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In a post on his message board Don Murphy posted a link to an article on reserveresult.com which claims that the Transformers Movie sequel will have the tag line Revenge of the Fallen. As regular visitor to the site will know, we broke the news that Hasbro Inc has applied for a trademark with the USPTO for that mark along with Revenge of Unicron, Return to Cybertron, Revenge of the Decepticons and Return of the Decepticons.
Hasbro then later confirmed the title for the second Transformers Movie as Transformers 2: Revenge of the Fallen in an article on Transformers.com. The fallen in the title of cause refers to the Decepticons and not the character The Fallen.
Roberto Orci has also confirmed that the title was actually the brainchild of Alex Kurtzman himself, according to a poster on Shoot for the Edit.