I wish there was more consistency. Buying and Selling generic domains is a legitimate business. It is really no different than buying and selling property. Just because you don't do anything with it gives no entity a right to take it, assuming it is generic and not clear TM infringement.
There has also been precedent set that buying and selling generic domains is a legitimate business as well
See also General Machine Products Company, Inc. v. Prime DomainsFA0001000092531, in which the panel concludes that because the registrant "is in the business of selling generic and descriptive domain names. . . [registrant] does have a legitimate interest in the domain name." (craftwork.com)
Full Text -
The Panel finds therefore that Prime Domains has rebutted General Machines' arguments and has proven that it is in the business of selling generic and descriptive domain names such as craftwork.com. As a result, Prime Domains does have a legitimate interest in the domain name. That Prime Domains has offered to sell this descriptive, non-source identifying domain name does not make its interest illegitimate.
Brad