Resolution Policy (UDRP). The UDRP allows a trademark owner to challenge domain name registrations in expedited administrative proceedings. A UDRP proceeding can be faster and cheaper for trademark owners than an ACPA lawsuit. Also, UDRP outcomes tend to be pro-plaintiff because many UDRP arbitrators are trademark lawyers. However, some trademark owners prefer to bring ACPA claims because they offer more remedies than the cancellation or transfer of the domain name (the only remedies available under UDRP proceedings) and a court ruling can lead to a final resolution of the matter. Also, a suit under the ACPA may deter future cybersquatters more effectively than a UDRP proceeding. Domaining and the ACPA While the ACPA contemplated the purchase of domain names for resale to trademark owners, it did not contemplate the more modern practice of domaining. Domaining is the business of registering a domain name and parking it or placing pay-per-click ads on it. Domainers rely on type-in traffic, which is when Internet surfers type in the domain name rather than using a search engine. Domainers can make a lot of money by buying and selling domain names. Some domainers relied on domain tasting, which involves placing pay-per-click ads on the domain for five days (or less) to determine whether the ads will make more than the annual cost of the domain. If the domain is dropped within the five-day grace period, no fee is incurred. An industry has grown up out of this business with domainers taking part in these mass registrations. This practice was largely eliminated by 2009, when ICANN began raising fees to registrars with excessive domain tasting. In Verizon California, Inc. v. Navigation Catalyst Systems, 568 F. Supp. 2d 1088 (C.D. Cal. 2008), the domainer lost under the ACPA. One of the defendants, Basic Fusion, Inc. argued that they were not cybersquatters, but as an Internet registrar accredited by ICANN they could register domain names on behalf of its customers and it specialized in "bulk registration". Navigation Catalyst Systems, another defendant and a customer of Basic Fusion, used their "proprietary automated tool" to find domain names that were not already registered and then registered them using Basic Fusion. Navigation used the five days following the registration (the "advertisement grace period") to put advertisements on the websites making money from the advertisements even when they dropped the domain name registration before the five-day window closed. Plaintiff Verizon argued that