events I AM LAMBO

[lambo.com]

Hello frens,

I AM LAMBO of LAMBO.com and I will defend, defeat and humiliate those endeavouring to steal any of my domain name brands - including my moniker.

We have stood by in meek positioning watching poor decisions, one after another, rendered typically by "SOLE PANELISTS" - albeit with exceptions and inconsistency.

Digital assets stripped from legal holders and registrants who immediately (apparently), default to defensive posturing against Reverse Domain Name Hijackers (RDNH).

The injustice propagated against domain investors, speculators and BUILDERS - will not continue as it has.

In my case, a car company called "Automobili Lamborghini S.p.A." is attempting THEFT of my asset, nomenclature and taxonomy they possess ZERO rights to.

https://www.udrpsearch.com/wipo/d2022-1570

Counter measures to humiliate such endeavours are afoot. Unlawful theft will be duly punished through legal and commensurate counter efforts including any coerced and submissive accomplices.

Humiliation is inevitable should they desire METAWAR, even as the car company, NISSAN, found out with NISSAN.com
https://web.archive.org/web/20200131113518/https://www.nissan.com/

This is enough for now, I will continue to update as necessary.

In the meanwhile, you can add me on lichess (@lamboDOTcom).

We will save our industry from the filth that seeks to dismember it's legitimacy.

Thank you for time and God Bless. May the VRIL be with you.

 

[jberryhill]

I guess it varies tremendously, but can you tell a bit about what expenses you can expect if you take a case like this to a US court?

https://domainnamewire.com/2021/01/...orneys-fees-in-reverse-domain-hijacking-case/

U.S. Magistrate Judge Deborah M. Fine has ordered (pdf) sports apparel company Lotto Sport Italia to pay approximately $237,000 in attorneys’ fees stemming from a reverse domain name hijacking case.

Lotto Sport filed a cybersquatting dispute under the Uniform Domain Name Dispute Resolution Policy (UDRP) against David Dent’s domain names LottoStore .com and LottoWorks .com. Dent acquired the domains for over $11,000 with plans to use them for his online gaming business, only to be hit with the UDRP shortly after acquiring the domains.

Dent’s initial case was poorly defended and a World Intellectual Property Organization (WIPO) panel found in Lotto Sport’s favor. So Dent was forced to defend his domains by filing a lawsuit.

 

[jberryhill]

I guess it varies tremendously, but can you tell a bit about what expenses you can expect if you take a case like this to a US court?

One thing to realize about taking a UDRP decision to court, such as the lottoworks case mentioned in the article linked above, is that if we are talking about the US, then the trademark claimant will also counterclaim for cybersquatting and other violations of its mark. So if you take a UDRP case to court, you're no longer just playing to keep the domain name. You're playing for real money, and you can't just walk away if it starts tilting against you.

But, since the original post in this thread notes:

Counter measures to humiliate such endeavours are afoot. Unlawful theft will be duly punished through legal and commensurate counter efforts including any coerced and submissive accomplices.

...then perhaps the show may continue - especially against those "coerced and submissive accomplices" whomever they might be. Sounds scary.

 

[jberryhill]

I am pretty sure he is the same guy who bought a 3L dot com domain name disputed as stolen for cheap and asked people "so what?".

https://www.namepros.com/threads/a-quick-due-diligence-saved-losing-25k.1203053/

Another thing to note about "going to court" is that one's history of domain registrations and dealings is also subject to discovery. Parties litigating domain cases will regularly subpoena a lot of information directly from registrars and other service providers to flesh out a full picture.

 

[karmaco]

He may have messed up the case by his own actions and not retaining counsel but earlier in this thread we can see many companies use the term lambo. Lamb is a dictionary word.

They have no more right to it than any REAL lambo based company and they didn’t care enough to keep the mark active because lets get real its, for them, a nickname. Nothing more and nothing less.

I think this has more to do with who filed the udrp and less to do with the word Lamb plus a letter o. being exclusively their term because it is not. Money and power talks.

