Step-by-step: file a UDRP complaint for a .info domain

Step-by-step: file a UDRP complaint for a .info domain. UDRP and ccTLD domain recovery and defense across .info. Email the firm to assess your case.

Your brand name sits in a .info domain you do not own. The registrant is using it to redirect traffic, host a pay-per-click page, or simply wait for you to make an offer. The UDRP is almost certainly the fastest route to a decision – and .info is squarely within its reach.

To file a UDRP complaint for a .info domain, a complainant must satisfy all three elements of Paragraph 4(a) of the UDRP: confusing similarity to a mark the complainant holds, absence of rights or legitimate interests on the registrant's side, and registration and use in bad faith. The standard case runs approximately two months from filing to a decision, with a WIPO filing fee starting at USD 1,500 for a single-member panel covering one to five domains. The only remedies are transfer to you or cancellation of the domain.

This guide walks each step in sequence – the filing, the evidence, the forum choice, and the traps that stop a complaint before a panel even reads it.

Why .info falls under the UDRP – and what that means for your complaint

.info is a generic top-level domain (gTLD) accredited through ICANN, and every .info registrar is contractually bound by the UDRP. That means the same Policy, the same forums (WIPO, the Forum, CAC, and ADNDRC), and the same remedies apply here as they do to .com or .net. There is no separate ccTLD procedure for .info, no national eligibility requirement, and no local court you must exhaust first.

That is a genuine advantage. A brand owner based in one country can file a UDRP complaint against a .info registrant anywhere in the world, before the forum of its choice, on the same legal standard that decades of panel decisions have built up. Panels in .info cases draw freely on the same body of UDRP precedent that governs .com disputes.

The trap at this step: some brand owners assume .info's early reputation as a "less valuable" zone means less established abuse. Panels do not share that view. Pay-per-click parking, phishing pages, and typosquatting operate in .info just as they do in .com – and they satisfy the same bad-faith grounds. Do not file a lighter complaint just because the zone feels secondary.

Step 1: Confirm you hold a qualifying trademark right

The first UDRP element requires that the complainant hold rights in a mark – and that the disputed domain is identical or confusingly similar to it. Without a trademark, the complaint fails on the first element regardless of what the registrant has done.

A registered trademark is the clearest qualifying right. A national or international registration – a USPTO mark, an EUIPO registration, a UK IPO mark, or a registration in any jurisdiction – will ordinarily satisfy the first element if the domain reproduces or closely resembles the mark. The registration need not predate the domain; the first element is a pure similarity test, not a chronological one. Date of registration becomes relevant in the third element, not here.

Unregistered (common-law) rights can also qualify, but the complainant must demonstrate them through use – evidence of secondary meaning, longstanding commercial use, and recognition of the mark in trade. This is a harder case to make. In our practice, we advise clients to assess the strength of unregistered-rights evidence before filing, not after. A complaint built on thin common-law rights that collapses on the first element wastes the filing fee and can invite a reverse domain name hijacking (RDNH) finding.

The similarity test itself is relatively permissive. Panels generally strip the ".info" suffix and compare the remainder to the mark. Transpositions, missing vowels, hyphenation, or the addition of a generic word alongside the mark (such as "brand-info" or "officialbrands") typically meet the confusing-similarity threshold. What matters is whether a reasonable internet user would associate the domain with the mark.

For a read on whether the three UDRP elements are met on your .info domain, reach us at info@cognomenlaw.com.

Step 2: Assess the registrant's rights or legitimate interests – and your evidence

The second UDRP element asks whether the registrant has any legitimate interest in the domain. Complainants cannot always prove a negative directly, but a well-built complaint shifts the burden to the respondent to produce evidence of legitimacy – and most cybersquatters cannot.

Paragraph 4(c) of the UDRP sets out the three main safe harbors a registrant can invoke: (1) use of the domain in connection with a bona fide offering of goods or services before notice of the dispute; (2) being commonly known by the domain name; and (3) legitimate noncommercial or fair use. Your job is to show that none of these applies on the facts you can see.

