"Whatsapp.Com.Pk"

Total Page:16

File Type:pdf, Size:1020Kb

Domain Name Dispute Resolution Center (DNDRC) Arbitration and Mediation Center COMPLAINT PANEL DECISION Whatsapp Inc. v. WCL Case No. C2017-0007 Also in PDF C2017-0007 1. The Parties The Complainant is WhatsApp, Inc.1601 Willow Road Menlo Park, California United States of America 94025. The Complainant has initiated the Complaint vide their authorized representative, Mr. David Taylor of Hogan/ Jane Seager Lovells (Paris) LLP, located at 17, avenue Matignon 75008 Paris, France. The Respondent’s name is WCL with its address at 17 Tariq Road Karachi Pakistan. 2. The Domain Names and Registrar The domain name in dispute is <whatsapp.com.pk>, hereinafter referred to as the Disputed Domain Name. Vide email dated Wednesday 19 July 2017, PKNIC has informed DNDRC that the Agent Organization through which the registration was applied is WCL with its address at 173-p Tariq Road, Karachi, Pakistan and its Create Date was 2015-11-30 with an Expire Date of 2017-11-30. 3. Procedural History DNDRC was informed of the Complaint against the Respondent as per PKNIC - Internet Domain Registration Policy, by notification from the Complainant on 5 July 2017. The Respondent was issued notification of the dispute along with a copy of the Complaint and a Response Form on 19 July 2017 informing the Respondent that if a Response was not received 7 days from the notification, the dispute would be proceeded ex parte. DNDRC awaited the submission by the Respondent of the Response as per the prescribed forms also available at www.dndrc.com/downloads. Applying Paragraph 4(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the Rules), DNDRC appointed Mr. Abbas Lotia as the sole Arbitrator who has verified that the Complaint satisfies the formal requirements of the Policy and the Rules. Factual Background The domain name upon which the Complaint is based is <whatsapp.com.pk> PKNIC has confirmed via their email dated 19 July 2017 that the Disputed Domain Name has been registered by the Respondent named in the Complaint and that their email address is [email protected]. 4. Parties Contentions A. Complainant The Complainant’s brief contentions are reproduced below: The Complainant, WhatsApp Inc., is a provider of one of the world’s most popular mobile messaging applications (or "apps"). Founded in 2009 and acquired by Facebook, Inc. in 2014, WhatsApp allows users across the globe to exchange messages via smartphones without having to pay for SMS. Its main website available at www.whatsapp.com is the 49th most visited website in Pakistan and the 71th most visited website in the world, according to web information company Alexa (Annex 3). Since its launch in 2009, WhatsApp has become one of the fastest growing and most popular mobile applications in the world, with over 1 million users by the end of 2009, 200 million users in April 2013, 500 million users in April 2014, 800 million users in April 2015 and 900 million users worldwide in September 2015. Today, WhatsApp has over 1 billion monthly active users worldwide (as of February 2016) in 180 countries. It is available in over 50 languages, including Urdu since August 2015. Needless to say, WhatsApp has acquired considerable reputation and goodwill worldwide, including in Pakistan where the Respondent is based, as widely reported by the national and international press, and it has consistently ranked amongst Apple iTunes 25 most popular free mobile applications. Furthermore, the Complainant's official website available at www.whatsapp.com is regularly amongst the Top 100 most visited websites in the world, according to web information company Alexa. See Annex 4 for information on the Complainant including company information and press articles on WhatsApp's explosive growth and popularity worldwide, including in Pakistan. Reflecting its global reach, the Complainant is the owner of numerous domain names consisting of the WHATSAPP trade mark, including, for instance, <whatsapp.com>, <whatsapp.net>, <whatsapp.org>, <whatsapp.info> as well as under numerous country code extensions such as <whatsapp.eu> (European Union), <whatsapp.am> (Armenia), <whatsapp.cl> (Chile), <whatsapp.de> (Germany), <whatsapp.hk> (Hong Kong), <whatsapp.in> and <whatsapp.co.in> (India), <whatsapp.ly> and <whatsapp.com.ly> (Libya), <whatsapp.nl> (the Netherlands), <whatsapp.nz> (New Zealand), <whatsapp.pk> (Pakistan), <whatsapp.tw> (Taiwan), <whatsapp.uk> and <whatsapp.co.uk> (United Kingdom), and <whatsapp.us> (United States). See Annex 5 for copies of the WHOIS records of some of these domain names. The Complainant also has also made substantial investments to develop a strong presence on the different social media forums available online and currently has approximately 27.4 million "likes" on its official Facebook page: − https://www.facebook.com/WhatsApp − https://twitter.com/whatsapp − https://www.linkedin.com/company/whatsapp-inc. Screen captures of the Complainant's social media websites are available at Annex 6. The fame