Step-by-step: request a three-member panel to defend a .global domain

Step-by-step: request a three-member panel to defend a .global domain. UDRP and ccTLD domain recovery and defense across .global. Email the firm to assess your…

A complaint lands in your inbox. Someone is claiming your .global domain – the one your organization has operated under for years – and WIPO has formally commenced a UDRP proceeding. You have 20 days to respond. The single biggest procedural decision you will make in that window is whether to request a three-member panel instead of letting the appointed sole panelist decide alone.

A registrant defending a .global domain under the UDRP may request a three-member panel at any time before the response deadline expires. The governing framework is Paragraph 4(b) of the UDRP Rules, under which the respondent's request triggers a fee split: each side typically pays half of the incremental cost of a three-member panel, which at WIPO runs USD 4,000 for one to five domains. The request is strategic, not automatic – it is most valuable when the complaint is thin, when legitimate-interest evidence is strong, or when an RDNH finding is a realistic goal.

This guide walks each step of the process, flags the trap inside each one, and explains how to build the evidence record that actually decides the outcome in a .global dispute.

What governs a .global domain dispute – and why the UDRP applies

The .global registry has adopted the UDRP as its dispute-resolution policy, which means the same three-element test that governs .com governs .global. The complainant must prove all three elements of Paragraph 4(a): (i) the domain is identical or confusingly similar to a mark in which the complainant has rights; (ii) the registrant has no rights or legitimate interests in the domain; and (iii) the domain was registered and is being used in bad faith. All three must be satisfied. The failure of any single element ends the case.

That cumulative structure is the registrant's first line of defense. In our practice, we see complainants who establish element one readily – they hold a registered trademark, the names match – but cannot clear element two because the registrant has a genuine business reason for holding the domain. The .global extension, by design, attracts organizations with a genuinely international scope: advocacy groups, cross-border commercial platforms, intergovernmental bodies, and large distributed enterprises. Many of those registrants have a legitimate story to tell. The question is whether the response tells it effectively.

WIPO administers the overwhelming majority of UDRP proceedings for new gTLDs, including .global. Its Supplemental Rules and the Expedited Option (which can return a decision within about one month for single-panel cases of up to five domains) also apply. Choosing WIPO's standard track versus the expedited option is a complainant's call, not yours – but knowing which track the complaint is on shapes your timeline.

If you have received a UDRP complaint for a .global domain and need a rapid assessment of your legitimate-interest position, contact info@cognomenlaw.com.

Step 1: Read the complaint immediately – and identify the weakness before drafting a word

The single most productive use of the first 48 hours after commencement is a careful reading of the complaint for structural gaps, not a first draft of your response. The three elements are sequential; a gap in any one of them can be decisive. Ask: Does the complainant actually hold a registered mark – or only a pending application, a trade name, or a common-law claim that requires factual support? Does the mark predate your registration? Is the claimed similarity really confusing, or does the complainant conflate a generic or descriptive word with a distinctive brand?

The trap at this step is responding to the emotional weight of the complaint rather than its legal structure. Complainants sometimes build lengthy narratives of alleged harm while the foundational legal question – whether the domain was registered in bad faith – is supported only by inference. A response that tracks the legal elements precisely, section by section, is more persuasive than one that answers the narrative.

Document your reading. Note the page and line of every evidentiary claim the complainant makes. That annotation becomes your response outline.

Step 2: Decide whether to request a three-member panel to defend a .global domain

Under the UDRP Rules, either party may request a three-member panel. If the complainant asked for a sole panelist and you want three panelists, you bear half the cost difference – at WIPO, that means you pay USD 1,250 of the three-member fee for a single domain, with WIPO holding the complainant's USD 1,500 filing fee and collecting the balance from you. Confirm the exact current figure with WIPO's Case Administration at the time of filing; fees are published on WIPO's website and updated periodically.

