This webpage consist of two cases, five court opinions, and the ultimate French disposition of this cross-Atlantic litigation. The first case, from the TRIBUNAL DE GRANDE INSTANCE OF PARIS, is the French segment of the ongoing Yahoo! litigation.
.....The second phase of this litigation was the related filing in the United States..See ORDER DENYING FRENCH DEFENDANT'S MOTION TO DISMISS.The US court's restatement of the facts in the Paris proceedings is presented in paragraphs [a] through [c] of the San Francisco proceedings is a convenient, abbreviated, and digestable--but incomplete--introduction to the "terriorial" nature of this major Internet issue.
.....The third court opinion (below) is the November 7, 2001 ORDER GRANTING PLAINTIFF YAHOO! MOTION FOR SUMMARY JUDGMENT. This US decision ended this litigation at the trial court level. Yahoo! thus managed to obtain a conflicting judgment from the US court.
.....The fourth court opinion, issued on August 23, 2004 was an ORDER DISMISSING CASE FOR LACK OF PERSONAL JURISDICTION by the federal appellate court in California. It eeversed the declaratory relief judgment--which the trial court had rendered in favor of Yahoo--on the basis that the trial court had no personal jurisdiction over the defendant French students. The case was thus dismissed (and may be appealed by Yahoo to the US Supreme Court). One of the three judges on this federal appellate panel dissented from this dismissal--arguing that the court did have jurisdcition over the French defendants. The dissenter asserted that the French and US proceedings are not "parallel," and that the US federal court thus had an obligation to proceed because of what he described as "distinct" issues. For a summary of this latest opinion is provided below.
.....The fifth opinion, dated February 10, 2005, is the federal appellate court's order that the appellate case be reheard by eleven judges.
.....The current phases include: (a) the actual trial of the French case in Paris (originally scheduled for trial on May 7, 2002); (b) the pending appeal of the San Francisco judgment by the French defendants (likely to be decided in Spring of 2003); and (c) potential negotiations between France and the US to resolve this sensitive stalemate. It pits those who would prohibit the availability of Nazi memorabilia to French Internet users, on the continent where the Holocaust occurred, against the US Constitution's guarantee that the government will not unreasonably limit freedom of speech. (The February 11, 2003 dismissal of the initial French case, and filing of a second suit, is mentioned just after case two of four on this webpage.)

.....  Examples of Nazi memoribilia available for sale on the Yahoo! website. Posting this information on this website would be a violation of French law, but protected under the US Constitution's First Amendment.  .............

.................................................................[Opinion one of four]
.....................................................
FRENCH YAHOO! JUDGMENT
......................................................Union des Etudiants Juifs de France
..................................................Ligue contre le Racisme et l'Antisémitisme
...............................................................................v.
........................................................Yahoo! Inc. and Yahoo France
.............................................TRIBUNAL DE GRANDE INSTANCE OF PARIS (2000)

........<http://www.gigalaw.com/library/france-yahoo-2000-11-20-lesecq.html>
...............Reprinted with permission of GigaLaw.com <www.gigalaw.com>
..........Translated by Christian Lesecq (French e-lawyer) <les16@lesecq.com>

Author's Note: There are two civil tribunals of "first instance" (trial courts) within each cours d'appel (intermediate appellate court). A "tribunal d'instance" is a single judge court. A "tribunal de grande instance" hears the larger civil cases. See <http://www.justice.gouv.fr/justorg/degresju.htm>.
.....The plaintiff, Union of Jewish Students of France was joined by the intervener, League Against Racism and Antisemitism ("MRAP") in suing to prevent Yahoo! from allowing individuals to advertise Nazi memorabilia on its worldwide web site. The decision below barred Yahoo! from allowing electronic visitors in France to access the portion of Yahoo's web site which contained information about this merchandise. There were various rulings in the Yahoo matter, beginning on May 22, 2000. The case on this web page is the latest judgment of November 20, 2000.
.....The French judge therein issued an interim order. The French anti-defamation groups, the plaintiffs in the French segment of the litigation, have not yet attempted to enforce the French judgment. This placed Yahoo! in the precarious position of having to wait until a decision might be made to enforce that judgment, which would result in Yahoo incurring the daily fine--roughly US$13,300.00.
.....Yahoo! then filed an action seeking declaratory relief in the United States. Yahoo! thus hoped to get the opposite result from a court in the nation where Yahoo! is physically located and incorporated. This related lawsuit appears just after the following French judgment below (which has been reformatted by the textbook author). This case will be closely monitored by business and civil liberties groups in the US, because of the potential conflict between enforcement and the US First Amendment--which would presumably not require Yahoo to block any user from accessing the offensive web page offering the Nazi artifacts for sale.
.....The red numbered or lettered paragraphs--in both decisions--have been added by the textbook author. Occasional bolding and italics are added, to separate the French opinion's various components..

Court's Opinion.
.....I, the President of the Court,
[1] Considering the terms of my ordinance [injunction against Yahoo!] of May 22, 2000, to which it is appropriate to refer expressly, whereby I ordered:
.....1 / Yahoo Inc: to take all appropriate measures in order to deter and prevent any [Internet] visit to the .........service of auction sales of Nazi items on Yahoo.com and to any other site or service which constitutes .........an apology for nazism or a contention about nazi crimes;
.....2 / Yahoo France: to give any internaut [user], before he opens the link enabling him to proceed with .........searches on Yahoo.com, a notice informing him about the risks he takes by going on visiting such sites;
.....3 / the pursuance of the case to allow Yahoo Inc to debate contradictorily the measures it intends to take .........in order that disorder and suffered damage are ended and that any further disorder is prevented;
........................................................................ . . .
[2] Considering the conclusions developed by Yahoo France as well as by Yahoo Inc. for their defence and aiming to fulfill the purposes mentioned in my previous ordinance;
.....Considering the report from the consultants Wallon - Vinton Cerf - Laurie [below];
....................................................................... . . .
.....After having heard the State Attorney's oral conclusions;
.....After considering the documents submitted by the parties;
.....After having heard Mr Vinton Cerf's oath as an unregistered expert, and Mr Norek's oath, as a registered expert though intervening in the present case as a translator in English language beside Mrs Kinder, an expert registered in the specialty;

[3] On the claims directed against Yahoo Inc.

[4] Whereas Yahoo Inc argues that:
- this Court has no jurisdiction to decide upon the case;
- there does not exist any technical means to satisfy the terms of the ordinance [this court's original order] of ..May 22, 2000;
- assuming that such means might exist, their implementation would generate an over cost for Yahoo Inc., .which would even put at risk and would endanger in a certain way the existence of the Internet network, a .space of freedom, reluctant to attempts for its control and restriction to its access;

[5] Whereas to support its exception concerning non-jurisdiction, reiterated for the third time, Yahoo Inc. argues that:
- its services are rendered essentially to internauts located in the territory of the United States of America;
- its servers are installed in this same territory;
- a coercitive measure against the company could not be enforced in the United States because such a .measure would be contrary to the First Amendment of the Constitution of the United States, which .guarantees to any citizen the right of freedom of thought and expression;

[6] Whereas, if it is true that the site "Yahoo Auctions" is in general addressed mainly to internauts based in the United States, having regard among other things to the nature of items for sale, methods of payment, delivery terms, language and currency used, that is not true concerning items representing symbols of the nazi ideology, which can be of interest and are accessible to any person who wishes to bid, including the French;

[7] Besides, as that has already been judged, merely sighting such objects in France is a violation of article R.645-1 of the penal code and is therefore against the country's public policy;

[8] Moreover, looking at such objects causes obviously a wrong in France to the plaintiffs, who have grounds to claim that it be ended and they be indemnified;

[9] Whereas at last Yahoo is aware that it addresses to French internauts, since in reply to a connection to its auction site opened from a computer located in France, there are in response advertising banners written in French language;

[10] A tying link of the present case with France is consequently sufficiently characterized, which gives this Court full jurisdiction to hear the claims from the plaintiffs;

[11] The possible difficulties of enforcing the Court's decision in the territory of the United States, invoked by Yahoo Inc. do not by themselves justify a claim of lack of jurisdiction;

[12] That such exception [by Yahoo! to jurisdiction] will therefore be rejected;

[13] Whereas, regarding the argument developed by Yahoo and derived from the impossibility to implement technical means such as to satisfy the terms of the ordinance of May 22, 2000, it is at first necessary to quote the conclusions of the group of consultants appearing on pages 62 through 76 of their report:

Opinion of the consultants
Preamble
The undersigned consultants want to stress that their duties were limited to answer to the technical questions asked by the Court. Their answers could in no event be construed as endorsing, technically or morally, the Court's decisions or, on the contrary, as criticizing them.

