9.2 KiB
Dear Sir/Madam,
My name is [private] and I am an attorney-at-law with Han Kun Law Offices, a law firm in the People’s Republic of China. I am writing to you on behalf of my client 百度在线网络技术(北京)有限公司（Baidu Online Network Technology (Beijing) Co., Ltd hereinafter “Baidu”). A website that your company hosts, GitHub.com, is infringing on several copyrights owned by Baidu.
We identified that several documents/links are copied onto your servers without Baidu's authorization or permission. Said documents/links are directed to copies of Baidu’s product code or product development code, which have never been published. Baidu owns the exclusive copyrights to all of such documents and/or the contents directed by the links. Besides, the above-described code also contain trade secret of Baidu.
The specific unauthorized and infringing copies of the documents or links can be found in the list in Appendix I of this letter. Please immediately remove and/or disable access to all contents/links identified in Appendix I.
Please be advised that this letter also constitutes our official notification under Section 512(c) of the Digital Millennium Copyright Act (“DMCA”). We seek immediate removal of the aforementioned infringing materials from your servers. We also request that you immediately notify the infringer(s) of this notice and inform them of their duty to remove the infringing materials immediately, and notify them to cease any further posting of infringing materials to your server in the future.
Please also be advised that the law requires you, as a service provider, to remove or disable access to the infringing materials upon receiving this notice. Under the U.S. law a service provider, such as yourself, enjoys immunity from a copyright lawsuit provided that you act expeditiously to investigate and rectify the ongoing copyright infringement. The immunity is lost if service providers do not investigate and remove or disable the infringing material.
We provide this notice in good faith and with the reasonable belief that rights Baidu owns are being infringed. Under penalty of perjury I certify that the information contained in the notification is both true and accurate, and I have the authority to act on behalf of Baidu, the owner of the copyright(s) involved.
Should you wish to discuss this with me, please contact me directly. My email address is [private], and my phone number is [private]. Thank you.
Best,
[private]
Appendix I - List of URLs Containing Infringing Documents (Contains Highly Confidential Baidu Information)
No.
Infringing URL
Representative Keywords Identifying Baidu's Proprietary and Confidential Information
Type of Proprietary Information
1
a0e2b70c07/src/main/resources/robot.properties
[redacted]
Product development code owned by Baidu
2
37d1283952/cstorage/irdservices/conf/material-sync/db.py
[redacted]
Product development code owned by Baidu
3
b214f5e574/config/database.yml
[redacted]
Product development code owned by Baidu
4
da970d06ac/cluster/scmtools.conf
[redacted]
Product development code owned by Baidu
5
da970d06ac/cluster/.svn/text-base/builder.py.svn-base
[redacted]
Product development code owned by Baidu
6
da970d06ac/cluster/.svn/text-base/scmtools.conf.svn-base
[redacted]
Product development code owned by Baidu
7
[redacted]
Product development code owned by Baidu
8
0937eadc22/src/biz/admin/index/changePwd.js
[redacted]
Product development code owned by Baidu
9
0937eadc22/src/biz/admin/index/model/changePwd.js
[redacted]
Product development code owned by Baidu
10
88847d1b93/medmeeting/settings.py
[redacted]
Product development code owned by Baidu
11
[redacted]
Product development code owned by Baidu
12
602968d45d.svn-base
[redacted]
Product development code owned by Baidu
13
734275dacf/Ruby/watir/sit_manage.rb
[redacted]
Product development code owned by Baidu
14
adf0d6ea1d/conf/application.conf
[redacted]
Product development code owned by Baidu
15
[redacted]
Product development code owned by Baidu
16
[redacted]
Product development code owned by Baidu
17
af6d6693ec/task_controler/bin/pu sh_constants.py
[redacted]
Product development code owned by Baidu
18
10f693621f/wifishare-server/src/main/resources/db.properties
[redacted]
Product development code owned by Baidu
19
967e656d07/threadpool/common/mysqlLib.py
[redacted]
Product development code owned by Baidu
20
[redacted]
21
37d1283952/cstorage/irdservices/conf/material-sync/db.py.off
[redacted]
Product development code owned by Baidu
22
[redacted]
Product development code owned by Baidu
23
8e5c207433/src/main/resources/dao/db.properties
[redacted]
Product development code owned by Baidu
24
[redacted]
Product development code owned by Baidu
25
[redacted]
Product development code owned by Baidu
26
[redacted]
27
86acd86087/src/main/resources/conf/local/jdbc-mysql.properties
[redacted]
Product development code owned by Baidu
28
452b8b57e3/template/CloneTarget.json
[redacted]
Product development code owned by Baidu
29
[redacted]
Product development code owned by Baidu
30
734275dacf/Ruby/watir/fflogin.rb
[redacted]
Product development code owned by Baidu, also include trade secrets owned by Baidu
31
734275dacf/Ruby/watir/fireopentc.rb
[redacted]
Product development code owned by Baidu, also include trade secrets owned by Baidu
32
734275dacf/Ruby/watir/login.rb
[redacted]
Product development code owned by Baidu, also including trade secrets owned by Baidu
33
734275dacf/Ruby/watir/site_review.rb
[redacted]
Product development code owned by Baidu, also including trade secrets owned by Baidu
34
734275dacf/Ruby/watir/super_foot.rb
[redacted]
Product development code owned by Baidu, also including trade secrets owned by Baidu
35
734275dacf/Ruby/watir/super_site_count.rb
[redacted]
Product development code owned by Baidu, also including trade secrets owned by Baidu
36
734275dacf/Ruby/watir/super_stat.rb
[redacted]
Product development code owned by Baidu, also including trade secrets owned by Baidu
37
734275dacf/Ruby/watir/super_user_manage.rb
[redacted]
Product development code owned by Baidu, also including trade secrets owned by Baidu
38
[redacted]
[private]
Han Kun Law Offices
Suite 906, Office Tower C1
Oriental Plaza, 1 East Chang An Avenue
Beijing 100738, P. R. China
General: [redacted]
Direct: [redacted]
Mobile: [redacted]
Facsimile: [redacted]
Email: [redacted]
Website: www.hankunlaw.com