**Are you the copyright owner or authorized to act on the copyright owner's behalf?**

Yes. ZenHub is a wholly-owned business of Launch Labs, Inc., dba Axiom Zen.

**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 original location is https://www.zenhub.com/ 

ZenHub is also available through the GitHub Marketplace here https://github.com/marketplace/zenhub

The following document details the copyright work that has been infringed by Issue.sh in detail:

This document details Issue.sh’s infringement of  ZenHub’s copyrights. 
Issue.sh was recently placed for sale via the GitHub Marketplace, and contains numerous instances of copyright infringement from both the ZenHub website and the ZenHub marketplace listing. 
ZenHub.com on the left, Issue.sh on the right throughout:
Website and marketplace copy
Issue.SH is using ZenHub copy with minor edits to change the company name. The first two examples below show the Issue.SH Marketplace listing hosted on GitHub.com. The third is the Issue.sh website.  Again, the ZenHub copy is on the left, and Issue.sh’s is on the right.  Please note the nearly exact copying by Issue.sh of our titles, language, and look-and-feel. 

[screenshot redacted]

The examples below show how the Issue.sh website is replicated from the ZenHub.com website. With particular note to the home page style, title and layout.  Again, the ZenHub copy is on the left, and Issue.sh’s is on the right.  

[screenshot redacted]

Product ‘tag line’ (adds predictability and visibility to software development). This is taken from ZenHub.com and added to the Issue.sh marketplace listing.  Again, the ZenHub copy is on the left, and Issue.sh’s is on the right.  Please note the nearly exact copying of our language. 

[screenshot redacted]

Pricing page language, layout and style

[screenshot redacted]

Both paid plans have the same name on the GitHub marketplace, adding to user confusion between the two products.  Issue.sh has infringed upon our look-and-feel, in a specific attempt to create customer confusion:

[screenshot redacted]

Privacy policy / terms of service
The GitHub marketplace listing for Issue.sh contains direct links to the Issue.sh privacy policy and terms of service. Both of which have been lifted by Issue.sh from ZenHub.com.  Again, the ZenHub copy is on the left, and Issue.sh’s is on the right.  Please note the nearly exact copying by Issue.sh of our titles, language, and look-and-feel. 

[screenshot redacted]

For illustration purposes, I have included snapshot examples of the texts. As they are both long items of text, I have not included full screenshots. But by visiting the following links, it is possible to see:
https://issue.sh/privacy is a full copy and paste of https://www.zenhub.com/privacy-policy
And so is https://issue.sh/terms of https://www.zenhub.com/terms-of-service 

[screenshot redacted]

Chrome store - same title and copy

[screenshot redacted]

Product
As part of potential user confusion. I would also like to highlight the similarities between the two products. 
The use of the navigation terms ‘boards’ and ‘reports’ in the same place 

[screenshot redacted]

A very familiar looking burndown chart:

[screenshot redacted]

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

The GitHub Marketplace product ‘Issue.sh’ has been created as a replica of ZenHub including the use of ZenHubs website copy to market the product.

https://github.com/marketplace/issue-sh

**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.**

N/A as this is related to the Marketplace rather than a repo

**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?**

No

**What would be the best solution for the alleged infringement? Are there specific changes the other person can make other than removal?**

Removal of Issue.sh from the GitHub Marketplace is required. There are no targeted changes to Issue.sh that would suffice to resolve the infringement.

As additional information here, we did start with a request to the GitHub [Private] team and were asked to operate through the DCMA channel to make sure this was all documented formally.

Issue.sh’s infringement of our copyright has caused the following immediate and continuing harms:

1) potential customers are confused about whether Issue.sh is the same product as ZenHub;

2) our own customers are beginning to question whether we ourselves are a copy of issue.sh.

**Do you have the alleged infringer's contact information? If so, please provide it:**

No. However the GitHub [Private] team will have the correct contact information. We have been working with [Private] ([Private]), who will be able to provide these.

**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/**

Confirmed

**So that we can get back to you, please provide either your telephone number or physical address:**

[Private]
[Private]

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

[Private]
