Ciidrc.org



Canadian International Internet Dispute Resolution CentreRESPONSE TO COMPLAINTIN THE MATTER OF A COMPLAINT PURSUANT TOTHE CANADIAN INTERNET REGISTRATION AUTHORITY (CIRA) DOMAIN NAME DISPUTE RESOLUTION POLICY (the “Policy”)THE CIRA DOMAIN NAME DISPUTE RESOLUTION RULES (the “Resolution Rules”)The response must be filed in accordance with paragraph 5 of the Rules within twenty (20) days of the Date of Commencement of the Proceeding. The following form is intended for the assistance of the parties. The Response shall a)?be submitted in English or French; (b)?be submitted in hard copy or electronic form. CIIDRC Case Number:TO:Name of Complainantat its address for serviceAND TO:Canadian International Internet Dispute Resolution Centre (CIIDRC)500 – 666 Burrard StreetVancouver, BC, Canada V6C 3P6Phone: 604-684-2821Email: resolution@This Response is hereby submitted on __________ for decision in response to the Complaint filed in accordance with the CIRA Domain Name Dispute Resolution Policy (the “Policy”) and the CIRA Domain Name Dispute Resolution Rules (the “Resolution Rules”). DISPUTED DOMAIN NAME(S):____________________________________________________________________________________PARTIES TO THE DISPUTEREGISTRANT:Full Name of the Registrant:Name of Contact Person:Address:Telephone:E-Mail Address(s):Preferred method of communication (regular mail, email or telephone):REGISTRANT AUTHORIZED REPRESENTATIVE, if any:Name of Contact Person:Address:Telephone:E-Mail Address(s):Preferred method of communication (regular mail, email or telephone):ADMINISTRATVE PANELResolution Rule 5.2(c): Nominate to serve as Panelists up to five (5) candidates. Click here for a list of CIIDRC panelists available for selection.1.2.3.4.5.RESPONSE TO FACTUAL AND LEGAL ALLEGATIONS MADE IN COMPLAINTResolution Rule 5.2(d): Respond in accordance with the Policy, but without exceeding five thousand (5,000) words for the first domain name and up to one thousand (1,000) additional words for each additional domain name in dispute plus any Schedules. Respond specifically to the statements and allegations contained in the Complaint and include any and all bases for the Registrant to retain registration and use of the disputed domain name.The Registrant should be considered as having a legitimate interest in the domain name, as described in the relevant provisions of paragraph 3.4 of the Policy, for the following reasons:Paragraph 3.5 of the Policy requires the Registrant to specify whether the domain name(s) has (have) been registered in bad faith. SUMMARY OF, AND REFERENCES TO, THE RELEVANT CANADIAN LAWResolution Rule 5.2(e): provide a summary of, and references to, the relevant Canadian law, and if desired, indicate a preference for the application of the laws of a particular Canadian province or a territory.SUMMARY OF, AND REFERENCES TO, PRIOR DECISIONS IN CIRA PROCEEDINGSResolution Rule 5.2(f): provide a summary of, and references to, prior decisions in CIRA Proceedings or the dispute resolution proceedings which apply to domain names registered under any other top-level domain which the Complainant considers persuasive.Resolution Rule 5.2(g): at the option of the Registrant, state, but without exceeding one thousand (1000) words plus any Schedules, a claim pursuant to paragraph 4.6 of the Policy for costs of up to five thousand dollars ($5000) incurred by the Registrant in preparing for, and filing material in, the Proceeding and provide particulars of the basis for the claim and receipts or other evidence of the costs.LIST OF SCHEDULES Resolution Rule 5.2(h): “have any Schedules, together with an index thereto, annexed”. Note: A complete list of Annexes with all Annexes and their corresponding filenames clearly labeled and sequentially numbered must be provided by the Registrant. APPENDIX BCERTIFICATION OF THE REGISTRANT IN THE MATTER OF A RESPONSE IN RESPECT OF DOMAIN NAME REGISTRATION(S): The Registrant certifies that the information contained in this Response is to the best of the Registrant’s knowledge complete and accurate and that the assertions in this Response are warranted under the CIRA Domain Name Dispute Resolution Policy (the “Policy”) and the CIRA Domain Name Dispute Resolution Rules (the “Resolution Rules”) and under applicable Canadian law, as it now exists or as it may be extended by a good faith and reasonable argument.2. The Registrant will submit, with respect to any challenge to a decision in the Proceeding to the jurisdiction of a superior court of a province or territory of Canada having jurisdiction over the Registrant pursuant to the rules of such court or, if no such court has jurisdiction pursuant to its rules, to the jurisdiction of the superior court of the province or territory in Canada in the city in which the Provider has its principal place of business in Canada, as posted on the Provider’s website, or the jurisdiction of the superior court in the City of Ottawa in the Province of Ontario.Respectfully Submitted, __________________Signature__________________Name__________________DateThe Response and Annexes can be submitted electronically to: resolution@.Please remove all text boxes before filing a Responseas they are only intended to assist you with your Response. ................
................

In order to avoid copyright disputes, this page is only a partial summary.

Google Online Preview   Download