**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 acting on behalf of our clients, Moonshine Technologies Private Limited and Baazi Games Private Limited, both being Indian companies, which are recognized globally as Baazi Group and through their gaming platforms, PokerBaazi, RummyBaazi or Card Baazi and BalleBaazi. I am engaged by the said entities for protection of their intellectual property rights in India and globally.

Baazi Games, as is popularly known worldwide, is India’s leading online gaming service provider. Established in 2014, Baazi Games, created a niche in gaming and its unique offerings and extensive marketing, made Baazi Games, the most preferred choice for online games in India. It is worth mentioning here that in a short span of six years, Baazi Games has over Two Million active players. To further its growth and outreach, in 2017, Baazi Games had introduced new gaming verticals, RummyBaazi for online card games and BalleBaazi for fantasy cricket league, both of which were launched in 2018. Under the umbrella of Baazi house of marks, Baazi games has extensively promoted, marketed and advertised its games and related gaming services. In fact, leading celebrities and sports persons such as Indian cricketer, [private], acclaimed boxer, [private] and Bollywood actor, [private]. Quite evidently, Baazi Games has become a household name and is synonymous to online gaming in India.

Our client has created a distinctive image and an impeccable reputation for its gaming platforms, which are available to global audience and userbase under the BAAZI brandings. The games and technology developed and offered by our Clients, provide for a unique user experience and hence our Client’s said games and technology are highly valued in the gaming business. Our Clients have invested heavily in acquiring seasoned professionals and expert skill sets, to develop the said games and technology. Being wary of its immense value, our Clients expends significantly on securing and protecting their intangible assets and rights. In accordance with the Indian Copyright Act, 1957 and by virtue of the Berne Convention for protection of literary and artistic work, the original codes and other subject matters of these games and technology are exclusively owned by our Clients and are protected globally, including in the USA.

**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.**

RummyBaazi / CardBaazi is one of our Clients' leading gaming platform. it was created in and around September 2020. For ease of development and working, the Codes were hosted through private account created on [private]. Details about our Clients' popular gaming platform is available at https://www.cardbaazi.com/

We have compared the codes which are uploaded on your platform, with ours and note that the same are identical. The malicious intentions of the infringer is writ large from the fact that the folder is named as “PokerBaazi”, which is our Clients’ registered trademark. Therefore, besides blatantly copying our Clients’ proprietary codes and uploading it on your platform for misuse by third parties, the infringer has also used our Clients’ trademarks, to wrongly suggest that the codes are in fact, uploaded / published by our Clients.

We believe that the infringing copy is uploaded by one [private] having email ID, [private]. We have checked our internal records but could not locate any details of this person. It is verily believed that [private] has illegally gained access to our [private] account, which is also in violation of the Indian IT Laws and attracts severe criminal penalties.

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

https://github.com/Goulamander/pokerbaazi.

**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.**

NA

**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]

**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]

[private]  
DSK Legal, [private], [private],  
[private], [private], [private]

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

[private]
