[Name & Address of )Disputed Site Names
Complainant])of Public Frogans Networks:
(Complainant))[list complete Frogans Addresses]
)
v.)Disputed Network Names
)of Dedicated Frogans Networks:
[Name and Address of )[list Network Names]
Respondent])
)Disputed Site Names
(Respondent))of Dedicated Frogans Networks:
)[list complete Frogans Addresses]
)
)Case Number:
)[enter assigned case number]
RESPONSE
[1.]Respondent received a Written Notice of Complaint and Commencement of Administrative Proceeding on [enter the date on which the Written Notice was received]. The Notification stated that Complainant had submitted a Complaint for decision in accordance with the Uniform Dispute Resolution Policy for Frogans Addresses (“UDRP-F”), the Rules for the Uniform Dispute Resolution Policy for Frogans Addresses (“UDRP-F Rules”), and theForumSupplemental Rules (“Supp. Rules”). UDRP-F Rule 4.
[2.]RESPONDENT INFORMATION
[a.]Name:[enter full name of Respondent – should be same as “Holder”]
[b.]Address:[enter mailing address]
[c.]Telephone:[enter telephone number]
[d.]Fax:[enter facsimile number]
[e.]E-Mail:[enter e-mail address]
[3.]RESPONDENT AUTHORIZED REPRESENTATIVE, IF ANY
[a.]Name:[enter full name of Representative(s)]
[b.]Address:[enter mailing address]
[c.]Telephone:[enter telephone number(s)]
[d.]Fax:[enter facsimile number]
[e.]E-Mail:[enter e-mail address(es)]
UDRP-F Rule 5(b)(ii).
Respondent’s preferred contact person for correspondence relating to this case:
[a.]Contact Name(s):[enter name(s) of contact persons]
[b.]Contact Emails(s): [enter email address(es) to receive all case emails]
UDRP-F Rule 5(b)(iii).
[In this section, you may respond to any allegations made by Complainant regarding Forum Supp. Rule 1(d).]
The Respondent chooses to have this dispute heard before a (check one):
[_____ single-member administrative panel; ____ three-member administrative panel].
UDRP-F 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 OP3FT -approved Provider’s list of panelists to serve as one of the panelists.] UDRP-F 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 OP3FT-approved Provider’s list of panelists to serve as one of the panelists and 2) submit the fee required pursuant to UDRP-F Rules 5(c), 6(c) and Supp. Rule 17(a).]
[4.]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 Network Name(s) or Site Name(s). UDRP-F Rule 5(b)(i). [The analysis in this section may require more space than provided, but the entire Complaint shall not exceed fifteen (15) pages. Forum Supp. Rule 5(a).]
[Elements of the UDRP-F are as follows:]
[a.][Specify in the space below the manner in which the Network Name(s) or Site Name(s) is not/are not identical or confusingly similar to a trademark or service mark in which the Complainant has rights.] UDRP-F Para. 4(a)(i).
[b][Specify in the space below why the Respondent (Network Name or Site Name holder) should be considered as having rights or legitimate interests in respect of the Network Name(s) or Site Name(s) that is/are the subject of the complaint.] UDRP-F Para. 4(a)(ii).
[The Panel may consider any relevant aspects included in, but not limited to UDRP-F Para. 4(c)]
[c.][Specify in the space below why the Network Name(s) or Site Name(s) should not be considered as having been registered and being used in bad faith.] UDRP-F Para. 4(a)(iii).
[The Panel may consider any relevant aspects included in, but not limited to UDRP-F Para. 4(b)]
[5.]OTHER LEGAL PROCEEDINGS
[Identify any other legal proceedings that have been commenced or terminated in connection with or relating to any of the Network Name(s) or Site Name(s) that is/are the subject of the Complaint.] UDRP-FRule 5(b)(vi).
[6.]RESPONSE TRANSMISSION
The Respondent asserts that a copy of the Response, as prescribed by Forum’s Supplemental Rules, has been sent or transmitted to the Complainant, in accordance with UDRP-F Rule 2(b). UDRP-F Rule 5(b)(vii); Forum Supp. Rule 5.
[7.]The Respondent respectfully requests that the Administrative Panel denies the remedy requested by the Complainant.
[If appropriate and the allegation can be substantiated with evidence, the UDRP-F Rules provide that a Respondent may ask the Panel to make a finding of reverse Network Name or Site Name hijacking.] UDRP-F Rule 15(e).
[8.]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] UDRP-F Rule 5(b)(ix).
[The Response, not including annexed material, shall not exceed fifteen (15) pages and shall be submitted electronically in a document separate from any Annexes.] Forum Supp. Rule 5(c).
[The Respondent shall submit the Response, including annexed material, to the Forum at or to the assigned case coordinator directly.] Forum Supp. Rule 5(b) (see also Annex to the Supplemental Rules for permissible file types). [The Response may alternatively be submitted online; Respondent’s portion of any three member panel fees may be paid online as well. ]