Context
The companies Yahoo! France and Yahoo! Inc. have been condemned [ordered] on May 22, 2000 by the Court of Great Instance of Paris in the following terms:

[14] "Order Company Yahoo! Inc. to take all appropriate measures to deter and prevent any visit to the auction sales service of nazi items on Yahoo.com and to any other site or service which constitutes an apology for nazism or a contention about nazi crimes; "Order Company Yahoo ! France to give to any internaut,
before he opens the link enabling him to proceed with his searches on Yahoo.com, a notice informing him that, if the result of his search, coming either from a tree structure or from key words, leads him to point to sites, pages or forums, the title and/or contents of which constitute a violation of the French law, which
is the case in consulting sites which contain an apology of nazism and/or exhibiting uniforms, badges, emblems reminding those which were carried or exhibited by nazis, or offering for sale objects and works the sale of which it strictly prohibited in France, then he must stop the consultation of the site concerned, lest he incurs
the penalties provided for by the French law or has to defend against legal actions which might be initiated against him."

[15] Company Yahoo ! France says that it has complied with the decision. Company Yahoo ! Inc makes the point that there was no technical solution enabling it to fully comply with the Court's decision.

[16] A group of consultants was then appointed to enlighten the Court about the various technical solutions which could be implemented by Yahoo! Inc. in order to comply with the decision of May 22 .

Internet
[17] Internet is a combination of several hundreds of millions of digital networks and associated sites which are interconnected in the world. The routers are computers dedicated to the interconnection of these networks. One estimates at one hundred millions the number of computers using Internet and at three times more, when including in the number laptop computers, desktop computers, organizers, mobile phones, etc.

[18] A set of procedures was defined from 1973 through 1980, under the control of the research laboratories of the American army (DARPA). These procedures, known under the name of TCP/IP [Internet Protocol], are the heart of several hundreds of protocols used on Internet.

[19] In the end of the nineteen-eighties, CERN conceived the Web (www) which uses additional procedures, protocols http and html language, to set up a global system for sharing information.

[20] The most usual applications include electronic mail (email), forums (news group), dialogue services (chat), services for auction sales, telephone, video and audio on line and many others.

[21] A widespread error consists in saying that all Internet services are performed by the Web. Actually, the Web is only one of the facets of Internet.

[22] Internet, which started like an experimental project used and developed by researchers in data processing, has become in ten years a worldwide business. The Internet services providers (ISP) have built and exploit networks opened to the public. The private networks of universities, companies, and even the home computers, are interconnected by the internet services providers in a global network. Some services providers specialized in the supply to users of an access to the commutated telephone network. Others specialized in the supply of access to users of cable television, to users of numeris (ISDN), to users of ADSL
services, local loop, etc. These services providers are generally named Internet Services Providers. They offer also various services, electronic mails, information, etc.
............................................................................ . . .
[23] This structure is not very convenient and a system has been set up to allow association of a name to an address. The names, each one corresponding to an address, are called domain names. The conversion of a domain name into a numerical IP address is made through a group of data bases spread on Internet (DNS). The DNS servers proceed along a tree structure and are specialized according to the kind of services offered (com, org, edu, gov, etc.) and according to countries (fr, uk, sf, etc).

[24] But, it must be well understood that there are no rules of correspondence between the countries appearing in the domain name and the numerical IP address. For instance www.yahoo.fr does not correspond to an IP address of a French network.

[25] Consequently, the extension of the domain name does not make it possible to determine which is the network to which belongs the numerical IP address.

[26] On the other hand, the allocation, insured originally by MANA and later by ICANN, of IP addresses granted to suppliers of Internet services (ISP) follows a tree structure going for example from the main network, to the sub-network, to the access provider and then to the local user. [ICANN's Uniform Domain-Name Dispute-Resolution Policy website is: <http://www.icann.org/udrp/udrp.htm>.]

[27] One can go up from a certain IP address to the access provider, the sub-network and the main network.

[28] Consequently, some organizations and some providers maintain data bases enabling them to find out the co-ordinates of a network, a sub-network, a router or a site, starting from its IP address.

[29] The DNS system offers to access providers, to sites, etc... the possibility of recording with their co-ordinates their geographical localization in the form of latitude and longitude. It is not an obligation.

[30] The exploitation of the geographical localizations of the holders of an IP address is however of a great interest, not only to target publicity but also to ensure a harmonious development of the web. Several services providers have the technology and data bases enabling them to locate geographically such or such address, fixed or even dynamically allocated. Several of them made openings [revelations] to the consultants stating they had the technical means to allow Yahoo! to satisfy the obligations ordered by the Court.

Problems

[31] To satisfy the terms of the condemnation decision [requiring Yahoo! to bloc French user access to the Nazi memorabilia website] and to forbid the access to auction sales of nazis items, Yahoo! must:
........1) have knowledge of the geographical origin and the nationality of the internauts desiring to have
............access to.the the site of auction sale
........2) prevent the French internauts or those connected in the French territory from learning the
............description of the nazis objects put for auction sale and a fortiori from bidding.

On the geographical origin and nationality

The case in general

[32] The interrogation of a Web site by the public consists in connecting the user working equipment (microcomputer or other) to a targeted site.

[33] This process takes place with the intervention of different categories of intermediaries: the access provider, the routers, one or more addressee sites.

[34] It is necessary at this stage to keep in mind that the user's computer, the access provider, the routers and the addressee site are identified on the network by an address conforming with the Internet protocol(IP).
.......................................................................... . . .
[35] One may add that for phone cost reasons, the French internauts use mainly the services of access providers present in their own country.

[36] One can therefore estimate that nearly 70% of IP addresses allocated to French internauts can be linked with certainty to a French domiciliation of access providers and can be filtered.

[37] Besides, it is this reality which enables Yahoo Inc to post Franco-French advertising banners on its auction sales site.
.......................................................................... . . .
Use of nationality by Yahoo Inc.
[38] Here is the second problem. What is to be done once the nationality or the place of localization of the computer is known? The measures to be taken depend upon every particular case. They cannot be generalized to concern all internet sites and services.

[39] In the present case, the site to be considered is "pages.auctions.yahoo.com". It is hosted by GeoCities IP address 216.115.104.70, localization 37°.352 of northern latitude, 121°.958 of western longitude, GeoCities network registered by Yahoo, 3400 Central Expressway, Suite 201, Santa Clara, CA 95051.

[40] The site is a site of auction sales of miscellaneous things, not [eclusively] dedicated to nazi objects. The characteristic of this type of site is to make it possible for internauts to easily find the objects which they look for.

[41] It appears that in order to abide with the terms of the decision of May 22, 2000, Yahoo must not allow internauts of French nationality or internauts connecting from the French territory to access to these objects.

[42] If, at the end of a search made from a query launched by a French internaut, one or more nazi objects described as nazi by their owner have been selected by the search engine, they must be hidden and excluded from the result of search.

[43] But, obviously, it is not possible for Yahoo to exclude . . . objects which would not have been described by their owner as being of nazi origin or from the nazi time, or whose characteristics would not have been made known to Yahoo.

[44] Verifications made collectively by the consultants confirmed that many nazi objects are presented as such by their owners. A more radical solution is also possible. It would be enough that the search engine would not fulfill the queries, transmitted in the URL, with the inclusion of the word "nazi" and coming from internauts
identified as French or declaring to be such.

Claim directed against Yahoo Inc
"To describe the information conveyed through the net allowing to determine the geographical origin of the calls."
........................................................................ . . .
[45] According to "Association Française des Fournisseurs d'Accès" (AFA), one can consider that 80% of the addresses allocated dynamically to members of the Association are identified as from French nationals. ... 20% are not French. Among the information conveyed through the net, exclusively the IP addresses of the senders make it possible to determine the geographical origin of the calls. 80% of the addresses allocated
dynamically by access providers which are members of AFA can be identified as from French nationals.

