[Name & Address of Complainant]
(Complainant)
v.
[Name and Address of Registry]
(Respondent)
Top Level Domain
In Dispute:
<enter TLD here>
COMPLAINT IN ACCORDANCE WITH
THE REGISTRY RESTRICTIONS DISPUTE RESOLUTION POLICY
[1.]
This Complaint is hereby submitted for decision in accordance with the Registry
Restrictions Dispute Resolution Policy (RRDRP), adopted by the Internet Corporation for
Assigned Names and Numbers (ICANN), and the Rules for Registry Restrictions Dispute
Resolution Policy (RRDRP Rules or “Rules”), in effect as of the date of submission of this
complaint, and the FORUM Supplemental Rules (Supp. Rules). RRDRP Rule 3(b)(i).
[2.]
COMPLAINANT INFORMATION
[a.]
[b.]
[c.]
[d.]
[e.]
Name:
Address:
Telephone:
Fax:
E-Mail:
[enter full name of Complainant]
[enter mailing address]
[enter telephone number]
[enter facsimile number]
[enter e-mail address(es)]
[3.] COMPLAINANT AUTHORIZED REPRESENTATIVE, IF ANY
[a.]
[b.]
[c.]
[d.]
[e.]
Name:
Address:
Telephone:
Fax:
E-Mail:
[enter full name of Representative(s)]
[enter mailing address]
[enter telephone number(s)]
[enter facsimile number]
[enter e-mail address(es)]
RRDRP Rule 3(b)(ii).
Complainant’s preferred contact person for correspondence relating to this case:
[a.]
[b.]
Document1
Contact Name(s): [enter name(s) of contact persons]
Contact Emails(s): [enter email address(es) to receive all case emails]
[4.] PANEL SELECTION
The Complainant chooses to have this dispute heard before a (check one):
_____ single-member Expert panel ____ three-member Expert panel.
Rule 3(b)(ix).
If Complainant selects a single –member Expert panel, please review RRDRP Supp. Rule 12(c)
If Complainant elects to have this dispute heard before a three-member panel, provide the names
and contact details of five RRDRP-qualified candidates from any ICANN-approved RRDRP
Provider’s list of panelists to serve as one of the panelists. RRDRP Supp. Rule 12(a).
[5.]
RESPONDENT INFORMATION-- from the Registry Agreement posted
on ICANN’s site
[a.]
[b.]
[c.]
[d.]
[e.]
Name:
Address:
Telephone:
Fax:
E-Mail:
[enter full name of Registry]
[enter mailing address]
[enter telephone number]
[enter facsimile number]
[enter e-mail address]
[6.] RESPONDENT AUTHORIZED REPRESENTATIVE, IF KNOWN
[a.]
[b.]
[c.]
[d.]
[e.]
Name:
Address:
Telephone:
Fax:
E-Mail:
[enter full name of Representative(s)]
[enter mailing address]
[enter telephone number(s)]
[enter facsimile number]
[enter e-mail address(es)]
Rule 3(b)(iii).
[7.] NAME AND ADDRESS OF THE OWNERS OF ANY AT-ISSUE DOMAIN NAMES
[a.]
Name:
[enter full name of Representative(s)]
[b.]
Address:
[enter mailing address]
[c.]
Telephone:
[enter telephone number(s)]
[d.]
Fax:
[enter facsimile number]
[e.]
E-Mail:
[enter e-mail address(es)]
Rule 3(b)(iv).
Sections 8 - 10 of the Complaint shall not exceed 5,000 words or 20 pages.
[8.] STANDING
In the spaces below, please provide the arguments for standing to file an RRDRP claim.
Complainant is reminded that the Burden of Proof is Preponderance of the Evidence [RRDRP
16.].
Describe Complainant’s 1. status as a member of an established institution in a defined
community related to the gTLD string that is the subject of the dispute, and 2. Ongoing
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relationship with a defined community that consists of a restricted population that the gTLD
supports. [RRDRP Section 5; see Rule 3(b)(v-vi).)
[provide arguments here]
[9.] STANDARDS

The community invoked by the objector (Complainant) is a defined community. [RRDRP
Section 6.1.1.]
[provide arguments here]

There is a strong association between the community invoked and the gTLD label or
string. [RRDRP Section 6.1.2.]
[provide arguments here]