 

[Altetra]

He may have messed up the case by his own actions and not retaining counsel but earlier in this thread we can see many companies use the term lambo. Lamb is a dictionary word.

They have no more right to it than any REAL lambo based company and they didn’t care enough to keep the mark active because lets get real its, for them, a nickname. Nothing more and nothing less.

I think this has more to do with who filed the udrp and less to do with the word Lamb plus a letter o. being exclusively their term because it is not. Money and power talks.

Also the lamb is not a Bull, there is no relation with their logo.

 

[bmugford]

He may have messed up the case by his own actions and not retaining counsel but earlier in this thread we can see many companies use the term lambo. Lamb is a dictionary word.

They have no more right to it than any REAL lambo based company and they didn’t care enough to keep the mark active because lets get real its, for them, a nickname. Nothing more and nothing less.

I think this has more to do with who filed the udrp and less to do with the word Lamb plus a letter o. being exclusively their term because it is not. Money and power talks.

Who filed the case certainly mattered.

If any of the many Lambo companies or several thousand people named "Lambo" around the world filed the case, they certainly would not have received the same treatment.

UDRP has (3) prongs that must be proven -

1.) Confusingly similar to a trademark or service mark in which the Complainant has rights

2.) Registrant has no legitimate reason to own domain.

3.) Being registered AND used in bad faith.

Even if you concede the first prong, on to the second prong.

No legitimate reason to own the domain.

Lamborghini does not have exclusive use to the term for every possible use. There are many others who use the term for various uses. The term can certainly be used in a non-infringing manner.

Now on to prong 3. Where is the actual bad faith when it comes to usage? That is required under UDRP language.

This is what Neil Brown called out in his long dissent.

What you have here are 2 panelists unfairly giving the benefit of doubt to a company, even though the facts of the case don't merit that outcome.

All they presented are very generic, broad, specious arguments.

Whether you like the OP or not does not change the facts of the case and should be no factor in the outcome.

Brad

 

[Embrand]

https://domainnamewire.com/2021/01/...orneys-fees-in-reverse-domain-hijacking-case/

U.S. Magistrate Judge Deborah M. Fine has ordered (pdf) sports apparel company Lotto Sport Italia to pay approximately $237,000 in attorneys’ fees stemming from a reverse domain name hijacking case.

Lotto Sport filed a cybersquatting dispute under the Uniform Domain Name Dispute Resolution Policy (UDRP) against David Dent’s domain names LottoStore .com and LottoWorks .com. Dent acquired the domains for over $11,000 with plans to use them for his online gaming business, only to be hit with the UDRP shortly after acquiring the domains.

Dent’s initial case was poorly defended and a World Intellectual Property Organization (WIPO) panel found in Lotto Sport’s favor. So Dent was forced to defend his domains by filing a lawsuit.

Thanks. That is certainly not small change for most people.

 

[1Darko]

Who filed the case certainly mattered.

If any of the many Lambo companies or several thousand people named "Lambo" around the world filed the case, they certainly would not have received the same treatment.

UDRP has (3) prongs that must be proven -

1.) Confusingly similar to a trademark or service mark in which the Complainant has rights

2.) Registrant has no legitimate reason to own domain.

3.) Being registered AND used in bad faith.

Even if you concede the first prong, on to the second prong.

No legitimate reason to own the domain.

Lamborghini does not have exclusive use to the term for every possible use. There are many others who use the term for various uses. The term can certainly be used in a non-infringing manner.

Now on to prong 3. Where is the actual bad faith when it comes to usage? That is required under UDRP language.

This is what Neil Brown called out in his long dissent.

What you have here are 2 panelists unfairly giving the benefit of doubt to a company, even though the facts of the case don't merit that outcome.

All they presented are very generic, broad, specious arguments.

Whether you like the OP or not does not change the facts of the case and should be no factor in the outcome.

