[co-author: Laëtitia Arrault, Sean Kelly, Cindy Mikul, Tony Vitali]
This is the March 2026 edition of Anchovy News. Here you will find articles concerning ICANN, the domain name industry and the recuperation of domain names across the globe. In this issue we cover:
DOMAIN NAME INDUSTRY NEWS
1. Pitcairn Islands look to new .PN bounty
2. Italian Registry works the “.IT Factor”
3. .EU turns 20
DOMAIN NAME RECUPERATION NEWS
4. No betting on the first element under the UDRP
5. UDRP Panel delivers a finding of Reverse Domain Name Hijacking in pizzaman case
6. Higher standards for UDRP complaints
DOMAIN NAME INDUSTRY NEWS
.PN, the country code Top-Level Domain (ccTLD) for the Pitcairn Islands – a group of four volcanic islands in the southern Pacific Ocean that form the sole British Overseas Territory in the Pacific Ocean, which are populated largely by the descendants of the mutinous British sailors of the Bounty, has recently been relaunched after undergoing a revamp. The Registry seems keen to emulate the success stories of other small island nations' ccTLDs, such as .TV (Tuvalu), .IO (British Indian Ocean Territory), .PW (Palau) and .AI (Anguilla).
The population of the Pitcairn Islands, which stands at only 35, making it the smallest territory in the world by number of permanent residents, is primarily made up of the descendants of nine British HMS Bounty mutineers and twelve Tahitian women. The ccTLD was officially delegated by IANA on 10 July 1997 with the initial delegation being made in the name of Tom Christian, a Pitcairn islander who was a direct descendant of Fletcher Christian, who led the 1789 mutiny.
For many years, the Registry's operations were carried out manually, which kept the number of domain name registrations small, but in 2023, Nominet (the UK Registry) took over the administrative and technical management of the .PN Registry and set about modernising it. It implemented the EPP standard (Extensible Provisioning Protocol – a standard, XML-based protocol used by registrars to communicate with Registries for registering, renewing, transferring, and managing domain names), RDAP (the Registration Data Access Protocol, which provides standardised registration records) and DNSSEC (a suite of protocols that secures DNS by adding cryptographic signatures to existing DNS records), thereby making it viable for, and accessible to, a large number of registrars worldwide and thus opening it up to a wider public.
One accredited .PN registrar is even making the most of the islands' colourful backstory by launching an about.pn website that sets out the history of both the islands and the .PN ccTLD as well as providing a list of acronyms with which the .PN ccTLD might align, such as “Prompt Network”, “Protocol Native”, “Payment Node”, “Photonic Network”, Peer Network”, “Private Node” and “Public Node”. Such a strategy can be compared with the Palau Registry's marketing of its .PW ccTLD to stand for “Professional Web” and Christmas Island's promotion of its .CX extension to represent “Customer Experience”.
Following a Sunrise period for trade mark holders, the .PN ccTLD entered General Availability on 23 March 2026. .PN domain names are available at the second level (.PN) or the third level (.CO.PN, .ORG.PN and .NET.PN) with no local presence requirements.
Registro.it, the organisation responsible for managing the .IT country code Top-Level Domain (ccTLD), recently released the third edition of its magazine Quarter. This edition covers the months from September through December 2025, highlighting positive trends in the ccTLD and emphasising the distinctive value of Italian online identity, one of digital expression and innovation that remains rooted in tradition and craftsmanship.
According to the Registry, the .IT namespace is experiencing renewed momentum as businesses and individuals rethink their digital presence. Growth in domain name registrations, new forms of online storytelling, and a stronger emphasis on personal and corporate identity are positioning the .IT ccTLD as a space where culture, commerce, and digital strategy intersect. Between September and December 2025, net domain name registrations increased by nearly 32,000 - more than twice the number recorded in the same months of 2024. October alone saw new registrations exceed deletions by roughly 13,000. By the end of this period, the total number of registered .IT domain names reached 3,537,551, marking a 1.22% year-on-year increase and signalling a return to steady growth after a slowdown in 2024.
Private individuals accounted for 52% of newly registered domain names, up five percentage points from the previous year. Domain name registrations by companies rose slightly to 29%, while domain names registered by freelancers or self-employed professionals declined to 10%. As noted by Registro.it, the growth of the .IT space is increasingly fueled by individuals, reflecting a broader shift toward personal branding and independent online presence. For businesses, domain names continue to serve as tools for visibility and credibility, whereas for younger users they represent “a space of opportunity, as well as one of awareness and responsibility”.
