business days to prevent a registrar from transferring the domain name in the relevant jurisdiction (either the location of the registrar’s principal office or the registrant’s location). Examples The UDRP process has already been used in a number of well-known cases. For example, in the Madonna Ciccone, p/k/a Madonna v. Dan Parisi and « Madonna.com » case, the panel found against the defendant registrant based on all three of the above factors and ordered the domain name turned over to Madonna. In the Wal-Mart Stores, Inc. v. Richard MacLeod d/b/a For Sale case, the decision describes the practice of cybersquatting. The UDRP was adopted to prevent such behavior where a domain name registrant tries to extort money from trademark owners. In this case, the expert found that the evidence showed the registrant was not using the domain name “wal-martsucks.com” for a criticism site but instead try to get a payout from Walmart. The Oki Data Americas, Inc. v. ASD, Inc. case is one of the most cited "fair use" decisions under the UDRP, it raises the question of whether an authorized (and non-authorized) sales or service agent of trademarked goods can use the trademark in a domain name. The Commissioners for HM Revenue and Customs v. Adil Khasanov case provides an example of the impact of the Covid-19 crisis in the Domain Name System, and the increasing number of fraudulent domain name registrations. Often there is contention over similar but not identical domain names, in which the offended party files a court action claiming trademark or copyright infringement. For example, actor Robert De Niro has claimed ownership of all domain names incorporating the text "Tribeca" for domain names with any content related to film festivals. In particular, he has a dispute with the owner of the website http://tribeca.net. Domain name disputes under new generic top-level domains In 2012, ICANN launched a process to create new generic top-level domains (gTLDs). Over 1,900 applications were made. As part of the expansion of the domain name system, ICANN introduced a number of new brand protection mechanisms. Opinions differ as to whether or not these new processes will be effective. Industry commentators predict that the UDRP will continue to be used, and that there will be a "substantial increase in cybersquatting". Evidence from previous expansions of the namespace, however, indicates the continued dominance of .com both in size and as the first-choice domain for