FA[ ]
(Complainant)
v.
[Name of Respondent]
(Respondent)
RESPONDENT’S PAPERS OPPOSING COMPLAINANT’S STANDING
TO FILE A COMPLAINT UNDER THE
TRADEMARK POST DELEGATION DISPUTE RESOLUTION POLICY
[1.]Respondent’s Opposition to Complainant’s standing is hereby submitted for Threshhold Reviewunder the Trademark Post Delegation Dispute Resolution Policy (PDDRP) and the Forum’s Supplemental Rules (Supp. Rules). PDDRP9.3; Supp. Rule 5(a).
[2.]RESPONDENT INFORMATION
[a.]Name: [enter full name of Registry]
[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 KNOWN
[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)]
[4.] FACTUAL AND LEGAL GROUNDS
In the space below, please provide your arguments regarding why Complainant lacksstandingto bring this PDDRP claim. [PDDRP 9.3.]. Your contentions shall not exceed 1,500 words. You may include any arguments related to PDDRP 7.2.3(d) and/or PDDRP 9.2.
[5.] EVIDENCE
Annex any documents supporting Respondent’s contentions.See the Forum’s Supplemental Rules for the Rules governing Annexes.
[6.]REMEDY SOUGHT
The Threshold Review Panel is limited to dismissing the complaint or moving it to a hearing. No additional remedies are possible.
[16.]CERTIFICATIONS
Provide this statement: “Respondent 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 domain-name holder and waives all such claims and remedies against (a) the Forum and panelists, except in the case of deliberate wrongdoing, (b) the registrar(s), and (c) the Internet Corporation for Assigned Names and Numbers, as well as their directors, officers, employees, and agents.
Respondent certifies that the information contained in this Respondent’s Opposition to Standing is to the best of Respondent's knowledge complete and accurate, that this Respondent’s Opposition to Standing 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]
[The Respondent’s Opposition to Standing and Annexes shall be submitted electronically, in accordance with the electronic submission requirements listed in the Annex to the Supplemental Rules, to .] [PDDRP 7.1, Supp Rule 4].
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