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| 1 | +Dear Sirs: |
| 2 | + |
| 3 | +We are writing on behalf of our company, Alethea Tech Pte Ltd (“Alethea AI”), registered under the laws |
| 4 | +of [private], which owns exclusive copyrights in proprietary software code related to its innovative |
| 5 | +technologies and services, notably including Intelligent Non-Fungible Tokens (“iNFTs”), Noah’s Ark |
| 6 | +software platform, ALIagents systems, AI Protocol frameworks, and legacy website code hosted at |
| 7 | +inft.alethea.ai (collectively, the “Protected Works”). This proprietary software was developed by our |
| 8 | +internal development team under employment agreements and work-for-hire arrangements, and is |
| 9 | +therefore exclusively owned by Alethea AI. |
| 10 | + |
| 11 | +It has come to our attention that a repository listed on the website located at GitHub.com (the "Site") has |
| 12 | +copied and displayed in totality the Protected Works without authorization from Alethea Tech Pte Ltd. |
| 13 | +The entire repository is infringing upon the Protected Works. The infringing repository is a direct |
| 14 | +imitation of the previously used Protected Works of Alethea AI. The repository infringing upon the |
| 15 | +Protected Works copies the previously written code of Alethea AI, which has since then been updated and |
| 16 | +modified by Alethea AI to reflect the new changes in the industry. The repository’s code still mentions |
| 17 | +references to proprietary websites of Alethea AI and prima facie demonstrates that this repo is the |
| 18 | +property of Alethea AI, just uploaded by another use without authorization. This letter is to serve notice of |
| 19 | +this infringement according to 17 U.S.C. § 512. |
| 20 | + |
| 21 | +We have reproduced a small excerpt from the infringing repo below for your reference, from the file |
| 22 | +directory at [private] which demonstrates the use of Alethea AI’s proprietary |
| 23 | +code. This is an example and does not limit the takedown to this file only: |
| 24 | + |
| 25 | +[private] |
| 26 | +[private] |
| 27 | +[private] |
| 28 | +[private] |
| 29 | +[private] |
| 30 | +[private] |
| 31 | + |
| 32 | +Pursuant to 17 U.S.C. § 512, we provide the following information: |
| 33 | + |
| 34 | +1. We are writing on behalf of our company, Alethea Tech Pte Ltd, the exclusive rights holder of the |
| 35 | +Protected Works currently being infringed on the Site, a list of which appears on Exhibit A hereto. |
| 36 | + |
| 37 | +2. The infringing material is located at the URL within the Site. See Exhibit A hereto for reference to this |
| 38 | +repo. You may contact Alethea Tech Pte Ltd through its undersigned representative at: |
| 39 | + |
| 40 | +[private] |
| 41 | +[private] |
| 42 | +[private] |
| 43 | +[private] |
| 44 | + |
| 45 | +3. We have read and understood GitHub’s Guide to Filing a DMCA Notice. |
| 46 | + |
| 47 | +4. We believe in good faith that the use of the referenced works on the Site is not authorized by Alethea |
| 48 | +Tech Pte Ltd, its agent, or the law, including under the fair use defense. |
| 49 | + |
| 50 | +5. The information in this notification is accurate, and, under penalty of perjury, we are authorized to act |
| 51 | +on behalf of Alethea Tech Pte Ltd, the owner of the exclusive rights in the works infringed by the |
| 52 | +Site. |
| 53 | + |
| 54 | +We therefore demand that the use of the infringing code immediately remove the complete code or that |
| 55 | +you immediately remove the infringing material from the Site, and confirm such removal to the |
| 56 | +undersigned within five days of the date hereof. The foregoing is without prejudice to any of our |
| 57 | +company's rights, remedies, and defenses, all of which are expressly reserved. |
| 58 | + |
| 59 | +Sincerely, |
| 60 | + |
| 61 | +[private] |
| 62 | + |
| 63 | +[private] |
| 64 | +[private] |
| 65 | +For and on behalf of Alethea Tech Pte Ltd |
| 66 | + |
| 67 | +Attachment |
| 68 | +EXHIBIT A. List of Infringing Works and URLs on the Site |
| 69 | +1- https://github.com/zenkodr/alethea-ai-backend |
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