RDNH Rulings on Pace to Set Record
– Nat Cohen
The first six months of the year saw 36 RDNH findings. If that pace continues there will be over 70 RDNH findings by year end.
There are many different reasons why a panel may determine that a finding of RDNH is justified. Ignoring precedent was cited in twelve of those 36 decisions from the first half of the year.
Misrepresentation was mentioned in nine. The Complaint appeared to be a Plan “B” after commercial negotiations failed was cited in 13 of the decisions.
That the Complainant was represented by counsel was cited as a contributing reason for finding RDNH in 13 of the decisions.
That the allegations were not supported by evidence is provided as a contributing reason for finding RDNH in twelve of the decisions.
Not surprisingly, the most frequently cited reason for making a finding of RDNH was that the Complaint did not include evidence of bad faith targeting of the complainant, which was cited in 17 of the decisions.
Most of the decisions cite more than one of the above reasons, with some decisions providing up to six separate contributing factors justifying a finding of RDNH.
As best as I can determine, the number of RDNH findings per year in prior years are:
2024 – 58
2023 – 50
2022 – 50
2021 – 48
2020 – 37
2019 – 33
2018 – 45
2017 – 45
2016 – 37
2015 – 31
2014 – 25
2013 – 26
2012 – 16
2011 – 14
2010 – 14
2009 – 15
2008 – 18
2007 – 10
2006 – 10
2005 – 8
2004 – 9
2003 – 5
2002 – 23
2001 – 17
2000 – 6
Possible explanations for why the number of RDNH findings are increasing include:
- the number of UDRP disputes as a whole has increased;
- abusive complaints are becoming more commonplace;
- the jurisprudence has become better established such that what is an appropriate vs an abusive complaint is now clearer;
- panels are increasingly impatient with and less willing to tolerate shoddy and abusive complaints;
- panels increasingly recognize that the UDRP imposes an affirmative duty on them to consider and make a finding of RDNH when warranted;
- panels recognize that protecting the integrity and credibility of the UDRP requires calling out abusive complaints when they occur.
Doug Isenberg recently alerted me that his Quarterly Digest is now covering RDNH decisions (https://giga.law/blog/2025/7/25/udrp-digest). He is able to source the information directly from the providers and to offer an authoritative listing of each quarter’s RDNH decisions. Thanks to Doug for gathering data on recent RDNH decisions and for sharing it with the community.
About the Author:
Nat Cohen is an accomplished domain name investor, UDRP expert, proprietor of UDRP.tools and RDNH.com, and a long-time Director of the ICA.