Name & Address of )

Name & Address of )

[Name & Address of )

Challenger])

)

(Qualification Challenger))

)

v.)Registered Items In Dispute:

)[list items]

[Name and Address of )

Respondent])

)

(Respondent))

)

COMPLAINT IN ACCORDANCE WITH

THE QUALIFICATION CHALLENGE POLICY

[1.]This Complaint is hereby submitted for decision in accordance with the Qualification Challenge Policy (“Policy” or “QCP”), adopted by the Internet Corporation for Assigned Names and Numbers (ICANN), and the Qualification Challenge Rules (“Rules”), adopted by ICANN, and the Forum’s QCP Supplemental Rules (Supp. Rules). Rule 3(b)(i).

[2.]QUALIFICATION CHALLENGER INFORMATION

[a.]Name:[enter full name of Qualification Challenger]

[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 Qualification Challenger’s authorized representative in the administrative proceeding.] Rule 3(b)(ii).

The Qualification Challenger’s preferred method for communications directed to the Qualification Challenger in the administrative proceeding: Rule 3(b)(iii).

Electronic-Only Material

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

[b.]Address:[enter one email 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 Qualification Challenger chooses to have this dispute heard before a [enter one: a) single-member administrative panel; b) three-member administrative panel]. Rule 3(b)(iv).

[If Qualification Challenger elects 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 3(b)(iv).

[3.]RESPONDENT INFORMATION

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

[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 3(b)(v).

[4.]DISPUTED REGISTERED ITEM(S)

[a.]The following Registered Items(s) is/are the subject of this Complaint: Rule 3(b)(vi).

[enter the disputed Registered Items(s) here without the “

[b.]Registrar Information: Rule 3(b)(vii).

[i.] Registrar’s Name:[enter the Registrar Company with whom the registered item(s) is/are registered.]

[ii.] Registrar Address:[enter Registrar’s address]

[iii.] Telephone Number:[enter Registrar’s phone number]

[iv.] E-Mail Address:[enter Registrar’s e-mail address]

[5.]FACTUAL AND LEGAL GROUNDS

This Complaint is based on the following factual and legal grounds: Rule 3(b)(ix). The analysis in this section may require more space than provided, but the entire Complaint shall not exceed ten (10) pages. Supp. Rule 4(a).

[a.][Specify in the space below the manner in which the Registrant has not complied with the Registration Requirements for the Registered Item, as described in Appendix L.] Rule 3(b)(ix); Policy ¶ 4(b)(i).

OR

[b.][Specify in the space below the manner in which the Registrant has not provided sufficient evidence of compliance with the Registration Requirements for the Registered Item, as described in Appendix L.] Rule 3(b)(ix); Policy ¶ 4(b)(ii).

OR

[c.][Specify in the space below the manner in which the Registrant is no longer in good standing or licensed in Registrant’s designated profession and in the designated jurisdiction.] Rule 3(b)(ix); Policy ¶ 4(b)(iii).

[6.]REMEDY SOUGHT

The Qualification Challenger requests that the Panel issue a decision that the domain-name registration be [“transferred” or “cancelled” – Note: if Qualification Challenger prevails and has requested “transfer,” the Qualification Challenger must apply to register the Registered Item within 21 days. Cancellation simply takes it from Respondent and makes the Registered Item available to register by anyone who meets the Registration Requirements.] Rule 3(b)(x); Policy ¶ 5(f).

[7.]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 3(b)(xi).

[8.]COMPLAINT TRANSMISSION

The Qualification Challenger asserts that a copy of this Complaint, together with the cover sheet as prescribed by the Forum’s Supplemental Rules, has been sent or transmitted to the Respondent (domain-name holder), in accordance with Rule 2(b), and has been sent or transmitted to the Registrar, in accordance with Supp Rule 4(e). Rule 3(b)(xii); Supp. Rule 4(c), (e).

[9.]MUTUAL JURISDICTION

The Qualification Challenger will submit, with respect to any challenges to a decision in the administrative proceeding canceling or transferring the Registered Item, to [choose one jurisdiction: a) the location of the principal office of the Registrar; or b) New York, U.S.A.; or c) the Registered Item holders address as shown for the registration of the Registered Item in Registry Operator’s Whois database at the time the Complaint is submitted to the Qualification Challenge Provider] Rule 3(b)(xiii); Rule (1).

[10.]CERTIFICATION

Qualification Challenger agrees that its claims and remedies concerning the registration of the Registered Item or the dispute’s resolution shall be solely against the Respondent and waives all such claims and remedies against (a) the Qualification Challenge Provider (Forum) and Panelist(s), except in the case of deliberate wrongdoing, (b) the Registrar, (c) the Registry Operator, and (d) the ICANN (Internet Corporation for Assigned Names and Numbers), as well as their directors, officers, employees, and agents.

Qualification Challenger certifies that the information contained in this Complaint is to the best of Qualification Challenger’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,

______

[Signature]

______

[Name]

______

[Date]

[Annex any documentary or other evidence, including a copy of the Policy applicable to the Registered Item(s) in dispute and evidence of the Qualification Challenger’s qualification to register the Registered Item under the Qualification Requirements, together with a schedule indexing such evidence.] Rule 3(b)(xv).

[The Complaint, not including annexed material, shall not exceed ten (10) pages.] Supp. Rule 4(a).

[The Qualification Challenger shall submit three (3) copies of the Complaint, including annexed material, to the Forum if the Qualification Challenger requested a single-member panel. If the Qualification Challenger requested a three (3) member panel, the Qualification Challenger shall submit five (5) copies of the Complaint, including annexed material, to the Forum. If the Respondent requests a three (3) member panel, the Qualification Challenger may be asked to submit additional copies of the Complaint.] Supp. Rule 4(b).