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Recent Case Notes & Commentary

Consent to Transfer

As they are needed by practitioners with what seems to be increasing frequency, we thought it useful for you if we noted another decision where a Panel has ordered transfer of a domain name by consent and without the usual UDRP analysis and without making findings on any of issues arising under the Policy.

The decision is a FORUM decision, Enterprise Holdings, Inc. v. Deepak Jain, Forum Claim Number: FA1912001875688,17 January 2020, and the domain name was <>.

The Panel followed the now well-established approach laid down in decisions such as Boehringer Ingelheim Int’l GmbH v. Modern Ltd. – Cayman Web Dev., FA 133625 (Forum Jan. 9, 2003); Malev Hungarian Airlines, Ltd. v. Vertical Axis Inc., FA 212653 (Forum Jan. 13, 2004) and Disney Enters., Inc. v. Morales, FA ;Forum June 24, 2005).

The decision is-perhaps- noteworthy as it concerns a domain name issued under the .ooo umbrella, as a new TLD based in India. It is .ooo, as in “o” for orange, not triple zero. See

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