Brad

If you search at OpenCorporates by the term Lambo you get 551companies that uses Lambo in their name. There are a lot of Lambo's around the world with jurisdiction:

• 1 Alabama (US)
• • 1 Alaska (US)
• 8 Arizona (US)
• • 1 Arkansas (US)
• 28 Australia
• • 3 Bahamas
  • 7 Belgium
  • 2 Brazil
  • 7 British Columbia (Canada)
  • 4 Bulgaria
• 31 California (US)
• • 2 Canada Federal Companies
  • 4 Colorado (US)
  • 1 Connecticut (US)
  • 1 Curaçao
  • 2 Cyprus
  • 3 Czech Republic
• 11 Delaware (US)
• • 3 Denmark
  • 1 Dominican Republic
• 45 Florida (US)
• 21 France
• • 1 French Guiana
• 18 Georgia (US)
• 10 Germany
• • 1 Greece
  • 1 Hawaii (US)
• 24 Hong Kong
• • 2 India
  • 4 Indiana (US)
  • 4 Iowa (US)
  • 1 Ireland
  • 1 Isle of Man
  • 5 Japan
  • 1 Jersey
  • 1 Kansas (US)
  • 2 Latvia
  • 3 Liechtenstein
  • 5 Louisiana (US)
  • 1 Luxembourg
  • 2 Maine (US)
  • 3 Malaysia
  • 5 Maryland (US)
  • 2 Massachusetts (US)
  • 1 Mauritius
  • 6 Michigan (US)
  • 5 Minnesota (US)
  • 4 Missouri (US)
  • 1 Moldova
  • 3 Montana (US)
  • 1 Nebraska (US)
• 25 Netherlands
• 14 Nevada (US)
• • 1 New Brunswick (Canada)
  • 1 New Hampshire (US)
• 8 New Jersey (US)
• • 2 New Mexico (US)
• 26 New York (US)
• • 6 New Zealand
• 9 North Carolina (US)
• • 1 Norway
• 8 Ohio (US)
• • 2 Oklahoma (US)
  • 2 Oregon (US)
  • 1 Pakistan
  • 3 Panama
• 13 Pennsylvania (US)
• • 1 Poland
  • 2 Puerto Rico
  • 2 Quebec (Canada)
  • 1 Rhode Island (US)
  • 1 Réunion
  • 4 Singapore
  • 1 Slovakia
  • 4 Slovenia
  • 5 South Africa
  • 4 South Carolina (US)
  • 3 Spain
  • 6 Sweden
• 10 Switzerland
• • 2 Tanzania
  • 1 Tennessee (US)
• 24 Texas (US)
• • 2 Thailand
• 27 United Kingdom
• • 2 Utah (US)
  • 6 Virginia (US)
  • 5 Washington (US)
• 8 Wisconsin (US)
• • 3 Wyoming (US)

 

[bmugford]

If you search at OpenCorporates by the term Lambo you get 551companies that uses Lambo in their name. There are a lot of Lambo's around the world with jurisdiction:

