Update: changes affecting how to request a three-member panel to defe…

Update: changes affecting how to request a three-member panel to defe. UDRP and ccTLD domain recovery and defense across .store. Email the firm to assess your…

A registrant holding a .store domain receives a UDRP complaint. The deadline to respond arrives in 20 days. One decision must be made almost immediately: file with a single panelist or request a three-member panel? That choice carries procedural and financial weight – and the rules around it deserve a close read.

To request a three-member panel to defend a .store domain under the UDRP, the respondent must elect a three-member panel in the response and contribute to the additional fee. The standard WIPO filing fee for a single-member panel is USD 1,500; a three-member panel costs USD 4,000, with costs typically split when the respondent makes the request. The election must appear in the formal response – it cannot be added later.

This alert covers what applies in the .store zone, how the fee split works, and when the three-member route is worth considering.

What changed and why it matters for .store registrants

The .store gTLD operates under the standard UDRP, administered by WIPO and other accredited providers. No ccTLD carve-out applies. The procedural rules have not changed in their text, but two practical dynamics have shifted the calculation for respondents.

First, complaint volume targeting commercial new gTLDs – including .store – has grown alongside brand-owner awareness of these zones. Second, panels in three-member compositions have shown a modestly higher rate of RDNH findings in cases where a complainant overreached. Neither observation is a guarantee of outcome; both are relevant to the election decision.

The mechanics remain settled. Under the UDRP Rules, if the complainant selected a single panelist but the respondent requests a three-member panel, the parties generally split the higher three-member fee. At WIPO, that means the respondent's share of a three-member panel for a single domain is approximately half the difference between the single-member and three-member rates. Verify the current WIPO schedule before filing, as the allocation formula can vary by case configuration.

Who is affected?

Any registrant who has received – or expects to receive – a UDRP complaint against a .store domain is directly affected. The election window is the response period: 20 days from the date the provider formally commences the proceeding. Miss that window and the panel composition defaults to whatever the complainant chose.

Registrants with a strong legitimate-interest record are the most likely candidates for the three-member route. In our practice, we regularly advise registrants who hold descriptive or generic .store names on whether that record is strong enough to justify the additional cost and the different panel dynamic.

For an initial read on whether your .store domain qualifies for a three-member defense, contact info@cognomenlaw.com.

What should you do now?

Three steps apply immediately upon receipt of a UDRP complaint against a .store domain.

1. Locate your registration history. The date of registration, the purpose at that time, and any use since then are the core of the Paragraph 4(c) safe harbors. A bona fide offering before notice of the dispute, use of a name by which the registrant is commonly known, or legitimate noncommercial use – these are the defenses the panel will weigh.
2. Assess the panel composition question. A three-member panel is not always superior. Where the legitimate-interest record is strong and the complaint appears abusive, three panelists increase the realistic prospect of an RDNH finding. Where the record is thin, a single experienced panelist may be the more efficient path.
3. Act before the 20-day window closes. The response deadline is firm. Extensions are possible but not guaranteed and require the consent of the other side or good cause shown to the provider.

What evidence decides the outcome? The respondent's burden is to produce enough to put legitimacy in issue; the evidentiary weight then shifts. Business records, correspondence, website screenshots, and any trademark or registration filings predating the complaint all strengthen the record. Panels have consistently held that bare assertions of legitimate interest, unsupported by documentation, are insufficient.

When is an RDNH finding realistic? Panels award RDNH where the complainant knew or should have known it could not succeed – typically because the domain is generic, the respondent's registration predates the complainant's trademark rights, or the complainant offered no credible bad-faith evidence. We have defended .com and new-gTLD registrants in exactly these circumstances, securing RDNH findings where the complaint record was plainly deficient.

To weigh UDRP defense options against your specific .store fact pattern, email info@cognomenlaw.com.

Related at COGNOMEN

• Respondent defense and RDNH – full service overview across gTLDs and ccTLDs
• Defending a UDRP complaint: strategy, evidence, and panel selection
• Case study: recovering a domain from a typosquat registration