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Asian Domain Name Dispute Resolution Centre
(Hong Kong Office)

COMPLAINT IN ACCORDANCE WITH THE
UNIFORM RAPID SUSPENSION SYSTEM RULES AND PROCEDURE

This form shall be used to apply to Asian Domain Name Dispute Resolution Centre (ADNDRC) pursuant to the Uniform Rapid Suspension System Rules for Domain Name Dispute Resolution, approved by the Internet Corporation for Assigned Names and Numbers (ICANN) on 28 June 2013 (the Rules), the Uniform Rapid Suspension System Procedure, approved by ICANN on 01 March 2013 (the Procedure) and the ADNDRC Supplemental Rules for Uniform Rapid Suspension System effective from 8 September 2014 (the Supplemental Rules). (Note: In case any section of the form is not applicable, please put in N/A”.)

Choice of ADNDRC Office to Administer the Proceedings
The Complainant hereby chooses the Hong Kong Office of the ADNDRC to administer the domain name dispute proceedings referred to in this Complaint.

   
1. Disputed Domain Name(s) and the Concerned Registry Operator(s) and Registrar(s):
 
  List of Disputed Domain Name(s):
 
  •        Registry Operator:
  •        Registrar:
  •   1.  
     
             Total 0 Domain Name(s)
       
    2. Details of the Parties:
       
      COMPLAINANT:
       
    Name: *
    Address: *
    City: *
    State:
    Postcode:
    Country: *
    Tel No: *
    Fax No: *
    Email: *
    Legal Status:
    Place of Incorporation:
    Principal Place
    of Business:
       
    Authorized Representative (if any):
    Name:
    Address:
    City:
    State:
    Postcode:
    Country:
    Tel No:
    Fax No:
    Email:
       
       
     
       
      RESPONDENT:
       
    Name: *
    Address: *
    City: *
    State:
    Postcode:
    Country: *
    Tel No: *
    Fax No: *
    Email: *
    Legal Status:
    Place of Incorporation:
    Principal Place of Business:
       
    Authorized Representative (if any):
    Name:
    Address:
    City:
    State:
    Postcode:
    Country:
    Tel No:
    Fax No:
    Email:
       
     
    3.
    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  
     
      1.  
       
     
    4.
    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)  
     
      1.  
       
       
    5. Selection of the Factual and Legal Grounds on which the Complaint is made:
       
     
    The registered domain name(s) is/are identical or confusingly similar to a word mark:
      (i) for which the Complainant holds a valid national or regional registration and that is in current use; or
      (ii) that has been validated through court proceedings; or
      (iii) that is specifically protected by a statute or treaty in effect at the time the URS complaint is filed.
         
    Registrant has no legitimate right or interest to the domain name(s); and
         
    The domain(s) was/were registered and is being used in bad faith. A non-exclusive list of circumstances that demonstrate bad faith registration and use by the Registrant include:
         
      (i) Registrant has registered or acquired the domain name(s) primarily for the purpose of selling, renting or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of documented out-of pocket costs directly related to the domain name;
      (ii) Registrant has registered the domain name(s) in order to prevent the trademark holder or service mark from reflecting the mark in a corresponding domain name, provided that Registrant has engaged in a pattern of such conduct; or
      (iii) Registrant registered the domain name(s) primarily for the purpose of disrupting the business of a competitor; or
      (iv) By using the domain name(s) Registrant has intentionally attempted to attract for commercial gain, Internet users to Registrant’s web site or other on-line location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of Registrant’s web site or location or of a product or service on that web site or location.
    (v) Others
         
         
    Screen shots of the Disputed Website(s)  
      1.  
         
    6. Explanatory Statement (Optional) (Word limit shall be 500 words maximum.)
       
     
       
    7. Remedy Sought:
       
      Suspend the Disputed Domain Name(s)
     
    8.
    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  
     
      1.  
       
       
    9. Mutual Jurisdiction:
       
      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.
       
     
    Location of the Registry Operator
    Location of the Registrant
       
    10. Other Relevant Details:
       
     
       
    11. Additional Information:
       
     
    (i) Annex any additional documentation to support the Complaint, together with a schedule indexing such document(s).
    (ii) The Complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.
    (iii) 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.
    (iv)

    Enclose appropriate fees in accordance with Article 16 of the Supplemental Rules.

    (v) 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”)
    (vi) Any communication by a party shall be copied to the other party and the ADNDRC’s Hong Kong Office.
       
    12. Payment
       
      As required by the Rules and Supplemental Rules, payment in the amount of USD
     
      (852) 25252381. Please do not include credit card details in the Complaint or any covering emails to the Center).
     
    13. Annexures
       
     
    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].  
       
     
      1.  
       
    14. Certificate
       
      Statement of Good Faith:
     
    The Complaint is not being files for any improper basis and there is a sufficient good faith basis for filing the Complaint.
       
      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.
     
      Respectfully submitted,
       
     
    Name
    Date 2017-12-14 (y-m-d)
    Electronic Signature If you have an electronic signature that requires upload, please upload here;   
     
    .  
      If you do not have an electronic signature, please enter your signature directly via the text box here.
     
       
    Verification b22cc
      Please enter below the characters displayed above
     
     
     
     
         
     
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