Model Complaint and Filing Guidelines

The WIPO Center has prepared Model Complaints intended to serve as guides for the preparation of a Complaint under the Rules for Uniform Domain Name Dispute Resolution Policy (Rules) and WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (Supplemental Rules). The WIPO Center makes available two sets of model Complaints, which are discussed below.

The first may be used by Complainants filing their UDRP Complaint with WIPO in electronic form only (eUDRP Complaint), such facility being available at WIPO from December 14, 2009. The second should be used for those cases in which a Complainant (also) elects to file their Complaint and/or any annexes in hard copy, which is an option available until February 28, 2010.

Filing Your UDRP Complaint with WIPO in Electronic Form Only (eUDRP)

As of December 14, 2009, WIPO UDRP Parties may choose to file Complaints (or Responses) including all annexes solely by electronic format. These may be submitted by email to domain.disputes@wipo.int. For Complaints (or Responses) filed in electronic-only format, reference is made to the modified Rules for Uniform Domain Name Dispute Resolution Policy, and to the modified WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy, which provide relevant guidance as to applicable format modalities. In order to facilitate filing of you electronic-only UDRP (eUDRP) pleading with the WIPO Center, the following options are available:

• download and complete the model Complaint (eUDRP) as a Word document to submit as an email attachment to an e-mail to domain.disputes@wipo.int; or
• complete and submit directly online (eUDRP) to the Center an electronic form of the model Complaint.

Please note that the use of the above methods is optional. You may also prepare and submit the Complaint without using these facilities, including (until February 28, 2010) in hard copy. From March 1, 2010, submission of your Complaint in complete electronic form (including all annexes) will become mandatory.

Using the model Complaint as a basis for the preparation of a party's submission does not preclude the possibility of the Complaint being found deficient in some respect following the WIPO Center's formalities compliance review, nor of the Center or an Administrative Panel requesting the Complainant for additional information. In addition, it does not guarantee a Complainant's success on the merits.

In filing your UDRP Complaint with the WIPO Center in electronic form only:

• The Complaint as submitted to the WIPO Center should state that a copy of the Complaint (including the Complaint Transmittal Coversheet (eUDRP)) has been forwarded to the Respondent in accordance with Rules, para. 2(b). (In cases where cyber flight (e.g. the transfer of a disputed domain name to a different registrant to frustrate or avoid UDRP proceedings) may be a risk, Complainants may wish to contact the WIPO Center prior to filing or forwarding copies of their Complaint (e.g. to discuss possibility for an expedited lock request being sent to the registrar in such cases).
• The Complaint as submitted to the WIPO Center should also state that a copy of the Complaint has been forwarded to the concerned registrar(s). Certain registrars have established specific contact details that should be used for these purposes, which may be obtained by contacting the registrar(s) in question.
• The Complaint and all annexes should be submitted electronically, taking guidance as to file size and format modalities as specified in Annex E of the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy. (The latter will become mandatory for all UDRP Complaints filed with WIPO from March 1, 2010.)
• The required payment should be made to the WIPO Center, as specified in Annex D of the WIPO Supplemental Rules, and we would also ask that you inform the Center as to how such payment is being made.

Filing Your UDRP Complaint with WIPO in Hard Copy
(under the original UDRP Rules)

If you should choose to file your UDRP Complaint (or any annexes) with WIPO in hard copy (an option that is available up to February 28, 2010), you may do so using the below methods, in accordance with the Rules for Uniform Domain Name Dispute Resolution Policy, as approved on October 24, 1999, and the WIPO Supplemental Rules, in effect as of December 1, 1999:

• download and complete the model Complaint as a Word document to submit as an email attachment to an e-mail attachment (along with all annexes) to an e-mail (along with an annexes available in electronic form) to domain.disputes@wipo.int; or
• complete and submit directly online to the Center an electronic form of the model Complaint.

Please note that the use of the above methods is optional. You may also prepare and submit the Complaint without using these facilities. You should also note that submission of Complaint in hard copy (with or without annexes) does not free you from also having to submit a copy of the Complaint in electronic form (except to the extent not available in electronic form) under paragraph 3(b) of the original UDRP Rules

Using the model Complaint as a basis for the preparation of a party's submission does not preclude the possibility of the Complaint being found deficient following the WIPO Center's formalities compliance review, nor of the Center or an Administrative Panel requesting the Complainant for additional information. In addition, it does not guarantee a Complainant's success on the merits.

• You may send the signed original and four hardcopies of the Complaint and annexes by postal mail or courier service to:

• The Complaint as submitted to the WIPO Center should state that a copy of the Complaint (including the Complaint Transmittal Coversheet) has been sent or transmitted to the Respondent in accordance with Rules, para. 2(b).
• The Complaint as submitted to the WIPO Center should state that a copy has been sent or transmitted to the concerned registrar(s). Certain registrars have established specific contact details that should be used for these purposes, which may be obtained by contacting the registrar(s) in question.
• Submit the required payment to the Center, as specified in Annex D of the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy; if payment is being submitted by check, it should be included with the hardcopies (see above). If payment is not being submitted with the hardcopies, inform the Center as to how payment is being made.

Additional information

The following documents should be consulted in connection with preparing and filing a Complaint:

• UDRP Uniform Domain Name Dispute Resolution Policy (UDRP Policy)
• UDRP Rules for Uniform Domain Name Dispute Resolution Policy (UDRP Rules)
• Modified UDRP Rules for Uniform Domain Name Dispute Resolution Policy (UDRP Rules)
• WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy
• Modified WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy

Parties may also wish to consult the Legal Index of WIPO UDRP Panel Decisions and WIPO Overview of WIPO Panel Views on Selected UDRP Questions.

Questions concerning the filing requirements may be sent by e-mail to arbiter.mail@wipo.int.