UNIFORM DOMAIN NAME DISPUTE RESOLUTION POLICY (UDRP) COMPLAINT

PARTIES

• Complainant: [Name, Entity, Address, Email]; authorized representative [if any].
• Respondent: [Name/Unknown], Whois info/Privacy service, domain: [DOMAIN].

DOMAIN AND REGISTRAR

• Domain: [DOMAIN]; Registrar: [REGISTRAR]; Registration Date: [DATE].
• Status: [Active/Parked/For Sale]; screenshots and historical records attached.

COMPLAINANT’S MARKS

• Mark: [MARK]; registrations: [Nos./countries]; first use: [DATE]; goods/services: [Describe].
• Evidence of goodwill and recognition: [sales, media, website traffic, awards].

1. IDENTICAL OR CONFUSINGLY SIMILAR

• Domain incorporates the Mark in its entirety or with minor additions/typos/descriptors; analysis of visual/phonetic/suggestive similarity.

2. NO RIGHTS OR LEGITIMATE INTERESTS

• Respondent not commonly known by the domain; no authorization/license; no bona fide offering; use is [parking/redirecting to competitors/counterfeit/lead capture/confusing business name].

3. REGISTRATION AND USE IN BAD FAITH

• Evidence: [offer to sell for excessive price, PPC ads targeting Complainant’s sector, phishing/spoofing, pattern of registrations, false Whois, passive holding with fame, blocking Complainant].

REMEDY REQUESTED

• Transfer of the Domain to Complainant (or cancellation).

MUTUAL JURISDICTION

• Courts at [Registrar location or Respondent address if known].

PROCEDURAL

• Provider: [WIPO/Forum/etc.]; panel request: [single/three-member].
• Annexes: Whois, mark registrations, evidence of use, screenshots, correspondence, certification.

CERTIFICATION

“Complainant certifies that the information contained in this Complaint is to the best of Complainant’s knowledge complete and accurate, that this Complaint is not being presented for any improper purpose, and that the assertions are warranted under the Policy and Rules.”

Signature:
Name: [NAME]
Title/Role: [if counsel, include bar info if required by provider]
Date: [DATE]