CIIDRC Supplemental Rules - Canadian International Internet Dispute Resolution Centre

OF THE CANADIAN INTERNATIONAL INTERNET DISPUTE RESOLUTION CENTRE (the “Centre” or the “CIIDRC” or the “Provider”) FOR THE UNIFORM DOMAIN NAME DISPUTE RESOLUTION POLICY (the “Policy”) AND THE RULES FOR THE UNIFORM DOMAIN NAME DISPUTE RESOLUTION POLICY (the “UDRP Rules”) approved by the Internet Corporation for Assigned Names and Numbers (“ICANN”)

NOTE: The UDRP Rules provide that Supplemental Rules shall not be inconsistent with the Policy or the UDRP Rules and shall cover such topics as fees, word and page limits and guidelines, file size and format modalities, the means for communicating with the Centre and the Panel, and the form of cover sheets.

The Supplemental Rules

(In effect as of May 9, 2018)

Application
Definitions
Communications
Complaint and Annexes
Administrative Review of the Complaint
Response and Annexes
Case Administrator
Panelist Appointment Procedures
Panelist Declaration
Panel Decisions
Settlement and Termination of the Proceeding
Fees
Word Limits
File Size and Format Modalities
Amendments of the Supplemental Rules
Exclusion of Liability

Schedules Index

APPLICATION
1. These Supplemental Rules (the “Supplemental Rules”) apply in connection with administrative proceedings for the resolution of disputes under the Policy and also in connection with the UDRP Rules.
2. To the extent that these Supplemental Rules conflict with the UDRP Rules, the UDRP Rules supersede.
3. The version of these Supplemental Rules in effect at the time a Complaint is submitted to the Centre applies to the administrative proceeding related to the Complaint.
DEFINITIONS
Any word or phrase defined in the Policy or in the UDRP Rules has the same meaning in these Supplemental Rules.
A reference to the singular shall include a reference to the plural and vice versa.
COMMUNICATIONS
1. No party to a proceeding or person purporting to represent a party may communicate directly with a Panel, but may do so only via the Centre and initially with the Case Administrator appointed with respect to the administrative proceeding.
2. Any submission or other communication to the Centre must be made:
  1. By email to the email address of the Centre; or
  2. Via any electronic system established by the Centre for the administration of proceedings; or
  3. By any other means or manner agreed with the Centre.
  4. After an administrative proceeding has been commenced, a party to the proceeding who sends any such communication to the Centre shall at the same time send a copy of that communication to any other party to the proceeding.
3. Archive
  The Centre shall maintain an archive of all communications received or made with respect to administrative proceedings conducted by it and all such communications shall be so retained in the archive for three years after their deposit.
COMPLAINT AND ANNEXES
1. The Complaint that institutes the administrative proceeding and its annexes shall be submitted electronically to the Centre and shall request a decision with respect to the disputed domain name in accordance with the Policy, the UDRP Rules and these Supplemental Rules.
2. The Complaint shall be in compliance with the word and page limits set out in Supplemental Rule 13 and the file size and format modalities set out in Supplemental Rule 14.
3. A Complaint shall be submitted via the CIIDRC online platform in the form set out in Schedule A to these Supplemental Rules.
4. A Complaint shall be expressed in the language of the registration agreement of the relevant domain name or in the English language.
5. Upon receipt of the Complaint, the Centre shall assign it a case number.
ADMINISTRATIVE REVIEW OF THE COMPLAINT
1. As soon as practicable after the Centre receives the Complaint and Annexes, the Centre shall conduct an administrative review of the same to assess compliance with the Policy, the UDRP Rules and these Supplemental Rules.
2. If the Centre finds that the Complaint is in such compliance, it shall then forward to the Respondent electronically a copy of:
  1. a completed Notification of Commencement of Proceedings in the form set out in Schedule C to these Supplementary Rules;
  2. a Notice with login information and the link to the Complaint and Annexes; and
  3. the Written Notice of the Complaint in the form set out in Schedule D or Schedule E to these Supplemental Rules, depending on whether the Complainant has requested a single member or a three-member Panel.
3. If the Centre finds that the Complaint in not in such compliance, it shall notify the Complainant of all deficiencies and invite the Complainant to rectify them.
4. If the Complainant rectifies the deficiencies to the satisfaction of the Centre, the Centre shall then forward to the Respondent electronically a copy of:
  1. a completed Notification of Commencement of Proceedings in the form set out in Schedule C to these Supplemental Rules;
  2. a Notice with login information and the link to the Complaint and Annexes; and
  3. the applicable Written Notice of the Complaint referred to in 5 (b) (iii) above.
