RegisterFly.com customers have been denied the ability to transfer or renew domain names and many have lost their domain names as a result. RegisterFly has transferred many individuals' domain ownership to its own name to prevent people from fleeing the site. Furthermore, RegisterFly has charged many individuals for services that have not been delivered, causing a great deal of heartache for individuals who did not know if they were going to lose their domain names, their livelihoods, or any one of myriad injustices.

RegisterFly's conduct has had substantial, and in many cases severe, impact on individuals and business that currently have domains held by RegisterFly. Repeated efforts by many customers to resolve issues with RegisterFly have proven fruitless. People are continuing to lose their hard won livelihoods as a result of RegisterFly's egregious behavior.

ICANN, which accredited RegisterFly as a domain registrar - in the face of a litany of pre-existing complaints against RegisterFly - has refused to fulfill its legal obligations. Despite being notified by a multitude of wronged RegisterFly clients, ICANN continually, and consistently, has refused to take action. Instead, ICANN has ignore the problem, accepting RegisterFly's empty promises to improve. ICANN violated its own policies and procedures and specifically the Registrar Accreditation Agreement ("RAA"). According to section 5.3.4 of the RAA, RegisterFly should have only had 15 working days to cure the breaches which ICANN was aware of last summer. It was not until Anne Martinez filed this Class Action lawsuit (which was placed under Seal by the Court due to the threat that RegisterFly may destroy Data) and gave notice to ICANN on March 15th 2007 that ICAAN began to enforce the RAA, but for many people who have lost their domains and/or business, it is too little too late.

It is time for the American legal system to halt further damage from being done and to remedy and make whole the individuals and business who have already been irreparably harmed. For these reasons this class action lawsuit has been brought. You do not have to be an American citizen to participate in this lawsuit.

First and foremost to halt the damage and help the hundreds of thousands of RegisterFly domain name owners regain control of domains they have purchased and registered through RegisterFly.com. To stop RegisterFly.com from continuing to register new domains even as they fail miserably in their duties to handle the ones currently under their control. To hold RegisterFly accountable for the damage it has caused. To hold ICANN responsible for its breach of duty, ranging from accrediting RegisterFly in the first place to letting them keep their accreditation after they time after time violated term after term of the accreditation agreement, and failed to give adequate weight to the endless stream of appeals for help from RegisterFly customers, all during which time ICANN was collecting a fee for each domain RegisterFly registered. To hold ENOM accountable for its apparent role in withholding authorization codes that were registered during the time that RegisterFly was an ENOM reseller, making it impossible for those domains to be transferred to another registrar, and billing RegisterFly customers, (who were registered when RegsieterFly was an agent of eNom) to provide services they were already liable to provide under their agent's (RegisterFly's) agreement. To ensure that the victims of the gross failures of these entities are justly compensated for their losses.