DOMAIN NAME DISPUTE COMPLAINT FORM
(All references to "Rule" are to ICANN's "Rules for Uniform Domain Name Dispute Resolution Policy."
Utilizing this Complaint form is not a substitute for reading and understanding the ICANN rules)

COMPLAINT
File Number: (Assigned by The Forum)
Filing Date: FA0005000094906


COMPLAINANT (Name, full address & contact information: Rule 3(b)(ii))
Name: Ruben L. Lopez
Address 1: 7030 De Longpre Ave.
Address 2:
Address 3:
City: L.A. State: Postal Code: 90028
Country: US
Telephone: 323-461-6600 Fax: 323-461-6622
E-Mail Address: webmaster@rockcitynews.com

RESPONDENT (Name, full address & contact information: Rule 3 (b)(v))
Name: Irish Realty Inc.
Address 1: 120 N. Robinson #2100
Address 2:
Address 3:
City: Oklahoma State: OK Postal Code: 73102
Country: US
Telephone: 405-232-2100 Fax: 405-232-2107
E-Mail Address: irish2100@aol.com

The above named Complainant requests that this Complaint be submitted for decision in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy and Rules. Rule 3(b)(i)

Name and contact information of person or representative authorized to act for the Complainant in the proceeding if different from above: Rule (b)(ii)

Name: Attorney at Law
Address 1: 444 S. Flower St. #2300
Address 2:
Address 3:
City: L.A. State: CA Postal Code: 90071
Country: US
Telephone: 213-626-3588 Fax: 213-833-7812
E-Mail Address:

Contact person's preferred method for receiving electronic and hard-copy material (e-mail required): Rule 3(b)(iii)
(Check one preferred method, enter all three addresses/numbers.)
( ) Fax to: 213-833-7812
( x) E-mail Address:
( ) US Postal Service at: 444 S. Flower St. #2300, L.A., CA 90071


The Complainant is seeking a panel of ( x )One ( )Three arbitrator(s). Note: If Complainant seeks only one arbitrator, no arbitrator candidate names are required below.

Name of Arbitrator candidate(s) - If Available: Rule 3 (b)(iv)
Candidate(s) Name Address Telephone Number
1.
2.
3.

Specify the domain name(s) that is/are the subject of the complaint: Rule 3(b)(vi)

rockcity.com


Identify the Registrar Company with whom the domain name(s) is/are registered (e.g. Network Solutions, Register.com): Rule 3(b)(vii)
Registrar's Name: Verio Inc.
Registrar's Address: 5 Financial Plaza, Napa, CA 94458
Telephone Number: 707-256-1999 Fax Number: 707-256-1997
E-Mail Address: veriohostmaster@TABNET.COM

Specify the trademark(s) or service mark(s)(e.g. logo, symbol, company name, product name, etc;) upon which the complaint is based: Rule 3(b)(viii)

Rock City


THIS SECTION NOT TO EXCEED 10 PAGES Ð Supp. Rules 4(a)

Please print or type on this form or on a separate document if more space is needed.

Describe the grounds on which the complaint is made. Rule 3(b)(ix). In particular, the complaint must describe:
1. The manner in which the domain name(s) are identical or confusing
2. Why the Respondent should be considered as having no rights or legitimate interest in the domain name(s)
3. Why the domain name(s) should be considered as having been registered and used in bad faith

The description should, for elements (2) and (3), discuss any aspects of Paragraphs 4(b) and 4(c) of the ICANN Uniform Domain Name Dispute Resolution Policy that are applicable.

Grounds included on separate documents.

Specify the remedy sought: Rule 3(b)(x), Policy Paragraph 4(i) (transfer or cancel Ð only one)

Transfer of domain name to complaintant.



Identify any other legal proceedings that have been commenced or terminated in connection with or relating to any of the domain names that are the subject of this complaint. Rule 3(b)(xi)

1. We have filed for a U.S. trademark for "Rock City."
2. They have filed for a U.S. trademark for "rockcity.com"
3. We are currently filing our opposition to their application for trademark with the evidence enclosed with this complaint.

I/We Ruben L. Lopez assert the following under penalty of perjury;

1. A copy of this Complaint together with the "Complaint Transmittal Sheet" has been sent or transmitted to the Respondent in accordance with Rule 2(b), Rule 3(b)(xii).

2. Complainant submits to court jurisdiction in (only one of the following must be checked):
( x ) The location of the principal office of the Registrar where the domain name was registered.
( ) The location of the domain name holder's address as shown for the registration of the domain name in Registrar's Whois database at the time the complaint was submitted to the Forum. Rule 3(b)(xiii)

3. Complainant agrees that its claims and remedy concerning the registration of the domain name, the dispute, or the dispute resolution shall be solely against the domain-name holder and waives all such claims and remedies against;
- The dispute-resolution provider and panelists, except in the case of deliberate wrongdoing
- The registrar
- The registry administrator
- The Internet Corporation for Assigned Names and Numbers, as well as their directors, officers, employees and agents.

4. Complainant certifies that the information contained in the Complaint is to the best of the Complainant's knowledge complete and accurate and that this Complaint is not being presented for any improper purpose, such as to harass.

5. That the assertions in this Complaint are warranted under these Rules and under applicable law, as it now exists or as it may be extended by a good faith and reasonable argument.

Signature of Complainant or Representative:

Date: 5/31/00


By signing this document or checking here ( x ) I certify the above assertions are true and correct.



Send the Complaint Transmittal Sheet, a copy of ICANN's Uniform Domain Name Dispute Resolution Policy, the Complaint, and any documents or other evidence applicable to the domain name(s) in dispute and any trademark or service mark registration upon which the complaint relies, together with a table of contents of the evidence, Rule 3(b)(xv), to The National Arbitration Forum by email (info@arb-forum.com) and also by mail (P.O. Box 50191, Minneapolis, Minnesota 55405 USA), Supp. Rule 4.d.

Enclose the appropriate Filing Fee with Complaint Submission.

Filing Fee Amount: $ 750.00
( x ) Check or Money Order Enclosed
( ) Charge to Credit Card Account ( )Visa ( )MasterCard ( )Discover ( )American Express

Account Number: Expiration Date:

Signature:
Date:

By signing this document or checking here ( x ) I authorize the National Arbitration Forum to charge the Filing Fee Amount entered above to the account indicated above.


National Arbitration Forum
P.O. Box 50191, Minneapolis, Minnesota 55405 USA
Telephone: 651-631-1105 or 800-474-2371
www.arbitration-forum.com

Rock City vs. rockcity.com - Table of Contents w/ evidence - Complaint - Grounds - Trademark /Timeline - Response Cover - Response - Response to Response - ICANN Decision - Our Opinion/Press Release - Call 323-461-6600 or email us.