Before disabling any content in relation to this takedown notice, GitHub
- contacted the owners of some or all of the affected repositories to give them an opportunity to [make changes](https://docs.github.com/en/github/site-policy/dmca-takedown-policy#a-how-does-this-actually-work).
- provided information on how to [submit a DMCA Counter Notice](https://docs.github.com/en/articles/guide-to-submitting-a-dmca-counter-notice).

To learn about when and why GitHub may process some notices this way, please visit our [README](https://github.com/github/dmca/blob/master/README.md#anatomy-of-a-takedown-notice).

---

**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 write on behalf of my client, Ad Hoc Research Associates, LLC (“Ad Hoc”), to request a takedown of confidential and proprietary information posted by your user, [private]. Attached please find a binding Preliminary Injunction signed by [private] of the American Arbitration Association. For background, [private] is a former employee of Ad Hoc. After his termination, it was discovered that [private] posted significant amounts of Ad Hoc’s confidential and proprietary code/information/data to GitHub. Specifically, all of the information contained in his folder titled “PythonAutomation/IGTS/TopologyScriptProcessing/builderScenario/” is the exclusive, confidential property of Ad Hoc. This can be found here: https://github.com/EvanGertis/PythonAutomation/tree/main/IGTS/TopologyScriptProcessing/builderScenario. Not only did[private] unauthorized publication of Ad Hoc’s confidential information violate the confidentiality and trade secret agreements he signed with Ad Hoc, but his actions are also in violation of The Maryland Uniform Trade Secrets Act.

Although [private] ordered [private] to take down this information on January 3, 2024, [private] has refused to comply and has not even acknowledged [private] binding Order. I have attempted several times to reach out to [private] to ask him to comply with [private] Order; however, [private] has refused. Accordingly, Ad Hoc is forced to reach out to GitHub directly in order to put GitHub on notice that [private] is using your platform to leak Ad Hoc’s confidential information, in direct violation of his agreements, state law, and [private] Preliminary Injunction. I trust that GitHub will act swiftly to take down all of the information found at the following link: https://github.com/EvanGertis/PythonAutomation/tree/main/IGTS/TopologyScriptProcessing/builderScenario.

Please let me know if there is any additional information that you need in order to facilitate this takedown. I can be reached by email or phone any time. Please keep in mind, however, that this leaked information is highly sensitive and Ad Hoc continues to suffer incalculable harm each day if its proprietary code remains publicly available for all competitors to see and use for their own benefit. It is for precisely this reason that the American Arbitration Association held that Ad Hoc will suffer irreparable harm if the Preliminary Injunction were not granted.

Once again, this is a highly urgent matter. Please contact me as soon as possible in order to resolve [private] violations. I look forward to hearing from you.

**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.**

I write on behalf of my client, Ad Hoc Research Associates, LLC (“Ad Hoc”), to request a takedown of confidential and proprietary information posted by your user, [private]. Attached please find a binding Preliminary Injunction signed by [private] of the American Arbitration Association. For background, [private] is a former employee of Ad Hoc. After his termination, it was discovered that [private] posted significant amounts of Ad Hoc’s confidential and proprietary code/information/data to GitHub. Specifically, all of the information contained in his folder titled “PythonAutomation/IGTS/TopologyScriptProcessing/builderScenario/” is the exclusive, confidential property of Ad Hoc. This can be found here: https://github.com/EvanGertis/PythonAutomation/tree/main/IGTS/TopologyScriptProcessing/builderScenario. Not only did [private] unauthorized publication of Ad Hoc’s confidential information violate the confidentiality and trade secret agreements he signed with Ad Hoc, but his actions are also in violation of The Maryland Uniform Trade Secrets Act.

Although [private] ordered [private] to take down this information on January 3, 2024, [private] has refused to comply and has not even acknowledged [private] binding Order. I have attempted several times to reach out to [private] to ask him to comply with [private] Order; however, [private] has refused. Accordingly, Ad Hoc is forced to reach out to GitHub directly in order to put GitHub on notice that [private] is using your platform to leak Ad Hoc’s confidential information, in direct violation of his agreements, state law, and [private] Preliminary Injunction. I trust that GitHub will act swiftly to take down all of the information found at the following link: https://github.com/EvanGertis/PythonAutomation/tree/main/IGTS/TopologyScriptProcessing/builderScenario.

Please let me know if there is any additional information that you need in order to facilitate this takedown. I can be reached by email or phone any time. Please keep in mind, however, that this leaked information is highly sensitive and Ad Hoc continues to suffer incalculable harm each day if its proprietary code remains publicly available for all competitors to see and use for their own benefit. It is for precisely this reason that the American Arbitration Association held that Ad Hoc will suffer irreparable harm if the Preliminary Injunction were not granted.

Once again, this is a highly urgent matter. Please contact me as soon as possible in order to resolve [private] violations. I look forward to hearing from you.

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

I write on behalf of my client, Ad Hoc Research Associates, LLC (“Ad Hoc”), to request a takedown of confidential and proprietary information posted by your user, [private]. Attached please find a binding Preliminary Injunction signed by [private] of the American Arbitration Association. For background, [private] is a former employee of Ad Hoc. After his termination, it was discovered that [private] posted significant amounts of Ad Hoc’s confidential and proprietary code/information/data to GitHub. Specifically, all of the information contained in his folder titled “PythonAutomation/IGTS/TopologyScriptProcessing/builderScenario/” is the exclusive, confidential property of Ad Hoc. This can be found here: https://github.com/EvanGertis/PythonAutomation/tree/main/IGTS/TopologyScriptProcessing/builderScenario. Not only did [private] unauthorized publication of Ad Hoc’s confidential information violate the confidentiality and trade secret agreements he signed with Ad Hoc, but his actions are also in violation of The Maryland Uniform Trade Secrets Act.

Although [private] ordered [private]s to take down this information on January 3, 2024, [private] has refused to comply and has not even acknowledged [private] binding Order. I have attempted several times to reach out to [private] to ask him to comply with [private] Order; however, [private] has refused. Accordingly, Ad Hoc is forced to reach out to GitHub directly in order to put GitHub on notice that [private] is using your platform to leak Ad Hoc’s confidential information, in direct violation of his agreements, state law, and [private] Preliminary Injunction. I trust that GitHub will act swiftly to take down all of the information found at the following link: https://github.com/EvanGertis/PythonAutomation/tree/main/IGTS/TopologyScriptProcessing/builderScenario.

Please let me know if there is any additional information that you need in order to facilitate this takedown. I can be reached by email or phone any time. Please keep in mind, however, that this leaked information is highly sensitive and Ad Hoc continues to suffer incalculable harm each day if its proprietary code remains publicly available for all competitors to see and use for their own benefit. It is for precisely this reason that the American Arbitration Association held that Ad Hoc will suffer irreparable harm if the Preliminary Injunction were not granted.

Once again, this is a highly urgent matter. Please contact me as soon as possible in order to resolve [private] violations. I look forward to hearing from you.

**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.**

No

**<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.**

[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.**

I can be reached at [private]. I have emailed the Preliminary Injunction to the following email addresses:

1. [private]  
2. [private]  
3. [private]  
4. [private]  
5. [private]  

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

[private]  