[46] But, it is appropriate to specify that the geographical origin discussed here is that of the site of the access provider used by the internaut. Nothing prevents a user in France from calling by phone an access provider whose telephone number is foreign. In this case, an address IP allocated dynamically will be most likely
identified as a foreign one. A foreigner may also call an access provider located in France and be looked in that way as being allocated a French IP address.

[47] However, one can estimate, as things now stand, that more than 70% of IP addresses of internauts residing in the French territory can be identified as being French.

[48] The consultants stress that it is not possible to say that things will remain same in the future. Encapsulation is being developed, services suppliers and access providers are getting international and internauts seek more and more to protect their privacy.
......................................................................... . . .
[49] "To describe the filtering procedures which can be implemented by company Yahoo to prevent internauts operating from the French territory from accessing to items which could be considered as illegal by the French judicial authorities."
..... "In the event that no technical solution could guarantee a 100% filtering, to provide any and all technical and factual information permitting to appreciate the filtering efficiency of every one of the filtering procedures described by the consultants".
....."More generally, to provide all technical and factual information permitting the Court to enforce the access restrictions ordered to Yahoo Inc."

[50] The consultants consider that to be efficient a technical solution must be adapted to the particular case. Companies [like] Yahoo! run many services . . . through the Net, ranging from personal pages ("GeoCities") to astrology ("Yahoo astrology") with in between finance, etc... Most of the sites do not seem (sic)concerned (sic) by [to be of concern to] the present lawsuit.

[51] Only the auction sales site is precisely described by the decisions of the Court and the claims. No claim against other sites and services of Yahoo! is formulated with sufficient precision to enable the consultants to propose adapted and operational technical solutions.

[52] As the matter now stands, the consultants will limit consequently their answers to the case of the auction sales site ("Yahoo auctions") [whereon one may purchase nazi memorabilia]. . . .

Answer of the consultants Laurie and Wallon
[53] These consultants point out that, in the current state of development of the Internet:
.....1) The figures provided for by AFA, crossed with their personal experience, make it possible for the
..........consultants to estimate at nearly 70% the IP addresses of French nationals or residents in the French
..........territory which may be correctly identified by specialized services suppliers like InfoS-plit, GeoNet or
..........others, on the basis of specialized data bases.
.....2) Yahoo! posts advertising banners targeted to internauts who are regarded as French by Yahoo! who
..........has therefore technical means to spot them.
.....3) Approximately 30 % of IP addresses allocated to French nationals cannot be identified correctly with
.........the above mentioned techniques.
.....4) Many sites, most of the time which are related to the field of national defence (cryptography) authorize
.........the access to some pages of the site or the down-loading of software, only after having requested from
.........the internaut a declaration of nationality.
.....5) "Cookies" are of current practice and make it possible to prevent that certain information should be
..........given again by the internaut every time that he consults a site. [Anyone] [w]ho wants to destroy one's
..........cookies or prevent them from being memorized knows perfectly well that consultations with the sites
..........they came from [time to reaccess] will be longer [without the Internet cookies].
.....6) The nazi objects are generally described as such by the sellers with a mention "nazi", said description of
..........object appears to them as a reason for the buyer to purchase. Consequently, the consultants consider .........that in addition to the geographical identification already used by Yahoo to target its publicity, it would .........be appropriate to ask the internauts, when their IP address is ambiguous, that they subscribe a
..........declaration of nationality.

[54] The declaration upon honor, would concern only the internauts whose IP address cannot be identified as being related to a French ISP (i.e. multinationals ISP like AOL address originating from an anonymous site or encapsulation of an address allocated by an intranet server). The declaration could, as Yahoo! would think it
fit, be subscribed either on the index page of its auction sales site, or only, in the case of a query for nazi objects, if the word nazi is mentioned in the user's query, just before it is processed by the search engine.

[55] In these conditions, the consultants consider that it cannot reasonably be supported that that would have negative effects on the performances and response time of the server hosting the auction sales site of Yahoo! The combination of the two procedures, geographical identification of IP addresses and declaration of nationality, would probably make it possible to reach a filtering ratio close to 90%.

Answer of consultant Vinton Cerf
....................................................................... . . .
Free translation: There follows a translation into French of Mr. Vinton Cerf's opinion:
....................................................................... . . .
[56] Whereas it results from said conclusions that physical localization of an internaut is possible on the basis of one's IP address; Whereas YAHOO Inc. attempts to make these conclusions totally unoperative by opposing to them the contents of a separate note prepared by one of the consultants Mr Vinton Cerf; but whereas, first, during the session devoted, among other matters, to hearing the consultants, Mr Vinton Cerf admitted the feasibility of a geographical localization in accordance with the terms and conditions of the report and with the proposals appearing in said report, the contents of which he approved;

[57] Whereas, then, his separate note of November 5, 2000, that Yahoo Inc. mentions, does not contradict the conclusions of the report: the note merely states on one hand that it would be "incorrect, in any case likely to induce in error", to affirm that it would be possible to determine with a high rate of reliability the
physical localization of an address IP, the term "high rate of reliability " meaning obviously a rate of reliability much higher than the one mentioned in the report, which is about 70%, and on the other hand, which the consultants collectively admitted entirely, that the answer which was given about this point could only concern the auction sales site of nazi objects and could not be extrapolated to services site under Yahoo's control;

[58] Whereas it is, besides, appropriate to mention that Yahoo Inc. already practices geographical identification of French internauts or internauts connecting from the French territory, since Yahoo Inc. systematically posts advertising banners in French language aimed to these internauts, whom Yahoo Inc. has therefore the means to spot; Yahoo Inc could not validly argue that the technology in question in the present case would be a "rough technology" with no reliability, unless one would have to consider that Yahoo Inc. has made the decision to waste its money or cheat the advertisers about the quality of the services and advantages which it is engaged to offer to them, which does not appear to be the case in this instance;

[59] Whereas, in addition to geographical identification, which is already practiced by Yahoo Inc. as that has just been demonstrated, the consultants' report suggests that the internauts, whose IP address is ambiguous (going through an anonymiser [site guaranteeing anonymity] - or allocation of IP addresses by AOL COMPUSERVE not taking into account the country of origin from the subscriber) may subscribe a declaration of nationality actually a declaration concerning the geographical origin of the internaut, that Yahoo Inc. could require either at the time when its home page is opened, or in the case of a search for nazi objects, if the word "nazi" appears in the query from the user, just before the query is processed by the search engine;

[60] Whereas the consultants, who challenge the allegations of Yahoo Inc. relating to the negative effects of such control over the performance and the response time of the server hosting the auction sales site, figure that the combination of both procedures, geographical identification and declaration of nationality, would make it possible to reach a filtering rate close to 90%;
....................................................................... . . .
[61] Whereas, in addition to the measures suggested by the consultants, it is necessary to add control by Yahoo on delivery location for the objects purchased in the auction sales;

[62] Whereas, as a matter-of-fact, the visit of the auction sales site of nazi objects is not exclusively consultative; its purpose is often the purchase of objects; consequently, if Yahoo did not have the possibility to identify with certainty the geographical origin of the internaut, French in the present case, Yahoo will have, because the place of delivery is known, the ability to prevent the delivery when it is scheduled to take place in France;

[63] Whereas, at last, on the basis of the language version of the navigator, Yahoo Inc, could have additional information on the nationality of the internaut;

[64] Whereas Yahoo Inc. argues however that in order to use that information it would be necessary to modify the software to manage its sites and a significant increase in the associated hardware resources;

[65] Whereas Yahoo Inc. adds that filtering all information at the level of the web server could be envisaged only if it was possible to make sure that prohibition would apply only to French internauts, unless other internauts throughout the world are deprived from information published on its sites, which cannot be envisaged;
....................................................................... . . .
[66] Whereas, furthermore, Yahoo Inc. does not demonstrate, with a convincing study forecast, that the technical changes which would be necessary to control access to the auction sales site of nazi objects would entail a significant increase in the associated hardware resources;

[67] Whereas in any event, company Yahoo! Inc. has proposed to cooperate with the plaintiffs; in effect Yahoo! Inc. requests that it be acknowledged that it is prepared to set up a watch system with the assistance of the plaintiffs, the fight of whose it has always respected, in order, when an offending site is brought to
its attention by the plaintiffs and on condition that it is obviously aimed to French users, to stop hosting it;

