dmca/2016/2016-06-02-TDBank.md

Dear GitHub,

We are submitting the below information for a claim of trademark infringement on behalf of our client,
The Toronto-Dominion Bank.

A physical or electronic signature of the copyright owner, or a person authorized to act on behalf of
the owner, of an exclusive copyright that has allegedly been infringed.

Please see attached authorization letter  
[private]

Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted
works at a single online site is covered by a single notification, a representative list of such works on
that site.

https://www.tdbank.com/

Identification of the material that is claimed to be infringing or to be the subject of infringing activity
and that is to be removed or access to which is to be disabled, and information reasonably sufficient
to permit GitHub, Inc. to locate the material.

The Toronto-Dominion Bank – All cases below contain private TD owned information: source code,
sensitive configuration data such as internal URLs, credentials, destination IP addresses, server names or
sensitive internal operational documentation which was uploaded without TD's authorization. Private
TD Source code was used to access TD network

1)

[redacted]

2) 

[redacted]

3)

[redacted]

4)  
https://github.com/vishaalc/TD-Coop-work  
This user's profile clearly indicates they were a co-op student at TD Bank and have uploaded their work
after their internship was completed. This code is property of TD Bank Group and not the individual
posting. An example of the exact python script they wrote is attached below from the team he was
working for.

Information reasonably sufficient to permit GitHub, Inc. to contact the Complaining Party, such as an address, telephone number, and, if available, an electronic mail address at which the Complaining Party may be contacted.

CSC Digital Brand Services Brand Protection and Phishing Response Team  
[private]

A statement that the Complaining Party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.

CSC DBS has a good faith belief that the use of The Toronto-Dominion Bank materials is not
authorized by the copyright owner, The Toronto-Dominion Bank, its agent, or the law.

A statement that the information in the notification is accurate, and under penalty of perjury, that the Complaining Party is the owner, or is authorized to act on behalf of the owner, of an exclusive right that is allegedly infringed.

CSC DBS, under penalty of perjury, states that the information contained is accurate and that CSC
DBS is authorized to act on behalf of The Toronto-Dominion Bank.

From the information above, The Toronto-Dominion Bank items (replicas) sold on github.com are
counterfeit because they use The Toronto-Dominion Bank name, trademarks, and logos without consent
from The Toronto-Dominion Bank. Additionally, the trafficking of counterfeit merchandise is illegal and
punishable by law. On behalf of The Toronto-Dominion Bank, CSC DBS requests that all The TorontoDominion
Bank related content be removed from the website immediately.

The Toronto-Dominion Bank is the exclusive owner of all rights in the world-famous The TorontoDominion
Bank trademarks, registered throughout the world on or with respect to fragrance and beauty
products, clothing, jewelry, footwear, accessories, leather goods and other items. These registrations
constitute conclusive evidence of The Toronto-Dominion Bank 's ownership of The Toronto-Dominion
Bank Marks, as well as The Toronto-Dominion Bank 's exclusive right to use The Toronto-Dominion Bank
Marks. As a matter of law, these trademark registrations have put github.com on constructive notice of
The Toronto-Dominion Bank 's rights in The Toronto-Dominion Bank Marks.

I have read and understand GitHub's Guide to Filing a DMCA Notice.

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.

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.

We believe that the above provides all of the requested information in order for you to take action but
do let us know of any other documentations that are required from us. If you have any further
questions, please feel free to contact us back.

Thank you,  
[private]

CSC Digital Brand Services Brand Protection and Phishing Response Team  
[private]