of the Complainant's trade mark is also evidenced by the number of cybersquatters who have sought to unfairly and illegally exploit the very significant consumer recognition and goodwill attached to its trade marks. Prior domain name dispute panels have recognized the strength and renown of the Complainant's WHATSAPP trade mark, and have ordered infringing respondents to transfer the disputed domain names to the Complainant, including but not limited to in the following decisions: a) Whatsapp Inc. v. Meraart, DNDRC Case No. C2017-0001, (<whatsapp.pk>); b) WhatsApp, Inc. v. Abdallah Almqbali, WIPO Case No. D2016-1287 (<watsabsplus.com>, <whatsapp-plus.ws> et al); c) WhatsApp, Inc. v. Nasser Bahaj, WIPO Case No. D2016-0581 (<ogwhatsapp.org> and <whatsapp-plus.org>)("the trademark WHATSAPP is well-known".); d) Facebook, Inc. and WhatsApp, Inc. v. Domain Manager, NA, WIPO Case No. D2016- 0394 (<whtaapp.com> et al); e) WhatsApp Inc. v. Francisco Costa, WIPO Case No. D2015-1708 (<webwazzup.com>); f) WhatsApp Inc. v. Francisco Costa, WIPO Case No. D2015-0909 (<webwhatsapp.com>) (finding that the WHATSAPP trademark had acquired "worldwide renown... amongst mobile applications" and an "impressive number of users... since the launch of the WhatsApp services in 2009"); and g) WhatsApp Inc. v. Private Whois whatsappandroid.com, Private Whois whatsappipad.com and Private Whois whatsappiphone.com, WIPO Case No. D2012- 0674 (<whatsappandroid.com>, <whatsappipad.com> and <whatsappiphone.com>). See Annex 7 for copies of domain name dispute decisions involving the Complainant. The term WHATSAPP is exclusively associated with the Complainant. All search results obtained by typing the term WHATSAPP in Google's search engine available at www.google.com or www.google.com.pk refer to the Complainant (see Annex 8). In addition to its strong presence online, the Complainant has secured ownership of numerous trade mark registrations in the term WHATSAPP in many jurisdictions throughout the world, including in Pakistan, as detailed above. The Complainant's valuable reputation offline and online is not only crucial to maintain the value and distinctiveness of its brand, but also vital to the success, integrity and protection of its business and consumers. Accordingly, the Complainant devotes significant resources to protect its trade mark rights and goodwill in forums such as this administrative proceeding. The Complainant was alerted to the fact that the Complainant's WHATSAPP trade mark had been registered under the .COM.PK Top-Level Domain (TLD) for Pakistan by the Respondent. The Domain Name was registered on 30 November 2015 by the Respondent (see Annex 1 for a copy of the WHOIS record), a few months after the release of Whatsapp in Urdu in Pakistan. Copies of press articles are attached at Annex 4. The Domain Name is, at the time of filing, pointing to a website displaying the Complainant's trade mark and falsely appearing to offer WhatsApp and other services for download, although in actual fact the links redirect to other websites. See Annex 9 for screen captures of the website associated with the Domain Name. A search carried out by the Complainant has revealed that the Respondent is also the registrant of two other domain names infringing third party trademarks: <googke.com.pk> and <waptric.com.pk>. Copies of WHOIS records are attached at Annex 10. It is worth noting that the Domain Name Dispute Resolution Center (DNDRC) has recently ordered the transfer of the domain name <whatsapp.pk>, which was used by the registrant to resolve to a website appearing to offer WhatsApp in Urdu for download while this was not the case. See Annex 7 for a copy of this domain name dispute decision. On 17 March 2017, the Complainant's lawyers in Paris sent a disclosure request letter to the .PK registry, PKNIC, for the full WHOIS details for the Domain Name to be revealed in order to contact the registrant of the Domain Name. On 21 March 2017, PKNIC indicated the formalities to file a complaint and further noted that the registrant's contact details could not be disclosed due to privacy reasons. A copy of the correspondence between the Complainant and PKNIC is attached at Annex 11. Given the blatantly abusive registration and use of the Domain Name, and the Complainant's inability to contact the Respondent in the absence of any contact details, the Complainant had no choice but to file the present Complaint under the Policy to protect its legitimate business interests and rights and to protect consumers from confusion. Therefore, the Complainant seeks the following remedy: In accordance with Paragraph 4(b)(i) of the Policy, the Complainant requests that the Administrative Panel appointed in this administrative proceeding transfer the Domain Name to the Complainant. B. Respondent The Respondent has not submitted any response to DNDRC. Under section 5(e) of the UDRP, in the absence of a response, the Panel has the authority to commence the proceedings in default and to determine the matter based upon the Complaint.
