Domain Name News: October 2025

• Domain name industry news
  • British territories ride wave of tech boom
  • Continued growth for global domains in Q3 2025
  • EURid publishes Q3 2025 Quarterly Update
• Domain name recuperation news
  • Complainant fails to magic up a transfer
  • If you fake it you won’t make it under the UDRP
  • Domain Name Disputes and Business Breakdowns:Lessons from Pioneer Recovery Center

For earlier Anchovy News publications, please visit our Domain Names practice page. Learn more about Anchovy® - Global Domain Name and Internet Governance here.

Domain name industry news

British territories ride wave of tech boom

Anguilla, a British Overseas Territory in the Eastern Caribbean and home to around just 16,000 people, has struck digital gold of late with its .AI extension, bringing in US$62 million in revenue in just the first three quarters of 2025 from .AI domain name registrations.  The year prior to that, the British Indian Ocean Territory, an archipelago comprised of seven atolls and over 1,000 individual islands, the sovereignty of which is currently in the process of being handed over by the British government to Mauritius, saw sales of its .IO domain names increase by 6.7%, mainly due to the association of the extension with the world of information technology.

Both .AI and .IO have profited from the serendipitous alignment of their extensions with the current Artificial Intelligence (AI)-driven tech boom – the former due to its reflection of the acronym for Artificial Intelligence, and the latter due to the semantic appeal of the abbreviation “I/O” (input/output), a term that describes the way computers and other information systems communicate with the world and which resonates with IT platforms, startups and developers.  

.AI domain name registrations have surged from 48,000 in 2018 to around 880,000 in September 2025.  In 2023, the Anguillan government, which receives a fee for every .AI domain name registered, generated roughly US$32 million from .AI domain name registrations, a figure that made up nearly 20% of the island’s total government revenue.  By 2024, that figure had jumped to about US$39 million, accounting for around one-quarter of Anguilla’s annual income.

Anguilla’s Premier, Ellis Webster, has stated that revenue from the .AI boom will be used to finance the island’s airport expansion, to subsidise free medical care for senior citizens, to enable the completion of a vocational technology training centre at Anguilla's high school, and to put in place hurricane-resilient infrastructure, including secure domain-hosting facilities.

With .AI domain name renewal rates hovering at around 90% and government projections showing that .AI domain name revenues will reach approximately US$49 million in 2025 and nearly US$51 million by 2026, the future looks bright for Anguilla.

The British Indian Ocean Territory (BIOT) is a British Overseas Territory established in 1965, comprising a group of islands in the central Indian Ocean.  The territory was created when the UK separated the islands from Mauritius and the Seychelles in order to establish a U.S. military base on the atoll Diego Garcia.

Although BIOT has no official permanent residents (only temporary US military personnel and UK government officials), the .IO domain name extension was delegated by the Internet Assigned Numbers Authority (IANA) to the British government as the country-code Top-Level Domain (ccTLD) for BIOT in 1997.  Over the last decade, the .IO Registry has re-branded itself as a tech-friendly global TLD and, indeed, the extension is treated as a generic Top-Level Domain by many search engines, compounding its popularity.

.IO domain name registrations grew from approximately 660,000 in 2021 to over 1.6 million by 2025 with the UK-based Registry, Internet Computer Bureau, last month reporting revenue for 2024 of £31.6 million ($42.4 million), up from £29.6 million ($39.7 million) in 2023.  Revenue has grown a whopping 93% since 2021, with a sharp surge in 2022 (around 59% year-on-year) and steady growth ever since.

It's not all plain sailing for the .IO TLD, though.  The future of the extension is somewhat uncertain due to the ongoing sovereignty questions concerning BIOT, which is in the process of being handed over by the British to Mauritius. Uncertainty over whether the transfer of control could lead to changes in the administration of the .IO Registry, or even the complete retirement of the TLD, has sparked concerns among investors, tech companies, and domain registrants.  For the time being, however, reassurances of a long lead-in time for any such changes appear to be mitigating any such fears and failing to dampen enthusiasm for the TLD.  Nevertheless, registrants should bear in mind that there are inherent risks attached to the .IO extension and they should have an adequate back-up plan in place.

For more information on the registration of .AI and .IO domain names, please contact David Taylor or Jane Seager.

