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Smiley v. ICANN

First Amended Complaint [PDF, 1.50 MB] 1 August 2001
Defendant NeuLevel, Inc.'s Corrected Brief in Opposition to Plaintiffs' Motion for Preliminary Injunction [PDF, 823 KB] 17 September 2001
Defendant NeuLevel, Inc.'s Evidence in Support of its Opposition to Plaintiffs' Motion for Preliminary Injunction (cover page) [PDF, 33 KB] 14 September 2001
ICANN's Opposition to Plaintiffs' Motion for Preliminary Injunction 14 September 2001
Declaration of Louis Touton in Opposition to Plaintiffs' Motion for Preliminary Injunction 14 September 2001
Plaintiffs' Reply to Defendant NeuLevel's Opposition to Motion for Preliminary Injunction; Declaration of Paul Traina [PDF, 1.78 MB] 21 September 2001
Plaintiffs' Reply to Defendant ICANN's Opposition to Motion for Preliminary Injunction [PDF, 598 KB] 21 September 2001
ICANN's Supplemental Opposition To Plaintiffs' Motion For Preliminary Injunction 5 October 2001
Supplemental Declaration of Louis Touton in Opposition to Plaintiffs' Motion for Preliminary Injunction 5 October 2001
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."