5. If the Complainant does not rectify the deficiencies to the satisfaction of the Centre within 5 calendar days of notification, the Centre shall notify the Complainant that the Complaint is deemed to have been withdrawn, without prejudice to the right of the Complainant to file a fresh Complaint.
6. Where a Complaint is so deemed to have been withdrawn, the Complainant may within 10 days of being so advised, apply to the Centre for a refund of the whole or a part of the initial fixed fee prescribed in accordance with UDRP Rule 19 and the Centre shall determine the outcome of any such application in the exercise of its discretion.
7. The date of commencement of the administrative proceeding is the date on which the Centre completes its responsibilities under Supplemental Rule 5 in connection with sending a completed Notification of Commencement of Proceedings, login information and the link to the Complaint and Annexes, posted on the CIIDRC online platform, and the Written Notice to the Respondent.
RESPONSE AND ANNEXES
The Response and its Annexes shall be submitted via the CIIDRC online platform to the Centre in compliance with the word and page limits and the file size and format modalities set out respectively in Supplemental Rules 13 and 14.
CASE ADMINISTRATOR
1. The Centre shall appoint from its staff a case administrator (“Case Administrator”) who shall deal with administrative aspects of the administrative proceeding and the proceedings. The Centre shall advise the parties of the Case Administrator’s appointment when it is made.
2. The Case Administrator may provide administrative assistance to the Panel or a Panelist. The Case Administrator is neutral as between the parties and has no power to make a decision on any substantive issue in an administrative proceeding or influence any such decision.
PANELIST APPOINTMENT PROCEDURES
1. Proceedings under the UDRP are conducted before single member and three member panels. The Complainant and the Respondent both have the opportunity to request a single member panel or a three-member panel to preside over the administrative proceeding in question.
2. Single Member Panel
  This Supplemental Rule deals with the appointment of the single member Panel when neither party has requested a three-member Panel. The Centre will appoint the single Panelist from its own published list of Panelists:
  1. after the Respondent has submitted a Response and neither party has requested a three-member Panel, or
  2. when a Respondent does not submit a Response and the time for filing a Response has lapsed, or
  3. when a Respondent does not make the payment provided by UDRP Rule 5(d) within the time specified.
3. Three Member panel
  This Supplemental Rule deals with the first and second Panelists of a three-member Panel where one or other of the parties have requested a three-member Panel. The UDRP Rules require each party to the administrative proceeding to submit the names of three candidates to serve as one of the three Panelists who will constitute the three-member Panel where:
  1. under UDRP Rule 3(b)(iv) the Complainant has elected to have a three member Panel and the Complainant is required to submit a list of three candidates, from which list, one Panel member will be chosen by the Centre; and under UDRP Rule 5(c)(v) the Complainant having chosen to have a three member Panel, the Respondent must submit a list of three candidates, from which list, one Panel member will be chosen by the Centre; or
  2. the Complainant has elected to have a single member Panel, but the Respondent has elected under UDRP Rule 5(c)(iv) to have a three member Panel, so that each of the Complainant and the Respondent must submit a list of three candidates from each of which lists one Panel Member will be chosen by the Centre.
4. When the respective party prepares its list of three candidates, the names of the candidates included in the list shall be drawn from the list of Panelists of any of the providers approved by ICANN and not necessarily from the list of Panelists of the Centre.
5. When the respective party has compiled its list of candidates, it shall send them to the Centre in writing and in the order of its preference for appointment.
6. In making the appointment of each of the two Panelists appointed pursuant to the UDRP Rules, the Centre shall give due regard to the order of preference expressed by each party in its list of candidates, subject to each candidates’ availability to serve on the Panel.
7. The process just described results in the Complainant and the Respondent each having contributed to the appointment of one of the two members of a three-member Panel.
8. The Third or Presiding Panelist on a Three Member Panel
  This Supplemental Rule now deals with the appointment of the third or Presiding Panelist on a three-member Panel. The third Panelist shall be the Presiding Panelist and shall be responsible for coordinating the functions of the members of the Panel.
9. The process for the appointment of the third or Presiding Panelist starts with the Centre submitting to each party a list of five candidates in accordance with UDRP Rule 6(e). In response, the parties shall indicate to the Centre their order of preference as between the five candidates.
