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File a TDRP Request for Enforcement

Note: These instructions summarize certain portions of ICANN's Registrar Transfer Dispute Resolution Policy (TDRP) and the FORUM's TDRP Supplemental Rules that concern the filing of a Request for Enforcement. This summary is not a substitute for reading and understanding the Rules governing this proceeding.

File TDRP Requests for Enforcement Properly
Parties interested in filing a TDRP Request for Enforcement must do so according to the TDRP and the FORUM’s TDRP Supplemental Rules. Please read and review the policy and rules prior to filing your Request for Enforcement.

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 TDRP Request for Enforcement
A model Request for Enforcement 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 Request for Enforcement shall not exceed ten (10) pages. National Arbitration Forum Supplemental Rule (hereafter "Supp. Rule") 4(a).

  2. Include a request that the Request for Enforcement be submitted for decision in accordance with the Registrar Transfer Dispute Resolution Policy (hereafter “Policy”) and the Forum’s Supplemental Rules. Policy 3.1.2(i).

  3. Include the name, postal and e-mail addresses, telephone and facsimile numbers of the Filing Registrar. The Request for Enforcement must also include the name of the representative who is authorized to act for the Filing Registrar in the proceeding. Policy 3.1.2(ii).

  4. Designate whether the Filing Registrar requests one arbitrator or a panel of three arbitrators. Supp. Rule 4(d).
    • When a one-member panel is requested, the National Arbitration Forum shall appoint a neutral and impartial arbitrator. Policy 1.1.

    • If the Filing Registrar opts for a three-member panel, the Filing Registrar 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. Supp. Rule 4(d). The other two panelists shall be selected in accordance with Supp. Rule 9(e). (To search through a list of National Arbitration Forum panelists go to: List of Qualified Dispute Resolution Panelists,

  5. Provide the name of the Respondent and all information (including any postal and e-mail addresses, and telephone and facsimile numbers) known to the Filing Registrar regarding how to contact Respondent or any representative of Respondent, including contact information based on pre-complaint dealings. Policy 3.1.2(iii).

  6. Specify the domain name(s) that is/are the subject of the Request for Enforcement. Policy 3.1.2(iv). The Request for Enforcement may relate to more than one domain name, provided that the domain names involve the same Filing Registrar and Respondent and that the claims arise out of the same or similar factual circumstances. Policy 3.1.3.

  7. Specify the incident(s) that gave rise to the dispute. Policy 3.1.2(v).

  8. Describe, in accordance with the Policy, the grounds on which the Request for Enforcement is based. Policy 3.1.2(vi).

  9. State the specific remedy being sought. Policy 3.1.2(vii). The Policy limits the remedies available to approval of the transfer or denial of the transfer. Policy 4.3.8(iv).

  10. Identify any other legal proceedings that have been commenced or terminated in connection with or relating to any of the domain name(s) that are the subject of the Request for Enforcement. Policy 3.1.2(viii).

  11. State that a copy of the Request for Enforcement, together with the "Request for Enforcement Transmittal Cover Sheet" (available on the National Arbitration Forum's website), has been sent or transmitted to the Respondent. Policy 3.1.2(ix).

  12. Conclude with the following statement followed by the signature of the Filing Registrar or its authorized representative:

    “<insert name of Filing Registrar> agrees that its claims and remedies concerning the registration of the domain name, the dispute, or the dispute’s resolution shall be solely against the Respondent and waives all such claims and remedies against the dispute resolution provider and panelists, as well as the dispute resolution provider’s directors, officers, employees, and agents, except in the case of deliberate wrongdoing or gross negligence.”“

    <insert name of Filing Registrar> certifies that the information contained in this Request for Enforcement is to the best of Filing Registrar’s knowledge complete and accurate, that this Request for Enforcement is not being presented for any improper purpose, such as to harass, and that the assertions in this Request for Enforcement are warranted under this Policy and under applicable law, as it now exists or as it may be extended by a good-faith and reasonable argument.”

    Policy 3.1.2(x).

  13. Attach any documents or other evidence, including a copy of the Policy applicable to the domain name(s) in dispute together with a table of contents of the evidence. Policy 3.1.4.

  14. Include the appropriate fee in accordance with the Forum's Supplemental Rules and Fee Schedule (Supp. Rule 16). Policy 4.4.

File Your TDRP Request for Enforcement
Pursuant to Policy 3.1.2, send the Request for Enforcement, the Request for Enforcement Transmittal Sheet, any other attached evidence, and a copy of ICANN's Registrar Transfer Dispute Resolution Policy to the National Arbitration Forum by email, at, and to the Non-filing Registrar. Attachments should be in Microsoft Word, PC format.

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


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

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