1 DOMAIN REGISTRATIONS SERVICES,
INC., a Florida corporation; DOTSTER,
2 INC., a Washington corporation;
EMARKMONITOR INC., an Idaho
3 corporation; ENOM, INC., a Washington
corporation; GO DADDY SOFTWARE,
4 INC., an Arizona corporation;
INTERCOSMOS MEDIA GROUP INC., a
5 Delaware corporation; INTERNET NAMES
WORLDWIDE(US),INC., a Delaware
6 corporation; NAMESECURE INC., a
California corporation; NETWORK
7 SOLUTIONS, INC., a Delaware corporation;
PARAVA NETWORKS, INC., a Texas
8 corporation; REGISTER.COM, INC., a
Delaware corporation; THE REGISTRY AT
9 INFO AVENUE, a South Carolina
corporation; VERISIGN, INC., a Delaware
10 corporation; DOMAIN BANK, INC, a
Pennsylvania corporation; CYDIAN
11 TECHNOLOGIES, LLC, a New York
limited liability company; YAHOO! INC., a
12 Delaware corporation; #1 DOMAIN NAMES
INTERNATIONAL, INC.; 007NAMES,
13 INC; 1 ENAMECO; 123 REGISTRATION,
INC.; 21 COMPANY; 4DOMAINS.COM;
14 ALTERNATEDOMAINS.COM;
AMERICAN DATA TECHNOLOGY INC.;
15 BB ONLINE UK LTD.;
BUDGETREGISTER.COM; CASDNS INC;
16 CORE INTERNET COUNCIL OF
REGISTRARS; CORPORATE DOMAINS,
17 INC.; CSL COMPUTER SERVICE
LANGENBACH; CYBERSEARCH-US,
18 INC.; CYBERVISORS, INC.; DIRECT
INFORMATION PVT LTD.; DIVERSITY
19 NETWORK SERVICES; DOMAIN-IT!,
INC.; DOMAININFO; DOMAINMART;
20 DOMAINNAMEREGISTRATION.COM;
DOMAINPEOPLE, INC.;
21 DOTBIZLOTTERY.COM; EARLY BIRD
DOMAIN; EDIFAX INTERNET SERVICES
22 LLC; FIRSTDOMAIN.NET; G+D
INTERNATIONAL LLC; GAL
23 COMMUNICATIONS, LTD; I.D.R.
INTERNET DOMAIN REGISTRY;
SNIPPETS:
INC., a Washington corporation;
Delaware corporation; INTERNET NAMES WORLDWIDE,INC., a Delaware
INFO AVENUE, a South Carolina corporation;
REGISTRARS; CORPORATE DOMAINS,
22 LLC; FIRSTDOMAIN.NET; G+D INTERNATIONAL LLC; GAL
LTD; I.D.R. INTERNET DOMAIN REGISTRY;
14 as "Plaintiffs" and each individually as a "Plaintiff") hereby allege for their complaint
15 the defendants named above (collectively, the defendants are referred to herein as
22 right to register 1 domain names2 in exchange for a fee from Plaintiffs,
For example, is a domain name and, likewise, is a domain name.
members, and members of the general public.
Plaintiffs have paid Defendants fees for the chance to
laws of the state of California and most other states.
12 stop Defendants' unfair and illegal lottery enterprise.
16 SMILEY PRODUCTIONS, a sole proprietorship doing business in San
20 general public pursuant to Business & Professions Code § 17200,
22 California limited liability company with its principal place of business located in
11 Street, Los Angeles, California 90017, with its principal place of business located at 505
14 such Registrar entered with Defendant ICANN.
and all of which such Agent Defendants
25 entered into an agreement with at least one Principal Defendant providing that such Agent
13 refers to all Defendants except Defendant ICANN and Defendant Neulevel.
Each TLD is divided into second-level domains.
The top-level domain
The second level domain name includes the TLD but begins
The third-level domain includes the second-level domain,
14 C. Registrants, Registries, and Registrars
for consideration); Alaska: Alaska Stat.
Code Ann.
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