10. The Centre will select one from among the submitted list of five candidates in a manner that reasonably balances the preferences of both parties; and the candidate so selected shall be the third or Presiding Panelist.
11. If a party does not express to the Centre its order of preferences between the five candidates, the Centre will appoint the third or Presiding Panelist without that party’s input.
12. Further Appointment
  If, after a Panelist has been appointed but before the Panel has rendered its decision, a Panelist dies, is unable to act, or refuses to act, the Centre will, upon request by either party, appoint a replacement Panelist.
PANELIST DECLARATION
1. A candidate for appointment as a Panelist must submit a Declaration of Impartiality and Independence to the Centre in the form of Schedule G to these Supplemental Rules.
2. The Declaration of Impartiality and Independence must be provided to the Centre prior to the appointment of the candidate as a Panelist.
PANEL DECISIONS
1. The Panel shall render a decision in the administrative proceeding in accordance with the requirements of UDRP Rule 15.
2. The decision shall be of a length that the Panel deems appropriate.
3. The Centre shall communicate the full text of a decision to each party, the Registrar, and ICANN in accordance with UDRP Rule 16.
4. Correction of Panel Decision
  Within seven days of receiving the decision, the Centre or a party may, by written notice to a Panel and other parties, request the Panel to correct in the decision any clerical mistake, typographical error, or any errors of a similar nature.
5. Upon request under Supplemental Rule 10(d) or on its own initiative, a Panel may correct any clerical mistake, typographical error, or any errors of a similar nature. Any correction made by a Panel shall become a part of the decision.
6. The Centre shall communicate the full text of any corrected decision to each party, the Registrar(s), and ICANN in accordance with UDRP Rule 16.
7. The Centre will publish the decision on the CIIDRC online platform and the CIIDRC website.
8. All requests pursuant to Policy paragraph 4(j) and UDRP Rule 16(b) to have a portion of a decision redacted, must be made in the Complaint, the Response, or an Additional Submission that is submitted before the Panel’s decision is published.
SETTLEMENT AND TERMINATION OF THE PROCEEDING
1. UDRP Rule 17 provides for the termination of an administrative proceeding because the parties have agreed on a settlement of the administrative proceeding before the Panel’s decision.
2. In those cases where there are settlement discussions and settlement take place, the procedural steps to be followed are set out in UDRP Rule 17.
3. The settlement steps include a Standard Settlement Form of the Centre which is to be completed by the parties and submitted to the Centre. That form is set out in Schedule H to these Supplemental Rules.
FEES
1. The Complainant shall pay to the Centre an initial fixed fee for the administrative proceeding.
2. The initial fixed fee is to be paid in accordance with Schedule B of these Supplemental Rules.
3. Other provisions relating to fees, including any refund, are specified in Schedule B to these Supplemental Rules.
WORD LIMITS
Complaint
The word limit for the description of the grounds on which the Complaint is made pursuant to UDRP Rule 3(b) (ix) is 5,000 words.
Response
The word limit for the portion of the Response responding to the statements and allegations in the Complaint and including the basis for the Respondent to retain registration and use of the disputed domain names pursuant to UDRP Rule 5(c) (i) is 5,000 words.
Panel decisions and dissenting opinions
With respect to panel decisions and dissenting opinions there shall be no word limit.
FILE SIZE AND FORMATS
Complaint
The file size and format modalities pursuant to UDRP Rule 3(b) with respect to a Complaint are as follows:
1. Complainants must file submissions via the CIIDRC online platform.
2. Annexes may not exceed 10MB each. Larger files may be split and uploaded to the CIIDRC online platform separately.
3. A Complaint (including the Annexes) may not exceed 50MB, other than by express and prior agreement with the Centre.
Response
The file size and format modalities pursuant to UDRP Rule 5(c)(i) with respect to a Response are as follows:
1. Respondents must file submissions via the CIIDRC online platform.
2. Annexes may not exceed 10MB each. Larger files may be split and uploaded to the CIIDRC online platform separately.
3. A Response (including the Annexes) may not exceed 50MB, other than by express and prior agreement with the Centre.
AMENDMENT OF THE SUPPLEMENTAL RULES
Subject to the Policy and UDRP Rules, the Centre may amend any provision in these Supplemental Rules in its discretion.
EXCLUSION OF LIABILITY
Except in the case of deliberate wrongdoing, neither a Panelist, a Panel, nor the Centre are liable to a party, a Registrar or ICANN for any act or omission in connection with an administrative proceeding.

