On Feb 18, 2008 10:23 PM, larry price <[EMAIL PROTECTED]> wrote:

> On Feb 18, 2008 8:25 PM, marbux <[EMAIL PROTECTED]> wrote:
> > So pertinent questions might be:
> >
> >  1. Who arranged the UAE "investment" and loan?
>
> I'm sure it's entirely coincidental that Microsoft is pouring a bunch
> of money into the UAE
>
> http://www.khaleejtimes.com/DisplayArticleNew.asp?col=&section=theuae&xfile=data/theuae/2008/January/theuae_January854.xml
>

Absolutely! :-)

>
> Wow, I'm glad that there are people like you and the Groklaw crew out
> there, I do not have the tolerance required to sift through that
> particular pile of long and tedious arguments of insidious intent.
>

It's a different kind of nerdiness, I'll grant you, that often leaves me
wondering why I don't get a life instead.


>
> Speaking of network legal issues what do you all think of the
> wikileaks.org case?
>

I'm not a lawyer, but some of the stories I read made me very dubious
of the judge's injunction, defendants in civil cases are supposed to
have a right to respond; and notification by email is not equivalent
to service of notice.


I had a bit of trouble tracking down a wikileaks.org mirror that worked for
a few minutes, actually two, long enough to get a copy of the order and the
Wikileaks.org press announcement about it.

What is supposed to be the court order is here if you can get through.  <
http://wikileaks.in/w/images/Dynadot-injunction.pdf>. The press release I
found is on another server here, <
https://wikileaks.cx/wiki/Wikileaks.org_under_injunction>


It's hard to come to an opinion when the facts are so sketchy. But in
checking the terms of service offered by the domain name registrar involved,
it looks like their lawyer wrote terms that allow them to cancel a domain
name registration at any time with or without reason. See section 7 at <
http://www.dynadot.com/registration_agreement.html>.

Offhand, I'd say those terms are likely subject to challenge as an
unconscionable adhesion contract, but it would require more legal research
than I've got time for at the moment to nail such issues down. I've never
researched unconscionability in the context of domain name registrars but am
aware that there's lots of law out there specific to domain name
registration, so I'm unwilling to take a hard position on that legal issue.
So let's just say for now that there's a smell there that the
wikileaks.orglawyers will likely be tracking down if the decision is
to fight the case.

Without boring you with too much discussion of the rules of procedure that
give added meaning to a lot of the words and phrases in the court order,
what has apparently happened is that Wikileaks.org exposed some serious
wrongdoing by a bank in the Cayman Islands, the bank filed a lawsuit in
California's federal Northern District Court naming the Dynadot domain name
registrar, Wikileaks, Wikileaks.org and 1-10 unknown John Does as
defendants. Dynadot is headquartered in California so it's an appropriate
jurisdiction for the case to be filed in, unless it turns out that one of
the John Does is from California. My sense is that wikileaks.org may not
exist as a formal legal entity, so there may be problems with getting it
served with a summons and complaint. I suspect that's the reason the John
Doe defendants were named, so that real people could be named as defendants
after they are identified.

Dynadot promptly cut a deal with the bank agreeing to  cancel the domain
name registration for Wikileak.org and to nail the door shut on that domain
name and to preserve all records Dynadot had about the domain name and the
folks involved with it.

The deal was conditioned on the court ordering Dynadot to do these things
and the bank dismissing Dynadot as a defendant "with prejudice." The court
did just that and ordered Dynadot to file a voluntary dismissal with
prejudice, entering the order as a permanent injunction while retaining
jurisdiction to enforce the injunction.

"With prejudice" means in effect that it will be very difficult for the Bank
to resurrect a case against Dynadot. If Dynadot violates the injunction, it
would be handled as a contempt of court rather than as a new case. But it
should not mean that Wikileaks.org  or one or more of the John Does could
not name Dynadot as a third party defendant.

My guess would be that the deal talks a lot about Wikileaks.org infringement
of the bank's copyrighted documents, theft of trade secrets and confidential
business information, and whatever other excuses Dynadot's lawyer felt like
throwing in that might help Dynadot if Wikileaks.org counter-sues
Dynadot. *(See,
a federal judge ordered us to do it; we had no choice. And look how bad you
were. Even if the judge hadn't ordered us to do it, we had a right and civic
responsibility to cancel your domain name registration anyway. You violated
our terms of service. You're bad, bad, bad. Yadda, yadda, yadda.) *

I have issues with the way the judge handled it.  Oversimplifying the rules,
folks aren't supposed to be able to get injunctions that determine other
people's rights without basically what you said, They have to be named as
parties, served with a summons and complaint, and given an opportunity to
oppose the injunction.

