Strict interpretation of UDRP rules

Many panels had an extensive interpretation of the "mark", a word which is not defined in the UDRP rules. But not this one:

"[T]he Panel is of the opinion that the Policy and Rules do not leave room for extending trademarks in paragraph 4(a) of the Policy and paragraphs 3(viii) and 3 (ix) of the Rules to include trade names (which are not also used as non registered trademarks)".

[WIPO Arbitration and Mediation Center, Enmersan Granit Mermer ve Inşaat Taahhut Sanayi ve Ticaret A.S. v. Ibrahim Sahin, Case No. D2004-0439, August 13, 2004]