SCHEDULES INDEX Schedule A – COMPLAINT

Schedule B – FEES

Schedule C – NOTIFICATION OF COMMENCEMENT OF PROCEEDINGS

Schedule D – WRITTEN NOTICE – SINGLE MEMBER PANEL

Schedule E – WRITTEN NOTICE – THREE MEMBER PANEL

Schedule F – RESPONSE TO COMPLAINT

Schedule G – STATEMENT OF ACCEPTANCE AND DECLARATION OF IMPARTIALITY AND INDEPENDENCE

Schedule H – STANDARD SETTLEMENT FORM

Canadian International Internet Dispute Resolution Centre

SCHEDULE B

FEES

A non-refundable filing fee of $400 USD is paid by the Complainant when a Complaint is filed in connection with any domain name administrative proceeding under the Rules for Uniform Domain Name Dispute Resolution Policy.

Panel fees set out below are in addition to the non-refundable filing fee specified above.

Number of Disputed Domain Names	Single-Member Panel	Three-Member Panel
1 – 3	USD $1,000	Total: USD $2,400
4 – 7	USD $1,200	Total: USD $2,700
8 or more	Please contact the Centre for a fee quote	Please contact the Centre for a fee quote

All funds are in U.S Dollars.

All amounts are subject to the relevant sales tax(es), if/as applicable.

Payments can be made by credit card, cheque, or wire transfer for your convenience. For credit card payments, please reach out to the CIIDRC Team at resolution@ciidrc.org.

All bank charges or other amounts that may be levied in connection with a payment made to CIIDRC shall be borne by the party making the payment.

Notes:

The Panel fees are payable at the time of the appointment and not in advance.
Complainants are responsible for all fees unless a Respondent requests a three-member Panel.
When a Respondent requests a three-member Panel, the Respondent shall submit one half of the total amount payable for a three-member Panel.

SCHEDULE C

NOTIFICATION OF COMMENCEMENT OF PROCEEDINGS

Case Number:

Attached is a Complaint that has been filed against you with the Canadian International Internet Dispute Resolution Centre (“CIIDRC”) (the “Centre”) pursuant to the Uniform Domain Name Dispute Resolution Policy (the “Policy”) adopted by the Internet Corporation for Assigned Names and Numbers (ICANN) on October 24, 1999, Rules for the Uniform Domain Name Dispute Resolution Policy approved by ICANN on September 28, 2013, and in effect as of July 31, 2015 (the “UDRP Rules”) and the Canadian International Internet Dispute Resolution Centre’s (the “Centre” or the “CIIDRC” or the “Provider”) Supplemental Rules for the Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”).

The Policy is incorporated by reference into your Registration Agreement with the Registrar(s) of your domain name(s), in accordance with which you are required to submit to and participate in a mandatory administrative proceeding in the event that a third party (a Complainant) submits a Complaint to a dispute resolution service provider, such as the Centre, concerning a domain name that you have registered. You will find the name and contact details of the Complainant, as well as the domain name(s) that is/are the subject of the Complaint in the document headed Written Notice that accompanies this Notification of Commencement of Proceedings.

The Centre has checked the Complaint and determined that it satisfies the formal requirements of the Policy, the UDRP Rules and the Supplemental Rules, and it has received the required payment from the Complainant. An official copy of the Complaint is now forwarded to you through the applicable Written Notice. You have 20 calendar days within which to submit a Response to the Complaint in accordance with the UDRP Rules and the Supplemental Rules to the office of the Centre and the Complainant. Should you so desire, you may wish to seek the assistance of legal counsel to represent you in the administrative proceeding.

The ICANN Policy (the “Policy”) can be found at:

http://www.icann.org/en/help/dndr/udrp/policy

The ICANN Rules (the “UDRP Rules”) can be found at:

http://www.icann.org/en/help/dndr/udrp/rules

The Supplemental Rules, as well as other information concerning the resolution of domain name disputes can be found at:

https://www.ciidrc.org/domainnames/ICANN/SupplementalRules

Alternatively, you may contact the Centre’s office to obtain any of the above documents. The contact details are as follows:

Tel: 778-370-1432

Email: resolution@ciidrc.org

A copy of the attached Complaint has also been sent to the Registrar(s) with which the domain name(s) that is/are the subject of the Complaint is/are registered.

By submitting the attached Complaint to the Centre, the Complainant has agreed to abide and be bound by the provisions of the Policy, the URDP Rules and the Supplemental Rules.

SCHEDULE D

WRITTEN NOTICE – SINGLE MEMBER PANEL

Case Number:

1. Notification. You, the Respondent, are hereby notified that an administrative proceeding has been commenced against you pursuant to the Uniform Domain Name Dispute Resolution Policy, approved by the Internet Corporation for Assigned Names and Numbers (ICANN) on October 24, 1999 (the “Policy”) (https://www.icann.org/resources/pages/policy-2012-02-25-en), the Rules for Uniform Domain Name Dispute Resolution Policy (the “URDP Rules”) as approved by ICANN on September 28, 2013, and in effect as of July 31, 2015 (https://www.icann.org/resources/pages/udrp-rules-2015-03-11-en), and the Canadian International Internet Dispute Resolution Centre (the “Centre” or the “CIIDRC” or the “Provider”) Supplemental Rules for the Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”) in effect as of May 9, 2018. (www.ciidrc.com/domainnames/ICANN/SupplementalRules).

The Policy is incorporated by reference into your Registration Agreement with the Registrar of your domain name(s), pursuant to which you are required to submit to and participate in a mandatory administrative proceeding in the event that a third party (the “Complainant”) submits a Complaint to an ICANN-approved dispute resolution service provider (https://www.icann.org/resources/pages/providers-6d-2012-02-25-en) concerning your domain name(s).