Recommended publications
  • Understanding the DNS Industry Both Globally and Regionally the Beginning
    Understanding the DNS industry both globally and regionally The Beginning | 2 Hosts.txt | 3 The Domain Name System (DNS) • ARPA ARPA Internet Hosts (Temporary) • GOV Government • EDU Education • COM Commercial • MIL Military • ORG Organization • INT Multiorganization • The two letter code identifying a country according the the ISO Standard for "Codes for the Representation of Names of Countries" http://tools.ietf.org/html/rfc920 | 4 Early Domains http://en.wikipedia.org/wiki/List_of_the_oldest_currently_registered_Intern et_domain_names | 5 Towards Commercialization • In 1993, Network Solutions Inc. (NSI) was awarded a contract to manage the root as well as domain registrations under .com, .net, .org • A move that was not appreciated by the technical community • In 1995, NSI began to charge $50 per domain registration • The era of “DNS Wars” • In 1997, Clinton Administration intervened and launched a process soliciting input on DNS policies and trademark issues • This process led to the establishment of ICANN in October 1998 | 6 Why ICANN? One reason ICANN was established was to introduce and promote competition in the registration of domain names | 7 Registry – Registrar Model Registry Registrar Reseller Registrant | 8 The Largest TLDs https://www.verisigninc.com/assets/domain-name-report- march2015.pdf | 9 Largest New gTLDs https://ntldstats.com | 10 Largest ccTLDs in MEAC Region Institute for Research in Fundamental ~600,000 IR Sciences TR Middle East Technical University ~350,000 AE Telecommunication Regulatory Authority ~130,000
    [Show full text]
  • Displaced Employees Speak Out
    An Associated Collegiate Press Pacema~er Award Winner • THE • John Waters makes an Mulhern brothers continue appearance at the a family tradition, Wilmington Film Festh al. Cl Bl :\on-Protit Org. 250 Student Center • University of Delaware • Newark, DE 19716 C.S Postage Paid ~e\\'ark. DE Thesday & Friday Pem1it , \) 26 FREE Volume 129~J~~ue 8 .J www.review.udel.edu Thesday, October 1, 2002 Displaced employees speak out BY K.\TIE GR\SSO Jo~eph !\1iller. assistant director of mold] in my office. It was this moldy. The symptoms reported on the 7 A ~~j Occupational Health and Safet). mildew smell."" she said. "We're in que twnnaire are condusive to sick - T\\ u um\·ersll~ ernpll>yees vac<:~ted confirmed that he found mold in those offices eight and a half hours a their Hulhhen Hall office' in lin and uilding syndrome. he said. Davi~ · office. day. There is no exchange in the air Diehl said she had a coughing have nnt )l't returned because mold In Da\ I'• saHJ OHS also found mold system we have. so we were JUSt sitting the bu,ldJJH! made them s1d.. the attack 1n her office on l\1ay 15. She on the second tloor of Hullihen Hall in in the stale air. employees -;a1d. smd a co-worker walking by stopped the office of the director of financial Da\ is said she told her personal l11Jd,1 D1ehl .md D1ane D:nh. who because the coughing was so bad. he aid. The ceiling tile was replaced but physician about l\liller·s findings.
