question Requesting Feedback on UDRP Draft for a domain

[Andrea Development]

Hi everyone,

I’ve drafted a UDRP complaint for a domain and I’m looking for feedback from those experienced in domain disputes. The draft was prepared according to ICANN and WIPO guidelines, but before filing through the official arbitration channel, we’d like to get a second opinion on its structure, argumentation, and any potential red flags.

If anyone here is familiar with UDRP filings or has gone through a similar process, I’d really appreciate any insights you could share, or if you'd be open to reviewing the draft privately, that would be amazing too.

Thanks in advance!

 

[jberryhill]

If anyone here is familiar with UDRP filings

I might qualify. I have either filed or defended on the order of 350 UDRP proceedings.

or if you'd be open to reviewing the draft privately, that would be amazing too

One thing I would strongly suggest is that you not communicate with anonymous strangers on web forums to review a document that could become relevant in a legal dispute at some future point.

First, it would be interesting to know how on earth are you going to decide whether that friendly person you found on a forum is not going to alert the registrant, or possibly even be the registrant of the domain name, in order to engage in some sort of further abusive behavior. In other words, what makes you think the domain registrant is not a member here?

Secondly, your communications with anyone other than an attorney are not subject to the ordinary confidentiality and privileges of attorney/client communications.

 

[Andrea Development]

Hi,
Thank you for your message, I genuinely appreciate the concern. That said, I was honestly a bit surprised by your response.
To clarify, I’m not looking to disclose any sensitive or identifying information. My request was strictly about getting a second opinion on the structure and wording of the document. I would never share the actual draft with real names, domain names, or any details that could compromise confidentiality or the integrity of the process.
Naturally, all identifying elements would be fully removed or replaced with fictional placeholders. I assumed that was a given, but I do understand your caution, and I respect your experience in this area.
If you’re open to it, I’d still really value your input, even just on a redacted version. Either way, thank you again for taking the time to respond!

 

[jberryhill]

Uh-huh. Sure.

 

[jberryhill]

Aside from the AI generated response itself, the idea that the “structure” of the UDRP complaint could be evaluated independent of the content is kind of odd, in view of how fact-intensive these kinds of disputes necessarily are.

But the idea of asking a bunch of strangers is even more weird. How would you even evaluate the feedback you received from people about whose level of expertise you know nothing? With more AI?

If you have a commercially valuable trademark over which it is worth filing a UDRP, then it is also worth consulting with someone who actually knows what they are doing. But I genuinely doubt that’s what you are up to here.

 

[jberryhill]

Shorter version - "I'd like help in training an AI bot to write a fake UDRP complaint that won't look overtly suspicious."

https://www.wipo.int/amc/en/domains/decisions/pdf/2025/d2025-0756.pdf

"This Complaint is replete with material omissions and outright lies, such as assuming the
identity of nonexistent and defunct corporations, submitting a copy of the Respondent’s (cancelled)
trademark certificate, and claiming continuous use of a domain name, website, and social media site without
proof that the Complainant ever controlled them. Moreover, it appears that the Complainant fabricated a
document to make a spurious case for bad faith against the Respondent. A valuable and apparently
dormant domain name makes a tempting target, and it is lamentable that a legitimate registrant should be
put to the burden of defending against such an abuse of the administrative proceeding."

 

[alop]

Thanks jberryhill

All jokes aside

A date would be helpful

Tyzzzzz

 

[lambo.com]

How would you even evaluate the feedback you received from people about whose level of expertise you know nothing?

Appeal to authority fallacy.

It may be rare but some actually possess discernment!

I know that must seem strange, especially here on NamePros.

 

[biggie]

Uh-huh. Sure.

Hi

spider cents was tingling!

imo...

 

[Gabriel360]

Shorter version - "I'd like help in training an AI bot to write a fake UDRP complaint that won't look overtly suspicious."

https://www.wipo.int/amc/en/domains/decisions/pdf/2025/d2025-0756.pdf

"This Complaint is replete with material omissions and outright lies, such as assuming the
identity of nonexistent and defunct corporations, submitting a copy of the Respondent’s (cancelled)
trademark certificate, and claiming continuous use of a domain name, website, and social media site without
proof that the Complainant ever controlled them. Moreover, it appears that the Complainant fabricated a
document to make a spurious case for bad faith against the Respondent. A valuable and apparently
dormant domain name makes a tempting target, and it is lamentable that a legitimate registrant should be
put to the burden of defending against such an abuse of the administrative proceeding."

Holy shit!
This is insane!

This is why it is very important for RDNHers to face tangible repercussions.

This scammer spent a couple of dollars in an attempt to hijack a multimillion-dollar asset.

He already attempted to hijack the domain name by using a fake russian email that corresponds to the domain owner's real name. When that failed, he filed a UDRP with that same russian email address.

Not a particularly smart scammer.
He fabricated a ransom note allegedly sent by the respondent demanding $3M to return the domain name.

He claimed to be the owner of an expired TM registration that was previously registered by the real domain owner.

He pretended to be represent a defunct/inactive company with a similar name to give legitimacy to his claims.

He submitted the LinkedIn Profile of a company he has no relationship with in order to claim legitimacy.

This is a criminal trying to use the UDRP in a domain heist.

We need more consequences for hijackers!

The UDRP needs to be better.
Apparently they don't verify the identity of complainants. The Complainant in this case used a fake name as his representative.

So anybody can claim to be anybody in a UDRP filing. I can claim to be Mark Zuckerberg and file a UDRP to hijack Meta names.

UDRP needs to do better.

 

[jberryhill]

I can claim to be Mark Zuckerberg and file a UDRP to hijack Meta names.

Yep. Pretty much. There are a couple of things you need to do in order to obscure the path back to - like using a pre-loaded debit card to pay the fees, etc.. But no, there’s no verification of the authority of anyone who files one.

I had a client who got a fake one. I got in touch with the attorney of record for the registered trademark in the complaint, and they got in touch with their client to confirm they had nothing to do with the UDRP filing.