(Please note that the administrative proceeding has been commenced against the registrant of the domain name(s) that is/are the subject of the Complaint and not the technical contact, zone contact, administrative contact or billing contact, if different from the domain name registrant. The technical contact, administrative contact or billing contact, if different from the domain name registrant, are requested to forward this notification and any attachments to the registrant of the domain name(s) in question.)

Pursuant to UDRP Rule 4 and Supplemental Rule 5, we have now had forwarded to you with this Written Notice an electronic copy of the Complaint (including any Annexes).

If you would like a copy of the Complaint (including any annexes) forwarded to an alternate email address(es), please advise the Centre’s office of this as soon as possible. Such request may be sent by email to the Centre at: resolution@ciidrc.org, referring to the above case number.

2. Date Complaint Received. The Complaint submitted by [identify complainant(s)] was received by email on [Date] Pacific Time by the Centre [Identify related submissions and dates of receipt.] A copy of the Complaint [and related submission] accompanies this notification.

3. Formal Requirements Compliance Review. In accordance with UDRP Rule 4(c) and Supplemental Rule 5, the Centre has verified that the Complaint satisfies the formal requirements of the Policy, URDP Rules and Supplemental Rules. The Complainant has made payment of the required amount to the Centre.

4. Commencement of Administrative Proceeding. In accordance with UDRP Rule 4(f), the formal date of the commencement of the administrative proceeding is [Date] Pacific Time.

5. Deadlines. You have 20 calendar days from the date of commencement of this administrative proceeding (see paragraph 4 above) within which to submit to us any Response (copying the Complainant) according to the requirements that are described in UDRP Rule 5. The email address to which you should send your Response (copying the Complainant) is resolution@ciidrc.com. Any request to the Centre for an extension pursuant to UDRP Rule 5(b) and 5(e), may be submitted to the same email address. The Respondent may expressly request an additional four (4) calendar days in which to respond to the Complaint, and the Centre shall automatically grant the extension in accordance with UDRP Rule 5(b). This extension does not preclude any additional extensions that may be given further to UDRP Rule 5(e). In the absence of any extension, the last day for sending any Response (copied to the Complainant) to us is [Date] Pacific Time. This is also the last date by which you should make any required payments to us if you choose to designate a three-member Panel (see paragraphs 8 and 10 below). In filing your Response, you may refer to the Model Response and filing guidelines made available on the Centre’s website.

6. Consent to remedy.Youmay consent to the remedy requested by the Complainant and agree to [transfer/cancel] the disputed domain name(s).

7. Default. If your Response is timely submitted by the specified due date, the Centre will duly acknowledge receipt. In the absence of any submitted Response (or evidence of its transmission), the Centre will forward a notice of the Respondent’s default. In either case, the Centre will proceed to appoint a Panel to review the facts and to decide the case. The Panel will not be required to consider a late-filed Response, but will have the discretion to decide whether to do so and, as provided for by UDRP Rule 14, may draw such inferences from your default as it considers appropriate. There are other consequences of a default, including no obligation on the Centre’s part to consider any designations you have made concerning the appointment of the Panel or to observe any guidelines you have provided concerning case-related communications.

8. Panel. The dispute between you and the Complainant will be decided by a Panel consisting of either one or three impartial and independent decision-makers. The Complainant in this administrative proceeding has elected for a Panel consisting of a single Panelist.

If you would also like the case to be decided by a single Panelist, the appointment of that Panelist will be made by us from the Centre’s published list of Panelist. The fees for the administrative proceeding will be paid in their entirety by the Complainant.

Despite the Complainant’s designation of a single Panelist, you can choose to have the case decided by a Panel consisting of three persons. If you choose this option, you will be required to pay half of the applicable fees for the administrative proceeding (see paragraph 10 below). The payment must be made at the time you submit your Response. Failure to submit the required payment at that time may, along with other considerations, be taken as grounds for proceeding with a single Panelist. If you choose a three-member Panel and make the required payment when you submit your timely Response, you should indicate the names and contact details of three persons in order of preference in your Response. These three persons can be selected from our published list or that of any other ICANN-accredited dispute resolution service provider (https://www.icann.org/resources/pages/providers-6d-2012-02-25-en). We will try to appoint one of the three persons you have nominated to the Panel. If we are unsuccessful, we shall make an appropriate appointment from the Centre’s published list. If you choose a three-member Panel, but do not provide us with the names and contact details of any candidates, we shall make the appointment from our published list.

