Step-by-step: recover multiple .info domains in one UDRP complaint

A brand owner discovers that the same registrant has registered a cluster of .info domains matching or closely mimicking its trademark – different suffixes, slight misspellings, hyphenated variants – all pointing at pay-per-click parking pages or left inert. Filing a separate complaint for each would multiply cost and time. The better question is whether a single UDRP complaint can capture all of them at once.

Under the UDRP, a single complaint may target multiple domains provided all domains are registered by the same registrant. The .info zone operates under the UDRP administered by WIPO, the Forum, and other approved providers, so the same rules apply as for .com. You must still satisfy all three elements of Paragraph 4(a): confusing similarity to your mark, no legitimate interest, and registration and use in bad faith. A standard case normally concludes within about two months, and the only remedies are transfer or cancellation.

This guide walks the process step by step, flags the trap inside each step, and explains how evidence and forum choice affect the outcome.

Step 1: Confirm that .info uses the UDRP – and that all domains share one registrant

The .info zone uses the UDRP in full. WIPO administers the large majority of .info complaints; the Forum and CAC are also approved providers. That means the three-element test, the timeline, the remedies, and the procedural rules from APPENDIX A all apply without modification.

The multi-domain consolidation rule has one absolute prerequisite: every domain named in the complaint must be registered to the same holder. Panels verify this against WHOIS/RDDS records at the time of filing. If two of your five target domains show different registrant names or different registrant email addresses, those two cannot join the single complaint without additional evidence that the registrations are under common ownership or control. This is the trap at Step 1.

What does "same registrant" mean in practice? The same registrant email, the same registrant organization, or – where privacy or proxy services mask the registration data – circumstantial indicators such as identical name servers, identical DNS configuration, the same parking monetization account, or a shared IP address. Panels have consistently held that materially indistinguishable technical footprints can satisfy the commonality requirement even where WHOIS names differ. Document those technical indicators before you file.

Before moving to the complaint itself, pull the full WHOIS/RDDS records for each domain and screenshot them. Records change. If a registrant transfers a domain after you file, the complaint may proceed for the remaining domains, but the transferred domain creates a procedural complication. Lock the targets in WHOIS evidence early.

How many domains can one UDRP complaint cover at WIPO?

WIPO's fee schedule applies per-domain-bracket rather than per-complaint. A single-member panel complaint covering 1–5 domains carries a filing fee of USD 1,500. Extending to 6–10 domains raises the fee to USD 2,000 for a single-member panel. Beyond ten domains, WIPO charges by individual quote. Those figures cover only the forum's administrative fee; legal fees are separate and typically in the USD 3,000–7,000 range for a straightforward single-domain case, rising with domain count and complexity.

Three-member panels cost substantially more: USD 4,000 for 1–5 domains and USD 5,000 for 6–10 at WIPO. If you request a single panelist but the respondent requests a three-member panel, the parties generally split the higher three-member fee. That split can alter your cost projection. Plan for both scenarios.

The filing fee decision is therefore a real one. A brand owner with twelve .info domains against one registrant faces either two sequential complaints (1–5 + 6–7) or a by-quote complaint covering all twelve. In our practice, consolidating into fewer complaints almost always produces the faster and more cost-efficient outcome, provided the same-registrant evidence is solid for every domain in scope.

For an assessment of whether your .info domains can be consolidated in a single UDRP complaint, contact info@cognomenlaw.com.

Step 2: Satisfy all three UDRP elements for every domain in the complaint

Consolidation does not collapse the three-element test. Each domain must independently satisfy Paragraph 4(a), and a panel may transfer some domains and deny the complaint for others if the evidence differs. That is the trap at Step 2: a complainant assumes that a strong case on one domain carries the others by association. It does not.

Element 1 – Confusing similarity. Your registered trademark or service mark is compared to each domain name. The .info suffix is generally disregarded; the comparison is mark versus the second-level label. Where a domain adds a generic word ("info," "buy," "cheap," the brand name plus a product category), panels routinely find confusing similarity because the dominant element remains the mark. Typosquats – transposed letters, doubled consonants, omitted vowels – are almost always caught by this element. Ensure your trademark registration covers the exact classes and territories that correspond to how the registrant is using the domains.

