of the Parties:
Indicate reasons why the Person / Entity identified in the Complaint has been identified as the Respondent: (Copy of database search(es) should be attached to this Complaint.)
Upload Whois Information
Complaint: (Please specify the trademark(s) or service mark(s) on which the Complaint is based and, for each mark, describe the goods or services, if any, in connection with which the mark is used. If applicable, please attach copies of all registration certificates.)
Copies of Trademark(s) or Service mark(s)
of the Factual and Legal Grounds on which
the Complaint is made:
limit shall be 500 words maximum.)
Suspend the Disputed Domain
Indicate whether there are 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:
Supporting documentation(s), if any
Complainant will submit, with respect to any challenges to a determination in this URS proceeding, to the jurisdiction of the courts in at least one specified Mutual Jurisdiction.
Other Relevant Details:
Annex any additional documentation to support the Complaint, together with a schedule indexing such document(s).
The Complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.
This Complaint shall be submitted in electronic form via the ADNDRC Online Submission System in accordance with the Rules to the Hong Kong Office of ADNDRC.
Enclose appropriate fees in accordance with Article 16 of the Supplemental Rules.
The following documents should be consulted in connection with preparing this Complaint:
ICANN Uniform Rapid Suspension System Procedure (“the Procedure”);
ICANN Uniform Rapid Suspension System Rules(“the Rules”);
ADNDRC Supplemental Rules for Uniform Rapid Suspension System (“the Supplemental Rules”)
Any communication by a party shall be copied to the other party and the ADNDRC’s Hong Kong Office.
As required by the Rules and Supplemental Rules, payment in the amount of USD
has made by Credit Card via PayPal. For payment-related queries or difficulties, please call
(852) 25252381. Please do not include credit card details in the Complaint or any covering emails to the Center).
The Rules provide that a Complaint or Response, including any annexes, shall be submitted electronically. Please note there is a files size limit of 10MB (ten megabytes) for any one attachment, with an overall limit for all submitted materials of no more than 50MB (fifty megabytes).
Add annexes below:
[Additionally, to avoid any uncertainty, it is requested that any Annexes (and their corresponding filenames) be clearly labeled and sequentially numbered (i.e. Annex1, Annex2, Annex3, etc), without space, and a complete list of Annexes supplied].
Statement of Good Faith:
Agreement to Terms:
Complainant 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 Provider and Examiner, except in the case of deliberate wrongdoing, (b) the Registrar, (c) the Registry Operator, 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.