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Continued growth for global domains in Q3 2025

The Domain Name Industry Brief (DNIB) recently released its Quarterly Report for Q3 2025 highlighting continued global growth.

According to the DNIB Report, there were 378.5 million domain names across all Top Level Domains (TLDs) at the close of Q3 2025, which marks an increase of 6.8 million domain name registrations, or 1.8%, compared to the previous quarter.  Year on year, domain name registrations grew by 4.5%, representing 16.2 million domain names, which reflects a continued upward trend in the domain name industry.

Despite the rise of newer, more niche generic Top Level Domains (gTLDs), .COM still accounts for the largest share of the domain name market due to its established recognition with 159.4 million domain names, up by 2.7 million or 1.8% year on year.  The second most popular gTLD, .NET, is however still on a downward trend with 12.5 million domain names, which is 100,000 domain names less quarter on quarter, and 400,000 less year on year.  The Report indicates that the estimated combined renewal rate for .COM and .NET is 75.3%.  As for the other legacy gTLDs (such as .ORG, .BIZ, .INFO, etc.), they totalled 18.9 million at the end of Q3 2025, a significant increase of 9.3% year on year.  Their most recent estimated combined renewal rate is 82.5%.

Turning to new gTLDs, their number has surged to 42.9 million domain names at the end of Q3 2025, a sharp increase of 8.5% (or 3.4 million domain names) quarter on quarter, and an even more impressive increase of 21% year on year (or 7.5 million domain names).  New gTLDs such as .XYZ, .TOP, .SHOP and .ONLINE are finding interest with startups, creatives and new brands seeking alternatives to the main generic extensions .COM, .NET and .ORG. 

However, it must be noted that although the number of new gTLDs shows very impressive growth, their most recent estimated combined renewal rate is only 32.2%, which is much lower than that of legacy gTLDs.  For example, .XYZ, despite being among the ten largest TLDs globally, with 5.9 million domain names at the end of Q3 2025 according to the Report, had a poor quarterly renewal rate of only 19.5%.  .SHOP (3.5 million domain names) is even lower at 12.2% and .SITE (1.6 million) is at 19.1%.  These figures suggest that many domain name registrations under the new gTLDs are speculative, short-term, or marketing driven but rarely maintained long-term.

As regards country code Top Level Domains (ccTLDs), domain name registrations continue to grow steadily and, at the end of Q3 2025, there were 144.8 million ccTLD domain names, representing a 3.4% increase year on year, or 4.8 million domain names.  The largest ccTLDs are still .CN (China) with 21 million domain names at the end of Q3 2025, .DE (Germany) with 17.6 million, and .UK (United Kingdom) with 10.2 million.  This shows that many businesses and individuals still prefer to register domain names under their own country’s ccTLD, for various reasons such as local visibility, trust, security or availability.

Finally, the Report shows that the 10 largest TLDs (of any type) by number of reported domain names are .COM, .CN (China), .DE (Germany), .NET, .ORG, .UK (United Kingdom), .RU (Russia), .NL (Netherlands), .XYZ and .BR (Brazil).

For more information or to register domain names under any TLD, please contact David Taylor or Jane Seager.

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EURid publishes Q3 2025 Quarterly Update

EURid, the Registry responsible for running the .EU country-code Top-Level Domain (ccTLD) for the European Union, has recently published its Quarterly Report for Q3 2025.  The report highlights EURid’s achievements and strategic advancements over the third quarter of 2025.

In Q3 2025, approximately 214,000 new .EU domain names were registered, representing a 17.8% increase from Q2 2025 (over 181,500 new registrations) and a 25.7% increase year-over-year from Q3 2024 (over 170,000 new registrations).  Despite the competitive nature of the global domain name market, .EU has maintained its standing in the top ten largest ccTLDs as per the latest Domain Name Industry Brief, reflecting the continued importance of .EU in the global domain name space. Indeed .EU continues to be a preferred choice for businesses and individuals seeking a European digital identity, particularly as the demand for secure, trusted domain names rises globally.

