[Name & Address of )

Complainant])

)Domain Names In Dispute:

(Complainant))[list names]

)

v.)

)Case Number:

[Name and Address of )[enter assigned case number]

Respondent])

)

(Respondent))

)

RESPONSE TO RESTRICTIONS DISPUTE RESOLUTION POLICY COMPLAINT

[1.]Respondent received a Notification of Complaint and Commencement of Administrative Proceeding on [enter the date on which the Notification of Complaint and Commencement of Administrative Proceeding was received]. The Notification stated that Complainant had submitted a Complaint for decision in accordance with the Restrictions Dispute Resolution Policy and Supplemental Rules and the Uniform Domain Name Dispute Resolution Policy and Rules. Rule 4.

[2.]RESPONDENT INFORMATION

[a.]Name:[enter full name of Respondent – should be same as “Registrant”]

[b.]Address:[enter mailing address]

[c.]Telephone:[enter telephone number]

[d.]Fax:[enter facsimile number]

[e.]E-Mail:[enter e-mail address]

[Provide the same information for Respondent’s authorized representative in the administrative proceeding.] Rule 5(b)(ii).

The Respondent’s preferred method for communications directed to the Respondent in the administrative proceeding: Rule 5(b)(iii).

Electronic-Only Material

[a.]Method:[i.e., e-mail]

[b.]Address:[enter one e-mail address only]

[c.]Contact:[enter name of one contact person]

Material Including Hard Copy

[a.]Method:[i.e., fax, post]

[b.]Address/Fax:[enter one address or fax number only]

[c.]Contact:[enter name of one contact person]

The Respondent chooses to have this dispute heard before a [enter one: a) single-member administrative panel as stated in the Complainant’s Complaint; or b) three-member administrative panel as stated in the Complainant’s Complaint; or c) three-member panel, even though the Complainant has chosen a single-member panel.] Rule 5(b)(iv).

[If Complainant has elected to have this dispute heard before a three-member panel, provide the names and contact details of three candidates from any ICANN-approved Provider’s list of panelists to serve as one of the panelists.] Rule 5(b)(v).

[If Complainant has elected to have this dispute heard before a single-member panel and Respondent elects to have the dispute heard before a three-member panel, 1) provide the names and contact details of three candidates from any ICANN-approved Provider’s list of panelists to serve as one of the panelists and 2) submit the fee required pursuant to Rules 5(c); 6(c); Forum RDRP Supp. Rule 16.]

[3.]RESPONSE TO FACTUAL AND LEGAL ALLEGATIONS MADE IN COMPLAINT

This Response specifically responds to the statements and allegations contained in the Complaint and includes any and all bases for the Respondent to retain registration and use of the disputed domain name. Rule 5(b)(i). [The analysis in this section may require more space than provided, but the entire Response shall not exceed ten (10) pages. Forum RDRP Supp. Rule 5(a).]

[Elements of the RDRP are as follows:]

[a.][Specify in the space below how the Respondent’s domain(s) is/are being or will be used primarily for a bona fide business or commercial purpose] RDRP Policy ¶ 4(a).

[b.] [Specify in the space below why the Respondent (domain-name holder) should be considered as having a bona fide intent to use the domain name or any content software, materials, graphics or other information thereon, to permit Internet users to access one or more host computers through the DNS:

-to exchange goods, services, or property of any kind; or

-in the ordinary course of trade or business; or

-to facilitate the exchange of goods, services, information, or property of any kind or the ordinary course of trade or business] RDRP Policy ¶ 4(b).

[c.][Specify in the space below why the domain name(s) should not be considered as having been registered and being used solely for the purposes identified below:

-selling, trading or leasing the domain name for compensation, or

-the unsolicited offering to sell, trade or lease the domain name for compensation.

-For illustration purposes, the following shall not constitute a "bona fide business or commercial use" of a domain name:

  • Using or intending to use the domain name exclusively for personal, noncommercial purposes; or
  • Using or intending to use the domain name exclusively for the expression of noncommercial ideas (e.g., registering exclusively to criticize or otherwise express an opinion on the products or services of ABC company, with no other intended business or commercial purpose).] RDRP Policy ¶ 4(c).

[d.][If this is a joint RDRP/UDRP Complaint, Respondent should address these UDRP elements below:

-the manner in which the domain name(s) is/are not identical or confusingly similar to a trademark or service mark in which the Complainant has rights,

-why the Respondent (domain-name holder) should be considered as having rights or legitimate interests in respect of the domain name(s) that is/are the subject of the complaint, or

-why the domain name(s) has not been registered and used in bad faith.] Policy ¶ 4.

[4.]OTHER LEGAL PROCEEDINGS

[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 Complaint.] Rule 5(b)(vi).

[5.]RESPONSE TRANSMISSION

The Respondent asserts that a copy of the Response, as prescribed by the Forum’s RDRP Supplemental Rules, has been sent or transmitted to the Complainant, in accordance with Rule 2(b). Rule 5(b)(vii); Forum RDRP Supp. Rule 5.

[6.]The Respondent respectfully requests that the Administrative Panel deny the remedy requested by the Complainant.

[If appropriate and the allegation can be substantiated with evidence, the Rules provide that a Respondent may ask the Panel to make a finding of reverse domain-name hijacking.] ICANN Rule 15(e).

[7.]CERTIFICATION

Respondent certifies that the information contained in this Response is to the best of Respondent’s knowledge complete and accurate, that this Response is not being presented for any improper purpose, such as to harass, and that the assertions in this Response 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.

Respectfully Submitted,

______

[Signature]

______

[Name]

______

[Date]

[Annex any documentary or other evidence upon which the Respondent relies, together with a schedule indexing such documents] ICANN Rule 5(b)(ix).

[The Response, not including annexed material, shall not exceed ten (10) pages.] Forum RDRP Supp. Rule 5(a).

[The Respondent shall submit three (3) copies of the Response, including annexed material, to the Forum if the Complainant requested a single-member panel (one copy, if sent by fax). If the Complainant or Respondent requested a three (3) member panel, the Respondent shall submit five (5) copies of the Response, including annexed material, to the Forum (one copy, if sent by fax).] Forum RDRP Supp. Rule 5(b).