond just the initial registration data.

Additionally, instead of letting the algorithm discover patterns on its own, the team specified what to watch for – such as numbers at the end of a domain name – and combined multiple factors into a reputation score.  According to the developers, this process, known as ‘feature engineering', requires expertise in both domain names and complex database queries.

Since its launch, DNS Belgium reports that RegCheck has significantly outperformed the previous manual verification system.  According to Maarten Bosteels, head of R&D at DNS Belgium, the machine-learning model evaluates the “combination of all characteristics instead of simply adding up the “violated” rules”, producing a more accurate assessment of suspicious registrations than previous manual assessments.  The system is flexible and can be tuned to be more or less strict depending on the desired level of risk tolerance.

As Thomas Daniels, a researcher in the R&D team at DNS Belgium, explains, RegCheck acts like a wide net: it can block roughly 30% of domain name registrations while identifying around 80% of potentially fraudulent ones, allowing eventual manual checks to be carried out “in a much more targeted manner.”

When a registration is flagged, it must go through a separate identification process before it can be activated.  This prevents potentially fraudulent .BE domain names from being used immediately for scams; a precaution which DNS Belgium points out “only takes place after the domain name is already active”.  While the domain name remains in the registrant's possession, they cannot use it until the verification process is complete, adding an extra layer of protection for users.

Since its rollout, RegCheck has already had a measurable impact at DNS Belgium.  In the seven months following its launch, the number of malicious domain name registrations reportedly fell by 30% compared with the same period the previous year.  

According to Thomas Daniels, while there are no plans to commercialise the tool or release it as open source, DNS Belgium is open to sharing the code and offering expertise to other Registries interested in adopting similar approaches.

For more information on .BE domain names, please contact David Taylor or Jane Seager.

Domain name recuperation news

In a recent decision under the Uniform Domain Name Dispute Resolution Policy (UDRP) before the World Intellectual Property Organization (WIPO), a Panel denied the transfer of the Domain Name at issue, finding that the Complainant failed to establish the Respondent's intent to target the Complainant's trade mark when registering the Domain Name.

The Complainant, El Baik Food Systems Co. S.A., was a company registered in Luxembourg operating a fast-food chain which was founded in Saudi Arabia in 1974. It traded principally under the names AL BAIK and EL BAIK and owned various trade marks around the world, including a EU figurative trade mark for EL BAIK registered in 1999, an Indonesian combined trade mark for AL BAIK registered in 2009 and a Saudi Arabia word trade mark for BAIK registered in 2010. The Complainant operated its website at “www.albaik.com”.

The Respondent, known as "twb twb" and based in Singapore, did not respond.

The Domain Name baik.com was initially registered in 1999 and resolved to a landing page offering the Domain Name for sale.

To be successful in a complaint under the UDRP, a complainant must satisfy the following three requirements:

(a) The domain name registered by the respondent is identical or confusingly similar to a trade mark or service mark in which the complainant has rights; and

(b) The respondent has no rights or legitimate interests in respect of the domain name; and

(c) The domain name has been registered and is being used in bad faith.

With respect to the first limb, the Complainant contented that the Domain Name was identical to its BAIK trade mark.  It further asserted that the term BAIK also constituted the most distinctive element of its AL BAIK and EL BAIK trade marks, given that the terms "al" and "el" within those trade marks were merely determiners.   

The Panel held that the Domain Name was identical to the Complainant's BAIK trade mark and confusingly similar to its EL BAIK and AL BAIK trade marks. The first requirement was therefore satisfied.

In regard to the second limb, the Complainant argued that the Respondent had failed to develop a website for the Domain Name, suggesting that its primary market value was in capturing web traffic driven by the Complainant's established reputation.

The Panel confirmed that registering and offering a domain name for sale did not, by itself, confer rights or legitimate interests.  Prior panels have ruled that holding domain names for resale - such as those using acronyms, dictionary words, or common phrases - could be legitimate under the UDRP.  However, the Respondent failed to demonstrate this.  It did not argue any legitimate interest based on an acronym or dictionary meaning of "BAIK" in the Domain Name. Nor did it demonstrate that the Domain Name was part of a broader domain investment business.  Therefore, the Panel found the second requirement to be satisfied.

Regarding the third limb, the Complainant claimed that a prior UDRP decision had deemed its AL BAIK trade mark "famous."  On this basis, the Complainant contended that the Respondent registered the Domain Name to capitalize upon the reputation and goodwill of its trade marks, which was clearly in bad faith.

The Panel first reviewed the date of the Respondent's registration of the Domain Name, initially in 1999, and remarked that the update date on the WhoIs (in May 2025) did not necessarily imply a change of ownership.  The Panel required relevant evidence to prove otherwise, which the Complainant failed to provide. 

