Dear Abuse Department:

We represent Nexon America Inc. ("Nexon"), a provider of online games, and submit this claim on its behalf. We hereby give you notice of infringing and unlawful content contained on a website you are hosting, located at https://github.com/aura-project/aura (the "Website"), and request that you immediately remove that content. Specific examples of the infringing content can be found at that domain, screenshots of which are enclosed. According to the Website, the infringing party can be contacted through the forums at http://aura-project.org/forum/.

Nexon is the exclusive licensee of all publishing rights to the MABINOGI® game in North America (the "Game"). The Game is protected under U.S. Copyright law as well as the laws of other countries. This copyright covers the software code (in source and object format), story elements, characters, audiovisual elements, and other aspects of the Game.

The owner of the Website is using the site to create and distribute software to facilitate private servers for the Game. These private servers are designed to alter a player's experience of the Game, circumventing or removing important components of gameplay. The servers run an unauthorized use of the copyrighted code for the game and are designed to circumvent Nexon's security measures that control access to this copyrighted code. Further, these servers are in direct violation of the End User License Agreement of the game. These actions constitute direct and indirect infringement in violation of the Copyright Act, 17 U.S.C. § 501, et seq., and unlawful circumvention and trafficking in circumvention devices in violation of the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 1201, et seq.

The owner of the Website is integrating protected intellectually property from the Game, specifically characters, scenes, and specific quest lines, into the server architecture without authorization. This use is not allowed under the Game's terms of use or under copyright law. These actions constitute direct and indirect infringement in violation of the Copyright Act, 17 U.S.C. § 501, et seq., and the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 1201, et seq.

Nexon is also the exclusive U.S. licensee of the MABINOGI trademark, which is the subject of U.S. Trademark Registration Nos. 4,164,983 and 4,150,681. The Website makes unauthorized use of the registered MABINOGI trademark, in violation of the Lanham Act, 15 U.S.C. § 1051, et seq.

Neither Nexon nor its agents authorize this unlawful and infringing conduct. Nexon has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law. Accordingly, we request that you immediately take the site down unless and until the infringing and unlawful content is removed.

We hereby certify under penalty of perjury that the statements in this Notice are accurate and this firm is authorized to act on behalf of Nexon. Please contact me if you have any questions.

Regards,  
[private]
