Merge pull request #984 from github/update-1472759325

2016/2016-08-31-Facet.md

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+To Whom It May Concern:
+
+I have read and understand GitHub's Guide to Filing a DMCA Notice.
+
+I am writing to request that Github take down the project at the following
+link: https://github.com/implydata/pivot.
+
+This project infringes the copyright of Metamarkets Group, Inc. in the
+proprietary, interactive visualization software called Facet, described at
+https://metamarkets.com/2015/introducing-facet/. Facet was developed
+internally at Metamarkets and Metamarkets holds the copyright thereto.
+Facet is only available to Metamarkets customers who purchase a license to
+use Facet.
+
+Pivot purportedly is owned by Imply Data. The [private] of Imply Data is [private]. Mr. [private] is a former employee of Metamarkets who had
+access to Facet, including its highly confidential and proprietary source
+code, by virtue of his employment with Metamarkets. Mr. [private] left
+Metamarkets’ employment in May 2015. At an unknown time in 2015, Mr.
+[private] joined Imply Data. Imply Data then published Pivot on Github
+under an Apache 2.0 open source license. Pivot’s first commit on Github
+includes text that literally references “Facet,” which Imply Data copied
+and thereby infringed, as set forth below:
+
+Pivot also copies functions, function names, arguments, variables, and
+lines of code from Facet, including lines 20-353 of formatter.ts in its
+first public commit on July 23, 2015, available here:
+
+https://github.com/implydata/pivot/commit/d9f525488d51a9e3d54962bbbd7f328c3191e890
+
+This code contains at least eight functions which are identical in name,
+and contain identical or nearly identical lines of code, to Metamarkets’
+private, proprietary dashboard repository which can be found at:
+
+[private]
+
+These eight functions and their corresponding code are involved in the
+copyrighted visual display of numbers in Metamarkets’ proprietary Facet
+software:
+
+humanizeNumberWithScale
+
+humanizeNumber
+
+add_separators_to_number
+
+make_humanizer
+
+get_small_large_template
+
+after_decimal_point_at_precision
+
+get_after_decimal
+
+humanizerFromData
+
+humanizeNumbers
+
+Pivot slavishly copies the proprietary Facet code in each of these
+corresponding functions. Set forth the below are screenshots showing
+examples of the infringing Pivot code, followed by the commit date and code
+line numbers of the corresponding proprietary Facet code Pivot has copied
+(which is contained in a private repository located at
+[private]).
+The Facet code is not pasted below in screenshot format because Github
+publishes all DMCA notices online, and such publication would only do
+further harm to Metamarkets’ proprietary rights in Facet:
+
+● humanizeNumberWithScale
+
+Corresponding lines of infringed Facet code: lines 79-93,  
+[private]
+
+● humanizeNumber
+
+Corresponding lines of infringed Facet code: lines 99-101,  
+[private]
+
+● add_separators_to_number
+
+Corresponding lines of infringed Facet code: lines 127-143,  
+[private]
+
+· make_humanizer
+
+Corresponding lines of infringed Facet code: lines 146-269,  
+[private]
+
+● get_small_large_template
+
+Corresponding lines of infringed Facet code: lines 344-366,  
+[private]
+
+● after_decimal_point_at_precision, get_after_decimal
+
+Corresponding lines of infringed Facet code: lines 370-400,   
+[private]
+
+● humanizerFromData, humanizeNumbers
+
+Corresponding lines of infringed Facet code: lines 402-429,  
+[private]
+
+In addition to this literal code copying, Pivot also extensively copies the
+nonliteral elements of Facet’s structure, sequence and organization, as can
+be seen in the following exemplary screenshots.
+
+Stacked Time Series View: Metamarkets’ Facet on left, Imply’s Pivot on
+right.
+
+Nested Table View: Imply’s Pivot on the left, Metamarkets’ Facet on right.
+
+Pivot is causing immense harm to Metamarkets. Facet is Metamarkets’
+flagship proprietary SaaS product. Imply Data has impermissibly copied its
+structure, sequence and organization in the form of Pivot, which Imply Data
+then improperly open sourced on Github. The entire Pivot repository must
+be taken down immediately in order to prevent further infringement of
+Facet, and further harm to Metamarkets.
+
+I have a good faith belief that use of the materials described above on the
+infringing web pages is not authorized by Metamarkets Group, Inc., or its
+agent, or the law.
+
+I swear, under penalty of perjury, that the information in this
+notification is accurate and that I am authorized to act on behalf of the
+owner, of an exclusive right that is allegedly infringed.
+
+Sincerely,
+
+[private]
+
+
+<http://www.metamarkets.com/>  
+[private]
+[private] | METAMARKETS <http://www.metamarkets.com/>  
+m [private] | t [private]  
+[private]