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Subramaniam v. ICANN, et al

This page collects filed documents from this lawsuit as related to ICANN. This page does not reflect the entire docket of the litigation. The documents are arranged by filing date in descending order.

Subramaniam v. ICANN, et al
(lawsuit in the Circuit Court for County of Washington, Oregon)

Denise Subraniam v. ICANN, Susan K. Woodard, Charles Steinberger and, Circuit Court of the State of Oregon, County of Washington, Case No. C11-1899CV

With additional proceedings in:

  • In re Charles F. Steinberger and Pamela J. Perry, U.S Bankruptcy Court, Middle District of Florida, Tampa Division, Case No. 8:10-bk-19945-KRM; Adversary Proceeding No. 8:11-ap-00418-KRM (Subramaniam v. Steinberger, ICANN, and Woodard)

  • Subramaniam v. ICANN, U.S. District Court for the District of Oregon, Portland Division, Case No. 3:11-CV-009892-MO

Order of Dismissal [PDF, 65 KB] 22 September 2011
Order to Show Cause [PDF, 54 KB] 29 August 2011
Request for Ruling on ICANN's Motion To Dismiss (with exhibits) [PDF, 15 MB] 4 August 2011
Order Granting Motion to Withdrawal and Transfer [PDF, 25 KB] 27 July 2011
Order Staying Adversary Proceeding as to ICANN [PDF, 24 KB] 24 June 2011
Order Granting Motion to Dismiss Woodard [PDF, 16 KB] 24 June 2011
Order Granting Steinberger's Motion to Dismiss [PDF, 136 KB] 24 June 2011
Subramanian's Response to Motion to Discharge Injunction and Sanctions [PDF, 547 KB] 6 June 2011
Notice of Hearing [PDF, 10 KB] 23 May 2011
ICANN's Memorandum of Law in Support of Motion for Withdrawal [PDF, 5 MB] 20 May 2011
ICANN's Motion for Stay of Adversary Proceedings [PDF, 66 KB] 20 May 2011
Declaration of Akram Atallah in support of ICANN's Motion to Dismiss [PDF, 812 KB] 20 May 2011
ICANN's Memo in Support of its Motion to Dismiss [PDF, 221 KB] 20 May 2011
Complaint - Exhibits [PDF, 9 MB] 31 March 2011
Complaint [PDF, 7 MB] 31 March 2011
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"""" is not an IDN."