During the same four-month period, 57 domain name oppositions were filed. At the end of 2025, 31% of the oppositions remained pending, as cases can be renewed up to two times. Among resolved cases, 18% ended with revocation, 17% with cancellation, 14% resulted in reassignment, 8% were abandoned, and 1% concluded with a judicial decision.
In parallel, between September and December 2025, Registro.it issued verification requests for 263 domain names, of which 243 were revoked, 2 were successful and 18 remain under review, reflecting the Registry's ongoing commitment to maintaining accuracy and integrity in the .IT namespace.
The Registry's focus on identity extends beyond numbers and disputes. In October, the Internet Festival in Pisa centered on the theme “#identity”. At the festival, Registro.it introduced its “.it Factor” campaign, aiming to highlight Italian identity online as a distinctive value. The campaign, in the Registry's words, “did not propose an abstract concept, but rather a synthesis of elements deeply rooted in Italy's productive and creative culture: attention to detail, a strong connection with local territories and the ability to innovate while remaining grounded in tradition.” Through this initiative, Registro.it drew a parallel between the qualities that make Italian art, craftsmanship, design, food, and fashion globally recognisable and the expression of these traits in the digital world.
The above data and initiatives underscore that the .IT Registry sees itself as more than just a technical provider, but rather as a provider of a platform where identity, commerce, and digital strategy intersect.
To visit the Registro.it website, please click here.
.EU, the country code Top-Level Domain (ccTLD) for the European Union, will celebrate its 20th anniversary on 7 April 2026, highlighting its long-standing role in Europe's digital landscape.
Launched in 2006 and managed by EURid, the .EU ccTLD was introduced to give individuals and businesses a way to express a European identity online. Since the beginning .EU attracted interest, as some one million domain name registrations were recorded on the first day of the Landrush launch. 20 years later, .EU counts over 3.7 million registered domain names, which makes it the 10th largest ccTLD worldwide. In addition .EU benefits from strong user confidence, reflected in a renewal rate of around 80%, indicating that most registrants retain their domain names in the long term.
To register a .EU domain name, applicants must have a connection to the European Union. Originally this meant that only people and organisations based in the European Union could apply for .EU domain names. This was later extended to all countries of the European Economic Area (EEA) meaning that this included Iceland, Liechtenstein and Norway. Since 2021, citizens of the EU and EEA countries can also register .EU domain names regardless of where in the world they are located.
A clear example of how the eligibility rule operates in practice is Brexit. Before the United Kingdom left the European Union, UK individuals and businesses were able to register and use .EU domain names freely. However, after Brexit, UK-based registrants without a presence in the EU / the EEA became ineligible. As a result, hundreds of thousands of .EU domain names held by UK registrants were withdrawn or suspended following the transition period. Many had to give up their .EU domain names unless they could demonstrate a legal connection to an EU / EAA country, such as establishing a company or residence within the European Union.
This eligibility rule ensures that .EU domain names are used by those who are genuinely part of the European market and community. It protects the credibility of the .EU ccTLD by ensuring that it represents genuine European entities, and it supports trust amongst users, who can expect that the website for an .EU domain name is linked in some way to the European Union. Finally, this rule contributes to the European Union's broader goal of maintaining a distinct digital presence in a global internet environment. Notably, across Europe, over half of domain name registrations are ccTLDs rather than generic domain names, showing a clear preference for regional digital identities.
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 a UDRP Complaint for the disputed domain names netbahisadresi.com, netbahisgirisi.net, and netbahissikayet.com. (the disputed Domain Names). The Panel found that the Complainant had failed to provide sufficient evidence of trade mark rights (registered or unregistered) in the term NETBAHIS, and therefore could not satisfy the first element of the UDRP.
The Complainant, an individual based in the United Kingdom, was self‑represented and claimed to operate an online betting and gaming platform under the NETBAHIS brand. The Complainant further asserted that it owned the domain name netbahis.com, which redirected to an online betting and gaming website. However, beyond a basic screenshot confirming the current registration period of netbahis.com, the Complainant did not provide substantive evidence regarding the history, commercial use, or market recognition of NETBAHIS.
The Respondent was also an individual, based in the United States, and did not respond to the Complaint.
The disputed Domain Names were all registered on 26 May 2025, and initially resolved to betting and gaming websites that used NETBAHIS‑like logos, described by the Panel as "highly similar if not identical" to those used on the Complainant's own website. Two of the disputed Domain Names continued to resolve to betting content at the time of the decision, while one (netbahisadresi.com) had become inactive.
