World Intellectual Property Organization

eUDRP Model Complaint and Filing Guidelines

Model Complaint and Filing Guidelines

The WIPO Center has prepared a Model Complaint intended to serve as a guide 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 the below model Complaint, which is discussed below.

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

As of March 1, 2010, WIPO UDRP Parties must 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:

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 should note the following:
  • Paragraph 8(a) of the UDRP states that a domain name registrant may not transfer a domain name to another domain name holder during a pending UDRP proceeding. Please note that the responsibility for any lock of the domain name pending a UDRP proceeding is with the concerned registrar and the WIPO Center does not have the technical capacity to ensure the lock of any domain name.
  • Once a Complaint is filed with the WIPO Center, the WIPO Center typically issues a request to the concerned registrar requesting confirmation that a domain name being disputed under the UDRP will not be transferred to another domain name holder during the filed UDRP proceeding. Such request is sent shortly after receipt of the filed UDRP Complaint which initiates that proceeding. Please note that the WIPO Center cannot issue such request merely in anticipation of a Complaint being filed – the Complaint must actually have been filed with and duly registered by the WIPO Center.
  • One very practical piece of advice we do give is to suggest filing your Complaint well within core WIPO Center filing hours (preferably between 9 and 5 pm, Geneva time, Monday to Friday), so that that the Complaint can be registered by the Center and the relevant lock request issued, on the day of filing. Complaints filed with the Center after 5pm Geneva time, other than by special arrangement, may not be processed by the Center until the next working day.
  • If you wish to explore possibilities for requesting the concerned registrar to prevent transfer of a domain name prior to the actual filing of a UDRP Complaint with WIPO, we can only suggest that you contact the concerned registrar directly in this regard.
  • 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 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. Please note that in cases where payment is to be made by Credit Card, Credit Card information should not be included in the Complaint itself or in any covering emails to the Center. (Payment by credit card should be made using the WIPO Center's secure online payment facility. For payment-related queries or difficulties, please call (+41 22) 338 8247.)

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

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