Element 2 – No legitimate interest. You must make a prima facie showing; the burden then shifts to the respondent to rebut. For a cluster of .info domains held by a single registrant, the absence of any pre-complaint use in connection with a genuine offering of goods or services, and the absence of any evidence that the registrant is commonly known by the domain names, will ordinarily satisfy this element. Do not assume default is the same as a win on this element: panels examine the record even when a respondent does not file a response.

Element 3 – Registration and use in bad faith. The UDRP's third element is cumulative – both registration and use must be shown in bad faith. Paragraph 4(b) lists non-exhaustive indicators: registration to sell to the mark owner; registration to disrupt a competitor; registration to attract users for commercial gain by confusion. For .info parking pages, the gain-by-confusion factor is frequently the strongest lever. Passive holding can also constitute bad faith where the mark is well known and no credible good-faith use is apparent.

For a multi-domain complaint, tailor at least a short paragraph of the complaint to each domain's specific use – its current DNS resolution, the content at the URL, the timing of registration relative to your trademark's first use. A generic "these are all bad" section rarely survives scrutiny on the domains where the evidence is weakest.

Step 3: Gather and organize the evidence before filing

Evidence decides .info UDRP outcomes more reliably than legal argument. A well-documented complaint on ordinary facts outperforms a clever legal brief on thin facts.

For each domain, assemble in a separate exhibit: a timestamped WHOIS/RDDS printout, a screenshot of the domain's current webpage (or DNS lookup confirming it is parked or inactive), and – for typosquats – a side-by-side comparison of the mark and the domain label. For parking pages, capture not only the landing page but also a sample of the sponsored links displayed, because panels look to whether those links target the complainant's own brand or competitive products.

For the trademark side: a copy of the registration certificate or registration data from the relevant trademark office for each mark you rely upon. If you hold registrations in multiple countries, lead with the strongest – typically the jurisdiction where the respondent appears to be based or where the parking traffic is directed. Common-law rights (unregistered marks) are recognized under the UDRP but demand substantially more documentary support: sales figures, advertising spend, press coverage, industry recognition. That evidence is harder to assemble for a multi-domain complaint under time pressure.

One practical point: gather the evidence before you instruct counsel. The complaint itself must be filed within any applicable deadline if, for example, you have already sent a cease-and-desist that started a clock. In our practice, clients who arrive with organized WHOIS records, trademark certificates, and URL screenshots cut the filing preparation time – and therefore the cost – significantly.

Step 4: Choose the forum and file the complaint

For .info domains, you have a genuine choice among providers. WIPO and the Forum handle the large majority of UDRP proceedings. CAC operates at a lower price point. How should you choose?

If your dispute is clear-cut – a registrant parking on your exact mark with no evident counterclaim – WIPO's expedited option delivers a decision within approximately one month for single-panel cases covering up to five domains. That is roughly half the standard timeline and available at no extra fee. Not every complaint qualifies, but for a straightforward .info parking cluster it is worth requesting at filing. The Forum does not offer an identical expedited track but has a strong single-panelist docket and a slightly lower entry-level filing fee of approximately USD 1,300 for 1–2 domains. CAC begins around USD 500–800, which matters if you are consolidating a modest number of low-value domains and the legal-fee-to-filing-fee ratio otherwise skews the economics.

The complaint itself must identify: the complainant's trademark rights and the registration details, the domains at issue (all of them, in a single list), the grounds for each element, and the remedy sought (transfer to the complainant, or cancellation). Procedural defects at filing – missing annexes, incorrect respondent identification, missing contact details – can cause a complaint to be dismissed without prejudice, requiring re-filing and restarting the timeline. Check the provider's administrative requirements line by line before submission.

Once filed and formally commenced, the respondent has 20 days to file a response. That window is short. Do not interpret silence in those twenty days as a concession; a default simply means the panel decides on the complaint alone. Panels do still check each element, and a complaint with thin evidence on one domain may lose that domain even on default.

Step 5: Manage the response window and prepare for the panel phase

Most multi-domain .info complaints against a single registrant proceed to default – the registrant does not respond. That is the most common outcome. But "most" is not "all." Some registrants hold .info portfolios as legitimate investment assets, have documentation of good-faith registration, and will file a substantive defense. What happens then?