>From a procedural standpoint, it looks to me like the only thing the judge
could have done legally was to issue a temporary restraining order requiring
what he required instead in the injunction and then renewing the order every
five days until wikileaks.org was served with a complaint and summons or it
proved infeasible to bring them in.

It would be tenuous at best for the Bank to argue otherwise because it named
wikilinks.org as a defendant. The key rule is Federal Rule of Civil
Procedure 19, <http://www.law.cornell.edu/rules/frcp/Rule19.htm>, which
provides in part:

A person who is subject to service of process and whose joinder will not
deprive the court of subject-matter jurisdiction *must be joined as a party
if*:

...

(B) that person claims an interest relating to the subject of the action and
*is so situated that disposing of the action in the person's absence may: *
*(i) as a practical matter impair or impede the person's ability to protect
the interest; *

...

If a person has not been joined as required, the court *must order* that the
person be made a party.

...

If a person who is required to be joined if feasible cannot be joined, the
court must determine whether, in equity and good conscience, the action
should proceed among the existing parties or should be dismissed. ...
[factors to be considered omitted].

...

The fact that the bank named wikileaks.org as a defendant is a real barrier
here, because you're not supposed to name defendants who can't feasibly be
joined as parties. Instead, the complaint has to state who they are and why
they cannot feasibly be joined in the claims for relief section, again from
Rule 19:

When asserting a claim for relief, a party must state:

(1) the name, if known, of any person who is required to be joined if
feasible but is not joined; and

(2) the reasons for not joining that person.
Now granted, a judge might permissibly ignore that last procedural nicety
if there's a stack of affidavits in the court file swearing that others have
repeatedly tried to serve wikileaks.org with a summons and a complaint but
the entity doesn't exist as a legal entity and the people involved can't be
identified, etc. But why then is the court ordering that Dynadot preserve
all of its records as to the people involved? That makes it sound as though
the bank and the judge think it may be feasible to join people as
defendants.

And all of the above blinks past the absolutely incandescent First Amendment
issues. If the New York Times can't be restrained from publishing the
Pentagon Papers (U.S. Supreme Court decision), it's hard to imagine how an
injunction could be issued that has the effect of a prior restraint on
publication of bank records.

The scope of the restraint imposed is enormous in this case. The court
granted an order that, analogized to the Pentagon Papers situation, ordered
the New York Times office landlord  to lock everyone out of the building and
not allow them to publish anything at all, whether it has to do with the
Pentagon Papers or, e.g., terrorists crashing airliners into New York
skyscrapers, classified advertising, the price of tea in China, etc.

Under First Amendment jurisprudence,  prior restraints aimed at curtailing
speech are pretty much flatly prohibited. But even where the restraint
imposed is only incidental to a legitimate government objective, what's
required is a remedy that is no more restrictive of speech than is
necessary. So, e.g., it's ok to require that picketing union members have to
do their picketing in a specified area to keep the sidewalks clear but you
step way over the line if you order them to stop picketing.

The basic concept here is that the right of free speech is so fundamental to
our form of government that  the only acceptable way of restricting speech
is minimistically or remedial, e.g., a jail sentence for shouting "Fire" in
a crowded theater when there was no fire, money damages for libel, etc.

Now there are exceptions, and maybe one is involved here. E.g., a judge can
permissibly order someone to cease infringing on a copyright by continued
publication of the infringed content. On the other hand, the fair use
doctrine is pretty flexible and I can see an argument that fair use should
allow publication of documents if they show wrongdoing. But I still see no
way you can get to ordering that someone not be allowed to publish anything
at all, whether it is infringing or not.

So without really digging into the case, my sense is that whether you regard
the situation as a direct restraint of speech or a restraint incidental to a
legitimate objective, the judge's injunction smells like overkill.

But I'll caution that I really don't know nearly enough about the case to
bad mouth the judge. There may have been some issue presented not discussed
in the order that compelled the decision.

On a personal level, I have issues with a domain name registrar just rolling
over like Dynadot apparently did, particularly when it's a human rights
group they rolled on at the request of what sounds like a fairly nasty group
of folk in the Cayman Islands. Dynadot brags on their web site about how
financially sound they are. It sounds like its customers have been good to
Dynadot so Dynadot should be good to its customers, all the more so when
it's apparently thugs out to silence a human rights group that blew the
whistle on them.

Sorry for the length, but it's an interesting case.

Best regards,

Marbux
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