**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, this is a new notice.

**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.**
 
Between 2015 and 2022, ZOLL Medical Corporation (“ZOLL”) provided technology to and paid
[private] and [private] to develop a heart defibrillation product, which included monitoring components. The
relevant agreements stated that all intellectual property, including copyright and source code,
created during the course of the development belonged to ZOLL. A relevant quote from the
development agreement states:

“Company [defined as ZOLL] shall own all right, title and interest in and to all
Intellectual Property created, conceived or made by or on behalf of Company or
Contractor [private] (including through any subcontractors and
whether solely or jointly with Company) in the course of performing activities
under this Agreement, any SOWs or the Supply Agreement or with reference to
Company’s Confidential Information, including all intellectual property rights
therein (collectively, “Development Inventions”).”

The materials uploaded on GitHub at https://github.com/Yangyuanxin/Appciton consist of
intellectual property that was developed pursuant to the above agreement and therefore solely
owned by ZOLL.
 
**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.**
 
One commercial product created from the aforementioned development agreement is the ZOLL
M2 monitor/defibrillator. Additional information about this product can be found at
https://info.zoll.com/en/zoll-m2-home.

I have reviewed the materials uploaded on GitHub at https://github.com/Yangyuanxin/Appciton,
and the entirety of the materials appears to be related to and have been created during the time
period of the aforementioned development agreement. For example, the GitHub page contains
approximately 30 unique Code Markers that are identical to the Code Markers for the ZOLL M2 product.

Below is a screenshot of the Code Markers found on GitHub:

[private]  
[private]

The above Code Markers on GitHub are identical to the Code Markers for the ZOLL M2:

[private]  
[private]

We have reason to believe that GitHub user [private] was a [private] who worked on
the ZOLL M2 project and uploaded the materials on GitHub without permission from ZOLL.
 
**What files should be taken down? Please provide URLs for each file, or if the entire
repository, the repository’s URL.**
 
The infringing content made by user “Yangyuanxin” can be found here:
https://github.com/Yangyuanxin/Appciton. All materials at this URL should be removed.

The infringing user can be found here: https://github.com/Yangyuanxin
 
**Do you claim to have any technological measures in place to control access to your
copyrighted content? Please see our Complaints about Anti-Circumvention Technology if
you are unsure.**
 
There is not a current claim that anti-circumvention technology was used to access the
copyrighted content. The copyright content was and is protected by reasonable technology
measures from unlawful disclosure or access.
 
**Have you searched for any forks 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.**
 
We have performed a reasonable search for forks, but it may be possible that other infringing
repositories are discovered in the future.
 
**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.**
 
No.
 
**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 fair use 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 Guide to Submitting a DMCA Takedown Notice.**
 
**So that we can get back to you, please provide either your telephone number or physical
address.**
 
Email : [private]  
Phone: [private]  
 
**Please type your full legal name below to sign this request.**
 
[private]  