Please note that if you choose a three-member Panel, the Complainant will be requested also to provide the names of three candidates, who can be taken from our published list or that of any other ICANN-accredited dispute resolution service provider. We will try to appoint one of these three persons to the Panel. If we are unsuccessful, we shall make an appropriate appointment from our published list. If the Complainant does not provide us with the names of its candidates, we shall make the appointment from the Centre’s published list.

If the case is to be decided by a three-member Panel, you and the Complainant will be contacted concerning the procedures for the appointment of the Presiding Panelist (i.e., the third Panelist).

9. Communications. Your Response should be communicated to us according to the requirements of UDRP Rule 5(c) (e.g., in electronic form (including the Annexes)) via email pursuant to Supplemental Rules 3 and 6. All case-related filings or submissions to the Centre in addition to the submission of your Response should be made according to the Supplemental Rule 3(b). The email address to use for both purposes is:

resolution@ciidrc.org.

If you have a preferred address for communication other than that used in this Written Notice and the Notification of Commencement of Proceedings, this preferred address should be indicated in your Response.

All communications that are required to be made to the Complainant under the UDRP Rules and Supplemental Rules, including your Response, should be made according to the contact details and methods specified in the Complaint. Any corrections or updates to the Respondent’s contact information during the remaining pendency of this administrative proceeding should be communicated to the Centre in accordance with UDRP Rule 5(c)(ii) and 5(c)(iii).

Questions about your case or other general queries may be emailed to:

resolution@ciidrc.org.

10. Fees. In accordance with UDRP Rule 5(d), payment to us in the following amount must be made at the time of the submission of your Response, if you designate a three-member Administrative Panel:

[Enter amount]

Payment methods and other relevant details can be found in Schedule B of the Supplemental Rules. Please identify in your Response the method by which payment is made. If you do not submit the required payment to us, we shall proceed to appoint a single member Panel.

11. The Administrative Proceeding. If this case is to be decided by a single member Panel, we shall appoint the Panel within five days following receipt of your Response, or the lapse of the time period for the submission thereof. If the case is to be decided by a three-member Panel and you have submitted a Response, after appointing two of the Panelists (see Paragraph 8 above) we shall send to you and to the Complainant a list of five candidates for the Presiding Panelist. You will each be asked to indicate your order of preference from among the five candidates. Unless we are notified of an agreement between you and the Complainant as to the identity of the Presiding Panelist, we shall make the appointment taking into consideration the preferences indicated by you and the Complainant.

The Panel will typically have 14 days from the date of its appointment to issue a decision in the case. Under normal circumstances, we will forward the decision to you, the Complainant, the Registrar(s) and ICANN within three business days of receiving it from the Panel. Should the decision require that the domain name(s) in question be either transferred or cancelled, the Registrar(s) will notify all parties concerned of the date that the decision will be implemented if the Registrar(s) does/do not receive notification and the required documentation from you in accordance with Paragraph 4(k) of the Policy. We will then post the decision on a publicly accessible web site, unless the Panel has directed us otherwise.

12. Case Administrator. The Centre, which is a neutral dispute resolution provider, has appointed a Case Administrator who is in charge of administering your case. The Case Administrator’s details appear below. Please note that, while the Case Administrator is at your disposal to answer questions relating to such matters as filing requirements and applicable procedure, he / she is not the decision-maker on the merits of this case, and cannot provide you with legal advice or make any representations to the Panel or otherwise on your behalf.

Case Administrator:

Address: Canadian International Internet Dispute Resolution Centre

500 – 666 Burrard Street,

Vancouver, British Columbia,

V6C 3P6 Canada

Telephone: 778-370-1432

Email Address: resolution@ciidrc.org

13. Additional Information. Additional information about the UDRP administrative procedure is available at https://www.icann.org/resources/pages/help/dndr/udrp-en and about the Centre’s Domain Name Dispute Resolution Service at www.ciidrc.org.

Canadian International Internet Dispute Resolution Centre

SCHEDULE E

WRITTEN NOTICE – THREE MEMBER PANEL

Case Number:

1. Notification. You are hereby notified that an administrative proceeding has been commenced against you pursuant to the Uniform Domain Name Dispute Resolution Policy, approved by the Internet Corporation for Assigned Names and Numbers (ICANN) on October 24, 1999 (the “Policy”) (https://www.icann.org/resources/pages/policy-2012-02-25-en), the Rules for Uniform Domain Name Dispute Resolution Policy (the “UDRP Rules”) as approved by ICANN on September 28, 2013, and in effect as of July 31, 2015 (https://www.icann.org/resources/pages/udrp-rules-2015-03-11-en), and the Canadian International Internet Dispute Resolution Centre (the “Centre” or the “CIIDRC” or the “Provider”) Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”) in effect as of May 9, 2018. (www.ciidrc.com/domainnames/ICANN/SupplementalRules).

Pursuant to UDRP Rule 4 and Supplemental Rule 5, we have now had forwarded to you with this Written Notice an electronic copy of the Complaint (including any annexes).