• 1 Alabama (US)
• • 1 Alaska (US)
• 8 Arizona (US)
• • 1 Arkansas (US)
• 28 Australia
• • 3 Bahamas
  • 7 Belgium
  • 2 Brazil
  • 7 British Columbia (Canada)
  • 4 Bulgaria
• 31 California (US)
• • 2 Canada Federal Companies
  • 4 Colorado (US)
  • 1 Connecticut (US)
  • 1 Curaçao
  • 2 Cyprus
  • 3 Czech Republic
• 11 Delaware (US)
• • 3 Denmark
  • 1 Dominican Republic
• 45 Florida (US)
• 21 France
• • 1 French Guiana
• 18 Georgia (US)
• 10 Germany
• • 1 Greece
  • 1 Hawaii (US)
• 24 Hong Kong
• • 2 India
  • 4 Indiana (US)
  • 4 Iowa (US)
  • 1 Ireland
  • 1 Isle of Man
  • 5 Japan
  • 1 Jersey
  • 1 Kansas (US)
  • 2 Latvia
  • 3 Liechtenstein
  • 5 Louisiana (US)
  • 1 Luxembourg
  • 2 Maine (US)
  • 3 Malaysia
  • 5 Maryland (US)
  • 2 Massachusetts (US)
  • 1 Mauritius
  • 6 Michigan (US)
  • 5 Minnesota (US)
  • 4 Missouri (US)
  • 1 Moldova
  • 3 Montana (US)
  • 1 Nebraska (US)
• 25 Netherlands
• 14 Nevada (US)
• • 1 New Brunswick (Canada)
  • 1 New Hampshire (US)
• 8 New Jersey (US)
• • 2 New Mexico (US)
• 26 New York (US)
• • 6 New Zealand
• 9 North Carolina (US)
• • 1 Norway
• 8 Ohio (US)
• • 2 Oklahoma (US)
  • 2 Oregon (US)
  • 1 Pakistan
  • 3 Panama
• 13 Pennsylvania (US)
• • 1 Poland
  • 2 Puerto Rico
  • 2 Quebec (Canada)
  • 1 Rhode Island (US)
  • 1 Réunion
  • 4 Singapore
  • 1 Slovakia
  • 4 Slovenia
  • 5 South Africa
  • 4 South Carolina (US)
  • 3 Spain
  • 6 Sweden
• 10 Switzerland
• • 2 Tanzania
  • 1 Tennessee (US)
• 24 Texas (US)
• • 2 Thailand
• 27 United Kingdom
• • 2 Utah (US)
  • 6 Virginia (US)
  • 5 Washington (US)
• 8 Wisconsin (US)
• • 3 Wyoming (US)

There are also more than 1500 people alone on LinkedIn with the surname, out of many more thousands in the world.

This is the type of the situation where you really should need to prove an abusive history, because granting "bad faith" on just generic arguments is a major issue when it comes to domains that are not clear cut cases.

This is not InstagramNFT.com or whatever. UDRP was designed for those type of cases, not these type of cases.

I am sorry, but in a case like this it seems like the (2) panelists already made their mind up then simply cherry-picked a way to get to the conclusion they wanted vs actually following the facts of the dispute.

Brad

 

[1Darko]

There are also more than 1500 people alone on LinkedIn with the surname, out of many more thousands in the world.

This is the type of the situation where you really should need to prove an abusive history, because granting "bad faith" on just generic arguments is a major issue when it comes to domains that are not clear cut cases.

This is not InstagramNFT.com or whatever. UDRP was designed for those type of cases, not these type of cases.

I am sorry, but in a case like this it seems like the (2) panelists already made their mind up then simply cherry-picked a way to get to the conclusion they wanted vs actually following the facts of the dispute.

Brad

Theoretically anyone out of this 1500 people and 551 companies could abuse the UDRP to get the domain. Is there maybe a case where actually multiple complainants tried to get a domain at the same time?

 

[jberryhill]

I think this has more to do with who filed the udrp

Well, of course it does.

In any trademark dispute, reputation matters.

When the Google results look like this:

Then the fact that there are some minor other uses doesn't change the basic point that the UDRP is driving at:

"Why did this person register this domain name?"

A trademark doesn't have to be unique for a trademark owner to win a domain dispute, but these cases ultimately come down to the panel's assessment of the credibility of the reason why the respondent claims to have registered the domain name.

Take a trademark like "Monster". It's well known as an energy drink, and electronic cable manufacturer, and an employment service. To show that someone who has registered "Monster" in a domain name is cybersquatting, then the complaint is going to have to provide some factual basis to conclude the respondent was targeting them.

But, when you have an association of the term with the trademark owner which is this strong, then a lot is going to depend on the credibility of the respondent's explanation of why they registered the domain name, and whatever evidence backs that up. Absolutely, the UDRP places the burden of proof on the complainant, but as a practical matter - and really as a point of common sense - if your defense is going to be "it's my nickname" then you are going to have to come up with solid evidence of that.

That's just a basic truth. I've defended a lot of "commonly known as cases" and "because I say so" doesn't work out very well.