When does a three-member panel make strategic sense? Consider requesting one where any of the following apply:

• The complaint is aggressive or thin – a weak evidentiary record with strong legal conclusions – and you want the protection of a collegiate decision.
• Your legitimate-interest case is nuanced. Three panelists bring three independent assessments of a fact-intensive argument.
• You intend to seek an RDNH finding. A finding that the complaint was brought in bad faith is more credible, and more reputationally significant for the complainant, when issued by a panel of three rather than a sole panelist.
• The complainant chose a three-member panel, in which case the respondent pays nothing extra – but you still nominate one of the three panelists from the provider's roster.

The trap: requesting a three-member panel as a delay tactic, without a substantive defense strategy, wastes your fee contribution and signals to the panel that the respondent lacks confidence in the merits. Request three panelists when the facts warrant it. Not as a default.

Step 3: Build the Paragraph 4(c) safe-harbor record before you file anything

Paragraph 4(c) of the UDRP sets out three non-exhaustive circumstances that, if demonstrated, establish rights or legitimate interests in the domain. They are: (i) before notice of the dispute, you used the domain or made demonstrable preparations to use it in connection with a bona fide offering of goods or services; (ii) you have been commonly known by the domain name; or (iii) you are making a legitimate noncommercial or fair use of the domain, without intent for commercial gain to misleadingly divert consumers or tarnish the mark. You need to satisfy at least one.

In our experience with new-gTLD disputes, the bona fide offering safe harbor at Paragraph 4(c)(i) is the most frequently relied upon – and the most frequently under-evidenced. Panels look for concrete, contemporaneous proof of use before notice: live website screenshots with archived dates, invoices or contracts referencing the domain, internal emails or board records planning the launch, and registration history showing the domain was acquired for an operational purpose rather than speculative resale.

Gather everything before drafting the response. Common evidence categories include:

• Archived screenshots from the Wayback Machine or similar services, showing the site at specific dates.
• Business registration documents, licenses, or incorporation papers reflecting the name.
• Press coverage, third-party directories, or conference listings using the domain or the matching trade name.
• Internal communications – board minutes, project plans, pitch decks – showing the .global registration was planned as an operational asset.
• Email traffic routed through the domain, demonstrating active use in commerce.

The trap here is assuming use is obvious and therefore does not need documentation. Panels decide on the record. If the evidence is not in the annexes, it does not exist for the panel's purposes. Every legitimate-interest argument must be anchored to an exhibit.

How do you assess whether an RDNH finding is realistic?

Reverse Domain Name Hijacking – a panel finding that the complaint was brought in bad faith to deprive a legitimate registrant of the domain – is a genuine remedy under the UDRP, though it is reputational rather than financial. No money is awarded. The finding appears in the published decision and forms part of the complainant's public record before WIPO and the Forum.

Panels have consistently held that an RDNH finding is warranted where the complainant knew or should have known it could not prevail – for example, because the respondent's registration predated the complainant's trademark rights, because the domain is composed of a generic term, or because the complainant had actual knowledge of the registrant's legitimate use. The standard is high. A case that simply fails on the merits does not automatically attract RDNH.

We regularly advise respondents who have a strong RDNH case but do not press it in the response because they are focused only on defeating the transfer. That is a missed opportunity. If the evidentiary record supports it, a targeted RDNH argument – briefly stated, clearly anchored to the complaint's own failings – adds value at no incremental procedural cost. In a recent matter (a .global domain held by an international advocacy body, spring 2025), we secured an RDNH finding for a registrant whose domain predated the complainant's trademark registration by over two years. The complainant's filing had cited only a post-registration trademark application as its rights basis.

The trap: over-arguing RDNH. A respondent who devotes half the response to attacking the complainant's motives, while neglecting to document legitimate interest, risks losing on both counts. Build the legitimate-interest record first. Let the RDNH argument follow from the complainant's demonstrable failings, not from frustration with the filing.

If you believe the complaint against your .global domain may warrant an RDNH finding, email info@cognomenlaw.com for an assessment of whether the record supports that argument.

Step 4: Draft and file the response within the 20-day window

The response must be filed with WIPO – or the relevant UDRP provider – within 20 days of formal commencement of the proceeding. Missing this deadline is catastrophic. A default does not mean automatic transfer, but panels deciding without a response have only the complainant's version of the facts and a strong structural presumption in favor of the complaint. Extensions are available only in exceptional circumstances and must be requested before the deadline expires.

