On June 30, 2020, the Supreme Court held in U.S. Patent and Trademark Office v. Booking.com B.V. that trademarks paring generic terms with top-level domain names (i.e., BOOKING.COM) are not per se generic. Exactly three months later, at least one UDRP panelist, citing the Supreme Court’s analysis, would have denied a complaint based on complainant’s inability to establish common-law rights in an arguably generic domain name (but the decision ultimately turned on other issues).