You can point to other companies, surnames, etc., but at the end of the day, these cases come down to what the panel believes the most likely answer is to the question "why did this person register this domain name?" If the response is sketchy on details like when the name was registered, and relies on a changed username on a web forum after the name was acquired, then some panelists - and in this instance two out of three - are going to be skeptical of the respondent's motivation.

The "MONSTER" example makes a good contrast. Here are the top organic Google results:

Notice that the top organic results are the employment service, the energy drink, and the cable manufacturer, followed by a movie.

Of course, on top of that "monster" is an ordinary generic dictionary word.

So, for any one of the "Monster" trademark owners to make out a case of cybersquatting, they have a harder job than something like "Lambo". You can post all the business directories you want, but the bottom line is that if you walk down the street and ask people:

1. What, if anything, does the term "Lambo" mean to you?

and

2. What, if anything, does the term "Monster" mean to you?

You are going to get two very different and distinguishable types of answers. The difference in Google results between a term like "Lambo" and a term like "Monster" should be telling you something important about the difference between these two terms.

If the difference is not clear to you, then, yes, a lot of UDRP results are going to seem hard to distinguish.

And, once again with feeling, the dissent reflects the fact that the complainant did not do a very good job in presenting their case either. That sort of thing can make a big difference in cases that can go either way, depending on the details.

 

[bmugford]

Theoretically anyone out of this 1500 people and 551 companies could abuse the UDRP to get the domain. Is there maybe a case where actually multiple complainants tried to get a domain at the same time?

This is not a dispute, but I once had a case where (2) different companies tried to threaten me over an "Edible" domain at around the same time.

I always wondered about those domains like MicrosoftFacebook.com. If they both file a dispute, who gets it?

Brad

 

[bmugford]

And, once again with feeling, the dissent reflects the fact that the complainant did not do a very good job in presenting their case either. That sort of thing can make a big difference in cases that can go either way, depending on the details.

Fair enough, but sometimes you just get bad a decision regardless of the dispute itself.

Even if you present the best case in the world, you are completely at the mercy of the panelists who could rule for or against you based on any whim, with no appeal process.

You represented the defendant in VisitQatar.com. It went 3-0 for the complainant.

If you look at the history of these "Visit" domains there is basically no precedent that is followed and the decisions are unpredictable and erratic.

When the system yields results that are this unpredictable, the system itself is flawed.

IMO.

Brad

 

[jberryhill]

When the system yields results that are this unpredictable, the system itself is flawed.

I don't know what you mean by "this unpredictable" absent some quantifiable measurement.

I don't believe that "agrees with me 100% of the time" is a reliable measurement of whether something is flawed.

It's also worth understanding something about the way legal practice works. I turn down a lot of frivolous cases from people who have no chance of winning, and who somehow think "hiring a lawyer" turns a loser case into a winner. As mentioned in the thread above, I will also represent people who are trying to extricate themselves from a case arising from drunk-registering, unhelpful friends, portfolio purchases with bad names in them, etc., or just plain old ignorance or bad judgment.

That doesn't make every case which I do take as strong as every other case. Sometimes, I might believe there is a slim chance of a win, but if there is a non-frivolous defense and the client is fully informed, then we will make that non-frivolous defense.

When I showed up at the emergency room after my heart stopped beating, it might have gone either way, but not every patient in my condition can be saved. Some show up in better condition than others. When I went for my last check-up, my cardiologist said, "It's nice to have a success story now and then." He doesn't win every time either, but he did with me.

I don't think you are going to find any system of adjudication - whether its arbitration, courts, or anything else - that will satisfy the standard of "agrees with me every time", but I don't think that is the measure of how "flawed" it is. But, even so, if we cover the years 2019 to present and include all cases which have gone to a decision in which I represented either party, then it comes to around 53 cases. Of those, one case, VisitQatar.com, did not result in a win for my client. Do I think "agrees with me 98.1% of the time" is "flawed"? No, I don't. But I think I can deal with a world that doesn't go my way 2% of the time.

Your mileage may vary, but I consider a 98% hit rate to be within the range of "predictable".

