One of the advantages of UDRP is that you can refile the same complaint against the same respondent over the same domain name: WIPO D2006-0596.
In the domain name disputes ADR rules I have seen, I don't remember reading a provision that prevents from doing this. Even though there is a non bis in idem principle in civil and criminal procedures, it is not unfair to let someone sue the same domain name owner again, since the way this person uses the domain name may have changed.
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