[68] To prove its good faith, Yahoo Inc. indicates to have stopped hosting the Protocole des Sages de Sion (Protocol of the Wise Men of Sion), considering sufficient the link of this document to France because of the language of the work;

[69] Whereas with a bit of good will, company Yahoo! Inc. will be able to convince itself that it is useful to extend that link to pictures and descriptions of objects representing symbols of nazism;

[70] Whereas, according to information put in the report from the consultants on the initiative of the plaintiffs and which was not earnestly disputed, company Yahoo refuses as of now its service for the auction sales of human organs, drugs, works or objects related to pedophilia, cigarettes, or animals alive, all sales which it
excludes automatically and rightly from the benefit of the [US Consitution's] First Amendment of the American Constitution which guarantees freedom of thought and expression;

[71] Whereas most certainly it would cost Yahoo! Inc. very little to extend the above prohibitions to symbols of nazism and such an initiative would have the merits of satisfying the requirements of ethics and morality shared by every and all democratic societies; Whereas the combination of the technical means that Yahoo! Inc. has together with the initiatives it is able to take on behalf of simple social morality give consequently to Yahoo! Inc the possibility to comply with the injunctions contained in the ordinance of 22 May, 2000 concerning filtering access to the auction sales service of nazi objects and to the service related to the work "Mein Kampf" which was included in the formulation of the aforesaid ordinance under the mention "and of any other site or service which constitutes an apology of nazism ";

[72] Whereas nevertheless a three months period will be granted to Yahoo! Inc. to comply with this ordinance [from November 20,2000] ;

[73] Whereas after the expiration of that period Yahoo! Inc. will have to pay a daily fine for non compliance in the amount of French Francs 100,000.00 [approximately US $ 13,000.00 as of November 2000] till perfect performance.

About claim against Yahoo France
Whereas the report from the consultants specifies and suggests:
....."to check whether Yahoo France has well satisfied the terms of our injunction contained in the ordinance of May 22, 2000"

[74] The ordinance of May 22, 2000 provides in this respect:

"Order company Yahoo France to warn any internaut consulting yahoo.fr, and this even before he uses a link enabling him to go on with his search on yahoo.com, that if the result of his search, either starting from a tree structure, or starting from key words, leads him to point to sites, pages or forums the title and/or the contents of which constitute a violation of the French law, which is the case of a consultation of sites making an apology of nazism and/or exhibiting uniforms, insignia, emblems recalling those which were worn or exhibited by nazis, or offering for sale objects or works the sale of which is strictly prohibited in France, then he must stop consulting the site concerned, lest he is liable to penalties provided for by French laws or he has to defend against lawsuits initiated against him."

[75] To conform with the terms of the ordinance, Yahoo! France has:
........1)changed and supplemented its terms of use which are accessed to by clicking on the link "tout savoir sur Yahoo!" appearing at the bottom of every page of the site. The following paragraph has been added:
......"At last, if within the framework of a search undertaken on www.yahoo.fr starting from a tree structure, of key words, the result of which would lead you to point to sites, pages or forums the title and/or contents of which constitute a violation of the French law, taking into account in particular the fact that Yahoo! France cannot check the contents of these sites and external sources (including the contents referred to on other sites and services of Yahoo! throughout the world), you must stop your consultation of the site concerned, lest you would be liable to penalties provided for by French laws or would have to defend against lawsuits initiated against you."
........2) installed, in the case of a search through a tree structure (categories) a warning drafted as follows: "Warning: by going on with your search on Yahoo! US you may be led to consult revisionist sites, the contents of which constitute a violation of the French law and the consultation of which, if you persevere, would make you subject to penalties.
....."It has been found that the terms of use of Yahoo ! were not systematically posted at the time of the first connection to the site and besides that the link "tout savoir sur Yahoo!"did not refer necessarily to the access for general terms of use.
...................................................................... . . .
[76] It is technically possible for Yahoo! France to force the posting of its terms of use at the time of the first connection of a user to its site.

[77] Yahoo! could also, in addition to, or in place of, the previous measure, cause systematically the posting of the notice mentioned in [para. 75] 2) as soon as the link to Yahoo.com is opened.

[78] But on this last point, Yahoo! sustains that such were not the terms of the ordinance. It will be up to the Court, then, to construe the terms of its own decision. Contrary to what Yahoo! sustains, "to warn any internaut consulting yahoo.fr and this as soon as he uses the link..." can mean that the notice must be posted every time the link is opened.

[79] Whereas Yahoo France sustains that it has perfectly complied with the ordinance of May 22, 2000 by amending the link targeted at by the plaintiffs , by installing on several links the notice mentioned in the ordinance, by recalling to internauts the terms of use of the service which may be accessed to by users as soon as they connect with Yahoo.fr and which may be consulted on all the pages of yahoo.fr since November 3, 2000, and by modifying the general terms of use of the service by incorporating a message even exceeding the requirements of the ordinance of May 22, 2000, and this in accordance with the terms of article 6.2 new;

[80] Whereas the initiatives taken by Yahoo! France are technically such that they may to a large extent satisfy the terms of our ordinance of May 22 2000, reserve being made however that the warning must be mentioned every time the link is posted, that is "even before the internaut put the link in use";

About other claims filed against Yahoo! France
[81] Whereas there is no urgency concerning the claims from LICRA, UEJF [the plaintiffs], and MRAP aiming that Yahoo! France be ordered, subject to a fine in case of non-compliance, to suppress any link from its site to sites owned directly or indirectly by Yahoo! Inc. till Yahoo! Inc has fulfilled its obligations, having regard to the existence of a dispute raised in earnest by Yahoo! France about claims, disputes which are outside our jurisdiction;

[82] For these reasons

........[a] Ruling publicly in first instance, by contradictory ordinance,
........[b] Reject the exception about non-jurisdiction reiterated by Yahoo! Inc;
........[c] Order Yahoo! Inc to satisfy, within 3 months as of notification of this ordinance [order dated Nov.
..............20, 2000], the injunctions contained in the ordinance of May 22, 2000, subject to a penalty for
..............non-permormance in the amount of French Francs 100,000.00 per day [approximately US $
..............13,300.00 per day] of delay as from the 1st day which will follow the expiry of the 3 months period;
........[d] ....Appoint Mr. Wallon 19, rue D. 75016 Paris Telephone:0147...... Fax: 0147...... at the expense to .............be paid in advance by Yahoo Inc.
........[e] With the duties to report about the ways according to which the terms of this ordinance are fulfilled;
........[f] Acknowledge that Yahoo Inc. has made the decision to stop hosting the Protocol of the Wise Men of ............Sion (Le Protocole des Sages de Sion);
........[g] Acknowledge that Yahoo! France has to a large extent satisfied the spirit and the letter of the
.............ordinance of May 22, 2000 containing injunction against it;
........[h] Order however that the warning to internauts must be posted before they put to use the link to
.............Yahoo.com, and this within 2 months after the present decision is notified;
........[i] Condemn Yahoo Inc to pay to each of the plaintiffs the sum of French Francs 10,000 [approximately ............US $ 1,330.00] pursuant to article 700 of the new code of civil proceedings;

Made in Paris, on November 2000

The Clerck of the Court: Nicole Vouriot

The President: Jean-Jacques Gomez


..........................................[[Opinion two of four]
............
Yahoo! Inc. v. La Ligue Contre Le Racisme Et L'Antisemitisme
......... ..........United States Court for the Northern District of California
.......................................145 F.Supp.2d 1168 (2001)
...ORDER DENYING FRENCH DEFENDANT'S MOTION TO DISMISS

Author's Note: Yahoo! filed this declaratory relief action in the United States. Yahoo! did not want to wait until the French government decided whether it would take enforcement action on the above French judgment. Yahoo!, the California-based Internet Service Provider, thus sued the French parties who obtained the order from French court--which had previously required Yahoo! to block French citizens' access to Nazi material displayed or offered for sale on provider's US site. Yahoo! thus seeks a declaration that the above French is unenforceable in US.
.....Yahoo has a French subsidiary <Yahoo.fr>. That Yahoo branch complies with French law. The US judge thus determined that--assuming Yahoo France continues to operate in good faith to discourage French citizens from accessing the illegal Nazi memorabilia auctions--that no claim can be made against the parent company in California.
.....The US filing was not immediately answered. Instead, the former French plaintiffs--now nominal defendants in the San Francisco federal court--asked the judge to dismiss this "second round." Some citations have been omitted from the court's opinion. The paragraph numbers have been added by the textbook author.