There are situations where reasonable minds can differ. I think several of those cases could have gone either way. You are not going to reach perfection in any human system of decisionmaking. That's just the way it is.

The basic outline in this one is that some guy acquired a domain name that is overwhelmingly and strongly associated with a luxury auto brand, put it up for sale for millions, and had a sketchy explanation for why that doesn't really hold up to a lot of scrutiny and wasn't supported by convincing evidence. That's the starting point for "what do you think he was up to?" Picking around the edges with surnames or other companies doesn't make the affirmative story any more convincing.

 

[Future Sensors]

I always wondered about those domains like MicrosoftFacebook.com. If they both file a dispute, who gets it?

Here's a blog post about such a situation:

https://giga.law/blog/2015/12/02/multiple-trademarks

 

[bmugford]

Here's a blog post about this situation:

https://giga.law/blog/2015/12/02/multiple-trademarks

Interesting article.

Brad

 

[jberryhill]

There are also more than 1500 people alone on LinkedIn with the surname, out of many more thousands in the world.

That's right. And you know what would make an argument like that more convincing?

How many other surname domains does the registrant have?

For example, BOSCH is a well known brand for things from kitchen appliances to auto parts. It's also a surname.

So, what kinds of things would persuade you that bosch.net was registered because it is a surname, and not a well known brand?

https://www.wipo.int/amc/en/domains/search/text.jsp?case=D2017-2549

"The Respondent has provided credible and detailed evidence that the Disputed Domain Name forms part of its portfolio of domain names which are used in a business providing email addresses to persons where the second-level domain name element of the relevant email address corresponds to a person's surname.

The Panel has no doubt that this represents a legitimate and bona fide business. A number of previous UDRP panels have reached the same conclusion in relation to the Respondent's business in this regard (or its predecessors in that business) – see for example Grasso's Koninklijke Machinefabrieken N.V., currently acting as Royal GEA Grasso Holding N.V. v. Tucows.com Co, WIPO Case No. D2009-0115; International Raelian Religion and Raelian Religion of France v. Mailbank.com Inc., WIPO Case No. D2000-1210; and Buhl Optical Co v. Mailbank.com, Inc., WIPO Case No. D2000-1277."

So, absolutely, it's fine to register domain names based on their significance as a surname, if that was the motivation. However, if this is the only surname domain name the respondent owns, then why this one and no others?

I typically find that a domainer who has one dictionary word or phrase will typically have several other domain names relating to the same word or phrase. If a domainer has one surname, they typically have several others. One way to demonstrate that a challenged domain name was registered because it was a surname, and not someone's trademark, is to provide a list of the OTHER surname domains that were registered for the same reason.

There are a lot of surnames in the world. Some are more popular than others. But if you are going to say "I registered this domain name because it was a surname" then the next question is "what other surnames did you register for the same reason?"

And if the answer is "there aren't any others", then you kind of wonder "Why this one in particular? What made it so special?"

 

[Brian L.]

Fight the good fight!

 

[MadAboutDomains]

There are a lot of surnames in the world. Some are more popular than others. But if you are going to say "I registered this domain name because it was a surname" then the next question is "what other surnames did you register for the same reason?"

And if the answer is "there aren't any others", then you kind of wonder "Why this one in particular? What made it so special?"

Could be "because I wanted that one surname and I'm not made of money".

How many surnames does one have to own in order to keep their domain?

I think that you should have got a TM and established a brand on it (for something other than cars, or related industries, obviously), they didn't have a registration on LAMBO since it expired and you could have established legitimate rights in it somewhere in the world. I guess it's too late now... or maybe it isn't...

 

[jberryhill]

they didn't have a registration on LAMBO since it expired

First, that's not true. They have several:

Second, as has been explained on Namepros many times, whether someone has allowed their trademark registration to lapse does not necessarily mean they have abandoned the underlying trademark. I might let my dog license expire, but that doesn't mean I don't have a dog.

