Hi, I just got a udrp (via WIPO) filed against us couple of days ago and need to respond by May 24. We are in USA. Complainant is from India (complainant lawyer is from India too) and they didn't have any registered TM in USA (in fact they still don't have any registered TM in USA per USPTO.gov search) when we registered the domain in Mar 2005. We don't believe we are infringing any TM. Their complaint basically relies on their common law TM from India as they claim. They only registered their TMs in Indian in last couple of years and submitted that as evidence of TMs. We also have evidence of running a information blog website on the domain in 2008 and then later we couldn't manage the site actively and shut it down and parked the domain. Parking page never displayed any link to or name of the complainant...just generic links. The entire blog and its pages, posts, etc are all archived in the wayback machine / internet archive and are accessible to anyone. We never attempted any contact with the complainant and the complainant never contacted us before. They claim common law TM in India and accuse us of registering domain to sell them later for huge sum (never did anything like this, never contacted them at all) and saying that we never had fair use for domain because they just submitted a recent snap shot of uniregistery parking page with generic links on it. They never mentioned that we had a full blog on it in 2008, may be they don't know about it. I am thinking of filing a response myself (can't afford a lawyer as I can't afford anything over 5 to 6 hundred...things are little tight) but have the following questions: 1. Can I just send a simple response back in the email and attach a word document or pdf etc as a response to the complaint email we received. 2. Do I need to use a specific form or response template to file response to WIPO? 3. Is there any database that shows positive wording cases (such as parking is a bonafide business etc.) that I can use to refer to while preparing my response. I have just made all the notes of response points to write back after reading the complaint. Please let me know what you think. Thank you for your advise.