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File a usNDP Complaint

Note: These instructions summarize certain portions of the United States Nexus Dispute Policy (usNDP), usNDP Rules, and the FORUM's usNDP 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 usNDP Complaints Properly
Parties interested in filing a usNDP Complaint must do so according to the usNDP Rules and the FORUM’s usNDP 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 usNDP 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 Supplemental Rule (hereinafter "Supp. Rule") 4(a).

  2. Include a request that the complaint be submitted for decision in accordance with the United States Nexus Dispute Policy (hereinafter "Policy") and Rules. United States Nexus Dispute Policy Rule (hereinafter "Rule") 3(c)(i).

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

  4. Specify the preferred method for communicating with the Complainant. 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(c)(iii).

  5. Provide the name of the Registrant (domain name holder), including the postal address, e-mail address, telephone and facsimile numbers, and any other contact information available to Complainant which will allow the National Arbitration Forum to send the complaint in compliance with Rule 2(a). Rule 3(c)(iv). (Contact information may be found at a "Whois" database such as:

  6. Specify the domain name that is the subject of the complaint. If more than one domain name held by the same Registrant is in dispute, all may be included in one complaint. Rule 3(c)(v), Rule 3(d).

  7. Identify with whom the domain name(s) are registered at the time the complaint is filed. Rule 3(c)(vi).

  8. Describe the grounds on which the complaint is made. In particular, the complaint must describe (Policy 3(a); Rule 3(c)(vii); and Supp. Rule 4(a)):

    1. why Registrant should not be considered to be (a) a United States citizen, (b) a permanent resident of the United States of America or any of its possessions or territories, or (c) primarily domiciled in the United States of America or any of its possessions; OR

    2. how Registrant is not a United States entity or organization that is (a) incorporated within one of the fifty (50) U.S. states, the District of Columbia, or any of the United States possessions or territories, or (b) organized or otherwise constituted under the laws of a state of the United States of America, the District of Columbia, or any of its possessions or territories (including a federal, state, or local government of the United States or a political subdivision thereof, and non-commercial organizations based in the United States); OR

    3. how Registrant is not a foreign entity (including an individual) or organization that has a bona fide presence in the United States of America. In order to have a "bona fide" presence, Registrant must have real and substantial lawful connections with, or lawful activities in, the United States of America.

  9. Identify any other legal proceedings that have been commenced or terminated in connection with or relating to any of the domain names that are the subject of the complaint. Rule 3(c)(viii).

  10. 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 Registrant in accordance with Rule 2(b). Rule 3(c)(ix), and Supp Rule 4(c).

  11. State that the Complainant will submit to the jurisdiction of the courts in one specified jurisdiction, as provided in the definition of Mutual Jurisdiction in Rule 1, if any challenge is made to a decision in the arbitration proceeding. Rule 3(c)(x).

  12. Conclude with the following statement followed by the signature of the Complainant or its authorized representative:

    "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 National Arbitration Forum and panelists, except in the case of deliberate wrongdoing, (b) the registrar, (c) the registry administrator, and (d) the Department of Commerce, 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." Rule 3(c)(xi).

  13. Attach any documents or other evidence, upon which the complaint relies, together with a schedule indexing such evidence. Rule 3(c)(xii).

  14. Include the appropriate fee in accordance with the Forum's Supplemental Rules and Fee Schedule (Supp. Rule 16). Rule 15.

File Your usNDP Complaint
Pursuant to Supp. Rule 4(b), send the Complaint, along with any other attached evidence, and the Complaint Transmittal Sheet to The Complaint and attachments should be in Microsoft Word, PC format.

If any portion of the Complaint cannot be filed electronically, it must be submitted either by fax or by mail using the addresses 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

In addition, in accordance with Paragraph 3(c)(ix) of the Rules, the Complainant must also send or transmit its Complaint to the Registrant.

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