Court's Opinion. ...............
.....
FOGEL, District Judge.
[a] This case presents novel legal issues arising from the global nature of the Internet. Defendants La Ligue Contre Le Racisme Et L'Antisemitisme ("LICRA") and L'Union Des Etudiants Juifs De France ("UEJF") have obtained a court order in France which requires Plaintiff Yahoo!, Inc. ("Yahoo!") to "render impossible" access by persons in France to certain content on servers based in the United States. Yahoo! now seeks a declaration by this Court that the order of the French court is unenforceable in the United States because it contravenes the Constitution and laws of the United States. Defendants move for dismissal of this action on the ground that this Court lacks personal jurisdiction over them. The Court has read the moving and responding papers and has considered the oral arguments of counsel presented on Monday, April 9, 2001. For the reasons set forth below, the motion will be denied.

.............................................................I. BACKGROUND
[b] LICRA and UEJF are citizens of France. Yahoo! is a corporation organized under the laws of Delaware with its principal place of business in Santa Clara, California. Yahoo! is an Internet service provider which operates various Internet web sites and services which end-users can access at the Uniform Resource Locater ("URL") "http://www.yahoo.com." According to Yahoo!'s complaint, Yahoo! services ending in the suffix, ".com", without an associated country code as a prefix or extension (collectively, "Yahoo!'s U.S. Services"), use the English language and target users who are residents of, utilize servers based in and operate under the laws of the United States. Yahoo! subsidiary corporations operate regional Yahoo! sites and services in twenty (20) other countries, including, for example, Yahoo! France, Yahoo! India, and Yahoo! Spain. These regional web sites contain the host country's unique two-letter code as either a prefix or a suffix in their URL (e.g., Yahoo! France is found at http://www.yahoo.fr and Yahoo! Korea at http://www.yahoo.kr ). Yahoo! alleges that all of its regional sites use the local region's primary language, target the local citizenry, and operate under local laCertain services provided by Yahoo! allow end-users to post materials on Yahoo! servers which then can be accessed by end-users at Yahoo!'s Internet sites. As relevant here, Yahoo! end-users are able to post, and have in fact posted, highly offensive matter, including Nazi-related propaganda and memorabilia, the display and sale of which are illegal in France. While Yahoo! avers that its French subsidiary sites do not permit such postings, Yahoo!'s U.S.-based site ending in ".com" does not impose such a restriction because to do so might infringe upon the First Amendment to the United States Constitution. End-users in France are able to access Yahoo!'s U.S. services via the web site located at www.yahoo.com.

[c] On or about April 5, 2000, LICRA sent a "cease and desist" letter to Yahoo!'s headquarters in Santa Clara, California, stating that "unless you cease presenting Nazi objects for sale [on the U.S. Auction Site] within 8 days, we shall size [sic] the competent jurisdiction to force your company to abide by [French]
law." Defendants then employed the United States Marshal's Office to serve process on Yahoo! in California and filed civil complaints against Yahoo! in the Tribunal de Grande Instance de Paris (the "French Court") for alleged violation of a French criminal statute barring the public display in France of Nazi-related "uniforms, insignia or emblems" (the "Nazi Symbols Act"). See Le Nouveau Code Penal Art. R.645-2. On May 22, 2000 the French Court issued an order (the "French Order") directing Yahoo! to "take all necessary measures" to "dissuade and render impossible" any access via "yahoo.com" by Internet users in France to the Yahoo! Internet auction service displaying Nazi artifacts. (See Complaint, Exhibit A: Translated Copy of May 22 Order.) On November 20, 2000, the French Court "reaffirmed" its Order of May 22 and directed Yahoo!, inter alia, to 1) re-engineer its content servers in the United States and elsewhere to enable them to recognize French Internet Protocol ("IP") addresses and block access to Nazi material by end-users assigned such IP addresses; 2) require end-users with "ambiguous" IP addresses to provide Yahoo! with a declaration of nationality when they arrive at Yahoo!' s home page or when they initiate any search using the word "Nazi"; and 3) comply with the Order within three (3) months or face a penalty of 100,000 Francs (approximately U.S. $13,300) for each day of non-compliance. The Court denied Defendants' request to enforce its Order or impose any penalties directed at Yahoo! Inc. against Yahoo! France. Thereafter, Defendants again utilized the United States Marshal's Office to serve Yahoo! in Santa Clara with the French Order.

...........................................................II. LEGAL STANDARD
[d] Where no applicable federal statute indicates otherwise, a district court has personal jurisdiction over a nonresident defendant to the extent that the law of the forum state constitutionally provides.
............................................................................. . . .
[e] When a nonresident defendant raises a challenge to personal jurisdiction, the plaintiff bears the burden of showing that jurisdiction is proper.
............................................................................. . . .
.................................................................III. DISCUSSION
[f] . . .Yahoo! alleges that Defendants knowingly have engaged in actions intentionally targeted at its Santa Clara headquarters for the express purpose of causing the consequences of such actions to be felt in California, including 1) LICRA's "cease and desist" letter to Yahoo!'s Santa Clara headquarters; 2) Defendants' request of the French Court that Yahoo! be required to perform specific physical acts in Santa Clara (e.g., re-engineering of its Santa Clara-based servers); and 3) Defendants' utilization of United States Marshals to effect service of process on Yahoo! in California. Yahoo! further alleges that the conscious intent of these actions was to compel it to censor "constitutionally protected content on its U.S.-based Internet services."

[g] . . .In the present case, Yahoo! has alleged with particularity that Defendants "purposefully targeted" its Santa Clara headquarters and thus reasonably could have expected to be haled into a California forum in order to defend the Order they obtained from the French Court.[FN5]

[FN5.] Obviously, Defendants also reasonably could have expected to have to appear in a United States court in order to enforce the French Order. In this instance, Yahoo!'s declaratory relief action merely reverses the position of the parties while addressing the same issues which would arise were Defendants to bring such an enforcement action.

[h] The Court is especially mindful that "[g]reat care and reserve should be exercised
when extending our notions of personal jurisdiction into the international field." Accordingly, the Court looks to the Restatement (Third) of Foreign Relations Law § 101 et al. (1987) ("Restatement"), which articulates the limitations imposed by international law upon courts determining whether or not to exercise personal jurisdiction over a foreign defendant. Although the Restatement is not binding authority, it does provide valuable guidance. Adopting in essence a broad version of the effects test, the Restatement concludes that a court may exercise jurisdiction over a person "if at the time jurisdiction is asserted ... the person, whether natural or judicial, had carried on outside the state an activity having a substantial, direct, and foreseeable effect within the state, but only in respect to such activity."
............................................................................... . . .
[i] Generally, as just noted, a plaintiff seeking to hale a foreign defendant into court in the United States must meet a "higher jurisdictional threshold" than is required when a defendant is United States resident. However, since sovereignty concerns inevitably arise whenever a United States court exercises jurisdiction over a foreign national, this factor is "by no means controlling," otherwise "it would always prevent suit against a foreign national in a United States court." The instant action involves only the limited question of whether this Court should recognize and enforce a French Order which requires Yahoo! to censor its U.S.-based services to conform to French penal law. While this Court must and does accord great respect and deference to France's sovereign interest in enforcing the orders and judgments of its courts, this interest must be weighed against the United States' own sovereign interest in protecting the constitutional and statutory rights of its residents.

[j] California has an interest in providing effective legal redress for its residents. This interest appears to be particularly strong in this case in light of Yahoo!'s claim that its fundamental right to free expression has been and will be affected by Defendants' forum-related activities. As noted earlier, Defendants argue that Yahoo! has suffered no actual injury because they have not sought to enforce the French Order in the U.S. and may never seek to do so. Defendants' proposed "wait and see" approach, however, only highlights the importance of California's policy interest in providing a means for obtaining declaratory relief under circumstances such as those presented here. Many nations, including France, limit freedom of expression on the Internet based upon their respective legal, cultural or political standards. Yet because of the global nature of the Internet, virtually any public web site can be accessed by end-users anywhere in the world, and in theory any provider of Internet content could be subject to legal action in countries which find certain content offensive.[FN 7]

[FN 7] Indeed, there can be little doubt that most people in the United States, including this Court, find the display and sale of Nazi propaganda and memorabilia profoundly offensive. However, while this fact may cause one to sympathize with Defendants' efforts before the French Court, it is immaterial to this Court's jurisdictional determination. As Yahoo! and others have pointed out, a content restriction imposed upon an Internet service provider by a foreign court just as easily could prohibit promotion of democracy, gender equality, a particular religion or other viewpoints which have strong support in the United States but are viewed as offensive or inappropriate elsewhere.
....................................................................... . . .