    [Show full text]
  • Generic Top-Level Domains (Gtld)
    An essential pillar for any business is its brand. Brand presence on the Web is a key factor in a business appearing in Internet searches and being found by existing and prospective customers. For small business owners, the essential ingredients for building a strong brand are: o A memorable business name o brand identity elements: o domain name o logo o email address o business card o social Web presence ( Linkedin, Facebook, Twitter, et Generic Top-Level Domains (gTLD) The following table represents the generic top-level domains (i.e. including .com, .org, etc). Domain Purpose / Sponsoring Organization Generic top-level domain .COM VeriSign Global Registry Services Generic top-level domain .INFO Afilias Limited Generic top-level domain .NET VeriSign Global Registry Services Generic top-level domain .ORG Public Interest Registry (PIR) Generic-Restricted Top-Level Domains Generic-restricted top-level domain names are similar to the generic top-level domains, only eligibility is intended to be restricted and ascertained more stringently. Domain Purpose / Sponsoring Organization Restricted for Business .BIZ NeuStar, Inc. Reserved for individuals .NAME The Global Name Registry Ltd. Restricted to credentialed professionals and related entities .PRO Registry Services Corporation dba RegistryPro Sponsored Top-Level Domains (sTLD) These domains are proposed and sponsored by private agencies or organizations that establish and enforce rules restricting the eligibility to use the TLD. IANA also groups sTLDs with the generic top-level domains. Domain Purpose / Sponsoring Organization Reserved for members of the air-transport industry .AERO Societe Internationale de Telecommunications Aeronautique S.C. (SITA SC) Restricted to the Pan-Asia and Asia Pacific community .ASIA DotAsia Organization Ltd.
    [Show full text]
  • The Oxford Democrat: Vol. 63, No. 23
    The Oxford Democrat. Vol l MK β:*. SOUTH PARIS. MAINE, TUESDAY, JUNE 9,1896. NUMBER 23. l» ILLINOIS PATRONS CO OPERATING. REMEMBERED. little branch near It wus withiiu that the major cm vefdure. Reaching the welcome shade, was tied up in (A by, "About 20 I n>ckon, Isam. Il AMONG THE FARMERS. efforts yram, White some of the a in down where Isam hud al- and in it an ax and a co-operative thn«i t« util servant NevtT before he dropped lay paddle. di n, hit ttin' U r I*· 20 In a small Γι> and away like the dew "Well, go'u Counsellor At Law. of iIm.· I'atrou· of llusbaudry said the at he clam- That «oar· from tbe earth to It» home In the «un. hi* 1 ft> had a threat been lt*vt«lttl at ready pitched his handle. "Isani, major *f<»* emuthef. I'm go'u bave bccu a failure, the TWO RUNAWAYS years yer git me «η·Ι '* way yet prin- So let «teal iviv. lovingly, the faahion bered do»* it that gently ham who ww η character Mumbling after of old in, "bow liappen you r ev'n d»*e monfs m Ht vr<'Kt» rAI.M. MAISK. *'*r»iir»TuayLow still holds and lack* success remeinlier&l wlutt I have done. privileged t« git wi' hyah biff ciple good Only l»y a boat ax and abou the house. It was uot darkies, a m»-aning smile npon bis lips, find and all ready hen·, < r wuz cum- iu case from absence of busl- HARRY BTILLWELL EDWARDS suriirieing bout jiiiint.
