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Moreover, Complainant relies on a discredited legal theory espoused in a few cases between 2009 and 2010 on “retroactive bad faith” which does not, and has never, represented the Consensus view of UDRP Panelists.
Source: https://domainnamewire.com/2023/08/03/pre-made-meal-company-tries-reverse-domain-name-hijacking/
Panelist Steven M. Levy found for the domain name owner on the second and third elements of the UDRP but didn’t consider if this was a case of reverse domain name hijacking.
Source: https://domainnamewire.com/2023/05/24/painless-com-udrp-is-painful/