..................................................................IV. DISPOSITION
[j] Accordingly, and good cause therefore appearing, the motion to dismiss is denied. Defendants shall answer the complaint within twenty (20) days of the date this Order is filed.

IT IS SO ORDERED.


French Trial Court Disposition (more cases may be filed):

The Paris trial court dismissed accusations by the above French human rights activists regarding Yahoo's alleged responsibility for auctions of Nazi paraphernalia that were once available on Yahoo's California-based website. Yahoo eventually banned Nazi material, because it did not want to profit from such material, while insisting that Yahoo's ban was unrelated to the proceedings in France.

This matter may not be over. French Holocaust survivors and their families launched a fresh attack. A related group, called the Movement Against Racism and for Friendship Between People, joined survivors to sue for one symbolic Euro. The court also dismissed their case. Yahoo and its former chief executive were thus characterized as not acting in a way which would "justify war crimes and crimes against humanity." The plaintiffs in this second suit may appeal. For news story, see Verena von Derschau (Associated Press), French Court Clears Yahoo! in Nazi Case, Feb. 11, 2003, posted on Findlaw at <http://news.findlaw.com/ap/ht/1700/2-11-2003/20030211101502_08.html> & Kerry Shaw, Internet: French Court Rejects Suit Against Yahoo, NYT on the Web, Feb. 12, 2003.


...............................................................[Opinion three of four
...............................Yahoo! Inc. v. La Ligue Contre Le Racisme Et L'Antisemitisme
.......................... .............United States Court for the Northern District of California
...........................................................169 F.Supp.2d 1181 (2001)
..................ORDER GRANTING YAHOO!'s MOTION FOR SUMMARY JUDGMENT
Author's Note: A summary judgment is granted when one of the parties establishes that, there maybe be a well-pleaded issue, but the court agrees with the moving party that there is no genuine issue. Yahoo! was thus able to convince the San Francisco federal trial judge that the French defendant could not win, were this case to go to trial. Thus, no reasonable jury could hold for the French defendant.
.....The [red] paragraph numbering has been inserted by the textbook author. Most footnotes and quotations omitted.

Court's opinion. FOGEL, District Judge.
[a] Plaintiff moves for summary judgment. Defendants oppose the motion. The Court has read the moving and responding papers and has considered the oral arguments of counsel presented on September 24, 2001. For the reasons set forth below, the motion will be granted.
................................................................................ . . .
.................................................................... II. OVERVIEW
[b].As this Court and others have observed, the instant case presents novel and important issues arising from the global reach of the Internet. Indeed, the specific facts of this case implicate issues of policy, politics, and culture that are beyond the purview of one nation's judiciary. Thus it is critical that the Court define at the outset what is and is not at stake in the present proceeding.

[c] This case is not about the moral acceptability of promoting the symbols or propaganda of Nazism. Most would agree that such acts are profoundly offensive. By any reasonable standard of morality, the Nazis were responsible for one of the worst displays of inhumanity in recorded history. This Court is acutely mindful of the
emotional pain reminders of the Nazi era cause to Holocaust survivors and deeply respectful of the motivations of the French Republic in enacting the underlying statutes and of the defendant organizations in seeking relief under those statutes. Vigilance is the key to preventing atrocities such as the Holocaust from occurring
again.

[d] Nor is this case about the right of France or any other nation to determine its own law and social policies. A basic function of a sovereign state is to determine by law what forms of speech and conduct are acceptable within its borders. In this instance, as a nation whose citizens suffered the effects of Nazism in ways that are
incomprehensible to most Americans, France clearly has the right to enact and enforce laws such as those relied upon by the French Court here.[FN6]

[FN6] In particular, there is no doubt that France may and will continue to ban the purchase and possession within its borders of Nazi and Third Reich related matter and to seek criminal sanctions against those who violate the law [of France].

[e] What is at issue here is whether it is consistent with the Constitution and laws of the United States for another nation to regulate speech by a United States resident within the United States on the basis that such speech can be accessed by Internet users in that nation. In a world in which ideas and information transcend borders and the Internet in particular renders the physical distance between speaker and audience virtually meaningless, the implications of this question go far beyond the facts of this case. The modern world is home to widely varied cultures with radically divergent value systems. There is little doubt that Internet users in the United States routinely engage in speech that violates, for example, China's laws against religious expression, the laws of various nations against advocacy of gender equality or homosexuality, or even the United Kingdom's restrictions on freedom of the press. If the government or another party in one of these sovereign nations were to seek enforcement of such laws against Yahoo! or another U.S.-based Internet service
provider, what principles should guide the court's analysis?

[f] The Court has stated that it must and will decide this case in accordance with the Constitution and laws of the United States. It recognizes that in so doing, it necessarily adopts certain value judgments embedded in those enactments, including the fundamental judgment expressed in the First Amendment that it is preferable to
permit the non-violent expression of offensive viewpoints rather than to impose viewpoint-based governmental regulation upon speech. The government and people of France have made a different judgment based upon their own experience. In undertaking its inquiry as to the proper application of the laws of the United States, the Court intends no disrespect for that judgment or for the experience that has informed it.

..................................................................IV. LEGAL ISSUES
A. Actual Controversy

[g] The Declaratory Judgment Act protects potential defendants from multiple actions by providing a means by which a court declares in one action the rights and obligations of the litigants. A declaratory judgment will not expand a federal court's jurisdiction, but if jurisdiction exists, litigants have earlier access to federal courts to spare potential defendants from the threat of impending litigation.
................................................................................ . . .
[h] Third, it is by no means clear that Yahoo! can rely upon the assessment in Defendants' declarations that it is in "substantial compliance" with the French order. The French Court has not made such a finding, nor have Defendants requested or stipulated that such a finding be made. As set forth earlier, Yahoo.com continues to
offer at least some Third Reich memorabilia as well as Mein Kampf on its auction site and permits access to numerous web pages with Nazi-related and anti-Semitic content. The fact that the Yahoo! does not know whether its efforts to date have met the French Court's mandate is the precise harm against which the Declaratory Judgment Act is designed to protect.
................................................................................ . . .
[i] 2. Real and Immediate Threat
The French order prohibits the sale or display of items based on their association with a particular political organization and bans the display of websites based on the authors' viewpoint with respect to the Holocaust and anti-Semitism. A United States court constitutionally could not make such an order. The First Amendment does not permit the government to engage in viewpoint-based regulation of speech absent a compelling governmental interest, such as averting a clear and present danger of imminent violence. In addition, the French Court's mandate that Yahoo! "take all necessary measures to dissuade and render impossible any access via Yahoo.com to the Nazi artifact auction service and to any other site or service that may be construed as constituting an apology for Nazism or a contesting of Nazi crimes" is far too general and imprecise to survive the strict scrutiny required by the First Amendment. The phrase, "and any other site or service that may be construed as an apology for Nazism or a contesting of Nazi crimes" fails to provide Yahoo! with a sufficiently definite warning as to what is proscribed. . . .

[j] Rather than argue directly that the French order somehow could be enforced in the United States in a manner consistent with the First Amendment, [FN8] Defendants argue instead that at present there is no real or immediate threat to Yahoo!'s First Amendment rights because the French order cannot be enforced at all until after the cumbersome process of petitioning the French court to fix a penalty has been completed. . . .

[k] . . . The French order permits retroactive penalties. . . .

[l] 3. Abstention.
Defendants next argue that this Court should abstain from deciding the instant case because Yahoo! simply is unhappy with the outcome of the French litigation and is trying to obtain a more favorable result here. Indeed, abstention is an appropriate remedy for international forum-shopping. . . .