The Quarterly Report also highlights EURid's continued mission to ensure that the Internet remains accessible and inclusive by promoting multilingualism through Internationalised Domain Names (IDNs).  Despite advances in technology and policy, the adoption of IDNs has remained slow.  In this respect, the Quarterly Report also points to the latest IDN Market Report, which notes that only ten TLDs account for the vast majority (approximately 75%) of all IDNs globally, the top five by IDN registrations being .РФ (approximately 761,000 IDNs), .COM (754,000), .DE (637,000), .CN (537,000) and .中国 (185,000).  The Quarterly Report highlights EURid’s ongoing work to promote IDNs, including advocating for IDN adoption both within Europe and globally.  By offering support for multiple scripts and languages, EURid aims to make the Internet more inclusive for non-Latin script users.

As online threats become more complex, particularly with the rise of artificial intelligence and deepfake technologies, EURid has also enhanced its security protocols to protect the integrity of the .EU domain name space.  EURid believes that measures such as its Abuse Prevention and Early Warning System (APEWS) not only help keep the .EU domain name space safe and secure, but also uphold its “core values of transparency and accountability”.

For more information on .EU, please contact David Taylor or Jane Seager.

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Domain name recuperation news

Complainant fails to magic up a transfer

In a recent decision under the Uniform Domain Name Dispute Resolution Policy (UDRP or the Policy) before the World Intellectual Property Organization (WIPO), a Panel denied a UDRP Complaint brought in relation to the disputed Domain Name <magicmen.com> (the "Domain Name") due to the absence of evidence that the Respondent registered and used the disputed Domain Name in bad faith.  A key factor leading to this decision was the Panel's finding that the Respondent's registration of the Domain Name predated the Complainant's trade mark rights by over ten years.

The Complainant, Magic Men Holdings Pty Ltd, was an Australian-based company and the owner of the trade mark MAGIC MEN in Australia, registered in 2014, although having effect from the date of filing in 2013.  It provided no evidence as to its business activity. 

The Respondent was an individual based in the United States who claimed to have registered the Domain Name in April 2002 in connection with a personal magic hobby, with a view to using it for a website that would promote a small amateur magic act. The Respondent provided what the Panel deemed to be "a remarkable collection of evidence regarding its involvement in the magic hobby from the late 1990s", including a photograph of three magic newsletters and a receipt from a magic supplies shop.

The disputed Domain Name was registered on 2 April 2002. There was no evidence of it ever having resolved to an active website.

Before filing the Complaint on 6 August 2025, the Complainant attempted to purchase the Domain Name via a domain name broker, on or around 24 July 2025.  The Respondent did not reply.

To succeed under the UDRP, a complainant must satisfy the requirements of paragraph 4(a) of the Policy:

1. The disputed domain name is identical or confusingly similar to a trade mark or service mark in which the complainant has rights;
2. The respondent has no rights or legitimate interests in respect of the disputed domain name;and
3. The disputed domain name was registered and is being used in bad faith.

The Complainant argued that the disputed Domain Name was identical to its trade mark.  The Complainant further contended that the Domain Name was registered after the registration of its trade mark and that it was passively held by the Respondent, notably for the purpose of selling, renting or transferring it for valuable consideration.  According to the Complainant, such passive holding had previously been recognized as bad faith under the UDRP.  In its supplemental filings, the Complainant further insisted that the absence of archived website content, coupled with the lack of evidence of an alleged magic act, did not amount to a bona fide offering of goods and services.  The Complainant also asserted, without evidence, that its trade mark was distinctive and had acquired a reputation in the entertainment industry.

The Respondent argued that it had owned the Domain Name continuously since its registration on 6 April 2002, and that it did so with a view to creating a website to promote performances of a small amateur magic act it shared with a friend.  The Respondent further submitted that the Complainant's business was incorporated many years after the registration of the Domain Name, making it impossible for the Respondent to have registered the Domain Name to target the Complainant's business.  Additionally, the Respondent provided dated proof of its personal involvement in magic as a hobby to justify its choice of words in the Domain Name. 

As far as the first element was concerned, the Panel agreed that the Complainant had established rights in the trade mark MAGIC MEN, and found that the Domain Name <magicmen.com> was identical to the Complainant's trade mark.  The Complainant therefore satisfied the requirements of paragraph 4(a)(i) of the Policy.  The Panel noted that the first element of the Policy does not require a complainant's trade mark rights to predate the registration of the domain name, although this may be relevant under the second and third elements.

The Panel declined to make a finding under the second element, due to its findings under the third element.

