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).

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**Are you the copyright holder or authorized to act on the copyright owner's behalf?**

Yes, I am authorized to act on the copyright owner's behalf.

**Are you submitting a revised DMCA notice after GitHub Trust & Safety requested you make changes to your original notice?**

No

**Does your claim involve content on GitHub or npm.js?**

GitHub

**Please describe the nature of your copyright ownership or authorization to act on the owner's behalf.**

LeftField Technologies is a [private] for Paxiv LLC helping lead their development efforts and I am specifically authorized by the owners of the company to act on their behalf regarding this issue.

**Please provide a detailed description of the original copyrighted work that has allegedly been infringed. If possible, include a URL to where it is posted online.**

This infringing repository at https://github.com/metalentco/paxiv is a clone of a version of the private [private] [private] which contains private and confidential code owned by Paxiv LLC. This user was a previous [private] for LeftField Technologies working on this codebase under [private] and non-disclosure terms. The code was initially uploaded and made public by this user, "metalentco", in late December due to a billing dispute. The previous disclosure was voluntarily resolved before action was taken on the previous takedown notice when I resolved the billing dispute, including a signed agreement for him to delete this code and an acknowledgment that he has no rights to this code. This user has no rights to the software in question. He has now disclosed the code publically again and is demanding a payment of $10,000 to take it down. He is further threatening to not only disclose the code but also contact customers, use the code to compete directly with us, and attempt to destroy both, per his written statements.

**What files should be taken down? Please provide URLs for each file, or if the entire repository, the repository’s URL.**

The entire repository at https://github.com/metalentco/paxiv need to be removed as it is an exact copy of code from the private [private].

**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.**

Yes

**What technological measures do you have in place and how do they effectively control access to your copyrighted material?**

The code is not publicly available and was only disclosed to this user under a non-disclosure, [private] agreement that also required the destruction of the user's copy of such code after the project. This is the only breach that has occurred. The agreement that resolved the late December disclosure further included an acknowledgment that he has zero rights to the code and that he had deleted it (which obviously he did not)

**How is the accused project designed to circumvent your technological protection measures?**

The code was previously only on the user's computer as part of their [private]. It was not removed at the end of the [private] as agreed. It was also not removed when the previous disclosure was resolved as this user had [private] agreed to and asserted in writing had already been deleted. The code has now been deliberately published publicly in violation of that agreement.

**<a href="https://docs.github.com/articles/dmca-takedown-policy#b-what-about-forks-or-whats-a-fork">Have you searched for any forks</a> of the allegedly infringing files or repositories? Each fork is a distinct repository and must be identified separately if you believe it is infringing and wish to have it taken down.**

I have searched and am not aware of any forks.

**Is the work licensed under an open source license?**

No

**What would be the best solution for the alleged infringement?**

Reported content must be removed

**Do you have the alleged infringer’s contact information? If so, please provide it.**

I have interacted with him electronically via email, [private], [private], and [private]. His [private] address is [private]. On [private] he uses [private]. The name he has used is [private], although I believe he also has a [private] name. His physical address was provided as [private], [private], [private], [private].

**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 have taken <a href="https://www.lumendatabase.org/topics/22">fair use</a> into consideration.**

**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.**

**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>.**

**So that we can get back to you, please provide either your telephone number or physical address.**

My number fi [private] for sms or voice.

**Please type your full legal name below to sign this request.**

[private]
