The following summary is taken from Tiller's web page:

Religious Rights v. Free Speech?: South African Religious Sect Recovers
Name From Critic (Mission KwaSizabantu v. Benjamin Rost, Case No.
D2000-0279, June 7, 2000)

 On June 7, 2000, an ICANN panel held that an African religious sect
(Mission entitled to domain names (,, on which sites criticism and comment on the Mission
KwaSizabantu sect were posted. Benjamin Rost had registered the domain
sites to offer alternative and critical views of KwaSizabantu. The word
"KwaSizabantu" was said to be a Zulu word meaning "The Place Where
People are Helped" and is only found in the Zulu language.

The panel ordered the domain names transferred to Mission KwaSizabantu.
With respect to free speech, the panel stated:

	"It is beyond the scope of the present adjudication to consider any
such issues as the boundaries of free speech ... 

	The admitted nature of the use of the domain names ... includes
alternative views and indeed critical views concerning ...
[KwaSizabantu] and its activities. The Panel holds such activity amounts
to tarnishing the activities associated with the trademark or service
mark "KwaSizabantu" ... . Therefore, ... [Rost] does not establish any
rights or legitimate interests ...

	...[I]t is no rebuttal for ... [Rost] to assert that any disruption is
merely a consequence of him publishing his view of the truth."