UDRP Panel Concludes Planet Harvest Tried Reverse Domain Name Hijacking

The domain name was registered more than two decades before the company had any trademark rights.

A dispute over the domain planetharvest.com ended with a panelist finding that produce company Planet Harvest, LLC attempted reverse domain name hijacking. The company operates at a different web address using a hyphenated domain, planet-harvest.com.

The disputed domain was originally registered in 1999 by Vance More and later transferred to his company, MV3 Inc. Because Planet Harvest only began using its name in 2023, the panel concluded that the domain was registered long before the company held any trademark or common-law rights in the name. As a result, the complainant could not reasonably prove that the domain was registered in bad faith to target its mark.

Before filing the formal dispute, Planet Harvest tried to buy the domain. The company offered $2,201, and the registrant responded with a counteroffer of $100,000. After negotiations stalled over price, Planet Harvest initiated the administrative complaint. The panel characterized this sequence as a classic example of a “Plan B” strategy: seeking to obtain a domain through the UDRP only after private purchase efforts failed.

Nicholas J.T. Smith, the panelist hearing the case, identified several key reasons for concluding that the complaint amounted to reverse domain name hijacking. Chief among them was the timing: the domain registration date predates any use or rights claimed by Planet Harvest by more than twenty years. Given that chronology, the panel found it implausible that the registrant had targeted a mark that did not yet exist.

The panel also criticized arguments advanced by the complainant despite legal representation. One such argument treated a domain renewal as if it were a fresh registration, a theory the panel found legally unsupported. The combination of weak legal theories and the clear timeline strongly suggested the complaint lacked merit.

In addition to the timing and legal reasoning, the panel looked at the complainant’s conduct. The attempt to acquire the domain through negotiation and then switch to an administrative complaint after rejecting the owner’s price reinforced the view that the complaint was an afterthought driven by dissatisfaction with the asking price rather than a legitimate claim of bad-faith registration.

The dispute was brought by Planet Harvest and represented by counsel from Saturday Legal, LLC. The respondent, the domain owner, represented himself. With the respondent’s long-standing ownership and the complainant’s late adoption of the name, the panel found that the complaint failed on the threshold elements necessary to establish bad faith registration and use.

As a result of these findings, the panel concluded that the filing qualified as reverse domain name hijacking. That determination carries professional and reputational consequences for complainants and their counsel, signaling that bringing an administrative claim should be based on sound legal grounds and credible facts rather than as leverage after failed purchase negotiations.

This decision serves as a reminder to trademark owners and their legal advisers to carefully assess registration dates, prior use, and the overall factual record before initiating domain disputes. When a domain has existed for many years and a complainant’s rights are recent, the likelihood that a claim will succeed is diminished, and the risk of a reverse domain name hijacking finding increases.