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WIPO domain disputes › RDNH findings › D2002-0535

D2002-0535: RDNH finding over sfm.com

On 13 September 2002, a WIPO panel declared that Sustainable Forestry Management Limited brought its complaint over sfm.com in bad faith, the finding known as reverse domain name hijacking (RDNH). The complaint was denied, so the registrant kept the name.

The record

WIPO caseD2002-0535
Domain namesfm.com
ComplainantSustainable Forestry Management Limited
Decision date13 September 2002
Outcome (WIPO)Complaint denied with dissenting opinion
How the finding appearsdeclared in the operative decision
PanelistsSmith, Warwick (presiding)
Sorkin, David E.
Willoughby, Tony
PanelThree-member panel
Complainant representedYes
RespondentRepresented by counsel

The panel’s finding

For the foregoing reasons, the Panel�sunanimous decision is that the Complaint is dismissed. The Panel therefore declines to order a transfer of the domain name to the Complainant. In accordance with the views of the majority on the issue of reverse domain name hijacking, the Panel declares that the Complaint has been brought in bad faith and constitutes an abuse of the administrative proceeding.

The panel’s decision, D2002-0535

Quoted exactly from the decision. Read the full decision on WIPO for the reasons.

Read the decision on WIPO · WIPO case record

All RDNH findings · WIPO domain disputes

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How the RDNH archive is built

WIPO publishes every panel decision and a full-text search over them. This archive starts from that search for the wording a panel uses when it declares reverse domain name hijacking, reads each decision in full (older ones are web pages, newer ones PDFs converted to text), and keeps those where the panel itself says the complaint was brought in bad faith. A finding is marked declared in the operative decision when the final order says so, or found in the panel’s reasoning when only the reasoning does.

The reading is automatic and has been checked by hand on samples, but it is not exhaustive and not perfect: some findings may be missing, and a few listed cases may be borderline. A case is listed only when the panel’s own closing words can be quoted cleanly; decisions with an irregular layout, or not written in English, are held back. Every page links to the decision on WIPO, which is the authority. Dates, parties and panellists come from WIPO’s case records. Respondents are not named.

This is an information resource, not legal advice. A finding of RDNH is a panel’s conclusion about one complaint, not a statement about the company beyond that case.