dmca/2021/03/2021-03-12-rigrepo.md

Re: Notice of Copyright Infringement and DMCA Takedown Request

Dear GitHub DMCA Agent:

We are counsel to Walt Disney Pictures d/b/a Walt Disney Animation Studios and Disney Enterprises, Inc. (collectively, “Disney”) in connection with the protection of certain intellectual property, including Disney’s copyrights in its software source code. I am duly authorized to act on Disney’s behalf on the matter described in this letter. It has come to our attention that third parties have been violating Disney’s copyrights in its rigRepo source code, and have posted infringing code on the GitHub website. We hereby provide notice of copyright infringements pursuant to the terms of the Digital Millennium Copyright Act (“DMCA”) and GitHub’s DMCA Takedown Policy.

Identification of Copyrighted Work:
The infringed work, Disney’s rigRepo system, is a collection of rigging tools and rig archetypes used for 3D animation. Disney has developed the codebase, toolset, and rigging framework for rigRepo internally. Disney is the copyright holder for each version of rigRepo, which Disney has not published or disclosed to the public. Because rigRepo is proprietary to Disney and not posted online, a URL is not available. Disney has not licensed any portion of rigRepo under an open-source license. Disney developed rigRepo as closed-source software, Disney has never opened the source code to rigRepo, and Disney has maintained rigRepo as a proprietary product accessible to only Disney employees.

Identification of Infringing Material:
The material posted at the following URLs includes direct or literal copies and/or derivative works of Disney’s confidential and proprietary rigRepo source code. These repositories (including all branches thereof) contain numerous files that appear to be direct, literal copies and/or derivative works of files in Disney’s proprietary rigRepo system. The material infringing Disney’s rigRepo system is located in at least the following repositories:

1. [invalid]
2. [invalid]

Based on our investigation to date, the following forks (including all branches thereof) also contain material infringing Disney’s copyrights in rigRepo:

1. https://github.com/deepakxyz/openrig
2. https://github.com/KrzymRR/openrig
3. https://github.com/matiascodesal/openrig
4. https://github.com/Mikfr83/openrig
5. https://github.com/spyxx/openrig
6. https://github.com/kattkieru/openrig
7. https://github.com/kurtontheway/openrig

Requested Remedy:
In order to remedy the infringement, we request that GitHub immediately remove or disable access to each of the infringing repositories and forks identified above, pursuant to Section 512(c) of the DMCA and GitHub’s Terms of Service and DMCA Takedown Policy. In addition, we request that GitHub immediately notify the users associated with the infringing repositories and forks identified above of this notice, inform them of their duty to promptly remove the infringing material, and require them to cease any future use of your service to host Disney’s copyrighted material.

Other Information:
I have read and understand GitHub’s Guide to Filing a DMCA Notice.
You may contact me at O’Melveny & Myers LLP, Two Embarcadero Center, 28ᵗʰ Floor, San Francisco, CA 94111-3823, [private], [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. Pursuant to Section 512(c) of the DMCA, I further state that the information in this notification is accurate, and under penalty of perjury, that I am authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Nothing contained in this letter is intended as or should be construed to be a waiver or relinquishment of any right or remedy held by our Disney, all of which are expressly reserved.

Sincerely,
/s/ [private]
[private]