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the "no content" argument wouldn't work to well since they already made one reasonable request, and had to follow up with a threatening letter.
They will just argue to ICANN that they attempted to settle this matter once, however how long till you do the same thing again?
never try to fight corporations with lots of money, it never really works out for you. A good example of this would be a woman who designed perfume/bath items and had her own boutique in New York, she marketed her products under the name "Glow" and had used it for years, When "J-Lo" released her perfume called "Glow" she had so many customers asking her affiliation with J-Lo she decided to sue for dilution of her trademark, needless to say J-Lo's attorney's threw money at the problem and bought a older trademark of perfume products marketed as "Glow" now she is not sure if she can continue selling her product with the name SHE created, marketed and ultimately made!
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