1. Develop nonverbal ways through your keyboard of creating credibility without being arrogant. A short bio demonstrating your computer literacy knowledge and mediation skills is useful.

2. Create a confidentiality agreement that describes the online process. Include rules about responding to Email; the importance of disclosing information only to the mediator; managing delays in responding online; and notifying the mediator of travel plans to maintain uninterrupted communications over the Internet.

3. Set the agenda of the online discussion early by instructing the parties to send you an Email with their suggested list of the issues in the dispute.

4. Develop a set of online "ground rules" which include "artificial" time limits.

5. When responding to Email messages, filter angry or emotional replies so that the other party receives a response that doesn't create further hostility.

6. Post no more than two or three short questions per Email that are like trial balloons in mediation. Keep them short and make sure you're not viewed as favoring one side or the other.

7. No matter how contentious the parties might become online, keep the conversation moving forward by reminding the parties of the goal of the mediation.

8. Be prepared to provide an evaluation of the case after the parties have exhausted their efforts at reaching an acceptable solution.

9. If you are providing an evaluation of the case, make sure you have strong factual and legal support that cannot be overcome by the parties.

10. Know the correct Email addresses of the parties and make sure you know which ones are used regularly and which ones are rarely used.

Outline