If a response is filed, you may have the opportunity to submit a supplemental filing, though panels grant those sparingly. The better strategy is to build the complaint so completely that no supplemental is needed. Anticipate the standard Paragraph 4(c) defenses: (i) bona fide use before notice of the dispute; (ii) the registrant is commonly known by the domain name; (iii) legitimate noncommercial or fair use. Address each one in the complaint itself, even if briefly.

You may also receive a settlement approach after filing. Respondents sometimes offer a free transfer once a complaint is on record. Whether to accept depends on timing: if the complaint is already in the panel phase, a settlement may produce a withdrawal and a partial refund from WIPO (commonly around USD 1,000 of the USD 1,500 single-panel fee, if withdrawn before panel appointment). Weigh that against the precedent value and any outstanding domains in other zones not covered by the complaint.

After the response period closes (or a response is received), the provider appoints a panel. The panel issues its decision, and the registrar implements any transfer order. The whole cycle – filing to registrar implementation – typically runs about two months for a standard case, somewhat shorter with WIPO's expedited option.

What if some domains are in other zones – .com, .net, or national ccTLDs?

The same-registrant consolidation rule under the UDRP applies across gTLDs. If the same registrant holds the identical squats in .com, .net, .org, and .info, those can in principle be consolidated into one complaint. The zones are different; the governing rules are the same. This can be a significant efficiency gain when a registrant has assembled a multi-zone portfolio targeting one brand.

National ccTLDs are a separate matter. A .de domain does not fall under the UDRP; it falls under German court procedure, with a DENIC DISPUTE entry available to block transfer while litigation proceeds. A .uk domain falls under Nominet's DRS, which applies a different test – "abusive registration" under a "registered or used" standard – and includes a free mediation stage before any expert decision. You cannot consolidate a .uk domain into a UDRP complaint alongside a .info domain. They require parallel proceedings under different procedural rules. Where the infringing portfolio spans ccTLDs, we identify the governing national procedure, check eligibility, and prepare the filing for each registry.

In a recent matter (a cluster of .info and .com domains, spring 2025), we filed a consolidated UDRP complaint at WIPO covering eight domains against a single registrant who had also registered the brand's .uk equivalent. The UDRP produced transfer orders for all eight gTLD domains in under ten weeks; the Nominet DRS proceeding for the .uk domain ran in parallel and resolved through mediation shortly after. Neither filing waited for the other, and neither produced a gap in coverage.

To weigh UDRP against a court action for your case, email info@cognomenlaw.com.

The traps that defeat otherwise strong complaints – a quick-reference checklist

In our practice handling multi-domain .info complaints, the same failure modes appear repeatedly. None of them involves a difficult legal point. All of them are avoidable with preparation.

• Different registrant names not reconciled. The complaint names five domains; two have privacy-protected WHOIS records with no technical evidence of common control. The panel severs those two.
• Generic trademark. The mark is descriptive or unregistered, and the complainant has not assembled the volume of use evidence needed to establish common-law rights. Element 1 fails on those domains.
• No domain-specific bad-faith analysis. The complaint addresses bad faith in a single paragraph covering all domains. One domain was registered before the complainant's trademark filing date. The panel denies transfer for that domain.
• Stale screenshots. The parking page content shown in the complaint exhibits has been replaced; the respondent points to current neutral content. Bad faith becomes harder to sustain.
• Missing annex with trademark certificate. The complaint references a registration number but omits the certificate as an exhibit. The provider flags a procedural defect; re-filing resets the clock.
• Ignoring the legitimate-interest safe harbors. The complaint never addresses why none of the Paragraph 4(c) factors applies. If the respondent raises a bona fide use argument, the panel has no complainant response to weigh.

Addressing each of these in the complaint itself – not in a supplemental filing after the response – is the single highest-impact step a complainant can take before filing.

Related at COGNOMEN

• UDRP recovery service – assessing elements, forum selection, and filing
• Analysis: recovering a phishing domain under Canadian ccTLD procedure
• Court recovery of a stolen domain in Australia – when UDRP cannot reach

Author: Cordelia Roe — UDRP complainant practice & gTLD recovery; domain transactions and brand protection. Meet the team.

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This publication is general information and does not constitute legal advice. For advice on your situation, contact info@cognomenlaw.com.