ASIAN DOMAIN NAME DISPUTE RESOLUTION CENTRE (Form C)
COMPLAINT IN ACCORDANCE WITH THE UNIFORM DOMAIN NAME DISPUTE RESOLUTION POLICY
This form shall be used to apply to Asian Domain Name Dispute Resolution Centre (ADNDRC) pursuant to the Uniform Policy for Domain Name Dispute Resolution, approved by the Internet Corporation for Assigned Names and Numbers (ICANN) on 24 October 1999 (the Policy), the Rules for Uniform Domain Name Dispute Resolution Policy, approved by ICANN Board of Directors on 28 September 2013 (the Rules) and the ADNDRC Supplemental Rules for Uniform Domain Name Dispute Resolution Policy effective from 31 July 2015 (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 Beijing Office of the ADNDRC to administer the domain name dispute proceedings referred to in this Complaint.
The ICANN Uniform Domain Name Dispute Resolution Policy provides, at Paragraph 4(a), that in the administrative proceeding, the complainant must prove that EACH of the following three elements is present:
The disputed domain name(s) is/are identical or confusingly similar to a trademark or service mark in which the Complainant has rights:
The Respondent has no rights or legitimate interests in respect of the domain name(s):
The disputed domain name(s) has/have been registered and is/are being used in bad faith:
The Complainant requests that the disputed domain name(s) be:
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 in accordance with the Rules to the Beijing Office of ADNDRC:
Enclose appropriate fees in accordance with Article 15 of the Supplemental Rules.
The following documents should be consulted in connection with preparing this Complaint:
ICANN Uniform Domain Name Dispute Resolution Policy (“the Policy”);
ICANN Rules for Uniform Domain Name Dispute Resolution Policy (“the Rules”);
ADNDRC Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (“the Supplemental Rules”)
Any communication by a party shall be copied to the other party and the ADNDRC’s Beijing Office.
The 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) ADNDRC, or any of its Offices, or any Panelist(s), except in the case of deliberate wrongdoing,, (b) the registrar, (c) the registry administrator, and (d) the Internet Corporation for Assigned Names and Numbers, as well as their directors, officers, employees, and agents.
The Complainant certifies that the information contained in this Complaint is to the best of the 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 the Rules and under applicable law, as it now exists or as it may be extended by a good-faith and reasonable argument.