http://www.icann.org/en/wipo/wipo-p...-30dec08-en.pdf

ICANN Comments forum
http://forum.icann.org/lists/eudrp/

Email address (Closes 12 August 2009)
eudrp@icann.org

I submitted a couple of comments:

http://forum.icann.org/lists/eudrp/msg00001.html
http://forum.icann.org/lists/eudrp/msg00003.html

NAF's comment included an interesting tidbit:

http://forum.icann.org/lists/eudrp/msg00000.html

The UDRP requires a "formalities" or "deficiency" check before a Complaint can be accepted by the Provider and served on the Respondent (UDRP Rule 4). In over 90% of cases (anectodally), the Complaint has at least one "deficiency" that needs to be corrected. (from bottom of page 1 of the PDF)

90% is a shocking statistic, given that complainants have unlimited time to prepare their complaints. This highlights the lack of fairness and lack of due process in the short time period for domain name registrants to respond to UDRP complaints (and potentially to URS complaints).