    [Show full text]
  • Professional Profile Expertise Recent
    Seema Shahid Mansoor Senior Associate PROFESSIONAL PROFILE [email protected] m Seema joined the firm in 1983 completed her law degree and pupilage while +92 (21) 3580 1020 working at the firm. Having worked for over three decades, she has vast experience and specializes in the area of Intellectual Property rights. She has 148, 18th East Street, Phase I, Defence Officers' been actively involved in protection and enforcement of intellectual property Housing Authority, Karachi- rights in relation to trademarks, copyright and domain names and has been 75500 - Pakistan handling various international and local clients. https://www.linkedin.com/i n/seema-s-mansoor- Seema has been actively involved in litigation proceedings and has appeared 6707a613 and assisted senior counsel of the firm in complex matters involving Intellectual Property Laws in tribunals and courts including the High Courts of EDUCATION Pakistan. Bachelor of Law (LL. B) Seema regularly participates in Intellectual Property international law Sindh Muslim Government conferences such as INTA (International Trademarks Association), APPA Law College, Karachi, Pakistan - 1986 (Asian Patents Attorneys Association) and SAARC Law and IP workshops & seminars both locally and internationally. Bachelor of Arts (B.A) P.E.C.H.S College For Women - 1983 RECENT EXPERIENCE INTELLECTUAL PROPERTY EXPERTISE Advised various international/local clients on Intellectual property covering trademarks, copyrights and domain names in relation to Intellectual Property various IP issues covering infringements, passing off action, unfair Corporate & Commercial competition, brand adoption, conflict and misleading advertisement, etc. Trademarks oppositions, rectifications and cancellation proceedings, before the Trade Marks Registry. Prosecution of applications, handling show cause notices and advise/opinion on registration of trademarks, disclaimers on trademarks and their effect on the exclusivity of trademarks and other related issues.
    [Show full text]
  • Domains of Convenience: Open Country Code Top-Level Domains And
    DOMAINS OF CONVENIENCE: OPEN COUNTRY CODE TOP-LEVEL DOMAINS AND THE GEOPOLITICS OF INTERNET GOVERNANCE By Kenneth A. Merrill Submitted to the Faculty of the School of Communication of American University in Partial Fulfillment of the Requirements for the Degree of Doctor of Philosophy In Communication Chair: Laura DeNardis, Ph.D. Patricia Aufderheide, Ph.D. Kathryn Montgomery, Ph.D. Derrick Cogburn, Ph.D. Dean of the School of Communication Date 2018 American University Washington, D.C. 20016 © COPYRIGHT by Kenneth A. Merrill 2018 ALL RIGHTS RESERVED DOMAINS OF CONVENIENCE: OPEN COUNTRY CODE TOP-LEVEL DOMAINS AND THE GEOPOLITICS OF INTERNET GOVERNANCE BY Kenneth A. Merrill ABSTRACT This project draws on multiple case studies to investigate the ways in which so-called “open” country code top-level domain names (ccTLDs) (ccTLDs with no local presence requirements) mediate global debates over Internet governance. Specifically, it focuses on three cases in which open ccTLDs became implicated in cross-border controversies over (1) political censorship (wikileaks.ch), (2) intellectual property rights enforcement (rojadirecta.me), and (3) cybercrime (the redelegation of .TK). Using an interpretive comparative approach, the project draws on interviews with ccTLD technical operators, regulators, civil society groups, and users, as well as analysis of relevant documents (e.g. registry and registrar policies, court documents, media reports, and minutes from various governance fora) to examine the outsized role that open ccTLDs play in the networked information economy. Identifying the “commodification of sovereignty” as a key component in the co-production of open ccTLDs, the project draws on a sociotechnical approach to examine the ways in which these country-specific identifiers simultaneously reinforce and undermine notions of sovereignty in cyberspace and the consequences this poses for Internet governance.
