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| 1 | +While GitHub did not find sufficient information to determine a valid anti-circumvention claim, we determined that this takedown notice contains other valid copyright claim(s). |
| 2 | + |
| 3 | +--- |
| 4 | + |
| 5 | +**Are you the copyright holder or authorized to act on the copyright owner's behalf? If you are submitting this notice on behalf of a company, please be sure to use an email address on the company's domain. If you use a personal email address for a notice submitted on behalf of a company, we may not be able to process it.** |
| 6 | + |
| 7 | +Yes, I am the copyright holder. |
| 8 | + |
| 9 | +**Are you submitting a revised DMCA notice after GitHub Trust & Safety requested you make changes to your original notice?** |
| 10 | + |
| 11 | +Yes |
| 12 | + |
| 13 | +**Please provide the Zendesk ticket number of your previously submitted notice. Zendesk ticket numbers are 7 digit ID numbers located in the subject line or body of your confirmation email.** |
| 14 | + |
| 15 | +#4193814 |
| 16 | + |
| 17 | +**Does your claim involve content on GitHub or npm.js?** |
| 18 | + |
| 19 | +GitHub |
| 20 | + |
| 21 | +**Please describe the nature of your copyright ownership or authorization to act on the owner's behalf.** |
| 22 | + |
| 23 | +The individual responsible for these uploads is a former contractor who had temporary access to our private repositories. After termination, they unlawfully retained and redistributed our proprietary code in violation of contract, NDA, and copyright law. |
| 24 | + |
| 25 | +This individual is currently attempting to extort our company by threatening to further distribute our intellectual property unless payment is made. |
| 26 | + |
| 27 | +I am the [private] [private] of the proprietary source code belonging to Louco Event (louco.app). |
| 28 | + |
| 29 | +The reported repositories contain code that was developed internally by our company and is protected under copyright law. The individual who uploaded the infringing repositories was temporarily engaged as a backend developer under a contractual agreement that explicitly prohibits any retention, reuse, distribution, or disclosure of our code after termination. |
| 30 | + |
| 31 | +This individual has signed a Non-Disclosure Agreement (NDA) and confidentiality clauses, which remain binding after termination. |
| 32 | + |
| 33 | +**Please provide a detailed description of the original copyrighted work that has allegedly been infringed.** |
| 34 | + |
| 35 | +The copyrighted work consists of proprietary software developed and maintained by Louco Event, including backend APIs, frontend web applications, mobile applications, and infrastructure code. |
| 36 | + |
| 37 | +This includes, but is not limited to: |
| 38 | +- Backend services (louco-api) |
| 39 | +- Mobile applications (louco-mobile, louco_mobile_private) |
| 40 | +- Web applications (louco_web_v2) |
| 41 | +- Infrastructure and deployment code (louco-infra, louco-terraform) |
| 42 | + |
| 43 | +These repositories are privately owned, not open source, and are commercially sensitive. |
| 44 | + |
| 45 | +The individual responsible for these uploads is a former contractor who had temporary access to our private repositories. After termination, they unlawfully retained and redistributed our proprietary code in violation of contract, NDA, and copyright law. |
| 46 | + |
| 47 | +This individual is currently attempting to extort our company by threatening to further distribute our intellectual property unless payment is made. |
| 48 | + |
| 49 | +We have filed a criminal complaint with the police and have substantial evidence supporting our claims. |
| 50 | + |
| 51 | +We request immediate removal of all infringing repositories and appropriate enforcement action, including suspension of the associated GitHub accounts. We also believe that the accounts "[private]" and "[private]" belong to the same individual. |
| 52 | + |
| 53 | +**If the original work referenced above is available online, please provide a URL.** |
| 54 | + |
| 55 | +Original work URLs: |
| 56 | +[private] |
| 57 | +[private] |
| 58 | +[private] |
| 59 | +[private] |
| 60 | +[private] |
| 61 | +[private] |
| 62 | + |
| 63 | +**We ask that a DMCA takedown notice list every specific file in the repository that is infringing, unless the entire contents of the repository are infringing on your copyright. Please clearly state that the entire repository is infringing, OR provide the specific files within the repository you would like removed.** |
| 64 | + |
| 65 | +**Based on the above, I confirm that:** |
| 66 | + |
| 67 | +The entire repository is infringing |
| 68 | + |
| 69 | +**Identify the full repository URL that is infringing:** |
| 70 | + |
| 71 | +https://github.com/Maksym00H/Louco_Web_v2_main |
| 72 | +https://github.com/Maksym00H/Louco_API_Staging |
| 73 | +https://github.com/Maksym00H/Louco-API-Dev |
| 74 | +https://github.com/Maksym00H/Louco_mobile_main |
| 75 | +https://github.com/Maksym00H/Louco_Mobile_Private_Main |
| 76 | +[private] |
| 77 | +https://github.com/Maksym00H/Louco_Infra_Main |
| 78 | +https://github.com/Maksym00H/Louco_Web_Main |
| 79 | + |
