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To Whom It May Concern:
Our firm represents Avid Life Media, Inc. and its related entities (collectively, "ALM") with respect to intellectual property and other matters.
This letter is to notify GitHub, Inc. and all related entities thereto ("GitHub") that the content hosted at https://github.com/johnSD/AshleyMadison (IP Address: [PRIVATE]) infringes the intellectual property rights of ALM. Specifically, the infringing files contain exact identical copies of ALM's copyrighted works, namely, extensive reproductions of software source code.
In order to expedite the removal of the infringing content, we are submitting this Notice of Copyright Infringement and request that GitHub expeditiously remove or disable access to the material hosted at
https://github.com/johnSD/AshleyMadison (IP Address: [PRIVATE]),
as required under 17 U.S.C. § 512. I also hereby note I have read and understand GitHub's Guide to Filing a DMCA Notice.
Although our investigation of this infringement is ongoing, the following sets forth the statutorily required elements of our Notice of Copyright Infringement:
(1) [PRIVATE], through the law firm of DLA Piper LLP (US), is authorized to act on behalf of ALM as its legal counsel. ALM is the owner of an exclusive right that is claimed to be infringed. The signature of [PRIVATE] is set forth below.
(2) The copyrighted work that is being infringed is an extensive amount of proprietary software source code owned by ALM.
(3) The work located at https://github.com/johnSD/AshleyMadison (IP Address: [PRIVATE]) is infringing on ALM's exclusive copyright rights and should be removed or disabled.
(4) Contact information:
[PRIVATE]
(5) ALM and [PRIVATE] have 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.
(6) The information in this Notice of Copyright Infringement is accurate, and under penalty of perjury, [PRIVATE] is authorized to act on behalf of ALM, the owner of an exclusive right that is being infringed.
Thank you for your prompt attention to this matter. If you require any clarification of the above information in order to expeditiously remove or disable access to the infringing content, please contact me right away.
Best regards,
[PRIVATE]
DLA Piper LLP (US)