KILPATRICK TOWNSEND & STOCKTON LLP
Palo Alto, CA 94301-1431
T [private] F [private]
February 3, 2011
Re: Notification of Copyright Law Violations at Listed URLs
To Whom It May Concern:
I, the undersigned, state under penalty of perjury that: We represent Sony Computer Entertainment America LLC (“SCEA”) in intellectual property and litigation matters. SCEA has recently learned that the content at the following URLs (hereinafter, “Listed URLs”) is hosted by GitHub, and the links are distributing materials that violate copyright laws, and/or contributes to and induces copyright infringement:
Specifically, the content at the Listed URLs markets, trafficks in, distributes, and offers “circumvention device” files or components thereof. These “circumvention device” files or components thereof are illegal because they facilitate infringement of copyrighted works, including SCEA copyrighted software programs, Programmer Tools, and video games, in violation of the Copyright Act, 17 U.S.C. § 101, et seq. and 17 U.S.C. § 501, et seq. The files also constitute circumvention programs, technologies, devices, services, or components because they circumvent SCEA’s PlayStation®3 computer entertainment system’s technological protection measures in violation of the Digital Millennium Copyright Act (“DMCA”), 17 U.S.C. § 1201, et seq. U.S. Federal law provides for injunctive relief, statutory damages, and recovery of monetary damages, including any profits derived from infringing activities and SCEA’s attorneys’ fees under such circumstances.
I have a good faith basis that the web content at the Listed URLs is an infringement of SCEA’s rights under copyright law, including but not limited to the DMCA, and that the infringing content is authorized by neither SCEA nor the law.
SCEA requests that you immediately take down the web content located at the Listed URLs, and promptly disclose to SCEA the identities and contact information corresponding to the account owners and/or users of your hosting services who posted the content identified herein.
Please remove the content as soon as possible, and no later than by February 4, 2011. Finally, the information in this notice is accurate. If you have any questions, please contact me at the email address or phone number listed above.
KILPATRICK TOWNSEND and STOCKTON LLP