Dear Sirs,

TAKE DOWN NOTICE - REQUIRES IMMEDIATE ACTION
http://ukworkfare.github.io/esg-holdings/

We refer to our previous telephone conversations with your customer service team and write in order to confirm the basis upon which GitHub Inc. is legally required to immediately remove the website http://ukworkfare.github.io/esg-holdings/ from its service.

As requested, we set out below the individual legal grounds in support of this request.

Copyright

1.	The http://ukworkfare.github.io/esg-holdings/ site is a straight copy taken from the source-code and design of our own site (see URL in point 2 below).

2.	The text from our site https://learning-employment.com/ has been copied and reproduced on the Infringer's site. In some cases the Infringer has made minor alterations to titles or minor additions to our original work. These minor alterations are defamatory and, in any event, are insufficient to prevent the body of the work being a breach of copyright.

3.	Our site expressly puts our copyright notice at the foot of every page as follows: "All content (c) Interserve Learning & Employment".

The copying of our original work can be very clearly seen by comparing the http://ukworkfare.github.io/esg-holdings/ URL pages against those where they have been copied from our site at https://learning-employment.com/.

A non-exhaustive list of examples of infringement marked "Infringer's URLs" is set out below, with the relevant page from our site immediately followed by the infringing URL pages from the Infringer's site. You will see that, apart from the occasional subtle manipulation of the copy, substantially all the data, text, layout and photography on virtually every page is a copy of our original work and copyright.

Our Interserve logo is the design and copyright of Interserve Plc. It is also a registered trademark. Interserve Learning and Employment is a trading business of ESG Holdings Limited. ESG Holdings Limited is a subsidiary of Interserve Plc. The Interserve logo has been used by the Infringer without the permission of Interserve Plc.

Furthermore, there can be no doubt whatsoever that the Infringer has failed to obtain permission to copy the logos of our governmental body partners, including: the Welsh Assembly Government; the Office for Standards in Education, Children's Services and Skills (Ofsted); the Skills and Funding Agency; and the Department for Business, Innovation and Skills. If the infringing website is not removed immediately we will have no option but to tell these bodies that their intellectual property rights are being infringed to enable them to take their own enforcement action.

Infringer's URLs

Please follow the below links for a comparison between Interserve Learning & Employment's website and the Infringer's site:

"About" page
Our page: https://learning-employment.com/about/
Infringer's page: http://ukworkfare.github.io/esg-holdings/about/

"Apprenticeships" page:
Our page: https://learning-employment.com/apprenticeships/
Infringer's page: http://ukworkfare.github.io/esg-holdings/slavery/

"Traineeships" page:
Our page: https://learning-employment.com/traineeships/
Infringer's page: http://ukworkfare.github.io/esg-holdings/traineeships/

"Employers" page:
Our page: https://learning-employment.com/employers/
Infringer's page: http://ukworkfare.github.io/esg-holdings/employers/

"Jobseekers" page:
Our page: https://learning-employment.com/jobseekers/
Infringer's page: http://ukworkfare.github.io/esg-holdings/slaveseekers/

"Partners" page:
Our page: https://learning-employment.com/partners/
Infringer's page: http://ukworkfare.github.io/esg-holdings/slave-partnerships/

To summarise, as can be clearly seen from the examples above, in an unambiguous breach of our intellectual property rights, every page of the Infringer's site is a copy made from the source-code of our site's pages, with our text and images having been copied.

Accordingly, we require the entire http://ukworkfare.github.io/esg-holdings/ site to be taken down immediately.

For the avoidance of doubt, we continue to reserve our position with regard to the brazenly defamatory nature of the content contained within the Infringer's site.

Declarations

I have read and understand GitHub's "Guide to Filing a DCMA Notice".

I have a good faith belief that use of the copyrighted materials described above on the infringing web pages is not authorised by the copyright owner, or its agent, or the law.

I swear, under penalty of perjury, that the information in this notification is accurate and that I am the copyright owner, or am authorised to act on behalf of the owner, of an exclusive right that is allegedly infringed

We look forward to your early confirmation of your action.

Yours faithfully,

[private]  
[private] - Interserve Learning and Employment
