Dear GitHub staff,

My name is [private] and I am the [private] at what3words Ltd and as such am authorised to act on behalf of what3words Ltd.

Urgent DMCA takedown notice

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I submit this letter in support of an urgent takedown under Section 512(c) of the Digital Millennium Copyright Act (”DMCA”).

A public repository that is hosted by GitHub contains the unlicensed intellectual property of what3words Ltd ("what3words") and can be found at: https://github.com/cardinalhood/what3words

This repository serves no purpose other than to infringe on the intellectual property of what3words. The entire repository contains materials which are:

(i)	proprietary files, owned by what3words, which are at the very core of what3words' codebase; and
(ii)	a small number of incidental files the sole purpose of which is to support the public disclosure of the what3words intellectual property.

Specifically, the GitHub user cardinalhood has created an anonymous account in the last calendar week. He or she has then uploaded the following files:

https://github.com/cardinalhood/what3words/blob/gh-pages/data/w3w_en_words
https://github.com/cardinalhood/what3words/blob/gh-pages/data/w3w_master
https://github.com/cardinalhood/what3words/blob/gh-pages/data/w3w_ybuckets

Each of these files contains, in whole and unamended proprietary code, the copyright in which is owned by what3words.
The infringing files detailed above are in breach of our licensing terms and conditions and as such as are also unlicensed.

The GitHub user cardinalhood has also reproduced, in its entirety, our algorithmic intellectual property in the following file: https://github.com/cardinalhood/what3words/blob/gh-pages/w3w.js

Accordingly, in line with section 1 of your DMCA notice policy, I confirm that what3words has conducted an investigation and confirmed beyond doubt that (a) we own the copyright to the reproduced works; and (b) that the content on GitHub is unauthorized and infringing.

In line with section 3 of your DMCA notice policy, we allege that the entire contents of the repository infringes what3words' intellectual property rights. We therefore urgently request that you "skip to Step 6 and disable the entire repository expeditiously".

The consequences of this or another GitHub user accessing, downloading or otherwise further distributing this material would be extremely damaging to what3words. We request this is dealt with as a matter of the highest urgency.

Background

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Our attention to this was drawn by comments from "cardinal_hood" at the following web page https://blog.ldodds.com/2016/06/14/what-3-words-jog-on-mate/ which read as:

"FWIW, I have reverse-engineered the what3words address decoding algorithm. If anyone else with the luxury of flaunting patents and copyrights is curious, check out the demo at https://cardinalhood.github.io/what3words/. It’s written in JS, and runs in browsers and Node.js."

We have been unable to contact the GitHub user cardinalhood as no contact information has been made publicly available on their profile page at https://github.com/cardinalhood.

This communication is official notification under Section 512(c) of the Digital Millennium Copyright Act (”DMCA”), and I seek the immediate removal of the aforementioned repository from your servers. I request that you immediately notify the infringer of this notice and inform them of their duty to remove the unlicensed material immediately, and notify them to cease any further posting of unlicensed material to your server in the future.

I have a good faith belief that use of the materials described above in the infringing repository web pages are not authorized 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 authorized to act on behalf of the owner, of an exclusive right that is allegedly infringed.

I have read and understood GitHub's Guide to Filing a DMCA Notice, as detailed at https://help.github.com/articles/guide-to-submitting-a-dmca-takedown-notice/.

Should you wish to discuss this with me please contact me directly.

Yours sincerely

[private]  
[private]  
what3words Ltd
[private]  
[private]  
Tel: [private]  
Email: [private]  