The evidence you need at this step includes WHOIS/RDDS registration data (who is listed as registrant, when, and under what name), screenshots of the domain resolving – or not resolving – to active content, any correspondence with the registrant, and any other indication that the domain is not in use for a genuine purpose. A page full of advertising links to competitors, a blank page, or a "domain for sale" banner are among the strongest indicators that no legitimate interest exists.

The trap here is the gap between "I cannot find any legitimate use" and "I have evidence of none." Panels expect complainants to investigate and document. Screenshot the site. Archive it. Check the Wayback Machine for prior uses. Run the registrant name against any other domains they hold. That work shapes the third element too.

Step 3: Build the bad-faith case – the element that decides most disputes

The third element – bad faith in both registration and use – is where most contested cases are won or lost. Paragraph 4(b) of the UDRP lists four non-exhaustive circumstances that constitute bad faith, and panels have developed a broad body of practice around each.

The most common bad-faith indicators in .info disputes include: registration of a domain identical or near-identical to a well-known mark, with no plausible innocent explanation; a pay-per-click page monetizing clicks from users seeking the brand; a "domain for sale" listing directed at the mark owner; use of the domain for a phishing or fraud scheme; and a pattern of registrations targeting multiple marks. None of these is automatic – each must be tied to your facts and your evidence.

Passive holding deserves a separate word. A registrant who does nothing visible with the domain is not automatically protected. Panels have consistently held that passive holding of a domain that could only have been registered with the mark in mind can constitute bad faith use, particularly where the mark is well-known and no conceivable legitimate use of the domain exists. Document the passive state carefully – consistent screenshots over time showing no active use strengthen that argument.

In a recent matter (a .info typosquat, spring 2025), we assembled bad-faith evidence from archived page states spanning nearly two years, showing the domain had cycled between parking pages and a brief period of redirection to a competitor site. The panel found bad faith in both registration and use and ordered transfer. No court proceeding was required.

Step 4: Choose your forum – WIPO, the Forum, or another provider

All four ICANN-accredited providers handle .info complaints. The choice matters for cost, timeline, and the body of precedent your panel will draw on. WIPO and the Forum together handle approximately 97% of all UDRP proceedings, and for most .info complainants those are the only two seriously worth weighing.

WIPO's standard single-member filing fee is USD 1,500 for one to five domains. The Forum's fees begin around USD 1,300 for one to two domains on a single-member panel. CAC starts around USD 500–800 and is the lowest-cost entry point, though it accounts for a much smaller share of proceedings. The filing fee is separate from any legal fee.

The decision-matrix in prose: if your .info domain is a single name and the case is relatively straightforward, WIPO or the Forum both work. WIPO carries the largest and most frequently cited body of precedent and tends to attract the most experienced panelists for contested matters. The Forum is a reasonable alternative and has comparable depth of practice. If budget is the primary constraint and the facts are clear-cut, CAC is available. If you need a decision faster than the standard timeline, WIPO offers an expedited option delivering a decision within approximately one month for single-panel cases covering up to five domains – worth considering if the registrant is actively damaging your brand.

What if the same registrant also holds a .com version of your mark? A single UDRP complaint may cover multiple domains if the registrant of record is the same holder. That consolidation can be cost-efficient, though the complaint must address each domain's facts. We regularly advise on whether to consolidate or file separately, depending on the registrant's portfolio and the evidence available for each domain.

Step 5: Draft and file the complaint – and the traps inside the form

Each ICANN-accredited forum has its own online filing system and its own word or page limits for complaints. Read the provider's Supplemental Rules before drafting. WIPO's system is web-based; the Forum uses an online portal. Both require the complainant to specify the registrar, the disputed domain or domains, the trademark relied on, and the grounds for each of the three elements.