In relation to the third element, the Panel accepted the evidence provided by the Respondent documenting its longstanding interest in magic and its argument that it registered the Domain Name in pursuit of that same hobby.  The Panel was satisfied on the evidence that it was reasonable to infer that the Domain Name was registered by the Respondent in 2002, insofar as the Complainant had failed to provide any evidence to the contrary, i.e., third-party use or historic WhoIs entries.  In the Panel's view, the Complainant's trade mark rights postdated the registration of the Domain Name and there were no exceptional circumstances in the present case relating to domain names having been registered in anticipation of trade mark rights.  In view of the lack of bad faith registration, the question of bad faith use was moot, given the conjunctive requirement of bad faith registration and use under the UDRP.

However for the sake of completeness, the Panel also dismissed the Complainant's argument that the Domain Name was used in bad faith under the doctrine of passive holding, given the lack of evidence provided by the Complainant as to the degree of distinctiveness or reputation of its trade mark and in light of the submission of the Response by the Respondent.  The Panel further found that the Respondent's contemplated good faith use of the Domain Name was entirely plausible.  The Complaint was therefore denied. 

Finally, based on its previous findings, the Panel found that the Complaint was brought in an attempt at "Reverse Domain Name Hijacking" (RDNH), defined as "using the UDRP in bad faith to attempt to deprive a registered domain-name holder of a domain name."  The Panel found that the Complainant knew or should have known that it could not succeed under the UDRP as the Respondent could not have anticipated the Complainant's rights when registering the Domain Name in 2002, long before the Complainant was established.  The Panel concluded that such a case should never have been brought under the Policy and acknowledged the difficulties the Respondent likely faced in collecting evidence from the late 1990s.

Comment:

This case highlights that timing matters.  Seeking to establish that a disputed domain name was registered in bad faith by relying on trade mark rights accrued long after the registration of the domain name and when the complainant itself was established long after the registration of the disputed domain name is rarely likely to succeed under the UDRP.  Finally, it is worth noting that passive holding of a domain name does not inherently constitute bad faith, in particular in the absence of clear evidence of reputation;  conclusory allegations are not sufficient.

The full decision is available here.

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If you fake it you won’t make it under the UDRP

In a recent decision under the Uniform Domain Name Dispute Resolution Policy (the UDRP or the Policy) before the World Intellectual Property Organization (WIPO), a Panel denied the transfer of the domain name <chafezero.com>, finding that the Complainants had failed to establish trade mark rights under the first element of the Policy.  The Panel made a clear finding of Reverse Domain Name Hijacking (RDNH), citing the submission of forged evidence as an abuse of the UDRP process.

The Complainants were AK Associates LLC, a US-based company, and its registered agent.  The Respondent, an individual based in Australia, registered the domain name <chafezero.com> in April 2025.  The domain name resolved only to a registrar landing page.

The Complainants alleged that they had sourced raw materials for CHAFEZERO-branded products since 2024 and that the Respondent’s refusal to sell the domain name for USD 200, coupled with its parking status, demonstrated bad faith.  To support their claim, they submitted what purported to be (i) a U.S. trade mark registration certificate stating that the mark CHAFEZERO had been registered on 29 July 2025, (ii) an advisory notice to the Respondent from the United States Patent and Trademark Office (“USPTO”) notifying the Respondent of the Complainant’s trade mark rights, and (iii) an email from a USPTO examiner purporting to grant the Complainant permission to use the trade mark in Australia.

The Respondent countered that the Complainants’ trade mark applications post-dated his domain name registration, that he registered the domain name in connection with new skincare products for his company, and that the Complainants only turned to the UDRP after a failed attempt to purchase the domain name.  He requested a finding of RDNH.

To succeed under the UDRP, a complainant must satisfy the requirements of paragraph 4(a) of the Policy:

1. The disputed domain name is identical or confusingly similar to a trade mark or service mark in which the complainant has rights;
2. The respondent has no rights or legitimate interests in respect of the disputed domain name;and
3. The disputed domain name was registered and is being used in bad faith.