If you would like a copy of the Complaint (including any annexes) forwarded to an alternate email address(es), please advise the Centre of this as soon as possible. Such request may be sent by email to the Centre at:

resolution@ciidrc.org.

referring to the above case number.

2. Date Complaint Received. The Complaint submitted by [identify complainant(s)] was received by email on [Date] Pacific Time by the Centre. [Identify related submissions and dates of receipt.] A copy of the Complaint [and related submission] accompanies this notification.

3. Formal Requirements Compliance Review. In accordance with UDRP Rule 4(c) and Supplemental Rule 5, the Centre has verified that the Complaint satisfies the formal requirements of the Policy, URDP Rules and Supplemental Rules. The Complainant has made payment of the required amount to the Centre.

4. Commencement of Administrative Proceeding. In accordance with UDRP Rule 4(f), the formal date of the commencement of the administrative proceeding is [Date] Pacific Time.

5. Deadlines. You have 20 calendar days from the date of commencement of this administrative proceeding (see paragraph 4 above) within which to submit to us any Response (copying the Complainant) according to the requirements that are described in UDRP Rule 5. The email address to which you should send your Response (copying the Complainant) is • . Any request to the Centre for an extension pursuant to UDRP Rule 5(b) and 5(e), may be submitted to the same email address. The Respondent may expressly request an additional four (4) calendar days in which to respond to the Complaint, and the Centre shall automatically grant the extension in accordance with UDRP Rule 5(b). This extension does not preclude any additional extensions that may be given further to UDRP Rule 5(e). In the absence of any extension, the last day for sending any Response (copied to the Complainant) to us is [Date] Pacific Time. In filing your Response, you may refer to the Model Response and filing guidelines made available on the Centre’s website.

6. Consent to remedy. You may consent to the remedy requested by the Complainant and agree to transfer/cancel the disputed domain name(s).

7. Default. If your Response is timely submitted by the specified due date, the Centre will duly acknowledge receipt. In the absence of any submitted Response (or evidence of its transmission), the Centre will forward a notice of the Respondent’s default. In either case, the Centre will proceed to appoint a Panel to review the facts and to decide the case. The Panel will not be required to consider a late-filed Response, but will have the discretion to decide whether to do so and, as provided for by UDRP Rule 14, may draw such inferences from your default as it considers appropriate. There are other consequences of a default, including no obligation on the Centre’s part to consider any designations you have made concerning the appointment of the Panel or to observe any guidelines you have provided concerning case-related communications.

8. Panel. The Complainant in this administrative proceeding has elected for a Panel consisting of three Panelists. The dispute between you and the Complainant will be decided by a Panel consisting of three members.

The Complainant has provided us with the names and contact details of three candidates to serve on the Panel, and has indicated its order of preference. We will try to appoint one of these three candidates. If we are unsuccessful, we shall make the appointment from the Centre’s published list of Panelist. The fees for the administrative proceeding will be paid in their entirety by the Complainant.

You are required to provide the names and contact details of three persons in order of preference in your Response. These three persons may be selected from the Centre’s published list or that of any other ICANN-accredited dispute resolution service provider (https://www.icann.org/resources/pages/providers-6d-2012-02-25-en). We will try to appoint one of the three persons you have nominated to the Panel. If we are unsuccessful, we shall make an appropriate appointment from our published list. If you do not provide us with the names and contact details of any candidates, we shall make the appointment from our published list.

Once we have appointed two Panelists, both you and the Complainant will be contacted concerning the procedures for the appointment of the Presiding Panelist (i.e., the third Panelist).

9. Communications. Your Response should be communicated to us according to the requirements of UDRP Rule 5(c) (e.g., in electronic form (including the Annexes)) via email pursuant to the Supplemental Rule 3. All case-related filings or submissions to the Centre in addition to the submission of your Response should be made according to the Supplemental Rule 3(b). The email address to use for both purposes is resolution@ciidrc.com.

All communications that are required to be made to the Complainant under the UDRP Rules and Supplemental Rules, including your Response, should be made according to the contact details and methods specified in the Complaint. Any corrections or updates to the Respondent’s contact information during the remaining pendency of this administrative proceeding shall be communicated to the Centre in accordance with UDRP Rule 5(c)(ii) and 5(c)(iii).

Questions about your case or other general queries may be emailed to: resolution@ciidrc.com

10. Fees. Please note that the fees for the administrative proceeding will be paid in their entirety by the Complainant.

11. The Administrative Proceeding. As this case is to be decided by a three-member Panel, we shall send to you and to the Complainant a list of five candidates for the Presiding Panelist. You will each be asked to indicate your order of preference from among the five candidates. Unless we are notified of an agreement between you and the Complainant as to the identity of the Presiding Panelist, we shall make the appointment taking into consideration the preferences indicated by you and the Complainant.

