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File a QCP Complaint

Note: These instructions summarize certain portions of ICANN's Qualification Challenge Policy (QCP), QCP Rules, and the FORUM's QCP Supplemental Rules that concern the filing of a Complaint. This summary is not a substitute for reading and understanding the Rules governing this proceeding.

File QCP Complaints Properly
Parties interested in filing a QCP Complaint must do so according to the QCP Rules and the FORUM’s QCP Supplemental Rules. Please read and review these rules prior to filing your Complaint.

If your Complaint involves one or more Internationalized Domain Names (IDNs), please proceed to our Internationalized Domain Names page for additional filing instructions.

Prepare Your QCP Complaint
A model Complaint form is available online in MS Word rich text format. You may download this form to assist you as you proceed through these instructions.
  1. Excluding attachments, the complaint shall not exceed ten (10) pages. National Arbitration Forum QCP Supplemental Rule (hereinafter "Supp. Rule") 4(a).

  2. Include a request that the complaint be submitted for decision in accordance with the Qualification Challenge Policy and Rules. ICANN Rules for Qualification Challenge Policy (hereinafter "Rule") 3(b)(i).

  3. Include the name, postal address, e-mail address, telephone and facsimile numbers of the Qualification Challenger. The complaint must also include the name of the representative who is authorized to act for the Qualification Challenger in the proceeding. Rule 3(b)(ii).

  4. Specify the preferred method for communicating with the Qualification Challenger. This shall specifically state the person to be contacted, the medium for contact and the address information. The complaint shall include this information for electronic transmission and hard copies. Rule 3(b)(iii).

  5. Designate whether the Qualification Challenger requests one arbitrator or a panel of three arbitrators.

    • If the Qualification Challenger requests a one-member panel, the Qualification Challenger shall submit three (3) copies of the complaint to the National Arbitration Forum. Supp. Rule 4(b).

    • When a one-member panel is requested, the National Arbitration Forum shall appoint a neutral and impartial arbitrator. Rule 6(b).

    • If Qualification Challenger opts for a three-member panel, the Qualification Challenger must provide names and contact information for three (3) candidates, one of whom will serve as a panel member. These candidates may be chosen from any ICANN approved provider's list of potential panelists. Rule 3(b)(iv). The other two panelists shall be selected in accordance with Rule 6(e). (For a list of National Arbitration Forum panelists go to: List of Qualified Dispute Resolution Panelists.

    • If the Qualification Challenger requests a three-member panel, the Qualification Challenger shall submit five (5) copies of the complaint. For three-member panels requested by the Respondent, the Qualification Challenger may be asked to submit additional copies of the complaint. Supp. Rule 4(b).

  6. Provide the name of the Respondent (Registered Item holder), including the postal address, e-mail address, telephone and facsimile numbers, and any other contact information available to Qualification Challenger that will allow the National Arbitration Forum to send the complaint in compliance with Rule 2(a). Rule 3(b)(v). (Contact information may be found at a "Whois" database such as:

  7. Specify the Registered Item that is the subject of the complaint. If more than one Registered Item held by the same Respondent is in dispute, all may be included in one complaint. Rule 3(b)(vi); Rule 3(c).

  8. Identify with whom the Registered Item(s) are registered at the time the complaint is filed. Rule 3(b)(vii). (To identify the current domain Registrar, go to a "Registry Whois" database or try

  9. Describe the grounds on which the complaint is made. In particular, the complaint must describe:

    1. the manner in which the Registered Item Holder does not comply with the Registration Requirements described in Appendix L; OR

    2. how the Registrant has not provided sufficient evidence of compliance with the Registration Requirements described in Appendix L; OR

    3. how the Registrant is no longer in good standing or licensed in Registrant's designated profession and in the designated jurisdiction. (Policy Paragraph 4(b)).

  10. Specify the remedies sought. The Policy limits the remedies available to cancellation of the Registered Item or transferring the Registered Item registration to the Complainant. Rule 3(b)(x), Policy Paragraph 5(f).

  11. Identify any other legal proceedings that have been commenced or terminated in connection with or relating to any of the Registered Items that are the subject of the complaint. Rule 3(b)(xi).

  12. State that a copy of the Complaint, together with the "Complaint Transmittal Cover Sheet" (available on the National Arbitration Forum's website), has been sent or transmitted to the Respondent in accordance with Rule 2(b) and to the Registrar in accordance with Supp. Rule 4(e). Rule 3(b)(xii).

  13. State that the Qualification Challenger will submit to the jurisdiction of the courts, if any challenge is made to a decision in the arbitration 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 holder's 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) ("Mutual Jurisdiction").

  14. Conclude with the following statement followed by the signature of the Qualification Challenger or its authorized representative:
    "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 (National Arbitration 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."
    Rule 3(b)(xiv).

  15. Attach any documents or other evidence necessary to establish Policy paragraph 4(b), a copy of the Policy applicable to the Registered Item(s), and any evidence of the Qualification Challenger's qualification to register the Registered Item under the Qualification Requirements, together with a table of contents of the evidence. Rule 3(b)(xv).

  16. Include the appropriate fee in accordance with the Forum's Supplemental Rules and Fee Schedule (Supp. Rule 17). Rule 19.

File Your QCP Complaint
Pursuant to Supp. Rule 4(d), send the Complaint, any other attached evidence, the Complaint Transmittal Sheet, and a copy of ICANN's Qualification Challenge Policy by email to Attachments should be in Microsoft Word, PC Format. You must also send us your complaint by either fax or mail using the address and numbers below:

Regular US Post:
National Arbitration Forum
PO Box 50191
Minneapolis, MN 55405

FedEx, UPS, or Overnight Mailings:
National Arbitration Forum
6465 Wayzata Blvd. #470
St. Louis Park, MN 55426

Fax: 612-235-3355
Toll-free Fax: 866-743-4517

Contact us via email or call (800) 474-2371.


National Arbitration Forum
P.O. Box 50191
Minneapolis, MN 55405
Tel: 800-474-2371
Fax: 612-235-3355
Toll Free Fax: 866-743-4517

FedEx and UPS Deliveries