    [Show full text]
  • Middle East and Adjoining Countries DNS Study
    Middle East and Adjoining Countries DNS Study Document Reference ICANN/ME-DNS/003 Protective Marking COMMERCIAL - IN CONFIDENCE Document Owner EURid Status FINAL Publication Date 25 Jan 2016 Latest review date 22 Feb 2016 Contents Acknowledgements ................................................................................................................... 7 Executive Summary ...................................................................................................................... 7 Understanding the region’s Internet environment ..................................................................... 7 The region’s domain name industry: registries, registrars and registrants ................................ 8 Domains in the region – facts and figures ................................................................................. 9 Analysis of the market potential for domains in the region ...................................................... 10 Recommendations .................................................................................................................. 10 I. Introduction .......................................................................................................................... 12 Research methodology ........................................................................................................... 13 User survey ............................................................................................................................. 13 Observations on methodology and potential
    [Show full text]
  • Open Source Used in Cisco Proximity 4.0
    Open Source Used In Cisco Proximity 4.0 Cisco Systems, Inc. www.cisco.com Cisco has more than 200 offices worldwide. Addresses, phone numbers, and fax numbers are listed on the Cisco website at www.cisco.com/go/offices. Text Part Number: 78EE117C99-1124799904 Open Source Used In Cisco Proximity 4.0 1 This document contains licenses and notices for open source software used in this product. With respect to the free/open source software listed in this document, if you have any questions or wish to receive a copy of any source code to which you may be entitled under the applicable free/open source license(s) (such as the GNU Lesser/General Public License), please contact us at [email protected]. In your requests please include the following reference number 78EE117C99-1124799904 Contents 1.1 effective-tld-names 2020.03.12 1.1.1 Available under license 1.2 pcre2 10.35 1.2.1 Available under license 1.3 libpng 1.6.37 1.3.1 Available under license 1.4 libtiff 4.1.0 1.4.1 Available under license 1.5 effective-tld-names 2020.03.12 1.5.1 Available under license 1.6 curl 7.64.1 1.6.1 Available under license 1.7 libdouble-conversion 3.1.5 1.7.1 Available under license 1.8 zlib 1.2.11 1.8.1 Available under license 1.9 visual-studio-runtime 10.00.40219.325 1.9.1 Available under license 1.10 qt 5.15.2 1.10.1 Available under license 1.11 free-type 2.10.1 1.11.1 Available under license 1.12 angle 3280 1.12.1 Available under license 1.13 libwebp 1.1.0 1.13.1 Available under license Open Source Used In Cisco Proximity 4.0 2 1.14 libjpeg-turbo 2.0.6 1.14.1 Available under license 1.15 zstd 1.4.8 1.15.1 Available under license 1.1 effective-tld-names 2020.03.12 1.1.1 Available under license : No license file was found, but licenses were detected in source scan.
    [Show full text]
  • Special Conditions for Additional Extensions Under the Gandi Corporate Service Specific for the Extensions
    Special conditions for additional extensions under the Gandi Corporate service specific for the extensions .AE, .BD, .BI, .BY, .CD, .DJ, .DM, .GH, .GA, .GL, .GM, .ID, .IL, .KG, .KR, .KW, .LK, .MA, .ML, .MY, .MZ, .NG, .NR, .PK, .PN, .PS, .QA, .RS, .SA, .SG, .SN, .ST, .TH, .TJ, .TO, .UG, .UZ version 1.12 – December the 10th, 2014 In addition to Gandi Corporate Special Conditions and Gandi's General Terms and Conditions for domain name registration, the registration and use of a domain name in the extensions mentioned above imply the acceptance of and compliance to the present special conditions contained herein. All Your legal information and contracts are presented to You at the time of the subscription to Our Services. Capitalized terms have the definition attributed to them in Our General Terms and Conditions of Domain Name Registration. Specifically, “You” refers to the owner of the domain name, and “We” designates Gandi. Description of the service In the framework of its Gandi Corporate service, Gandi allows You to register Your domain name in the additional extensions mentioned above only available to Our Gandi Corporate customers, via one of Our partners, IP Mirror. The following diagram presents the various parties involved in the providing of this service. Trustee Authority and Registry IP Mirror Service http://ipmirror.com Provider Gandi http://gandi.net Reseller Reseller Customers You ! Your internet Your web host provider 1/21 When You apply to register a domain name in one of the proposed extensions, You acknowledge that You have fully understood, and that You certify to have full knowledge of and that You agree to abide by all the rules and specific conditions of the extension chosen, as defined by the Trustee Authority and/or the Registry concerned.