People let their trademark registrations expire and go on using their trademark and maintaining their rights in their trademarks all of the time. Registration provides a lot of enforcement advantages, but it does not determine whether someone "has a trademark" any more than having a dog license determines whether someone "has a dog".

But, that said...

REGISTRATION IS NOT REQUIRED TO HAVE A TRADEMARK. I understand there are people who will never grasp "what is a trademark" and how that is not the same thing as "why is it desirable to register a trademark." I totally get that people think you "get a trademark" by filing a piece of paper with the government. But, what you will notice, is that you aren't going to find a single trademark attorney who is going to agree with that persistent and wrong belief among domainers who have principally learned misinformation about trademarks from other domainers.

It is unfortunate that a lot of misinformation about trademarks gets passed around and believed.

The term "LAMBO" is strongly associated in the minds of consumers as indicating a particular brand of automobile. Try doing a Google search for "LAMBO" and then try to explain how it does not function in the relevant marketplace as a distinctive indicator of their goods.

Could be "because I wanted that one surname and I'm not made of money".

How many surnames does one have to own in order to keep their domain?

Well, that first point might be a good reason, but there are a lot of low value surnames running around. Again, why that one in particular? When did you become aware it was a surname? Did you have a friend or associate by that name? You just woke up one morning with an insatiable desire to have a surname which, coincidentally, is known around the world as a common short version of a famous and well-known trademark? The Google search results are outstandingly uniform waaaaaaay down the result list, but you figured "that's a great surname" instead.

That could be true. But outside of the wishful thinking echo chamber of a domain forum, very few people are going to believe that.

The basic question a UDRP panel is trying to answer is "why did this person register this domain name?" and to decide whether they were more likely motivated by the complainant's trademark, or whether it was something else. You simply can't ignore the fact that pretty much everyone knows that "LAMBO" is very strongly associated with a high-end car manufacturer. To move the needle in the other direction, you are going to need more than "it's my username on Namepros".

But it's not a matter of "how many surnames does one have to own". It's a matter of establishing a credible defense, using whatever evidence may be helpful. For example, I've done a lot of three- and four- letter domain defenses. If the respondent has a lot of other three- or four- letter domains, then that is helpful in establishing a reason to conclude that, yes, the domain name is consistent with a pattern of registration having nothing to do with a trademark.

On the "not made of money" thing, it is also helpful to explain how you got the domain name, and how much you paid for it. Did Mr. Lambeth sell it? For how much? What was the conversation like?

The "not made of money" thing is fine. How much did this one cost compared to other surnames? Great direction to go.

For example, if there was an email to the effect of "I really like the 'Lambo' surname and I want to buy your domain" that could be helpful, since it is a statement made at a time when there was no dispute.

For example, did someone register "CityCentre.com" because it refers to a common urban feature, or did they register it because it is a trademark claimed by a shopping center developer? Well....

https://www.wipo.int/amc/en/domains/search/text.jsp?case=D2021-0591

"In 2001, the founder and CEO of the Respondent negotiated the purchase of a domain name reference site and news aggregator, <iGoldrush.com>. The former owner of the domain name had included various generic word and phrase domain names in the purchase as an apology for moving slow with the deal, thus offering the disputed domain name to the Respondent at no charge."

The email correspondence at the time of acquisition nailed down exactly why the respondent had the domain name.

So, it's not a matter of "how many other surnames" or some mechanical rule. It is a matter of credibility. Reality extends in three dimensions of space and one in time and encompasses a lot of facts. Facts don't exist in a vacuum isolated from the larger fabric of reality. If the overall reality is that the name was registered because it is a surname, then there are usually other facts which connect to support that version of reality. It's not a magic trick where you have to make sure the audience is focussed on one thing to the exclusion of everything else for the trick to work.

However, the respondent in this case seemed to want to ride a couple of horses at one time with "it's my nickname" as well. Again, that's a great defense, and is an absolute defense, but it is one that requires you show some evidence to that effect which exists independent of acquisition of the domain name. Otherwise, sure, I can register MicrosoftOffice.LOL and say it's my nickname too.