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• UDRPcommentaries (Gerald M. Levine) 08:10 am 22-Apr-2017 The Fine Art of Losing a UDRP proceeding Jireh Industries Ltd. v. DVLPMNT MARKETING, INC. / Domain Administrator, FA1703001719671 (Forum April 14, 2017) () Complainant alleging common law rights dating back to 1983 denied standing because it “failed to provide any evidence of the kind that would satisfy its burden of proving common law rights.” The Panel continues: “Complainant’s evidence is limited merely to the statements that it has been using its JIREH mark initially on food processing equipment and later on oilfield equipment since 1983 and on nondestructive testing equipment for industrial applications since 2002.” The lesson: “Such assertions alone, without facts to support a claim of common law rights, are insufficient to satisfy the requirements of the Policy.” (See also Zeca S.p.A. v. Whois Privacy Protection Service, Inc. / Domain Vault LLC, D2017-0158 (WIPO April 3, 2017) (, generic personal name, geographic location in Portugal, has a musical association. Complainant located in Italy, Respondent in the U.S.)