Assuming the Respondent registered the Domain Name in 1999, the Panel noted that the Complainant raised no complaint for the next 26 years.  Prior panels have ruled that such long delays make it harder to prove bad faith—especially at registration.  The Panel added that the Complainant's EL BAIK trade marks had limited geographic scope in 1999, that there were no AL BAIK registrations at that time, and that its BAIK trade mark was not registered until May 2010, over 10 years later.

After having cross-referenced the UDRP decision cited by the Complainant regarding the renown of its AL BAIK trade mark, the Panel found it more likely to infer that this trade mark was "well-known" in countries where the Complainant conducted business.  Neither did the Panel accept that there were no substantial differences between the Complainant's AL BAIK, EL BAIK, and BAIK trade marks because the terms "al" and "el" were merely determiners.  In the Panel's opinion, as opposed to its AL BAIK and EL BAIK trade marks, there was no evidence showing that the Complainant had ever traded under the name BAIK, making it challenging to assert that this mark had become a distinctive identifier which consumers associate with the Complainant's goods and/or services.

The Panel also conducted research and noted that the term "baik", when searched for on the Internet, could have various unrelated meanings across many languages, and further observed that trade mark databases contained over 200 registrations for this term in different jurisdictions.

Since the Domain Name had never been substantially used, the Panel continued to assess the Respondent's bad faith under the "passive holding" doctrine[1]. When considering the first factor of this doctrine, the Panel acknowledged that although the AL BAIK and EL BAIK marks may have become distinctive identifiers associated with the Complainant's business, it did not consider that to be the case in respect of the BAIK trade mark. Concerning the second factor, the Panel established that while the Respondent had failed to reply to the proceedings or to demonstrate good faith use of the domain name, the burden of proof remained upon the Complainant to show the contrary. In regard to the third factor, the Complainant did not at any point assert that the Respondent had provided false contact details.  Finally, the fourth factor – the implausibility of good faith use – was not demonstrated by the Complainant, noting that the term "baik" had been used in commerce by numerous parties other than the Complainant, and could also conceivably function as an acronym.  The Panel further explained that no confusion had ever arisen between the Domain Name and the Complainant, and nor had the Respondent attempted any impersonation.

In view of the above, the Panel concluded that the Complainant had failed to establish that the Respondent had registered the Domain Name with the intention of targeting the Complainant's trade marks and exploiting the goodwill and reputation associated with those marks.  The third requirement was not satisfied and the complaint was therefore denied.

This decision underscores that brand recognition is not broad or automatic; distinctiveness for a composite mark (like "al baik") does not inherently protect a single component (like "baik") without proof of standalone fame.  Ultimately, a complainant is required to show clear evidence of direct targeting at the time of registration, especially in relation to generic or multi-meaning terms, rather than relying on a brand's general popularity at the time the complaint is filed.

The decision is available here.

[1] Factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant's mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent's concealing its identity or use of false contact details (noted to be in breach of its registration agreement), and (iv) the implausibility of any good faith use to which the domain name may be put.

In a recent decision under the Uniform Domain Name Dispute Resolution Policy (UDRP) before the World Intellectual Property Organization (WIPO), a Panel denied a UDRP Complaint for the disputed domain name pets4jets.com (the disputed Domain Name).  The Panel found that the disputed Domain Name had not been registered by the Respondent in bad faith as it was acquired by the Respondent at the Complainant's request, at a time when the Respondent was providing assistance to the Complainant as part of the Parties' business relationship.  As a result, the Complainant was not able to prove that the disputed Domain Name had been registered and used in bad faith.

The Complainant was an individual residing in Nevada, United States.  The Complainant provided evidence that she was a managing member of the Nevada-based company Pets4Jets USA LLC, which offered international pet shipping services under the name "Pets4Jets".  As a result of the commonality of their interests in the matter, the Panel added Pets4Jets USA LLC as a Complainant and referred to both as the Complainant in the decision.

The Complainant registered the separate domain name pets4jet.com on 11 February 2020 and used it to operate a website at https://pets4jet.com since approximately 2021.  On this website, the Complainant claims to have founded Pets4Jets in 2009.  On 15 October 2025 (i.e., the day after filing the UDRP Complaint), the Complainant filed a trade mark application for PETS4JETS on the supplemental register of the United States Patent and Trademark Office (USPTO), claiming first use in commerce on 1 April 2019.

The Respondent was listed as an individual of the organization Tier One Credit Repair LLC, California, United States.  As stated in the Complaint, the Respondent was a person "known to the CEO" of the Complainant.  The Panel noted that the Respondent organization appeared to have been wound up in October 2010.

The Respondent registered the disputed Domain Name on 21 September 2021.  As at the date of the UDRP decision, the disputed Domain Name resolved to a landing page titled "Pets 4 Jets" with the tagline "Safe travels for your pets" and a contact form and a box that prompted Internet users to sign up for an email list.

According to the Parties' submissions and the evidence provided, the Panel noted that the Parties had a consulting relationship, pursuant to which the Respondent, usually at the Complainant's request, provided advice and assistance to the Complainant on a range of matters relating to the Complainant's international pet shipping business.  Such assistance included the Respondent registering the disputed Domain Name in September 2021 at the request of the Complainant, given the Complainant's lack of funds.  By 2025 the relationship between the Parties had broken down and the Complainant asked the Respondent to transfer the disputed Domain Name to it, or to facilitate the sale of the disputed Domain Name to a third party.  In response to the Complainant's request, the Respondent said that it would only do so in return for payment.  Shortly after this exchange, the Complainant filed a complaint under the UDRP to recuperate the disputed Domain Name.

In response, the Respondent filed a Response stating that the Complainant did not satisfy the three elements required under the UDRP.  In particular, the Respondent noted that it registered the disputed Domain Name at the Complainant's request, with its own funds, as part of its support of the Complainant's business, redirecting the disputed Domain Name to the Complainant's own website until the recent "contract dispute" between the Parties.  The Respondent argued that it had legitimate interests in the disputed Domain Name and did not register or use it in bad faith. 

The Complainant objected to the Respondent adducing text messages as evidence, arguing that the messages were from threads that were incomplete and were therefore misleading.  The Panel exercised its discretion and accepted the Response notwithstanding that it was filed four days after the deadline and noted that the Panel could request clarification regarding the text messages if necessary.

To be successful in a complaint under the UDRP, a complainant must satisfy each of the following three requirements:

(i) The domain name registered by the respondent is identical or confusingly similar to a trade mark or service mark in which the complainant has rights; and

(ii) The respondent has no rights or legitimate interests in respect of the domain name; and

(iii) The domain name has been registered and is being used in bad faith.

Regarding the first limb, the Panel found that there was evidence that the term PETS4JETS was used by consumers in association with the Complainant's services and ultimately considered it appropriate to accept the mark for UDRP standing purposes.  This was notwithstanding that the Complainant did not have a registered trade mark for PETS4JETS, did not provide early evidence of sales to support its claim of having founded the business in 2009, and that it applied to register PETS4JETS on the USPTO Supplemental Register rather than on the Primary Register.  The Panel noted that the Complainant's trade mark application on the USPTO Supplemental Register rather than the Primary Register cast doubt on whether the term had acquired distinctiveness in the market at that time.  Having found that the Complainant had rights in the term PETS4JETS for standing purposes, the Panel found that the disputed Domain Name was identical to the Complainant's trade mark. 

The Panel declined to address the second limb, i.e., the Respondent's rights or legitimate interests, given its analysis under the third limb.  Under the second limb, the Panel noted that the Respondent "admittedly registered the disputed Domain Name per the Complainant's request" and appeared to have used the disputed Domain Name to support the Complainant's business rather than to genuinely launch a venture of its own.

Regarding the third limb, at the outset the Panel noted that the burden of establishing that the Respondent registered the disputed Domain Name in bad faith was on the Complainant.  Having considered the facts, the Panel was not satisfied that the Respondent registered the disputed Domain Name in bad faith, noting that the record did not establish that the Respondent had any plan to "extort an exorbitant fee later in exchange for the disputed domain name".  As a result, the Panel denied the Complaint and did not order transfer of the disputed Domain Name.

In response to the Respondent's claim that the Complainant brought the Complaint in bad faith in an attempt at Reverse Domain Name Hijacking (RDNH), the Panel found that the Complaint was not brought in bad faith and did not constitute RDNH.  In making this finding, the Panel noted that the Complainant was self‑represented and was evidently unfamiliar with the UDRP and relevant principles of trade mark law and procedure, as shown by its reliance on a common law service mark and recent application to register the mark on the USPTO Supplemental Register.  The Panel also noted that the Complainant asserted that the Respondent registered the disputed Domain Name in bad faith without proof and failed to mention in the Complaint that the Complainant had authorized the Respondent to register the disputed Domain Name.

The case highlights the difficulty in general of proving bad faith registration of a disputed domain name when a third party, such as a consultant or website developer, registers it in its own name and uses it for the benefit of a business owner, and the parties later fall into disagreement. There is no presumption of bad faith in the registration of a disputed domain name in such cases, and a complainant is required to prove a respondent's bad faith intention upon the registration of the domain name.  It is therefore challenging for complainants when there is no written agreement concerning the ownership of the disputed domain name.  As a result, and given the narrow scope of the UDRP, such disputes are better resolved in a more suitable forum, such as a national court.  This decision therefore underlines the danger of relying on an oral agreement, particularly when such agreement relates to the registration of a domain name that is integral to a business. 

The decision is available here.