There seems to be an increase in the number of UDRP decisions issued by the Arbitration Center for Internet Disputes (aka the Czech Arbitration Court). The reason is probably that practitioners have spread the word that it is cheaper to file a complaint before this UDRP provider if the Respondent remains silent (500 € if there is no response).
In a recent decision by Matthew Harris (carefully penned, as usual), the panelist reminds that a further fee can be requested if the matter is complex.
Applying paragraph 1(b) of Annex A of UDRP Supplemental Rules - which states that "the Panel [may] determine that it is appropriate for the Complainant to pay
the Additional UDRP Fees, having regard to the complexity of the
proceeding", the panelist has required the Complainant to disburse 800 more euros with regard to the difficulties of the case.