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While GitHub did not find sufficient information to determine a valid anti-circumvention claim, we determined that this takedown notice contains other valid copyright claim(s).
---
**Are you the copyright holder or authorized to act on the copyright owner's behalf?**
Yes, I am the copyright holder.
**Are you submitting a revised DMCA notice after GitHub Trust & Safety requested you make changes to your original notice?**
Yes
**Please provide the Zendesk ticket number of your previously submitted notice. Zendesk ticket numbers are 7 digit ID numbers located in the subject line or body of your confirmation email.**
3105264
**Does your claim involve content on GitHub or npm.js?**
GitHub
**Please describe the nature of your copyright ownership or authorization to act on the owner's behalf.**
I am a [private] working for a company called Coding Ketchup Limited, based in [private]. We develop applications that are web-based. One of our application sites has been entirely duplicated and posted up on GitHub in breach of our copyright.
**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.**
We have developed a web-based portal for the distribution of technical documentation; one of our clients is Triumph Motorcycles. The portal can be viewed at www.triumphtechnicalinformation.com. Coding Ketchup has developed and hosts the front-end and back-end, and Triumph Motorcycles posts service documentation and other technical materials on the portal for authorised users to view. The site is accessible though paid subscriptions.
The entire front-end of this system plus substantial volumes of Triumph's technical documents has been illegally copied and posted on a "shadow" site that resides on GitHub. Triumph Motorcycles will be contacting GitHub in due course to also issue a copyright infringement notice.
**What files should be taken down? Please provide URLs for each file, or if the entire repository, the repository’s URL.**
The files and website that should be taken down is accessible at: https://forgottentemple.github.io/home
The repository holding the content: https://github.com/forgottenTemple/forgottenTemple.github.io/tree/main
This GitHub static hosting serving the content: https://forgottentemple.github.io/home
Further accounts associated with the user who has pirated the content and hosted it:
o [private]
o [private]
**Do you claim to have any technological measures in place to control access to your copyrighted content? Please see our <a href="https://docs.github.com/articles/guide-to-submitting-a-dmca-takedown-notice#complaints-about-anti-circumvention-technology">Complaints about Anti-Circumvention Technology</a> if you are unsure.**
Yes
**What technological measures do you have in place and how do they effectively control access to your copyrighted material?**
All of the content of our official website (www.triumphtechnicalinformation.com) is protected by requiring users to register and log on using a username and password, during the creation of which the user must accept the terms and conditions for accessing the site, which include prohibitions from copying content from the site. Furthermore, the specific content that has been scraped and posted on the GitHub repository (vehicle service manuals) is only accessible to registered users who additionally pay a monthly subscription; the subscription buys the subscriber access to the manual for a single vehicle. In addition to scraping the content for the vehicle to which the GitHub user purchased a subscription, the user also exploited a vulnerability in our code to enable them to access the content of other vehicles, which they also scraped. The GitHub user scraped the service manuals for approximately 30 vehicle types, and these have all been made available unrestricted via the GitHub repository. The GitHub user then directed others to the GitHub repository via a number of posts on multiple [private] [private].
**How is the accused project designed to circumvent your technological protection measures?**
The GitHub user has copied our front end code, which is protected by copyright (with the appropriate requirement to accept our site's terms and conditions), rewritten elements of it to bypass the requirement for users to create and use usernames and passwords or buy subscriptions so that content is available unrestricted, and posted that amended frontend code on the GitHub repository named above.
Additionally, the GitHub user has scraped large volumes of copyrighted content from our site and redirected the links and hooks in the amended front end so that users access scraped copies of the illegally copied copyrighted material that is also on the GitHub user's GitHub repository.
**<a href="https://docs.github.com/articles/dmca-takedown-policy#b-what-about-forks-or-whats-a-fork">Have you searched for any forks</a> 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.**
Yes. There is a fork here: https://github.com/anndreib/triumph
**Is the work licensed under an open source license?**
No
**What would be the best solution for the alleged infringement?**
Reported content must be removed
**Do you have the alleged infringer’s contact information? If so, please provide it.**
All I know about the person infringing copyright is that they post on [private] under the username: [private]
**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 <a href="https://www.lumendatabase.org/topics/22">fair use</a> into consideration.**
**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 understand GitHub's <a href="https://docs.github.com/articles/guide-to-submitting-a-dmca-takedown-notice/">Guide to Submitting a DMCA Takedown Notice</a>.**
**So that we can get back to you, please provide either your telephone number or physical address.**
[private]
[private]
[private]
Coding Ketchup Ltd,
[private]
**Please type your full legal name below to sign this request.**
[private]