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Zuccarini v. Network Solutions, LLC, 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.

Zuccarini v. Network Solutions, LLC, et al
(lawsuit in United States District Court for the Southern District of Florida)

Order Granting ICANN's Motion to Dismiss [PDF, 359 KB] 9 December 2011
Order Granting Network Solution and NameJet's Motions to Dismiss [PDF, 218 KB] 8 December 2011
5 December 2011
Zuccarini's Motion for Summary Judgment as to all Defendants [PDF, 1.3 MB] 5 December 2011
Zuccarini's Notice of Unresolved Discovery Motions [PDF, 130 KB] 18 November 2011
ICANN's Notice if Unresolved Discovery Motions [PDF, 33 KB] 17 November 2011
Zuccarini's Motion to Amend Response to ICANN's Opposition to Plaintiff's Motion to Compel [PDF, 105 KB] 8 November 2011
Zuccarini's Reply In Support of Motion to Compel ICANN Discovery [PDF, 803 KB] 3 November 2011
ICANN's Opposition to Motion to Compel (w/o Exhibits) [PDF, 1.5 MB] 28 October 2011
Plaintiff's Motion to Compel Further Discovery Responses [PDF, 1.2 MB] 13 October 2011
Zuccarini's Response to ICANN's Motion to Stay Discovery [PDF, 111 KB] 19 September 2011
14 September 2011
NameJet and Network Solutions Motion for Protective Order and For Temporary Stay of Discovery [PDF, 128 KB] 13 September 2011
Zuccarini's Response to Network Solutions, LLC and NameJet, LLC's Motion for Sanctions [PDF, 1.3 MB] 27 May 2011
Network Solutions, LLC and NameJet, LLC's Memorandum in Opposition to Plaintiff's Motion for Sanctions [PDF, 107 KB] 27 May 2011
Order Scheduling Trial Date, Pretrial and Mediation [PDF, 296 KB] 23 May 2011
Zuccarini's Motion for Sanctions Against Network Solutions and NameJet [PDF, 141 KB] 20 May 2011
Network Solutions, LLC and NameJet, LLC's Motion for Sanctions [PDF, 1.4 MB] 17 May 2011
Joint Scheduling Report [PDF, 123 KB] 18 April 2011
Joint Motion for Extension of Time to Serve Initial Disclosures [PDF, 28 KB] 18 April 2011
ICANN's Reply in Support of Motion to Dismiss [PDF, 49 KB] 18 April 2011
Plaintiff's Response to ICANN's Motion to Dismiss [PDF, 1.3 MB] 11 April 2011
ICANN's Motion to Dismiss [PDF, 381 KB] 22 March 2011
Zuccarini's Amended Complaint [PDF, 827 KB] 15 February 2011
Zuccarini's Complaint for Negligence [PDF, 1.1 MB] 11 February 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."