To be successful in a complaint under the UDRP, a complainant must satisfy 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.
According to the Complainant, the NETBAHIS trade mark had been used continuously and exclusively for online betting and gaming services for a substantial period of time prior to the registration of the disputed Domain Names and therefore enjoyed common law rights and was well known. The Complainant further argued that it had acquired the associated trade mark by assignment, and that a pending UK trade mark application was evidence of its rights. However, the trade mark application was filed in the name of TM Enfield Ltd, with no explanation or documentation confirming an assignment to the Complainant. The Complainant supplied no assignment agreement, no declaration of transfer, and no supporting evidence indicating that it had acquired rights in the trade mark before filing the UDRP action.
The first element under the UDRP acts primarily as a threshold or standing requirement. To satisfy it, a complainant must show that it owns rights in a trade mark and that the disputed domain name is identical or confusingly similar to that trade mark. In relation to the first element, the Panel found that a pending trade mark application was not evidence of trade mark rights and that the Complainant had produced no assignment document to support the claim of ownership. In addition, the Panel noted that no evidence was provided to demonstrate common law trade mark rights (for example, proof of long standing consumer recognition).
Noting that the Complainant was unrepresented and that the websites at the disputed Domain Names had all made use of a logo that was "highly similar if not identical" to the logo employed on the website to which the Complainant's netbahis.com domain name redirected, the Panel gave the Complainant several opportunities to substantiate its trade mark rights. Despite multiple opportunities to remedy the deficiency, including encouragement to seek legal representation, the Complainant failed to furnish any evidence beyond bare assertions.
Consequently, the Panel found that the Complainant had not established the first element. This failure rendered further analysis unnecessary, and the Panel denied the Complaint.
This case highlights a common but significant pitfall under the UDRP: the assumption that merely claiming rights in a trade mark without evidentiary support will suffice. Even where a respondent defaults, a complainant must still establish trade mark rights (whether registered or unregistered) with clear and credible evidence to be successful in a complaint under the UDRP. Pending trade mark applications, unsupported assertions of assignment, and minimal website screenshots generally fall short of the evidentiary threshold panels expect.
The decision is available here.
In a recent decision under the Uniform Domain Name Dispute Resolution Policy (UDRP or the Policy) before the World Intellectual Property Organization (WIPO), a Panel denied a UDRP Complaint for the disputed Domain Name pizzaman.com. The Panel found that the Complaint failed under the second and third elements, finding that the Respondent, a domain name investor, registered the disputed Domain Name because of its value as a common and descriptive term rather than with any knowledge of the Complainant or its trademark rights. The Panel also made a finding of Reverse Domain Name Hijacking (RDNH), concluding that the Complaint was brought in bad faith and constituted an abuse of the Policy as it followed an unsuccessful attempt to purchase the disputed Domain Name.
The Complainant, El Centro Foods, Inc., operated four pizzerias in the Los Angeles area, California, under the name "Pizza Man" and owned two U.S. trademark registrations for PIZZA MAN and one U.S. figurative trademark that prominently featured the term "pizza man". Each of these trademarks claimed first use and first use in commerce as of 1973.
The Respondent, Syncpoint, Inc., was a domain name investor that purchased and sold domain names comprising common phrases or desirable combinations of letters. The Respondent registered the disputed domain name on 18 April 1998. At the time of filing of the Complaint, the disputed Domain Name resolved to a page that advertised it for sale, with no evidence of use in connection with pizza-related goods or services.
Prior to filing the Complaint, on 21 February 2023 the Complainant contacted the Respondent and sought to buy the disputed Domain Name from the Respondent, stating that it was the right organisation to own the disputed Domain Name as it owned "the USPTO Trademark and restaurants in California with the name Pizza Man and [its] current website is pizzamanpizzeria.com." According to the Complainant, during a call between the parties, the Respondent offered to sell the disputed Domain Name to the Complainant for USD 70,000, an offer that the Complainant rejected.
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 trademark 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.
The Complainant argued that it had satisfied each of the elements required under the UDRP, including that its "Pizza Man" brand was well‑known and identifiable to consumers, that the Respondent had no rights or legitimate interests in the disputed domain name, and that because the Respondent registered the disputed Domain Name after the Complainant accrued trademark rights for the term PIZZA MAN, the Respondent must have done so in bad faith. The Complainant also argued that the price of USD 70,000 was unreasonable as it was in excess of the Respondent's out-of-pocket costs in registering and renewing the disputed Domain Name, and that the Respondent's conduct stood to harm the Complainant's business and reputation.
