I would agree but not in all cases, only in specific cases like (lambo,com) and other similar cases.
If there are allot of TM's on specific term and many domains in other TLD's available to pursue, this TM holders specifically target the COM or AI extensions.
You also need to see if the domain was registered after someone's TM registration, ultimately that is why UDRP is made, to do the investigation, but I agree that where are big money UDRP follows the big dollar boy.