On the first limb, the Panel found that the Complainants had no registered trade mark rights.  Their applications were pending, and under the Policy, trade mark applications do not confer enforceable rights.  The Panel further determined that the documents submitted were forgeries.  It was clear from an examination of the relevant USPTO records that the Complainants had not obtained a United States trade mark registration on 29 July 2025, the day after their application was filed, and their application was still awaiting examination as of the latest available status report.  Furthermore, to the knowledge of the Panel, it was not the practice of the USPTO to send out “advisory” communications to third parties, nor to “permit” the registrant of a United States trade mark to use that mark in Australia (or any other foreign jurisdiction), and nor would it have any jurisdiction to do so.

In addition, the Complainants had provided no evidence of unregistered or common law rights in CHAFEZERO.  As such, the Panel held that the Complainants had failed at the first hurdle, and the Complaint necessarily failed.

While it was unnecessary to assess the second and third elements, the Panel observed that it would have been impossible for the Complainants to establish bad faith, since there was no evidence that the Respondent was aware of the Complainants’ claimed mark prior to registering the domain name.

The Panel then addressed RDNH.  It found the case particularly egregious: not only had the Complainants first attempted to buy the domain name and then resorted to the UDRP when unsuccessful, but they had also relied on forged documents purporting to emanate from the USPTO.  The Panel described this as a deliberate attempt to pervert the UDRP process and underlined the Complainant’s false certification that the Complaint was complete and accurate.

The Panel concluded by denying the Complaint and declaring that it had been brought in bad faith, amounting to one of the most serious cases of RDNH encountered.

This decision underscores the fundamental requirement of honesty and transparency in UDRP proceedings, and demonstrates that UDRP Panels are rigorous in their examination of parties’ submissions and will not be deceived by false evidence.

The decision is available here.

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Domain Name Disputes and Business Breakdowns:  Lessons from Pioneer Recovery Center

In a recent decision under the Uniform Domain Name Dispute Resolution Policy ("UDRP") before the World Intellectual Property Organization ("WIPO"), a panel denied a Complaint regarding the disputed domain name <pioneerrecoverycenter.com.com> (the "Domain Name"), finding that the Complainant had failed to demonstrate bad faith registration and use of the Domain Name. 

The Complaint was filed by an individual in her capacity as the founder and CEO of Pioneer Recovery Center, LLC, The Complainant was a licensed alcohol and drug counsellor based in Minnesota, United States.  Pioneer Recovery Center, LLC was a company established under the laws of Minnesota on 4 September 2007, and duly licensed since 20 February 2009, to operate a treatment facility for those afflicted by substance use disorders in Cloquet, Minnesota.

The Complainant, together with her company, claimed common law rights in the name "PIONEER RECOVERY CENTER", having used it continuously since 2009.  The Complainant did not hold any registered trademarks;  however, the Complainant produced evidence of her business's existence and reputation in the form of licenses, registrations, brochures, and correspondence with marketing professionals dating back to 2013.

The Domain Name was registered on 27 April 2008, and was held by the Respondent, an individual based in Georgia, United States, and associated with Dino's Digital, a marketing firm located in New York City.

The Domain Name resolved to a website advertising the Complainant's services, with content and descriptions closely mirroring those of the Complainant's own website.  Historical screen captures of the website indicated that the Domain Name was once used for a different treatment center, but from 2013 onwards, it advertised the Complainant's services.

The relationship between the Parties is not fully explained.  The Complainant asserted that the Respondent acquired or retained the Domain Name with knowledge of her rights.  The Respondent contended that he had invested in the Complainant's struggling business, assuming responsibility for the website and email list, and that the transfer of the Domain Name and associated Squarespace account to his control was done with the Complainant's knowledge and cooperation, as evidenced by correspondence between the Parties in September 2024.

In October 2024, the Complainant sought the return of the Domain Name, wishing to regain control and launch a new website.  Her requests, repeated through December 2024, were met with requests from the Respondent for payment of approximately USD 50,000 for website development, search engine optimization, staff training, and other business expenses, as well as references to legal and accounting costs.

The website at the Domain Name had remained unchanged since June 2024, under the Respondent's control.  Meanwhile, The Complainant registered a new domain name, <pioneerrecoverycenter.net>, and now operates her website independently.

To succeed under the UDRP, a complainant must satisfy the requirements of paragraph 4(a) of the Policy:

1. The disputed domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights;
2. The respondent has no rights or legitimate interests in respect of the disputed domain name;and
3. The disputed domain name was registered and is being used in bad faith.