| 80 | +**Do you claim to have any technological measures in place to control access to your copyrighted content? Please see our <a href="https://docs.github.com/articles/guide-to-submitting-a-dmca-takedown-notice#complaints-about-anti-circumvention-technology">Complaints about Anti-Circumvention Technology</a> if you are unsure.** |
| 81 | + |
| 82 | +Yes |
| 83 | + |
| 84 | +**What technological measures do you have in place and how do they effectively control access to your copyrighted material?** |
| 85 | + |
| 86 | +Our copyrighted code is stored in private [private] repositories with strict access controls. Access is limited to authorized team members only via authenticated [private] accounts. |
| 87 | + |
| 88 | +Additional protections include: |
| 89 | +- Private repository settings (no public access) |
| 90 | +- Role-based access control |
| 91 | +- Contractual restrictions and NDAs prohibiting copying, sharing, or reuse |
| 92 | +- Internal security policies governing access and handling of source code |
| 93 | + |
| 94 | +These measures ensure that the code is not publicly accessible and cannot be accessed without explicit authorization. |
| 95 | + |
| 96 | +**How is the accused project designed to circumvent your technological protection measures?** |
| 97 | + |
| 98 | +The accused individual gained authorized access temporarily as a contractor. After termination of the engagement, they unlawfully retained copies of our private repositories and re-uploaded them to public GitHub repositories without authorization. |
| 99 | + |
| 100 | +By publishing our previously private code publicly, they effectively bypassed our access controls and made restricted content accessible to anyone on the internet. |
| 101 | + |
| 102 | +This constitutes a clear circumvention of our technological protection measures. |
| 103 | + |
| 104 | +**If you are reporting an allegedly infringing fork, please note that each fork is a distinct repository and <i>must be identified separately</i>. Please read more about <a href="https://docs.github.com/articles/dmca-takedown-policy#b-what-about-forks-or-whats-a-fork">forks.</a> As forks may often contain different material than in the parent repository, if you believe any of the repositories or files in the forks are infringing, please list each fork URL below:** |
| 105 | + |
| 106 | +https://github.com/Maksym00H/Louco_Web_v2_main |
| 107 | +https://github.com/Maksym00H/Louco_API_Staging |
| 108 | +https://github.com/Maksym00H/Louco-API-Dev |
| 109 | +https://github.com/Maksym00H/Louco_mobile_main |
| 110 | +https://github.com/Maksym00H/Louco_Mobile_Private_Main |
| 111 | +[private] |
| 112 | +https://github.com/Maksym00H/Louco_Infra_Main |
| 113 | +https://github.com/Maksym00H/Louco_Web_Main |
| 114 | + |
| 115 | +**Is the work licensed under an open source license?** |
| 116 | + |
| 117 | +No |
| 118 | + |
| 119 | +**What would be the best solution for the alleged infringement?** |
| 120 | + |
| 121 | +Other Change |
| 122 | + |
| 123 | +**Describe the change.** |
| 124 | + |
| 125 | +We request the immediate removal of all infringing repositories listed above. |
| 126 | + |
| 127 | +Additionally, due to the severity of the violation, including unauthorized distribution of private proprietary code, breach of NDA, use of false identity, and ongoing extortion attempts, we request immediate suspension of the associated GitHub accounts. |
| 128 | + |
| 129 | +First take the forks down! The accounts "Maksym00H" and "khiro95-king" belong to the same individual and should both be investigated and suspended to prevent further distribution of our copyrighted material. |
| 130 | + |
| 131 | +Failure to take action will likely result in continued unauthorized redistribution of our intellectual property across platforms. |
| 132 | + |
| 133 | +**Do you have the alleged infringer’s contact information? If so, please provide it.** |
| 134 | + |
| 135 | +The individual is operating under the GitHub accounts "[private]" and "[private]". |
| 136 | +We do not have verified personal contact information, as the individual used false identity details during engagement, including a fake ID. |
| 137 | +Our legal counsel will request all available identifying information related to these accounts through appropriate legal channels, in order to support an ongoing police investigation and identify the individual responsible. |
| 138 | + |
| 139 | +**I have a good faith belief that use of the copyrighted materials described above on the infringing web pages is not authorized by the copyright owner, or its agent, or the law.** |
| 140 | + |
| 141 | +**I have taken <a href="https://www.lumendatabase.org/topics/22">fair use</a> into consideration.** |
| 142 | + |
| 143 | +**I swear, under penalty of perjury, that the information in this notification is accurate and that I am the copyright owner, or am authorized to act on behalf of the owner, of an exclusive right that is allegedly infringed.** |
| 144 | + |
| 145 | +**I have read and understand GitHub's <a href="https://docs.github.com/articles/guide-to-submitting-a-dmca-takedown-notice/">Guide to Submitting a DMCA Takedown Notice</a>.** |
| 146 | + |
| 147 | +**So that we can get back to you, please provide either your telephone number or physical address.** |
| 148 | + |
| 149 | +[private] |
| 150 | + |
| 151 | +**Please type your full name for your signature.** |
| 152 | + |
| 153 | +[private] |
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