According to a message submitted by Bernhard's vote-auctioneering partner "LizVlx" (Elisabeth Haas) to the Web-law e-mail group, the shutdown of Vote-auction followed a chain of command they hope to retrace in their lawsuit.

The company that registered Vote-auction.com, she said, was the Dusseldorf-based CSL GmbH, which in turn brokers domain names via The Internet Council of Registrars (CORE), based in Geneva.

CORE, she said, responded to the American legal actions against Vote-auction by pulling the plug.

"Apparently, they feel that a Missouri restraining order is governed under Swiss law, and that e-mail proves authenticity," Haas wrote.

Stephanie Schliepack, a Berlin attorney representing Vote-auction, said the dynamic between the parties responsible for removing Vote-auction.com from the Internet has yet to be fully determined.

"We're considering suing CSL with an intent to explore the relationship with CORE as well," she said.

And since the Vote-auction case now has elements of Americans attempting to silence European-based satire -- raising the questions of both jurisdiction and international Internet governance -- such legal actions could raise some important legal issues outside of the immediate Vote-auction arena.

"We're trying to test how far different German judgments about the validity of American cases go," said Schliepack, adding that the roles of ICANN and international law are being explored as well.

These six legal actions -- five state cases and Vote-auction's suit -- now comprise a minuet of litigation that recall last year's legal battles over the fate of a Swiss Internet art corps Bernhard helped found, etoy. Sued by the toy retailer eToys for their nearly identical domain name, eToy turned the action into an opportunity for guerrilla theater.

"It seems that we are witnessing the birth of a new subgenre of action-art: Digital Legal Art," Bernhard and Haas wrote in a Vote-auction press release that came out on election day. "Apparently it is even not so much the end user in front of the terminal to whom we appeal most but the people in U.S. legal offices.... very sexy!

"Nevertheless, we are sure that the cases will be dropped, as it will be obvious, even to the legal folk, that there are people out there buying and selling votes -- but that it is not us. We just gave you the showcase. The real dealers do their business quite openly in Washington. Vive la difference!"