JURISDICTION: IN REM$/$QUASI IN REM

In December $2000,$ Office Depot obtained a court judgment against John Zuccarini under the Anti$-$cybersquatting Consumer Protection Act of $1999$ based on Zuccarini's registration of the domain name $"$

offic$-$depot.com." Because Office Depot was unable to collect on the judgment, it eventually assigned the judgment to another company, DS Holdings $($DSH$).$ DSH registered the judgment in the district court for the Northern District of California and subsequently learned that Zuccarini owned more than $248$ domain names registered with the company VeriSign, of which more than $190$ were "dot$-$com" domain names. Targeting the dot$-$com domain names, DSH sought to levy and sell some of those names owned by Zuccarini. $($The Anti$-$cybersquatting Consumer Protection Act states that jurisdiction over domain names shall be $"$in the judicial district in which the domain name registrar, domain name registry, or other domain name authority that registered or assigned the domain name is located. $...")$ The district court appointed a receiver to take control of and auction off some of Zuccarini's domain names in order to satisfy the original judgment in the Office Depot case. DSH never claimed that the district court in the Northern District of California had personal jurisdicticyn over Zuccarini himself but instead argued that the court had in rem jurisdiction over his intangible property rights $($i$.$e$.,$ his various $"$

dot.com" domain names$)$ located in the state of California. The district court ruled for DSH$,$ and Zuccarini appealed to the Ninth Circuit Court of Appeals, contending that the Northern District of California was not a proper place to levy against his domain names and that the appointment of the receiver was therefore improper.

CASE QUESTIONS

Do in rem and quasi in rem jurisdiction apply to intangible property rights like domain names? Why or why not?

Which form of jurisdiction should apply to this case: in rem or quasi in rem?

Why can the court obtain jurisdiction allowing the seizure and sale of domain names without first obtaining personal jurisdiction over the defendant John Zuccarini?