[m] In the present case, the French court has determined that Yahoo!'s auction site and website hostings on Yahoo.com violate French law. Nothing in Yahoo!'s suit for declaratory relief in this Court appears to be an attempt to relitigate or disturb the French court's application of French law or its orders with respect to Yahoo!'s conduct in France. [FN10] Rather, the purpose of the present action is to determine whether a United States court may enforce the French order without running afoul of the First Amendment. The actions involve distinct legal issues, and as this Court concluded in its jurisdictional order, a United States court is best situated to determine the application of the United States Constitution to the facts presented. No basis for abstention has been established.

[FN10] Arguably, Yahoo! does seek to relitigate the French court's factual determination that Yahoo! does possess the technology to comply with the French order. For the reasons discussed herein, the Court concludes that Yahoo!'s ability to comply with the order is immaterial to the question of whether enforcement of the order in the United States would be constitutional.

[n] 4. Comity
No legal judgment has any effect, of its own force, beyond the limits of the sovereignty from which its authority is derived. . . . The extent to which the United States, or any state, honors the judicial decrees of foreign nations is a matter of choice, governed by "the comity of nations." Comity "is neither a matter of absolute obligation, on the one hand, nor of mere courtesy and good will, upon the other." United States courts generally recognize foreign judgments and decrees unless enforcement would be prejudicial or contrary to the country's interests.

[o] As discussed previously, the French order's content and viewpoint-based regulation of the web pages and auction site on Yahoo.com, while entitled to great deference as an articulation of French law, clearly would be inconsistent with the First Amendment if mandated by a court in the United States. What makes this case
uniquely challenging is that the Internet in effect allows one to speak in more than one place at the same time. Although France has the sovereign right to regulate what speech is permissible in France, this Court may not enforce a foreign order that violates the protections of the United States Constitution by chilling protected speech that occurs simultaneously within our borders. The reason for limiting comity in this area is sound. "The protection to free speech and the press embodied in [the First] amendment would be seriously jeopardized by the entry of foreign . . . judgments granted pursuant to standards deemed appropriate in [another country] but considered antithetical to the protections afforded the press by the U.S. Constitution." Bachchan, 585 N.Y.S.2d at 665. Absent a body of law that establishes international standards with respect to speech on the Internet and an appropriate treaty or legislation addressing enforcement of such standards to speech originating within the United States, the principle of comity is outweighed by the Court's obligation to uphold the First Amendment.[FN12]

[FN12] The Court expresses no opinion as to whether any such treaty or legislation would or could be constitutional.

..................................................................V. CONCLUSION
Yahoo! seeks a declaration from this Court that the First Amendment precludes enforcement within the United States of a French order intended to regulate the content of its speech over the Internet. Yahoo! has shown that the French order is valid under the laws of France, that it may be enforced with retroactive penalties,
and that the ongoing possibility of its enforcement in the United States chills Yahoo!'s First Amendment rights. Yahoo! also has shown that an actual controversy exists and that the threat to its constitutional rights is real and immediate. Defendants have failed to show the existence of a genuine issue of material fact or to identify
any such issue the existence of which could be shown through further discovery. Accordingly, the motion for summary judgment will be granted. The Clerk shall enter judgment and close the file.
IT IS SO ORDERED.


...............................................................[Opinion four of four
...............................Yahoo! Inc. v. La Ligue Contre Le Racisme Et L'Antisemitisme
.......................... ...................United States Ninth Circuit Court of Appeal
......................................................379 F.3d 1120 (Aug. 23, 2004)
...........................................................
...................
ORDER DISMISSING CASE FOR LACK OF PERSONAL JURISDICTION

SUMMARY of MAJORITY OPINION: California Internet service provider (ISP) sued French associations who had obtained order from French court requiring ISP to block French citizens' access to Nazi material displayed or offered for sale on ISP's United States site, seeking declaration that order was unenforceable in the United States. The United States District Court for the Northern District of California, 169 F.Supp.2d 1181, granted summary judgment for ISP. Associations appealed.

French associations that had obtained order from French court, requiring California Internet service provider (ISP) to block French citizens' access to Nazi material displayed or offered for sale on ISP's US site, were not subject, under the specific jurisdiction doctrine, to personal jurisdiction in ISP's action seeking a declaration that the French court's order violated ISP's First Amendment rights; associations did not expressly aim at California inasmuch as they did not engage in any wrongful conduct by taking action to enforce their legal rights under French law. Specific jurisdiction doctrine permits jurisdiction over a defendant in a lawsuit arising out of or related to the defendant's contacts with the forum.

Exercise of in personam jurisdiction is consistent with due process requirements of minimum contacts and fair play and substantial justice where: (1) the non-resident defendant has purposefully directed his activities or consummated some transaction with the forum or a resident thereof, or performed some act by which he purposefully availed himself of the privileges of conducting activities in the forum, thereby invoking the benefits and protections of its laws; or (2) the claim arises out of or relates to the defendant's forum-related activities, and (3) the exercise of jurisdiction is reasonable.

Appellants La Ligue Contre Le Racisme Et L'Antisemitisme ("LICRA") and L'Union Des Etudiants Juifs De France ("UEJF") appeal the District Court's grant of summary judgment in favor of Appellee Yahoo! Inc. ("Yahoo!"). Appellants contend that the District Court lacked jurisdiction, that the case was not ripe, and that the District Court should have abstained from hearing the case. We hold that there was no personal jurisdiction over Appellants and reverse the District Court.

DISSENTING OPINION:
Appellants raise three issues on appeal. First, they assert that the case lacked ripeness for declaratory relief from the district court. Second, they argue that the district court improperly exercised personal jurisdiction over them. Finally, they claim that the district court erred when it refused to abstain from hearing the case.
...........................................................................* * *
The court's first task is to determine whether the federal and foreign proceedings are in fact parallel. Finova Capital Corp., 180 F.3d at 898. Here, the district court determined that the proceedings between LICRA and UEJF and Yahoo! in France turned on the question of whether Yahoo!'s postings violated French law; whereas, "the purpose of the present action is to determine whether a United States court may enforce the French order without running afoul of the First Amendment." Indeed, the court noted, "Nothing in Yahoo!'s suit for declaratory relief in this Court appears to be an attempt to relitigate or disturb the French court's application of French law or its orders with respect to Yahoo!'s conduct in France." Accordingly, the district court refused to abstain.

The district court acted within its discretion in refusing to abstain. The proceedings in France had concluded, Yahoo!'s ability to appeal had expired, and the French court order specifically instructed Yahoo! to remove or render inaccessible the offending postings or else be subject to ongoing fines. These fines continue to mount, and Yahoo! brought the within suit to challenge the constitutionality of such judgment's enforcement. The district court correctly concluded that the actions involve distinct legal issues and that no basis for abstention had been established.

..............................................................CONCLUSION [Dissent]
For the foregoing reasons, I would hold that Yahoo!'s action for declaratory relief was ripe for adjudication and that the district court properly exercised jurisdiction over LICRA and UEJF and acted within its discretion in refusing to abstain. I would therefore affirm the district court's decision.


...............................................................[Opinion five of five
...............................Yahoo! Inc. v. La Ligue Contre Le Racisme Et L'Antisemitisme
.......................... ...................United States Ninth Circuit Court of Appeal
......................................................399 F.3d 1010 (Feb. 10, 2005)  

ORDERE

.....SCHROEDER, CHIEF JUDGE:

.....Upon the vote of a majority of nonrecused regular active judges of this court, it is ordered that this case be reheard by the en banc court pursuant to Circuit Rule 35-3. The three-judge panel opinion shall not be cited as precedent by or to this court or any district court of the Ninth Circuit, except to the extent adopted by the en banc [eleven-judge] court. 


.

