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In Memoriam:

I have hesitated in writing this memorial for <> because I did not want to announce a demise that may not be true, or the fear that my saying it will make it so. The website went dark for a short period in 2017, before being restored after a brief shutdown, and (I thought) it could happen again. I was waiting for history to repeat itself. But, the website remains dark, without explanation, and I fear it will not return. We lost it on or about January 6, 2018. I did not record when <> first appeared, but my guess is somewhere around 2010 or 2012. It has been an invaluable research tool for the reason that it made basic information accessible across providers so that if I wanted to find cases that contained a certain word (“denied” or “credible” for example) it brought me all of them.

For his having created and maintained <> I thank you Dave Lahoti (Virtual Point), and I am sure the domain name and trademark community and those following the development of domain name jurisprudence (including innocent research drudges) thank you also for your generosity in providing and maintaining the database for so many years. Its loss is (will be) lamented by all! (This is not an obituary of Mr. Lahoti who is very much alive, and for whom I wish many more years of entrepreneurial success).

<> is not the only research tool to publish domain name decisions. Paragraph 4(j) of the Uniform Domain Name Dispute Resolution Policy (Policy) mandates in part that “All decisions under this Policy will be published in full over the Internet.”  Also, Rule 16(b) of the Rules of the Policy states that “the Provider shall publish the full decision and the date of its implementation on a publicly accessible web site.” Each of the providers maintains a search functionality for decisions filed by their Panels, all free as mandated (not equally good, incidentally), but until the fatal day only <> captured decisions from all the providers in a consolidated database. (ICANN had tried such a consolidation (I remember) but abandoned it.) The home page now resolves to a page that proclaims “Think Outside the Dot,” which is all very well, but not so wonderful if you want to think Within the Dot. In its plain-vanilla way, it was the best of all and I mourn its demise.

The reader may ask, why lament something that is only “plain-vanilla”? The answer lies partly in Mr. Lahoti’s genius for simply collecting information and in other part also in his modest goals. <> is (was) simply a collection of information, awake all the time, receiving and announcing new cases and new decisions (UDRP and URS), providing in column form domain names “transferred,” “denied,” or “withdrawn,” and who won and who lost. All very basic; very simple. And just like the myth of Earth ultimately resting on firm ground with a column of “turtles all the way down” <> comprehended the present, the intermediate, and the remote past (all the way down to the first decided case), and not just from providers that are still with us. It was a database of decisions without discrimination of their sources. It had a search field that was primitive (searching for one word!) but adequate.

We will only see its light again if a patron steps forward. There are, of course, a number of subscription domain name search resources but they are not really within reach of small investors and advisors. A recent free service collects only WIPO decisions (, but is useful because it provides a statistical breakdown of information. There is also a service that collects reverse domain name hijacking cases, Reverse Domain Name Hijacking Information. On top of this there are the highly valuable blog postings from a number of investor/writers that keep the community informed, but these complemented rather than replace <>.

What we have by way of databases are the following:

WIPO Decisions by Year, also a robust search function WIPO Search Decisions.
—  Forum (formerly National Arbitration Forum) Decisions.
—  eResolution Decisions.
Arbitration Center for “.eu” Decisions—ADReu.
ADNRC-Asian Domain Name Dispute Resolution Centre

Both WIPO and Forum have email subscription services for those who demand daily doses of decisions. The provider eResolution demised many years ago, but its database lives as indicated above. ADReu and ADNRC do not appear to have email subscription services.

What I could once find in one library I now have to rummage in many. I am putting my request for a simple database consolidating all decisions, nothing fancy, with a search function, in my wish box.  Who will take the baton from Mr. Lahoti?

Mr. Levine is the author of a treatise on trademarks, domain names, and cybersquatting, Domain Name Arbitration, A Practical Guide to Asserting and Defending Claims of Cybersquatting under the Uniform Domain Name Dispute Resolution Policy. (Legal Corner Press, 2015). Learn more about the book at Legal Corner Press. Available from Amazon and Barnes & Noble. Supplement and Update through August 2016 published January 2017. A Second Edition of the treatise is scheduled for publication August/September 2018. If you purchased the First Edition, you can buy the Second Edition 50% off list price by contacting or


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