The Panel will typically have 14 days from the date of its appointment to issue a decision in the case. Under normal circumstances, we will forward the decision to you, the Complainant, the Registrar(s) and ICANN within three (3) business days of receiving it from the Panel. Should the decision require that the domain name(s) in question be either transferred or cancelled, the Registrar(s) will notify all parties concerned of the date that the decision will be implemented if the Registrar(s) does/do not receive notification and the required documentation from you in accordance with Paragraph 4(k) of the Policy. We will then post the decision on a publicly accessible web site, unless we have been directed otherwise by the Panel.

12. Case Administrator. The Centre, which is a neutral dispute resolution provider, has appointed a Case Administrator who is in charge of administering your case. The Case Administrator’s details appear below. Please note that, while the Case Administrator is at your disposal to answer questions relating to such matters as filing requirements and applicable procedure, he / she is not the decision-maker on the merits of this case, and cannot provide you with legal advice or make any representations to the Panel or otherwise on your behalf.

Case Administrator:

Address: Canadian International Internet Dispute Resolution Centre

500 – 666 Burrard Street,

Vancouver, British Columbia,

V6C 3P6 Canada

Telephone: 778-370-1432

Email Address: resolution@ciidrc.org

Canadian International Internet Dispute Resolution Centre

SCHEDULE G

STATEMENT OF ACCEPTANCE AND DECLARATION OF IMPARTIALITY AND INDEPENDENCE

Case Number:

I, the undersigned, _____________________ (Last Name, First Name),

[ ] declare that I accept to serve as a Panelist under the Uniform Domain Name Dispute Resolution Policy (the “Policy”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “UDRP Rules”), and the Canadian International Internet Dispute Resolution Centre (the “Centre” or the “CIIDRC” or the “Provider”) Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”), currently in effect. By making this declaration, I confirm that I have familiarized myself with the principles, standards, requirements and fees set out in the aforementioned instruments and that I am available to serve as a Panelist in accordance therewith. I further declare that, by accepting to serve as a Panelist in this case, I shall execute my responsibilities honestly, fairly and within the time periods required by the UDRP Rules and the Supplemental Rules.

I particularly declare that I am available to start work on the administrative proceeding forthwith and that my commitments are such that I am able to devote the time to the delivery of the Panel decision within the prescribed time limit.

Please check the appropriate box below, taking into consideration, inter alia, whether there exists any past or present relationship, direct or indirect, with either of the parties, whether financial, professional or of another kind and whether the nature of any such relationship is such that disclosure is called for. [Any doubt should be resolved in favour of disclosure].

[ ] I am independent of each of the parties. To the best of my knowledge and belief, there are no facts or circumstances, past or present, or that could arise in the foreseeable future that need be disclosed as they might be of such a nature as to call into question my independence in the eyes of one or both of the parties.

[ ] I am independent of each of the parties. However, I wish to disclose the circumstances described in the attachment hereto (attach separate sheet) as they might be of such a nature as to call into question my independence in the eyes of one or both of the parties.

[ ] hereby declare that I decline to serve as a Panelist in the present case. (Disclosure of the reasons for declining to accept the appointment should be made on a separate sheet and attached hereto.)

Place: ____________ Signature:_____________________

Date: ____________

Canadian International Internet Dispute Resolution Centre

SCHEDULE H

STANDARD SETTLEMENT FORM

Standard Settlement Form Pursuant to UDRP Rule 17

Case No.

This Standard Settlement Form is submitted by the Parties pursuant to Rule 17(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the “UDRP Rules”) as approved by the Internet Corporation for Assigned Names and Numbers (“ICANN”) on September 28, 2013, and in effect as of July 31, 2015.

This form does not embody an agreement to settle the administrative proceeding but is to note the essential terms of a settlement agreement requiring Registrar action specified below.

The Canadian International Internet Dispute Resolution Centre (the “Centre”) will not disclose the completed Standard Settlement Form or its contents to any third-party.

The Parties have reached an agreement regarding the following disputed domain name(s):

[<disputed domain name(s)>]

Pursuant to such agreement, the Parties request the Registrar to take the following action [select one of the following options]:

[ ] The disputed domain name(s) should be transferred from the Respondent’s control to the Complainant. [If there are multiple complainants, please indicate the complainant to which the disputed domain name(s) is/are to be transferred.]

[ ] The disputed domain name(s) should be cancelled.

Unless the parties’ settlement agreement provides otherwise, the Centre will dismiss the administrative proceeding in compliance with the parties’ agreement without prejudice.

/s/__________________ /s/__________________

On behalf of Complainant On behalf of Respondent

Date: Date: