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UDRP Model Complaint and Filing Guidelines

The WIPO Arbitration and Mediation Center (Center) has prepared a Model Complaint intended to serve as a guide for preparing a Complaint under the Uniform Domain Name Dispute Resolution Policy (Policy or UDRP), Rules for Uniform Domain Name Dispute Resolution Policy (Rules) and WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (Supplemental Rules). The Model Complaint is available as a Word document.

WIPO UDRP Complainants must file their complaint, including all annexes electronically. To facilitate your filing with the Center:

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 Center’s administrative compliance review, nor of the Center or appointed Panel requesting additional information from the Complainant. In addition, it does not guarantee a Complainant’s success on the merits.

In filing your UDRP Complaint with the WIPO Center

  • The complaint and all annexes should be submitted electronically. File size and format modalities are specified in Supplemental Rules Annex E. Complaints filed outside the Center’s working hours (e.g., on weekends) may not be processed until the next working day.
  • Following changes to the Rules, as of July 31, 2015, a complainant does not need to provide a copy of the complaint to the Respondent. The Complainant should however provide a copy to the concerned registrar in accordance with Supplemental Rules paragraph 4(c). Certain registrars have specific contact details that should be used for this purpose, which may be obtained by contacting the registrar directly. A list of ICANN-accredited registrars can be found at the InterNIC Accredited Registrar Directory.
  • Once a complaint is filed, the Center requests the concerned registrar to “lock” the disputed domain name so that the domain name will not be transferred to another registrant during the UDRP proceeding. In accordance with Rules paragraph 4(b), within two business days of receiving the Center’s request, the registrar must confirm to the Center that a lock has been applied and that the disputed domain name will remain locked during the pendency of the UDRP proceeding.
  • The required payment should be made to the WIPO Center, as specified in WIPO Supplemental Rules Annex D . Payments by credit card should only be made using the Center's secure online payment facility. Please do not include any credit card information in the complaint or covering emails. For payment-related queries or difficulties, please call +41 (0)22 338 8247 or email domain.disputes@wipo.int.

Additional information

In addition to the UDRP, Rules, and Supplemental Rules referenced above, 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.