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File an ERDRP Complaint

Note: These instructions summarize certain portions of the Eligibility Requirements Dispute Resolution Policy (ERDRP), ERDRP Rules, and the FORUM's ERDRP Supplemental Rules that concern the filing of an ERDRP Complaint. This summary is not a substitute for reading and understanding the Rules governing this proceeding.

File ERDRP Complaints Properly
Parties interested in filing an ERDRP Complaint must do so according to the ERDRP Rules and the FORUM’s ERDRP Supplemental Rules. Please read and review these rules prior to filing your Complaint.

If you would like to file your Complaint online, prepare the information for steps 1-17 below and proceed to our Online Filing for ERDRP Complaints page.

If your Complaint involves one or more Internationalized Domain Names (IDNs), please proceed to our Internationalized Domain Names page for additional filing instructions.

Prepare Your ERDRP Complaint
A model Complaint form is available online in MS Word rich text format. You may download this form to assist you as you proceed through these instructions.


  1. Excluding attachments, the Complaint may not exceed ten (10) pages. National Arbitration Forum ERDRP Supplemental Rule (hereinafter "Forum ERDRP Supp. Rule") 4(b).

  2. Include a request that the Complaint be submitted for decision in accordance with the Eligibility Requirements Dispute Resolution Policy and Rules. Rules for Eligibility Requirements Dispute Resolution Policy (hereinafter "ERDRP Rule") 3(b)(i).

  3. Include the name, postal address, e-mail address, telephone and facsimile numbers of the Complainant. The Complaint must also include the name of the representative who is authorized to act for the Complainant in the proceeding. ERDRP Rule 3(b)(ii).

  4. Specify the preferred method for communicating with the Complainant. This must specifically state the person to be contacted, the medium for contact and the address information. The Complaint must include this information for electronic transmission and hard copies. ERDRP Rule 3(b)(iii).

  5. Designate whether the Complainant requests single-member or three-member panel. ERDRP Rule 3(b)(iv).

    • If the Complainant requests a single-member panel, the Complainant must submit three (3) copies of the Complaint to the National Arbitration Forum (one if filed by fax). Forum ERDRP Supp. Rule 4(c).

    • When a single-member panel is requested, the National Arbitration Forum will appoint a neutral and impartial panelist from its list of panelists. ERDRP Rule 6(b).

    • If Complainant opts for a three-member panel, the Complainant must provide names and contact information for three (3) candidates, one of whom will serve as a panel member. These candidates may be chosen from any ICANN approved provider's list of potential panelists. ERDRP Rule 3(b)(iv). The other two panelists will be selected in accordance with ERDRP Rule 6(e).

    • If the Complainant requests a three-member panel, the Complainant must submit five (5) copies of the Complaint (one if filed by fax). For three-member panels requested by the Respondent, the Complainant may be asked to submit additional copies of the Complaint. Forum ERDRP Supp. Rule 4(c).

  6. Provide the name of the Respondent (Defensive Registration or Registered Name holder), including the postal address, e-mail address, telephone and facsimile numbers, and any other contact information available to Complainant which will allow the National Arbitration Forum to send the Complaint in compliance with ERDRP Rule 2(a). ERDRP Rule 3(b)(v). (Contact information may be found at the Registry Operator's Whois database: http://www.gnr.com/.)

  7. Specify the Defensive Registration(s) or Registered Name(s) that is/are the subject of the Complaint. ERDRP Rule 3(b)(vi). The Complaint may relate to more than one Defensive Registration or Registered Name (domain name, SLD E-mail address, or both), provided that, in the case of Registered Names, the Registered Names are registered by the same holder. If the Complainant wishes to register a Personal Name that conflicts with a Defensive Registration(s) that is held by more than one registrant, the Complaint must name all such registrants as parties to the administrative proceeding. ERDRP Rule 3(c).

  8. Identify the Registrar with whom the Defensive Registration(s) or Registered Name(s) is/are registered at the time the Complaint is filed. ERDRP Rule 3(b)(vii). (To identify the current Registrar, go to the Registry Operator's Whois database: http://www.gnr.com/.)