The structural traps at this step are more consequential than they appear. First, the respondent's contact information: use the current WHOIS/RDDS record, not an old address or a guess. The forum sends the complaint to the contact details on record, and a defective service step can delay or derail the case. Second, the remedy: state clearly whether you seek transfer or cancellation. Most complainants want transfer. Third, the mutual jurisdiction clause: by filing, you agree to submit to the jurisdiction of the courts where the registrar is located or where the respondent is domiciled, for any post-decision challenge. Know which court that is before you choose your forum.

Once filed, the forum reviews for formal compliance before commencing the case. Formal deficiencies – a missing annexe, an incorrect respondent name, an unsigned filing – result in a request to remedy, which delays commencement. Draft carefully, annex every piece of evidence referred to in the body, and verify the registrar's current identity through the ICANN WHOIS before finalizing.

To assess whether your .info complaint is ready to file – or to identify what evidence is still missing – email info@cognomenlaw.com.

Step 6: The 20-day response window and what happens next

Once the forum formally commences the case, the respondent has 20 days to file a response. That window is fixed by the UDRP Rules; the respondent can request an extension, but the forum grants it only for good cause. Many registrants in abusive .info cases do not respond at all. A default does not mean automatic transfer – the panel still evaluates the complaint on its merits – but it eliminates a contested record.

After the response window closes (or a response is filed), the forum appoints a panelist. For a single-member panel, that appointment typically takes a few days. The panel then has an additional period to issue a decision. Throughout this phase, neither party normally files anything further unless the panel requests it. Supplemental filings – unsolicited additional submissions – are disfavored and generally rejected.

The standard case from filing to a decision runs approximately two months. From the decision to registrar implementation of a transfer order, the UDRP provides a brief waiting period during which the registrant can challenge the outcome in a competent court. That period passes in the overwhelming majority of cases without challenge. Once it expires and no court action has been filed, the registrar carries out the transfer.

In a second matter from our files (a .info domain in the financial-services sector, autumn 2024), the respondent filed a response asserting fair use. We had assembled a detailed evidentiary record – archived pages, a timeline of the mark's use predating the registration by several years, and evidence that the respondent had targeted the mark owner specifically. The panel found for the complainant on all three elements. Transfer was implemented within days of the decision becoming final.

What if the complaint fails – or if you are the one receiving a complaint?

A failed complaint is not simply a matter of paying a filing fee with nothing to show. Where a panel finds that the complainant knew it could not win, or filed primarily to deprive a legitimate registrant of a domain, it may issue an RDNH finding. That finding is public and carries reputational weight, even though the UDRP provides no monetary penalties. It is one reason why we stress pre-filing assessment rather than filing on instinct.

If you are the registrant and you have received a .info UDRP complaint, the same 20-day window applies to your response. Defaulting is almost always a worse outcome than responding, even with a difficult set of facts. The respondent's route is to document legitimate interest under Paragraph 4(c) – evidence of use before notice of the dispute, evidence of being commonly known by the domain, or evidence of genuinely noncommercial fair use. Where the complaint appears speculative or the complainant's mark is weak, we have pursued and obtained RDNH findings that close the matter in the respondent's favor.

The AUDIENCE_MYTH worth addressing here is that UDRP complaints are a formality that brand owners always win. They are not. Roughly 15% of WIPO cases settle before a decision, and a proportion of complaints are denied outright. The panel is an independent decision-maker. The evidence, the quality of the legal argument, and the specific facts of the registration all bear on the outcome. Filing without adequate preparation is a way to lose a winnable case.

For completeness: if the registrant also holds infringing domains in ccTLDs – .de, .fr, .uk – those require separate procedures. .de sits in German courts (with a DENIC DISPUTE block available while you litigate); .uk uses the Nominet DRS; .eu uses the CAC-administered ADR.eu procedure. We handle those routes as well, and the cross-zone strategy matters when a single bad actor has assembled a portfolio across zones.

Related at COGNOMEN

• UDRP domain recovery – our full-service complainant practice for gTLD and ccTLD disputes
• Case study: recovering a domain through a group UDRP complaint across multiple registrants
• Domain escrow and acquisition due diligence for .co and other gTLDs