    [Show full text]
  • Internet Governance Forum 2012 Panellists Biographies
    INTERNET GOVERNANCE FORUM 2012 PANELLISTS BIOGRAPHIES Table of contents Abdul Rahim Rinalia (Ms) ..................................................................................................................... 10 Abou Zahra Shadi (Mr) .......................................................................................................................... 10 Abraham Sunil (Mr) ............................................................................................................................... 11 Acuña Antonio (Mr) ............................................................................................................................... 11 Adeleye Peter Olugbenga (Mr) .............................................................................................................. 12 Afonso Carlos (Mr) ................................................................................................................................ 13 Aguerre Carolina (Ms) ........................................................................................................................... 14 Aguirre Carlos Dionisio (Mr) ................................................................................................................. 14 Ahmad Shahzad (Mr) ............................................................................................................................. 16 Aizu Izumi (Mr) ..................................................................................................................................... 17 Akoh
    [Show full text]
  • In the United States District Court for the District of Columbia
    Case 1:01-cv-01655-RCL Document 132 Filed 10/14/14 Page 1 of 40 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Jenny Rubin, et al. ) ) Plaintiffs, ) ) CIVIL ACTION NO. 01-1655-RCL v. ) ) The Islamic Republic of Iran, et al. ) ) Defendants. ) ) Susan Weinstein, et al. ) ) Plaintiffs, ) ) CIVIL ACTION NO. 00-2601-RCL v. ) ) The Islamic Republic of Iran, et al. ) ) Defendants. ) ) Seth Charles Ben Haim, et al. ) ) Plaintiffs, ) ) CIVIL ACTION NO. 02-1811-RCL v. ) CIVIL ACTION NO. 08-520-RCL ) The Islamic Republic of Iran, et al. ) ) Defendants. ) ) Case 1:01-cv-01655-RCL Document 132 Filed 10/14/14 Page 2 of 40 Ruth Calderon-Cardona, et al. ) ) Plaintiffs, ) ) MISC. NO. 14-648-RCL v. ) ) Democratic People’s Republic of Korea, et ) al. ) ) Defendants. ) ) Mary Nell Wyatt, et al. ) ) Plaintiffs, ) ) CIVIL ACTION NO. 08-502-RCL v. ) ) Syrian Arab Republic, et al. ) ) Defendants. ) ) Shaul Stern, et al. ) ) Plaintiffs, ) ) CIVIL ACTION NO. 00-2602-RCL v. ) ) The Islamic Republic of Iran, et al. ) ) Defendants. ) ) NONPARTY ICANN’S OPPOSITION TO PLAINTIFFS’ MOTION FOR SIX-MONTH DISCOVERY PERIOD ii Case 1:01-cv-01655-RCL Document 132 Filed 10/14/14 Page 3 of 40 TABLE OF CONTENTS INTRODUCTION .......................................................................................................................... 1 RELEVANT BACKGROUND ...................................................................................................... 3 ARGUMENT ................................................................................................................................ 10 I. A SIX-MONTH DISCOVERY EXTENSION IS NOT JUSTIFIED. ............................... 10 A. The Discovery Plaintiffs Seek Will Not Alter The Legal Conclusion That ccTLDs Are Not Attachable Property. ..................................................................................... 11 B. Plaintiffs Seek Discovery On Only Two Of The Six Legal Bases For Quashing The Writs Of Attachment Thereby Conceding These Issues.
    [Show full text]
  • List of Internet Top-Level Domains Donate to Wikipedia from Wikipedia, the Free Encyclopedia Wikipedia Store
    Article Talk Read Edit View history Search Wikipedia Thank you! Imagination becomes reality in the winners of the 2019 Wiki Loves Earth photo contest Main page Learn about the Wiki Loves Earth photo contest » Contents Featured content Current events Random article List of Internet top-level domains Donate to Wikipedia From Wikipedia, the free encyclopedia Wikipedia store Interaction This article has multiple issues. Please help improve it or discuss these issues on the [hide] Help talk page. (Learn how and when to remove these template messages) About Wikipedia This article may be too long to read and navigate comfortably. (September 2017) Community portal Recent changes This article may have too many section headers dividing up its content. (September 2017) Contact page This list of Internet top-level domains (TLD) contains top-level domains, which are those domains in the DNS root zone of the Domain Name Tools System of the Internet. The official list of all top-level domains is maintained by the Internet Assigned Numbers Authority (IANA) at the Root Zone What links here Database.[1][2] IANA also oversees the approval process for new proposed top-level domains. As of June 2019, the root domain contains 1530 Related changes top-level domains,[3] while a few have been retired and are no longer functional. Upload file Special pages Contents [hide] Permanent link 1 Types Page information 2 Original top-level domains Wikidata item Cite this page 3 Infrastructure top-level domain 4 Country code top-level domains Print/export 4.1 Notes Download
    [Show full text]