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DotConnectAfrica Trust v. ICANN

Amended Reply Memorandum in Support of ICANN's Motion to Dismiss First Amended Complaint [PDF, 178 KB] 14 April 2016
Order re: Plaintiff’s Motion for Preliminary Injunction [PDF, 45 KB] 12 April 2016
Reply Memorandum in Support of ICANN’s Motion to Dismiss First Amended Complaint [PDF, 824 KB] 11 April 2016

Plaintiff's Opposition to ICANN's Motion to Dismiss First Amended Complaint

4 April 2016
Stipulation Regarding Time for Defendant ZA Central Registry to File Its Response to Plaintiff's First Amended Complaint [PDF, 43 KB] 1 April 2016

The Court issued the following docket text entry: "SCHEDULING NOTICE TO ALL PARTIES AND ORDER by Judge R. Gary Klausner. Plaintiff DotConnectAfrica Trust's Motion for Preliminary Injunction, calendared for hearing on April 4, 2016, has been taken under submission and off the motion calendar. No appearances by counsel are necessary. The Court will issue a ruling after full consideration of properly submitted pleadings. IT IS SO ORDERED."

29 March 2016
28 March 2016

ICANN's Notice of Motion and Motion to Dismiss First Amended Complaint [PDF, 121 KB]

25 March 2016

Plaintiff's Reply in Support of Motion for Preliminary Injunction; Memorandum of Points and Authorities [PDF, 527 KB]

 21 March 2016
Order Setting Scheduling Conference [PDF, 26 KB] 18 March 2016

ICANN's Opposition to Plaintiff's Motion for Preliminary Injunction [PDF, 706 KB]

14 March 2016

Minute Order re Plaintiff's Ex Parte Application for TRO [PDF, 24 KB]

4 March 2016

ICANN's Opposition to Plaintiff's Ex Parte Application for Temporary Restraining Order [PDF, 220 KB]

3 March 2016

Notice of Ex Parte Application for Temporary Restraining Order; Memorandum of Points and Authorities [PDF, 764 KB]

2 March 2016

Notice of Motion and Motion for Preliminary Injunction; Memorandum of Points and Authorities [PDF, 866 KB]

1 March 2016
Plaintiff's First Amended Complaint [PDF, 613 KB] 26 February 2016
16 February 2016
Notice of Removal [PDF, 3.7 MB] 8 February 2016
Court Order Denying Plaintiff's Ex Parte Application for Temporary Restraining Order and Order to Show Cause Re Preliminary Injunction [PDF, 29 KB] 27 January 2016

At the hearing, the Honorable James C. Chalfan denied Plaintiff's Ex Parte Application for Temporary Restraining Order and Order to Show Cause Re Preliminary Injunction for improper notice and insufficient evidence. The ruling was issued orally from the bench. A written Minute Order will be issued by the Court and posted shortly.

25 January 2016

Special Appearance of ICANN in Opposition to Plaintiff's Ex Parte Motion for Temporary Restraining Order, with Exhibit A [PDF, 601 KB]

25 January 2016

Plaintiff DCA's Ex Parte Application for Temporary Restraining Order and Order to Show Cause Re Preliminary Injunction; Supporting Declarations of Sophia Bekele and Brandon Schantz [PDF, 19.8 MB]

25 January 2016

Complaint [PDF, 4.2 MB]

  • ICANN has not been served with the Complaint.

20 January 2016

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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."