The TLD operator violated the terms of the community-based restrictions in its
agreement. [RRDRP Section 6.1.3.]
[provide arguments here]

There is a measureable harm to the Complainant and the community named by the
objector. [RRDRP Section 6.1.4.]
[provide arguments here]
[10.] DESCRIPTION OF THE DISPUTE
Provide a statement describing the particular registration restrictions in the Registry Agreement
with which the registry operator is failing to comply. [RRDRP Section 7.2.3.1.]
[provide arguments here]
Provide a detailed explanation of how the registry operator’s failure to comply with the identified
registration restrictions has caused harm to the complainant. [RRDRP Section 7.2.3.2.]
[provide arguments here]
[11.] EVIDENCE
Annex any copies of any documents that the Complainant considers to evidence its basis for
relief. [RRDRP Section 7.4; Rule 3(d)] See the FORUM’s Supplemental Rules for the Rules
governing Annexes.
[12.]
REMEDY SOUGHT
The recommended remedy is determinated at the sole discretion of the Expert Panel. After
reviewing RRDRP 17, the Complainant may identify the Remedy(ies) it is seeking. [RRDRP
Section 17; Rule 12(b).]
[provide remedy recommendation here]
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[13.]
OTHER LEGAL PROCEEDINGS
[Identify any other legal proceedings that have been commenced or terminated in connection
with or relating to any of the domain name(s) or parties that are the subject of the complaint.]
Rule 3(b)(x).
[14.] DISCOVERY
Limited discovery may be granted in exceptional circumstances and upon payment of additional
fees. Please include any request for discovery here. [RRDRP Section 14; Supplemental Rule
15.]
Include the type of disovery desired: expert witnesses, live or written testimony, or limited
exchange of documents. Include the reason for the request, the material to be discovered with as
much specificity as possible, and identify any persons or witnesses.
[15.] HEARINGS
Hearings will be documentary, except in exceptional circumstances. [RRDRP 15; Supplemental
Rule 16.] If a telephone, videoconfererence, or in-person hearing is requested, please include
the type of hearing requested and a detailed reason why a documentary hearing will not suffice.
[16.] CONSOLIDATION
Complainant may request that this Complaint be consolidated with one or more related
Complaints, pursuant to Supp. Rule 7.
[17.]
MUTUAL JURISDICTION
The Complainant will submit, with respect to any challenges to a decision in the administrative
proceeding to the jurisdiction of the courts where the Registry has its principle place of business.
RRDRP Rule 3(b)(xii).
[18.]
CERTIFICATIONS
Provide a statement that the Complainant has filed a claim through the Registry Restriction
Problem Report System (RRPRS). [RRDRP Section 5.3; RRDRP Rule 3(b)(vii)]. Include in
your Annexes evidence of claim and any result or resolution.
State that Complainant has not filed a Trademark Post-Delegation Dispute Resolution Procedure
compaint relating to the same or similar facts or circumstances. [RRDRP Rule 3(b)(xi).]
A statement that the proceedings are not being brought for any improper purpose. [RRDRP
7.2.4.]
Provide a certification that the Factual and Legal Grounds (arguments provided in sections 8-10
of this document) of the Complaint do not exceed 5,000 words or 20 pages. [RRDRP 7.3]
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Provide this statement: “Complainant agrees that its claims and remedies concerning the
registration of the domain name, the dispute, or the dispute’s resolution shall be solely against
the domain-name holder and waives all such claims and remedies against (a) the FORUM and
panelists, except in the case of deliberate wrongdoing, (b) the registrar(s), and (c) the Internet
Corporation for Assigned Names and Numbers, as well as their directors, officers, employees,
and agents.
Complainant certifies that the information contained in this Complaint is to the best of
Complaint's knowledge complete and accurate, that this Complaint is not being presented for any
improper purpose, such as to harass, and that the assertions in this Complaint are warranted
under these Rules and under applicable law, as it now exists or as it may be extended by a goodfaith and reasonable argument.” [RRDRP Rule 3(b)(xiii)]
Respectfully Submitted,
___________________
[Signature]
__________________
[Name]
___________________
[Date]
[The Complaint and Annexes shall be submitted electronically, in accordance with the electronic
submission requirements listed in the Annex to the Supplemental Rules, to
domaindispute@adrforum.com.] [RRDRP 7.1, Supp Rule 4].
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