**Are you the copyright owner or authorized to act on the copyright
owner's behalf?**  
I am [private] at Zalando SE. The code in the the repositories at question are from the applications Fleek and Movmnt. Fleek is a product of the Mobile Fashion Discovery GmbH and Movmnt is a product of the Fashion Connectivity Technologies GmbH. Both are subsidiaries of Zalando SE. Zalando SE owns the copyright to the content in the repositories in question. I act on Zalando SE´s behalf.

**What work was allegedly infringed? If possible, please provide a URL:**  
The repositories contain proprietary reporting tools, framworks and testing tools Zalando uses to develop its products. Seleniumreports is a report generator with data private to Zalando. Galen-JS-Framework is a cross-browser testing suite. SeleniumSkeletonProject and SeleniumStartetKitJava are browser testing suites with proprietary data/trade secrets. JS-Webdriver-IO contains javascript rests. js-skeleton is a Javascript framework with proprietary data/trade secrets. Sauce Labs is a proprietary implementation with trade secrets.
Further the repositories contain key stores and api keys. A malicious user could extract key material and clone malicious versions of our software and thus harm users / commit fraud.
The publisher of this code has left the company and was neither authorised to take this code with him nor was he at any time during his employment and after allowed to publish this code.
Note that we filed a complaint for other proprietary data released by the same user (Movmnt, Fleek). This additional data was found during our investigation.

**What files should be taken down? Please provide URLs for each file, or**  
if the entire repository, the repository's URL:  
https://github.com/gavtyagi/seleniumreports - Report generator with data private to Zalando  
https://github.com/gavtyagi/Galen-JS-Framework - Cross-browser testing with proprietary data/trade secrets  
https://github.com/gavtyagi/SeleniumSkeletonProject - Browser testing with proprietary data/trade secrets  
https://github.com/gavtyagi/JS-Webdriver-IO - Javascript rests with proprietary data/trade secrets  
https://github.com/gavtyagi/SeleniumStarterKitJava - Browser testing with proprietary data/trade secrets  
https://github.com/gavtyagi/js-skeleton - Javascript framework with proprietary data/trade secrets  
https://github.com/gavtyagi/Saucelabs - Sauce Labs proprietary implementation with trade secrets  
All repositories must be taken down immediately. Please preserve any evidence as we are currently discussing to take further legal actions.  

**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.**  
The investigation is ongoing.  

**Is the work licensed under an open source license? If so, which open
source license? Are the allegedly infringing files being used under
the open source license, or are they in violation of the license?**  
The work is proprietary and not for release.  

**What would be the best solution for the alleged infringement? Are there specific changes the other person can make other than removal?**  
The code must be removed and evidence preserved. Also we need to know who downloaded the code. This is necessary to identify malicious activities using our source code and the involved key stores. We are working on setting up a legal process that enables us to do so. Please make sure to preserve any evidence and do not alter the repositories. We currently discuss taking legal actions and the repositories content could serve as evidence.

**Do you have the alleged infringer's contact information? If so, please
provide it:**  
The name of the former employee is [private]. His personal mail is listed in our records as [private] We do not have more current records about him to date. (investigation is ongoing)

**Type (or copy and paste) the following statement: "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 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."

**Type (or copy and paste) the following statement: "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 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."

**Please confirm that you have you have read our Guide to Submitting a
DMCA Takedown Notice:**  
https://help.github.com/articles/guide-to-submitting-a-dmca-takedown-notice/
"I have read and understand GitHub's Guide to Filing a DMCA Notice."

**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]  
