To Whom It May Concern,
I would like to file a DMCA Takedown Notice for text published on a
website that I believe GitHub is the host for. I have found the
following information for this website (suego.co) in which the DNS
Records lead me to believe that GitHub is the host:
https://who.is/dns/suego.co (also see attached screenshot). Please see
the official takedown request below.
This letter is a Notice of Infringement as authorized in § 512(c) of the
U.S. Copyright Law under the Digital Millennium Copyright Act (DMCA). I
wish to report an instance of Copyright Infringement. The infringing
material appears on a website for which you are the designated host.
1\. I have read and understand GitHub's Guide to Filing a DMCA Notice.
2\. The copyrighted material, which I contend belongs to me and appears
illegally on the website for which you provide hosting services, is the
following:
Website Text:
The text on the homepage of my website (section towards the bottom
of the site underneath the headline Why Choose WayLay Design) is
infringed by the following text on the homepage of the other
company's website, "To say that we know you have a choice when it
comes to hiring a web design company is an understatement. Our
personal attention to our clients is second to none and has not only
allowed us to compete in this ever saturated market, but to thrive."
This text has been on our website since September 24, 2014 as shown
in archive.org:
https://web.archive.org/web/20140924010229/http://www.waylaydesign.com
Website Text:
The text on the About page of my website is also infringed by the
following text on the About page of the other company's website,
"What began as a school project in [date changed] became a business
in [date changed] and now here we are today, (dare I say) one of the
best web design companies in [location changed], not only competing,
but thriving in this saturated [location changed] market.
We have been successful not just because of our quality work, but
because of the quality of service we provide and the appreciation we
receive from our clients. Without happy clients, we would not survive.
[Business name changed] is a web design company in [location
changed]. We know you only have about a million choices when it
comes to hiring a web design [service added], and we work hard to
differentiate ourselves from the crowd.
Being a small company, we can offer personal service and attention
to each of our clients individually, building long lasting
relationships that extend well beyond the completion of your project.
A lot of people ask us when we are going to start hiring employees
or begin outsourcing our work. The answer is, we’re not. Our goal
here isn’t to be the biggest, our goal is to be the best web design
team you’ve ever worked with."
Some of the verbiage above ("Being a small company, we can offer
personal service and attention to each of our clients individually,
building long lasting relationships that extend well beyond the
completion of your project.") has been on my website since February
21, 2013:
https://web.archive.org/web/20130221094918/http://www.waylaydesign.com/about/
The rest of the verbiage infringed has been on my website since
March 31, 2014:
https://web.archive.org/web/20150331135143/http://www.waylaydesign.com/about/
I noticed the infringement because I pay for a service to scan the
web for copies of my text since I have had several incidents in the
past where other web design companies have copied text from my site
verbatim. Here is a link to view the notice I received:
http://www.copyscape.com/view.php?us=waylaydesign&ch=11e133a&o=27264&u=http%3A%2F%2Fsuego.co%2Fabout-us%2F&t=1442327354&s=https%3A%2F%2Fwww.waylaydesign.com%2Fabout%2F&w=25
(See attached screenshots)
3\. The pages infringing the copyrighted work appears at the website
address: http://suego.co/
The original file is located here:
https://github.com/steverodrigz/steverodrigz.github.io/blob/master/index.html
Line 95:
```
To say that we know you have a choice when it comes to hiring a
web design company is an understatement. Our personal attention to
our clients is second to none and has not only allowed us to compete
in this ever saturated market, but to thrive.
```
http://suego.co/about-us/
The original file is located here:
https://github.com/steverodrigz/steverodrigz.github.io/blob/master/about.md
Code is here:
https://github.com/steverodrigz/steverodrigz.github.io/blame/master/about.md
Lines 18-22:
```
What began as a school project in 2009 became a business in 2015
and now here we are today, (dare I say) one of the best web design
companies in Washington DC, not only competing, but thriving in this
saturated Washington DC market.
We have been successful not just because of our quality work,
but because of the quality of service we provide and the
appreciation we receive from our clients. Without happy clients, we
would not survive.
Suego is a full service internet marketing and web design company
in Washington DC that is driven to help you in every facet of the
website world. We know you only have about a million choices when it
comes to hiring a web design & internet marketing company, and
we work hard to differentiate ourselves from the crowd.
Being a small company, we can offer personal service and
attention to each of our clients individually, building long lasting
relationships that extend well beyond the completion of your
project.
A lot of people ask us when we are going to start hiring
employees or begin outsourcing our work. The answer is, we’re not.
Our goal here isn’t to be the biggest, our goal is to be the best
web design team you’ve ever worked with.
```
Suego.co's domain was created on October 6, 2014
(http://www.whois.com/whois/suego.co). This means that there is no
way that the text copied above could have been on his website before
mine.
I have also found evidence that the other content on Suego.co'
website has also been taken verbatim from other websites by just
doing a search for a variety of full sentences throughout his web
pages (such as "Our services are broken up into separate sections so
you can buy services individually rather than having to bundle them
together like most other marketing firms." - Located on his Services
page: http://suego.co/services/)
4\. The affected user will need to remove all content referenced above
that was copied from waylaydesign.com in order to remedy the infringement.
5\. My contact information is as follows:
Name: [private]
Email: [private]
Phone: [private]
Address: [private]
6\. Contact information for the alleged infringer:
Name: [private]
GitHub Account: steverodrigz.github.io /
https://github.com/steverodrigz/steverodrigz.github.io
7\. 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.
8\. 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.
[private]
WayLay Design, LLC.