The Respondent argued that the Complainant had not satisfied any of the three UDRP elements, noting that "pizza man" was a common English expression associated with pizza preparation, sale, and delivery, and that the Complainant's claim to exclusive use was undermined by extensive third‑party use of the term. The Respondent also asserted rights and legitimate interests in the disputed Domain Name, stating that ownership of descriptive domain names was a legitimate activity under the UDRP, and that it was not required to operate a pizza business to enjoy such rights or interests. Finally, the Respondent asserted that the Complainant had not provided any evidence that the Respondent was aware of or targeting the Complainant when it registered the disputed Domain Name decades ago, and the Complainant's long delay in bringing this case undermined its claim of abusive registration.
The Panel found that the first limb of the UDRP was established, as the Complainant had shown trademark rights for PIZZA MAN and the mark was reproduced entirely in the disputed Domain Name.
The Panel found that the second element was not established, finding that the Respondent registered the disputed Domain Name over a quarter of a century ago for its value as a common and descriptive term as part of the Respondent's business of registering and selling domain names. The Panel noted that, contrary to the Complainant's assertion, a domain name investor does not have to offer goods (here, pizza-related goods or services) that are related to the dictionary meaning of the domain names in the investor's portfolio.
Following the Respondent's claim to have conducted a survey of registered domain names containing the string "pizzaman" or "pizza-man", the Panel carried out limited factual research, as it is permitted to do under section 4.8 of the WIPO Overview 3.1, and found that there were many uses of "pizza man" and "pizzaman" on the Internet, including across the United States, as well as a third party trademark registration for WHO'S YOUR PIZZA MAN for services including "restaurant services including pizza" that coexisted with the Complainant's trademark registrations. Ultimately, the Panel found that the fact that a complainant owns a trademark in a descriptive term does not transform a respondent's use of a domain name into an illegitimate one, and noted that there was no evidence that the Respondent registered the disputed Domain Name with any knowledge of the Complainant or its trademark rights.
The Panel considered the third limb of the UDRP even though it was not strictly necessary to do so given its finding under the second element. The Panel found that there was no evidence that the Respondent registered or used the disputed Domain Name in bad faith. The Complainant failed to show that the Respondent was aware of or targeted the Complainant or its trademarks when it registered the disputed Domain Name in 1998, or that the Complainant's trademark was so well known that the Respondent likely would have been aware of the Complainant and its trademark rights. The Panel also found that given that the Complainant's trademark was a common phrase used by numerous other pizza restaurants in the United States, the argument that the Respondent knew or should have known of the Complainant and its trademark rights was "simply not credible". The Panel further noted that the Respondent had not used the disputed Domain Name in a manner that would cause consumer confusion, and the Complainant's argument that the Respondent registered the disputed Domain Name to disrupt the Complainant's business was "entirely speculative".
The Panel found that the Respondent's offer to sell the disputed Domain Name for USD 70,000 did not, by itself, establish bad faith, as the Respondent was entitled to set whatever price it believed appropriate, citing section 3.1.1 of the WIPO Overview 3.1.
The Panel further found that the Complaint had been brought in bad faith and constituted an attempt at Reverse Domain Name Hijacking. Noting that the Complainant filed the Complaint only after failing to purchase the disputed Domain Name at the Respondent's price, as the Complainant acknowledged in the Complaint, the Panel found that the Complainant, who was represented, should have known that its Complaint could not succeed on all three required elements, especially given that the Complainant did not provide any evidence to show that the Respondent knew of its trademark rights when it registered the disputed Domain Name in 1998.
This case highlights the need for complainants to adduce evidence of a respondent having targeted their trademark to establish bad faith, rather than relying on the mere ownership of a trademark, especially when the disputed domain name comprises a common or descriptive term. The case also underlines that the UDRP should not be used as a "Plan B" or fallback option following an unsuccessful attempt to purchase a domain name, and that doing so will likely be considered abuse of the Policy and bad faith, leading to a finding of Reverse Domain Name Hijacking.
The decision is available here.
In a recent decision under the Uniform Domain Name Dispute Resolution Policy ("UDRP") before the World Intellectual Property Organization ("WIPO"), a panel denied a Complaint regarding the disputed domain name thehigherstandard.com (the "Domain Name"), finding that the Complainant had failed to demonstrate that the Respondent had registered and used the Domain Name in bad faith.