  9. Describe the grounds on which the Complaint is made, as follows:
    1. If the challenge is pursuant to Paragraph 4(b) of the ERDRP, describe, in accordance with the ERDRP, the manner in which the Registered Name(s) does not satisfy the Eligibility Requirements and, if the Complainant seeks transfer of the Registered Name(s), a representation and warranty that the Complainant meets the Eligibility Requirements.
    2. If the challenge is pursuant to Paragraph 4(d) of the ERDRP, a representation and warranty that the Complainant meets the Eligibility Requirements to register a Personal Name in conflict with the Defensive Registration.
    3. If the challenge is pursuant to Paragraph 4(e) of the ERDRP, the reasons the Phase I Defensive Registration does not meet the Eligibility Requirements for Phase I Defensive Registrations.

  10. For elements (1-3) above, the description should discuss any aspects of the ERDRP that are applicable. ERDRP Rule 3(b)(ix).

  11. Specify the remedies sought, in accordance with the ERDRP. ERDRP Rule 3(b)(x).

  12. dentify any other legal proceedings that have been commenced or terminated in connection with or relating to any of the domain names that are the subject of the Complaint. ERDRP Rule 3(b)(xi).

  13. State that a copy of the Complaint, together with the “ERDRP Complaint Transmittal Sheet”, has been sent or transmitted to the Respondent in accordance with ERDRP Rule 2(b) and to the Registrar in accordance with Supp. Rule 4(f). ERDRP Rule 3(b)(xii).

  14. State that the Complainant will submit to the jurisdiction of the courts in one specified Mutual Jurisdiction (See Definitions, ERDRP Rule 1), with respect to any challenges to a decision in the administrative proceeding canceling or transferring Defensive Registration(s) or the Registered Name(s). ERDRP Rule 3(b)(xiii).

  15. Conclude with the following statement followed by the signature of the Complainant or its authorized representative:

    "Complainant agrees that its claims and remedies concerning the registration of the Defensive Registration, domain name or SLD E-mail address, the dispute, or the dispute's resolution shall be solely against the Defensive Registration, domain name or SLD E-mail address holder and waives all such claims and remedies against (a) the dispute-resolution provider and panelists, except in the case of deliberate wrongdoing, (b) the registrar, (c) the registry administrator, and (d) 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 Complainant'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 good-faith and reasonable argument."

    ERDRP Rule 3(b)(xiv).

  16. Attach any documents or other evidence, including a copy of the Policy applicable to the Defensive Registration or Registered Name(s) in dispute and any evidence of the Complainant's eligibility to register the name under the Eligibility Requirements, upon which the Complaint relies, together with a table of contents of such evidence. ERDRP Rule 3(b)(xv).

  17. Include the appropriate non-refundable fee, or in Defensive Registration proceedings, the escrow deposit, in accordance with the Forum's ERDRP Supplemental Rules Fee Schedule (Forum ERDRP Supp. Rule 16). ERDRP Rule 19.

File Your ERDRP Complaint
Pursuant to Forum ERDRP Supp. Rule 4(e), send the Complaint, any other attached evidence, and a copy of the Complaint Transmittal Sheet by email to domaindispute@adrforum.com. Attachments should be in Microsoft Word, PC Format. You must also send us your complaint by either fax or mail using the address and numbers below:

Regular US Post:
National Arbitration Forum
PO Box 50191
Minneapolis, MN 55405
USA

FedEx, UPS, or Overnight Mailings:
National Arbitration Forum
6465 Wayzata Blvd. #470
St. Louis Park, MN 55426
USA

Fax: 612-235-3355
Toll-free Fax: 866-743-4517

Questions?
Contact us via email or call (800) 474-2371.


CONTACT US

National Arbitration Forum
P.O. Box 50191
Minneapolis, MN 55405
Tel: 800-474-2371
Fax: 612-235-3355
Toll Free Fax: 866-743-4517

FedEx and UPS Deliveries