Identity or confusing similarity 

In this case, the Panel was satisfied that the Complainant had established rights in an unregistered service mark.  The name "PIONEER RECOVERY CENTER" was found to be more than a simple description of place or service;  it served as a distinctive identifier under which the Complainant had operated for 18 years, providing state-licensed, professional services.  The evidence, comprising brochures, signage, a website active since at least 2013, and references to community events, demonstrated that the mark had achieved recognition within its local market.

The Domain Name incorporated the Complainant's mark in its entirety and was found to be confusingly similar to the mark.  The Complainant therefore satisfied the requirements of the first element of the Policy.

Rights or legitimate interests

The Respondent asserted a bona fide use of the Domain Name before any dispute arose.  However, the Domain Name had been used solely to advertise the Complainant's services, not the Respondent's.  The question of legitimate interest was considered by the Panel to be inseparable from the issue of bad faith, particularly given the initial consent of the Complainant.  These matters were therefore addressed together in the context of bad faith under the third element.

Bad faith

In this case, it was clear that the Respondent knew of the Complainant's name, which had acquired distinctiveness as a common law mark.  The Parties agreed that the Respondent provided services, paid expenses, and discussed a possible investment or acquisition of the Complainant's business.  The Complainant had voluntarily transferred control of the Domain Name to the Respondent for marketing purposes, intending for the arrangement to be temporary.  When the Complainant later requested the return of the Domain Name, the Respondent retained it, claiming it as security for unreimbursed expenses after the business sale did not proceed.

The Panel found that the facts did not fit the usual examples of bad faith under the Policy.  There was no evidence of cybersquatting, diversion for commercial gain, or competitive disruption.  The transfer occurred without a written agreement regarding ownership or addressing the return of the Domain Name in the event that negotiations were to fail.  The Panel considered that the Complainant was unable to prove that the Respondent had acted in bad faith from the outset, as required under paragraph 4(a)(iii) of the Policy.  Accordingly, the Panel found that the third element of the Policy was not established and the Complaint was therefore denied.

The Panel observed that its Decision rested solely upon the evidence before it.  It further noted that, in exceptional cases, where there are significant legal developments or new evidence that could not reasonably have been produced earlier, a panel may, in its discretion, permit a Complaint to be refiled.

Comment:

This case brings the scope of the UDRP into sharp relief. 

As set out in the decision, when parties engage in a commercial venture involving valuable digital assets such as domain names, it is important that their respective rights and obligations are clearly documented in writing.  Without such an agreement, as this case demonstrates, there is a significant risk of uncertainty and dispute. 

Moreover, the UDRP has a defined scope.  It is not intended to resolve all commercial disagreements or failed business relationships.  Its primary function is to address clear cases of cybersquatting and trademark abuse, rather than to settle complex contractual or investment disputes.

The assessment of legitimate interests and good faith requires consideration of the full context, including the parties' prior dealings, any consent given, and the circumstances surrounding the transfer or use of the domain name.

Finally, not every domain name dispute amounts to cybersquatting.  Where the core issue is a commercial disagreement, the appropriate forum may be the courts or arbitration, rather than the UDRP.

The full decision is available here.

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Authored by the Anchovy News team.

Anchovy News editorial team:

• Laëtitia Arrault
• Sean Kelly
• Ying Lou
• Cindy Mikul
• Eliza Parr
• Thomas Raudkivi
• Jane Seager
• David Taylor
• Tony Vitali
• Grace Wilshaw

Anchovy® - Global Domain Name and Internet Governance

Hogan Lovells offers a unique, comprehensive and centralised Paris-based online brand protection service called Anchovy® for global domain name strategy, portfolio management and global enforcement.  We are the only law firm to be an ICANN-accredited registrar and we are accredited with a number of country-specific Registries worldwide. 

We also specialise in all aspects of ICANN’s new generic Top Level Domain (gTLD) process and we are an agent for the Trademark Clearinghouse.  As the global Domain Name System undergoes an unprecedented expansion, brand owners must revise their online protection strategies and we are ideally placed to guide them.

We are also frequently brought in to advise on cybersecurity, data protection and on a whole range of technology-related issues.

For more information on our services, please contact David Taylor or Jane Seager.