Notes & Questions
.....1. On February 26, 2002, the Paris court gave notice that it would try the case against Yahoo starting on May 7, 2002. The French trial was rescheduled for January 2003. See J. Krause, Casting a Wide 'Net: Search Engines Yahoo and Google Tussle With Foreign Courts Over Content, 88 ABA Journal 20 (Nov. 2002). This development was the latest in the French group's two-year, trans-Atlantic legal struggle with Yahoo. During the interim period between the original French judgment and the ensuing trial announcement, Germany successfully pressured eBay to purge neo-Nazi merchandise from its website. See analysis at M. Lasden, Trouble on the Internet: Countries clash over website content, California Lawyer (April 2002). eBay's decision to comply with German authorities suggests that Yahoo's commercial interests may ultimately align with state-imposed limitations on what information is suitable for posting on the Internet.
.....2. On August 29, 2001, America Online was sued in the U.S. District Court in Alexandria, Virginia. The plaintiff seeks class-action status and an injunction requiring AOL to enforce its rules preventing members from sending e-mail messages which offend community standards. A Chicago attorney representing the plaintiff stated that "In light of the growing significance of the Internet, a public chat room should fall within this category as a place of entertainment and therefore should be free of harassment. Muslim members for years have been concerned about anti-Muslim harassment, but the harassers keep coming back."
.....AOL spokesman Andrew Weinstein said the lawsuit is "totally without merit," adding that "We have zero tolerance for hate speech on the service. When a complaint is brought to our attention, our staff reviews it, and can take action ranging from a reprimand to cancellation of service." The primary objective is to get AOL to enforce the terms of its service agreement in Muslim chat rooms." The AOL agreement prohibits members from using "offensive" speech. Source: Associated Press, Aug. 30, 2001 news story, click here.
.....3. The US Constitution's First Amendment encourages free speech. Federal civil rights law (the basis for the AOL suit) discourages hate speech. Should Yahoo! and AOL continue to be "caught in the middle," and thus be subject to law suits in liberal democracies like France and the US? Would it be acceptable for these countries to authorize private law suits against those who promote offensive speech on the Internet, rather than using the Internet Service Provider to police the Net?
.....Australia allowed such a suit to proceed in December 2002, based on an allegedly defamatory article placed on the Internet in Jew Jersey--subjecting the US publisher to a higher degree of tort liability than under the US Constitution's First Amendment Freedom of Speech approach. Jurisdiction over the defendant publisher was deemed to be where an allegedly defamatory article is read, rather than where the publisher places it on a web server. Dow Jones & Co.v. Gutnick, 2002 HCA 56 (High Court of Australia, Dec. 10, 2002) (appeal dismissed with costs). Click here. See also F. Barringer, Internet Makes Dow Jones Open to Suit in Australia, NYT on the Web (Dec. 11, 2002). See <http://www.austlii.edu.au/au/cases/cth/high_ct/2002/56.html>.
.....In April 2003, Barron's news bureau (owned by Dow Jones) editor/reporter Bill Alpert, author of the article at issue in the case, filed a complaint with the United Nations High Commissioner for Human Rights, under the Optional Protocol to the International Covenant on Civil and Political Rights. He contends that "that Australian libel law infringes upon [his] rights...as enumerated under Article 19 of the Covenant, which deals with freedom of expression." The case is of particular interest "because it exemplifies the problems that can occur when information disseminated globally on the Internet comes into conflict with the existing patchwork of local libel laws and judicial jurisdictions." Art. 19 provides that:

..........1. Everyone shall have the right to hold opinions without interference.
..........2. Everyone shall have the right to freedom of expression; this right shall include freedom to seek,
..............receive and impart information and ideas of all kinds, regardless of frontiers, either orally, in writing or .............in print, in the form of art, or through any other media of his choice.
..........3. The exercise of the rights provided for in paragraph 2 of this article carries with it special duties and .............responsibilities. It may therefore be subject to certain restrictions, but these shall only be such as are .............provided by law and are necessary: (a) For respect of the rights or reputations of others; (b) For the .............protection of national security or of public order, or of public health or morals.

.....4. Footnote 12 of the US court's November, 2001 decision in favor of Yahoo! effectively expresses reservations about whether a treaty resolution--say, between France and the US--would be constitutional. In Chapter 8 of this text, you will study: (a) how treaties are created; and (b) the hierarchy, in the event of a conflict between a treaty and the US Constitution. Assume that Yahoo! cannot block access to its website in just one country. If a treaty were to be negotiated, what would it say?
.....5. Since the mid-1990s, ISPs including AOL and Earthlink have won millions of dollars in settlements and judgments against spammers under trespass and computer fraud laws. The anti-spam organization Junkbusters, Inc. likens such suits to "mopping up an oil spill with a tooth brush." On the other hand, European Union members are developing laws which would require prior permission for spamming. But US business generally opposes such restrictions--equating business advertising with freedom of speech. A. Jesdanun, To Delete Junk E-Mail, Some Are Taking Retailers to Court, Associated Press, Jan. 14, 2002.
.....For information on government policy and/or laws regarding Internet censorship in various countries around the world (16), click here.
.....6. Further analyses are available as follows: (a) M. Geist, Is There a There There? Toward Greater Certainty for Internet Jurisdiction, p.4-5 (2001): click here; (b) J. Winer, If the U.S. Is from Mars and the EU Is from Venus, What Do You Do in Cyberspace?, 1 Privacy & Info. Law Rep. 8 (Apr. 2001); (c) H. Parness, Ebay Victorious (Again), Yahoo! Attacked (Again), as the Auction Wars Continue, 6 Cyberspace Lawyer 8-9 (March 2001); (d) S. Hines, Recent Developments: An Analysis of UEJF et Licra V. Yahoo!, 5 J. Small & Emerging Bus. Law 445-455 (Fall 2001: Northwestern School of Law of Lewis & Clark College); (e) Current Development: First Amendment and Internet, 19 Computer and Internet Lawyer 24-26 (2002).
.....7. In May 2002, Yahoo sued its insurance company in a California state court, claiming that the insurer told Yahoo in February of 2001 that its $5 million policy covered the defense of the action in Paris--but not Yahoo's federal declaratory relief suit in San Jose, CA. Yahoo v. Gulf Underwriters Insurance Co. (CV808117). Yahoo's lawyer said that the French court's order had "disastrous consequences" for the Internet industry as a whole, and had to be countered in the United States. Thus, "[t]he French court's order was not technically possible; [and] Yahoo could not prevent access to certain content on its U.S. site by French citizens." The outcome could impact Yahoo's continuing willingness to "defend" the case, first filed in France, by it's responsive action in California. For news story, click here.
.....8. On September 12, 2002, the PRC stopped blocking a popular U.S.-based Internet search engine. Previously, the PRC government had rerouted attempted access to Google by responding with the "Shanghai Hotline" at a distinct web location. Users in Shanghai and Beijing reported that they could once again view Google, which is widely used by China's thirty million-plus Internet users--because of its powerful feature for finding Chinese-language material online. Chatroom users thus reacted with expressions like "I'm thrilled that Google is back." On the website of the People's Daily, the official Communist Party newspaper," another user commented that "Google, I love you!" See Associated Press, Share The Love: China Ends Blocking of Google, OTOH, a Chinese author who posted essays about politics on the Internet was arrested on subversion charges in August 2002. See Associated Press, Its Now Safe For The Government To Turn Off Your Computer: China Author Arrested (Sept. 25, 2002).
.....
9. One possible solution might be a review of the French judgment by the European Court of Human Rights (ECHR, §11.3). Section 10 of the European Convention on Human Rights protects freedom of speech, although its perspective is not necessarily co-extensive with US Supreme Court interpretations of the First Amendment. The question in such a case would be whether French law is consistent with the ECHR's view of the scope of Article 10. Section (1) states that everyone has the right to freedom of expression. Section (2), however, continues with the following limiting principle: the exercise of such freedom "may be subject to such . . . restrictions or penalties as . . . are necessary in a democratic society, in the interests of national security, territorial integrity or public safety, for the prevention or disorder of crime, [and] for the protection of health or morals . . . .
.....10. At present, an en banc [eleven judge] federal court will rehear the US portion of this case.
.....11. ISP cooperation with national governments is a new privacy concern. In September 2005, a French media watchdog group claimed that Yahoo helped Chinese authorities convict and jail a writer who had submitted an e-mail about government press restrictions. Yahoo Holdings Hong Kong supposedly provided information resulting in a ten-year sentence because he circulated information regarding a PRC memo describing restrictions on the media in the PRC. Reporters Without Borders, Information supplied by Yahoo! helped journalist Shi Tao get 10 years in prison, available at: <http://www.rsf.org/article.php3?id_article=14884>.

 Go To Chapter 5, Section 5.2, text p.248, after French Yahoo! Judgment reference to this web page (§5.3).

..Last rev: 05/21/06
..Course Web Page