Nikolay Davydenko was again accused of not trying his hardest in a tennis match, with the chair umpire criticising the Russian's serving during a 6-2 6-2 loss to Marcos Baghdatis in the third round of the Paris Masters.

The defending champion, who was booed during the match, finished with 10 double-faults and 36 unforced errors. He lost serve five times.

Chair umpire Cedric Mourier spoke to Davydenko during a changeover, asking him what was wrong with his serve. Davydenko responded by asking what else he could do.

"Serve like me," Mourier said. "If you serve like me, you put it in the box. That's it."

Davydenko had said he was hampered by a sore elbow, but he didn't give a direct answer when Baghdatis asked him what was wrong as they shook hands at the end of the match.

"I cannot serve," Davydenko said later.

"That was happening in St Petersburg. I don't have pain really. I have no pain in my elbow. I need to find what's the reason I cannot really serve."

Last week at the St Petersburg Open, Davydenko was fined $US2,000 ($A2,150) by the ATP for "lack of best effort" during a 1-6 7-5 6-1 loss to Marin Cilic.

ATP spokesman Nicola Arzani said no action will be taken against the fourth-seeded Davydenko over his latest effort.

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