Structure the response to mirror the three UDRP elements in order. Address element one first, even if it is the weakest battleground, because every concession or admission there affects the panel's reading of elements two and three. On element two, lead with your strongest Paragraph 4(c) category and attach every supporting exhibit immediately. On element three, analyze both prongs – registration in bad faith and use in bad faith – because the UDRP requires both, and a failure on either defeats the complaint.

The trap is treating the response as a brief rather than an evidentiary submission. Panels are not courts. They give substantial weight to documentary exhibits over argument. A response supported by ten well-organized annexes will generally outperform a response that is twenty pages of prose with three exhibits attached. Organize the annexes logically, number them sequentially, and cross-reference each one in the body of the response.

Where a three-member panel has been requested, the response must also include the respondent's nomination of one panelist from WIPO's list of neutrals. WIPO provides the list; the complainant nominates one, the respondent nominates one, and WIPO's Center appoints the third who serves as presiding panelist. That appointment process adds a few days to the schedule, which is normal and expected under the Rules.

Step 5: Understand what evidence actually decides the outcome

After years of UDRP practice, we have found that the cases that turn against registrants are almost never lost on legal argument alone. They are lost because the evidentiary record is thin, inconsistent, or internally contradictory. The panel's task is to make findings of fact on limited materials submitted under a compressed timeline. What tips those findings?

Contemporaneity matters above all. Evidence of legitimate use that predates the complainant's notice – whether that notice came from a cease-and-desist letter, a WIPO communication, or an earlier informal approach – is categorically stronger than evidence assembled afterward. Panels are trained to spot after-the-fact documentation: a website relaunched days after a complaint was filed, business cards printed after commencement, domain renewal records updated to reflect a revised purpose.

Consistency matters next. If your response asserts you are commonly known by the domain name, but your corporate registration uses a different name, your invoices use a third name, and your email domain is a fourth, the inconsistency undermines the legitimate-interest claim. Panels are not hostile to complex organizational structures, but they expect the evidence to tell a coherent story.

Finally, the bad-faith analysis under Paragraph 4(b) is fact-specific. None of the non-exhaustive bad-faith indicators listed there – registration to sell to the mark owner, registration to disrupt a competitor, use to attract users by confusion – apply in isolation. A respondent who can show the registration predated the complainant's mark, or that there was no commercial motivation involving the complainant's brand, will generally defeat element three even where elements one and two are closer calls.

How does the .global zone compare to other dispute routes?

The .global extension operates under the UDRP, administered by WIPO. That alignment means the process, the evidence standards, and the remedies are the same as for .com: transfer or cancellation only, no monetary award, no cost order. A complainant who wants damages for cybersquatting must go to court – the UDRP cannot reach money.

Compare that to a national ccTLD. If the same dispute involved a .de domain, there would be no UDRP at all; the German courts govern, and a DENIC DISPUTE entry can block transfer while litigation proceeds. If it involved a .uk domain, the Nominet DRS would apply, with its own test of "abusive registration" and a critical difference from the UDRP: the DRS reads "registered or used" abusively, a meaningfully lower bar for complainants on the use prong than the UDRP's cumulative "registered and used in bad faith."

For .global registrants, the UDRP's cumulative bad-faith requirement is an asset. A complainant who cannot show both registration in bad faith and ongoing bad-faith use fails element three, period. In our practice, this is the most common point of failure in weak complaints against registrants with genuine operational histories under the domain.

If the same domain owner holds both a .global and a ccTLD registration, both may be covered in a single UDRP complaint only if the registrant is the same holder. Two separate forum tracks are otherwise required – which is relevant to budget planning and response coordination if you hold a portfolio.

See also our analysis of a national dispute procedure case study involving a .fr domain, where the cross-border angle produced a different procedural map.

Related at COGNOMEN

• UDRP respondent defense and RDNH findings – full service overview
• Defending a UDRP complaint before WIPO: the Switzerland-connected case angle
• Case study: national dispute procedure for a .fr domain