...which did not involve the UDRP, incidentally. It's important to understand that the lawsuit in France which led to that transfer was initiated by the domain registrant.
But, if one is going to post something like "Can CountryName.com be taken in a UDRP" it's worth mentioning UDRP cases where that has come up.
There have been two cases in which the government of a country brought a UDRP against a domain name of the type noted in the OP. In both cases, the government lost and the case was deemed RDNH.
As far as the UDRP is concerned, this is a very cut-and-dried issue - countries, territories, cities, etc. as geographic terms
per se - have all been tried. As a threshold matter, the UDRP requires a trade or service mark. Countries do not posses "trade or service mark" rights in the name of the country as a geographic entity.
NewZealand.com: Complaint Denied
https://www.wipo.int/amc/en/domains/decisions/html/2002/d2002-0754.html
The primary function of the name NEW ZEALAND is to identify a geographical location, which, while inevitably the geographical source of goods and services, is not the specific trade source of those goods and services.
As an indication of geographical origin, when properly applied to goods and services, the name NEW ZEALAND does indeed serve to distinguish goods and services emanating from New Zealand from the goods and services emanating from other geographical areas. But indications of geographical origin are not of themselves trade/service marks. They are not trade/service marks for precisely the reason that they serve to indicate geographical origin. Trade/service marks on the other hand indicate a very precise trade origin. They identify the specific trader, the source of the goods/services. Ordinarily, an indication of geographical origin cannot serve that purpose. A wine label reading "NEW ZEALAND wine", for example, indicates that the wine emanates from New Zealand, but it does not indicate which of the hundreds of New Zealand wine producers is the source of that particular wine.
Indications of geographical origin, whether they be the names of towns, cities, regions, countries or indeed continents are certainly capable of being trademarks or service marks, but only when the geographical significance of the name is displaced. This usually only occurs after long and extensive use of the name as a brand by a single trader in such a manner as to distinguish his goods and services from those of his competitors. Thus, in England, for example, to golfers, NEW ZEALAND is well known as being the name of a golf club; to the general public ICELAND is a well known supermarket chain and food brand, MALVERN, the name of a town, is well known as a brand of mineral water and YORK, the name of a city, is a well known brand of vehicular trailer. In all those cases, the names in question are trade/service marks in the narrow areas of activity identified, where the geographical significance of those names has been displaced.
Mexico.com : Complaint Denied
https://www.wipo.int/amc/en/domains/decisions/html/2004/d2004-0242.html
Even assuming that the word MEXICO was being used as a trademark by Complainant’s predecessor, the Tourism Ministry of Mexico, it is inconceivable to the Panel that Respondent selected the domain name <mexico.com> because of any trademark sense of the word MEXICO, rather than because of its sense as the name of a country. That precludes a finding of bad faith registration. Furthermore, there is no indication that Respondent has used the disputed domain name in a manner related to its trademark sense rather than its geographic sense. Even if Respondent did offer it for sale to Complainant as alleged in the Complaint (five years after registration), the context of that offer makes clear that the value of the domain name derived from its geographic rather than its trademark sense.
So, the answer to the OP is pretty simple. Two countries have tried it, and both times, it was found to be reverse domain hi-jacking.
This has also applied to territories, states or regions, and municipalities.
PuertoRico.com : Complaint Denied
https://www.wipo.int/amc/en/domains/decisions/html/2002/d2002-1129.html
Thus, both UDRP precedent and United States trademark law instruct the Panel that the Complainant does not have trademark rights in a word or phrase to which the disputed domain name, <puertorico.com>, is identical or confusingly similar: the Complainant has used it as a descriptive geographic place name in trademarks comprising jingles and phrases without any showing of acquired secondary meaning for "Puerto Rico". In fact, the Complainant has not shown any use of its trademarks, only that they have been registered. Nor has the Complainant shown that any use it may make of the words Puerto Rico for tourism services is any different from the myriads of other tourism and other service and goods providers in Puerto Rico that use the words Puerto Rico.
Andalucia.com : Complaint Denied
https://www.wipo.int/amc/en/domains/decisions/html/2006/d2006-0749.html
The Panel finds that where, as here, a respondent is using a geographic indication to describe his product/business or to profit from the geographic sense of the word without intending to take advantage of complainant’s rights in that word, then the respondent has a legitimate interest in respect of the domain name.
It has been applied to municipalities:
GoldCoast.com : Complaint Denied
https://www.wipo.int/amc/en/domains/search/text.jsp?case=D2013-1733
Firstly, the Panel has considered “the established principle that a geographical name standing alone is difficult to protect under the UDRP unless there are extraordinary circumstances.” Ipiranga Produtos de Petróleo S.A. v. Domain Admin, Mrs. Jello, LLC,WIPO Case No. D2011-0163. This case involves such a domain name. There is no dispute that the disputed domain name is associated with the geographic location of the Gold Coast. This is self-evidently the basis on which the Complainant has brought the Complaint.
Secondly, paragraph 1.5 of the Overview of WIPO Panel Views on Selected UDRP Questions, Second Edition (“WIPO Overview 2.0”) relevantly states that: “The report of the Second WIPO Internet Domain Name Process declined to recommend specifically extending protection to geographical terms under the UDRP. Some geographical terms, however, can be protected under the UDRP, if the complainant has shown that it has rights in the term and that the term is being used as a trademark for goods or services other than those that are described by or related to the geographical meaning of the term (secondary meaning).” The Complainant provided no evidence of using the term “Gold Coast” for goods or services unrelated to its geographic meaning.
Gstaad.com : Complaint Denied
https://www.wipo.int/amc/en/domains/search/text.jsp?case=D2016-2601
CityOfSalinas.com : Complaint Denied
https://www.adrforum.com/domaindecisions/97076.htm
CityofDearborn.com : Complaint Denied
https://www.adrforum.com/domaindecisions/99602.htm
Paris.tv : Complaint Denied
https://www.wipo.int/amc/en/domains/decisions/html/2009/dtv2009-0010.html
Categorically, "geographic name" cases are one of the simplest types of UDRP scenarios for a domain registrant to win.
In fact, they are so simple that I defended the last four on the list above, lol.
One notable exception was Barcelona.com, which was an early case of this type and in which transfer was ordered. The UDRP decision was then reversed in further court proceedings in the US.
