The Jan. 1996 contract was a promise for later transfer. The actual ICANN transfer took place later, in May 1996. The reason for the delay was the time it took for issuance of Sporty’s Farm, LLC’s certificate of organization. (A nice opportunity to talk to students about bus orgs issues!) In the interim, the plaintiff filed suit. Here’s text from op below, with cite:

In January 1996, nine months after registering the domain name “sportys.com”, Omega, through Milton Hollander and Betty R. Hollander, formed Sporty’s Farm, LLC. Sporty’s Farm is a Christmas tree farm. By way of an agreement dated January 12, 1996, Omega agreed to transfer the domain name “sportys.com” to Sporty’s Farm in consideration for $ 16,200, upon the issuance of the certificate of organization. Sometime in May 1996, Omega transferred the domain name to Sporty’s Farm. In May 1996, the domain name became operational and Sporty’s Farm started to advertise its Christmas trees on the Internet.

In March 1996, Sportsman’s Market discovered that Omega had registered its mark, Sporty’s, as a domain name. Sportsman’s Market contacted Omega and demanded that Omega cease using the domain name. Omega refused. On April 29, 1996, Sporty’s Farm commenced the instant action.

Sporty’s Farm, LLC v. Sportsman’s Mkt., Inc., 1998 U.S. Dist. LEXIS 23290