In 2025, there was an explosion of UDRP cases filed in bad faith.
2025 was the year of reverse domain name hijacking (RDNH).
Before running the calculations, I had a sense that 2025 had many more RDNH findings than years past. I write about most UDRP RDNH cases, and I was writing a lot more about these cases throughout the year.
While World Intellectual Property Organization (WIPO) provides a wealth of data about its cases, it doesn’t break out RDNH cases. Thankfully, other resources keep track.
UDRP.tools reports that there were 86 RDNH decisions across WIPO and its main competitor, FORUM, im 2025. That compares to just 56 RDNH decisions in 2024, 50 in 2023, and 47 in 2022.
Even when they aren’t finding RDNH, panelists are considering it more often. UDRP.tools found over 200 cases where it was considered in 2025, up from 122 in 2024.
GigaLaw began breaking out RDNH findings starting in Q2 this year. In addition to WIPO and FORUM, it monitors cases from Czech Arbitration Court, Asian Domain Name Dispute Resolution Centre, and Canadian International Internet Dispute Resolution Centre.
It found that 1.3% (20) of cases decided in Q2 (pdf) resulted in RDNH, and 1.2% (26) of cases decided in Q3.
What’s behind the increase in reverse domain name hijacking decisions? I think there are a couple of factors.
First, as good domain names become increasingly more expensive, more companies are turning to UDRP as a last resort when they can’t obtain the domains they want through the market.
Second, Internet Commerce Association (ICA) deserves credit for educating panelists about RDNH and why they should consider it. In addition to organizing UDRP training, ICA publishes a weekly newsletter that features decisions and provides analysis on them (whether transfers were granted, denied, or resulted in RDNH).
I expect RDNH cases to continue to rise, especially as AI tools give pro se Complainants false hope that they can self-file and win baseless cases. In 2025, we started to see more cases in which AI seems to have led Complainants astray.
Despite the rise in RDNH cases, it’s important to note that they make up a small minority of decisions. UDRP generally works well, and nearly all cases are clear-cut cybersquatting cases that result in domain transfers.
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