UDRP decision shows difficulty to prove bad faith when domain name is common dictionary word

In a recent decision under the UDRP, a three-member panel has denied the transfer of a domain name because it consisted of a Spanish dictionary word and there was insufficient evidence that it had been registered and used in bad faith. The decision highlights the fact that it can be extremely difficult to prove that a respondent was targeting a particular trademark owner when a domain name is a common dictionary word.