The complaints fall into two separate categories: human rights and consumer complaints:

1. Afilias administers and manages ccTLD .io to generate profits for its shareholders and in doing so abets the crime of apartheid against the African Chagossian people and supports the British Indian Ocean Territory (BIOT) regime which was declared unlawful colonialism by 116 members of the United Nations General Assembly including the Republic of Ireland. Afilias’ support for BIOT is a brazen violation of OECD human rights guidelines, “The Human Rights Complaints.”
2. Afilias has affirmatively marketed and administered ccTLD .io in such a manner that it has become an offshore haven for organized criminals using crypto assets in violation of the OECD consumer guidelines, “The Consumer Complaints.” Further Afilias has misappropriated the digital legacy of the Chagossian people without compensation and uses their name in promoting its products as “Chagosian Domains.”