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.**

I am the [private] and [private] of WhereBy.Us Enterprises, Inc, a Delaware C Corporation with a Github account under the name [NAME]. This account contains private, proprietary repositories related to the operation of Letterhead, a software-as-a-service product wholly owned and operated by WhereBy.Us Enterprises, Inc.

**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.**

The account belonging to user "richardmoore725" https://github.com/richardmoore725/Letterhead_API has posted a complete, older version of our "platform service" API repository on Github, publicly, without our permission and in direct violation of our copyright and ownership over these private repositories. Our version of the repository, as of the date this user illegally downloaded it to his personal device, is here: [private]

The unauthorized posting by this user follows a number of threats issued to our employees by this user or persons associated with this user, threatening to post this repository, and acknowledging its proprietary nature, if financial compensation was not received. This person was temporarily hired via [private] to perform work on this repository, before being terminated from [private] for fraudulent and unauthorized activity (as relayed to us by [private]).

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

The entire repository belonging to https://github.com/richardmoore725/Letterhead_API should be taken down.

**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?**

Access to our repositories is tightly controlled to provide access only to authorized employees and contractors. A single-project contractor may receive access to a single repository or branch for their work, which is removed at conclusion of their contract or termination of their relationship to us. Further, our contracting agreements provide that all local copies of any code must be removed upon termination or conclusion of a project.

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

The repository reposts in its entirety a proprietary project and copyrighted code from Letterhead. Further, this repository posts publicly API routes which could have been used by malicious actors to gain unauthorized access to our systems. Our API has been substantially updated since this version of the repository, and thus security risks have already been cleared by our team. Nonetheless, the repository in question clearly violates copyright law and Github's terms of service -- it even has the name of our product, Letterhead, in its name.

**<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.**

Yes.

**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. The owner, or someone associated with the owner, of the infringing account has contacted our team members via [private] direct message, but their account has already been deleted, presumably due to its fraudulent or malicious nature, and thus we cannot retrieve these messages.

**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.**

[private]

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

[private]
