Filing a UDRP Complaint to Recover a Domain
By Casey Scott McKay ·
This guide walks a trademark owner through recovering a squatted or infringing domain name under ICANN's Uniform Domain Name Dispute Resolution Policy, from the first evidence capture to the day the domain lands in your registrar account. It covers the go/no-go decision against the URS, the ACPA, and a quiet purchase; the three elements of UDRP Paragraph 4(a) and where each one actually fails; the choice between WIPO and FORUM, single and three-member panels, and the two available mutual jurisdictions; the anatomy of a complaint under Rule 3(b), with model drafting language for the confusing-similarity, legitimate-interest, and bad-faith sections; the compliance review, the registrar lock, and the amended complaint you will almost certainly have to file once the privacy shield comes off; and the ten-business-day window under Paragraph 4(k) in which a losing respondent can freeze everything by filing suit. It gives realistic costs and timelines, a consolidated deadline table, and a worked example carried from investigation to transfer. It also tells you when not to file, because a losing UDRP complaint is worse than no complaint at all.
IP and Technology > Internet | Guide | Published 15 January 2026 - Updated 18 June 2026 | Casey Scott McKay - marksy.us
Summary. This guide walks a trademark owner through recovering a squatted or infringing domain name under ICANN's Uniform Domain Name Dispute Resolution Policy, from the first evidence capture to the day the domain lands in your registrar account. It covers the go/no-go decision against the URS, the ACPA, and a quiet purchase; the three elements of UDRP Paragraph 4(a) and where each one actually fails; the choice between WIPO and FORUM, single and three-member panels, and the two available mutual jurisdictions; the anatomy of a complaint under Rule 3(b), with model drafting language for the confusing-similarity, legitimate-interest, and bad-faith sections; the compliance review, the registrar lock, and the amended complaint you will almost certainly have to file once the privacy shield comes off; and the ten-business-day window under Paragraph 4(k) in which a losing respondent can freeze everything by filing suit. It gives realistic costs and timelines, a consolidated deadline table, and a worked example carried from investigation to transfer. It also tells you when not to file, because a losing UDRP complaint is worse than no complaint at all.
Keywords: udrp complaint · domain name dispute · cybersquatting · wipo arbitration and mediation center · forum udrp · icann · domain name transfer · bad faith registration · reverse domain name hijacking · typosquatting · uniform rapid suspension · acpa · mutual jurisdiction · rdap whois · registrar lock · pay-per-click parking page · panel decision · registrar verification · domain recovery
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