The Complainant in this case was a United States-based corporation engaged in the provision of entertainment services including hosting a podcast and releasing leadership, business, and educational content. The Complainant held a United States Trademark Registration (No. 6940266) for THE HIGHER STANDARD, filed on 24 November 2021, registered on 3 January 2023, and had used the mark in commerce since 2021.
The Respondent was an individual, also based in the United States. The Domain Name was first registered in July of 1999. In November 2022, the Respondent engaged a domain broker to acquire the Domain Name. The Respondent subsequently purchased the Domain Name on 7 December 2022, for USD 3,609.63, for a project called "The Higher Standard", a non-profit project centred on underserved communities, in particular, Black and Brown youth. The Respondent's initiative was associated with his non-profit corporation called "The Elements Community Initiative", which focused on supporting organizations that uplift marginalized communities in Chicago, Illinois. The website to which the Domain Name resolved (the "Respondent's website") was first activated in December 2022, and according to the Respondent, was periodically in use when not being updated. The Respondent provided evidence that he had made preparations prior to acquiring the Domain Name in November 2022, including subscribing to a website-building platform. The Respondent had a fully operational website by at least February 2025, several months before receiving a cease-and-desist letter from the Complainant in November 2025.
To succeed under the UDRP, a Complainant must satisfy the requirements of paragraph 4(a) of the Policy:
(i) The disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights;
(ii) The Respondent has no rights or legitimate interests in respect of the disputed domain name; and
(iii) The disputed domain name was registered and is being used in bad faith.
Identity or confusing similarity
In regard to the first element, the Panel found that the Domain Name had reproduced the entirety of the Complainant's trade mark, THE HIGHER STANDARD, and that accordingly, the requirements of paragraph 4(a)(i) of the Policy had been established.
Rights or legitimate interests
Considering that the Complaint would ultimately fail under the third element, the Panel saw no need to enter findings under the second element of the Policy.
Bad faith
The Panel noted that the Respondent had provided an affidavit swearing that he had no knowledge of the Complainant or its podcast when acquiring the Domain Name, and concluded that there was no reason to doubt that claim. The Panel further observed that the Complainant's registered trade mark rights commenced in January of 2023, a month after the Respondent had acquired the Domain Name. The Panel further commented that the Complainant had failed to show that its mark possessed adequate distinctiveness or recognition at the time to attribute knowledge of it to the Respondent. Furthermore, the Panel noted that the Domain Name consisted of descriptive terms and that the record showed that the Respondent had registered it for its plain meaning aligned with the community‑uplift theme of the Respondent's initiative. The Panel therefore found that the Complainant had failed to demonstrate that the Domain Name was registered in bad faith.
The Panel also found that the Complainant had failed to demonstrate that the Respondent had used the Domain Name in bad faith. The Respondent was not using the Domain Name for the purpose of obtaining profit, often conducted through Pay-Per-Click links or paid advertising. Nor was the Respondent, the Panel noted, using the Domain Name to compete with the Complainant. The Panel did not accept the Complainant's assertions that the Respondent's website launch in 2025 was a means of seeking profit and found that the Respondent's website did not mention the Complainant, did not aim to confuse visitors, nor did it offer competing services. Rather, the Respondent had used the domain to promote a non-commercial empowerment project aimed at underserved communities.
The Panel further considered the Complainant's claim that the Respondent's failure to reply to the Complainant's pre-Complaint cease‑and‑desist letter evidenced the Respondent's bad faith to be "unpersuasive", given that the letter granted only a 10-business day response period and the Complaint was filed before this period had elapsed.
The Panel thus concluded that the Complainant had failed to establish that the Respondent had registered and used the Domain Name in bad faith.
Comment:
The decision underscores that allegations of bad‑faith registration require clear evidence that a registrant intentionally targeted another party's rights, rather than selecting a term for its ordinary meaning or for an independent, bona fide purpose. When a name consists of common or descriptive words, it becomes significantly harder for a complainant to establish exclusivity or to infer that the registrant acted with awareness of prior rights. Documented preparations made well before any dispute, such as purchasing a domain, building a website, and using it in a consistent, non-commercial manner, are likely to support a finding of legitimacy. Panels also consider whether the parties operate in unrelated fields and whether the registrant's use shows any effort to monetize, confuse, or divert traffic. Procedural conduct may also impact on a case outcome, with premature or overreaching complaints weakening assertions of bad faith. Ultimately, identical signs or wording alone is insufficient without convincing evidence of exploitative intent.
The full decision is available here.
[View source.]
