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Moore v. ICANN

This page collects documents from lawsuits and similar legal proceedings related to ICANN. They are arranged by initial filing date in descending order.

Moore v. ICANN
(lawsuit in United States District Court, Northern District of Alabama)

Court Order Dismissing ICANN for Lack of Jurisdiction [PDF, 169 KB] 9 November 2007
Third [sic] Amended Complaint [PDF, 2.6 MB] 8 October 2007
ICANN's Reply in support of its Motion to Dismiss and related exhibits [PDF, 1.8 MB] 28 September 2007
Plaintiff's Cover Page re: Evidentiary Submission in Support of Their Supplemental Statement of Facts and Brief in Opposition to Defendant ICANN's Argument that there is no Personal Jurisdiction over ICANN [PDF, 49 KB] 25 September 2007
Plaintiffs' Supplemental Statement of Facts and Brief in Opposition to Defendant ICANN's Argument that there is no Personal Jurisdiction over ICANN [PDF, 65 KB] 25 September 2007
Court Order re: Motions to Dismiss [PDF, 77 KB] 20 September 2007
eNom's Reply in support of its Motion to Dismiss [PDF, 49 KB] 19 September 2007
ICANN's Oppisition to Plaintiffs' Motion for Discovery [PDF, 141 KB] 14 September 2007
Plaintiff's Motion to Strike Certain Exhibits Submitted in Support of Defendants ICANN and eNom's Motions to Dismiss And Opposition to Defendants' Motions to Dismiss [PDF, 121 KB] 12 September 2007
Enom's Response to Motion for Leave to Conduct Discovery and eNom's Cross-Motion to Stay Discovery [PDF, 249 KB] 11 September 2007
Motion to Seek Leave To Conduct Discovery Regarding the Defenses Asserted by Defendants in Their Motions to Dismiss [PDF, 41 KB] 10 September 2007
Kane Declaration in Support of eNom's Motion to Dismiss [PDF, 6.5 MB] 30 August 2007
eNom's Brief in Support of Motion to Dismiss for Failure to State a Claim [PDF, 93 KB] 30 August 2007
eNom's Motion to Dismiss for Failure to State a Claim [PDF, 21 KB] 30 August 2007
ICANN's Disclosure Statement Pursuant to Local Rule 3.4 [PDF, 45 KB] 30 August 2007
Brent Declaration Re: Jurisdictional Issues in Support of ICANN's Motion to Dismiss [PDF, 885 KB] 30 August 2007
ICANN's Brief in Support of its Motion to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(2) and 12 (b)(6) [PDF, 985 KB] 30 August 2007
ICANN's Motion to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(2) and 12 (b) (6) [PDF, 49 KB] 30 August 2007
Motion to Substitute Name of Defendant [PDF, 41 KB] 17 July 2007
Complaint [PDF, 1.02 MB] 19 June 2007
Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as""icann.org"" is not an IDN."