From b3042e376df933504587bf46191e38123107a775 Mon Sep 17 00:00:00 2001 From: dmca-sync-bot Date: Fri, 25 Sep 2026 21:01:04 +0000 Subject: [PATCH] Process DMCA request --- 2026/09/2026-09-23-redesign.md | 87 ++++++++++++++++++++++++++++++++++ 1 file changed, 87 insertions(+) create mode 100644 2026/09/2026-09-23-redesign.md diff --git a/2026/09/2026-09-23-redesign.md b/2026/09/2026-09-23-redesign.md new file mode 100644 index 0000000000..12c4877a0b --- /dev/null +++ b/2026/09/2026-09-23-redesign.md @@ -0,0 +1,87 @@ +[private] +[private] +T: [private] +E: [private] + +[private] + +BY EMAIL & FEDERAL EXPRESS +GitHub, Inc. +c/o Corporation Service Company +[private] +[private] + +Re: TAKEDOWN REQUEST FOR STOLEN PROPRIETARY INFORMATION + +Dear GitHub Legal Support: + +We write on behalf of our client, Redesign Health Inc. and its affiliates (collectively, “Redesign” +or the “Company”) in connection with the unlawful publication of Redesign’s source code, +configuration, internal documentation, and other proprietary content (collectively, the +“Stolen Material”) by its former employee, [private] (username “effinrich”) on GitHub. +The Stolen Material can be found in the repository titled “rh-nx-monorepo” (see +https://github.com/effinrich/rh-nx-monorepo). The “about” section for that repository explicitly +notes that it contains Redesign’s proprietary information, stating that it is “[a] full-stack Nx +monorepo containing a re-creation of Redesign Health’s ‘Platform Portal’, mock API server, +express middleware, nextjs docs, Storybook, shared design system, and supporting libraries for +Redesign Health.” This includes Redesign’s source code and other extremely sensitive and +proprietary information. We have asked [private] directly to remove all Stolen Material from +GitHub, but he has not done so. Accordingly, by this letter, we request that GitHub remove all +Stolen Material, including the entirety of the repository titled “rh-nx-monorepo.” + +[private]’s publication on GitHub violates GitHub’s “Acceptable Use Policies,” section 3, +which states that GitHub does not “allow any content or activity on GitHub that . . . infringes any +proprietary right of any party, including patent, trademark, trade secret, copyright, right of +publicity, or other right.” GitHubs’s Terms of Service, section C, further provides that a user’s +use of GitHub “must not violate any applicable laws.” Here, [private] has violated the +Acceptable Use Polices and Terms of Service by, at a minimum, violating Redesign’s contractual +and trade secret rights, as described below. + +On July 6, 2022, [private] executed an Employee Inventions and Proprietary Information +Agreement with the Company (“EIPIA”).1 + Pursuant to the EIPIA, “all Assigned Inventions” and +“all other financial, business, legal and technical information regarding or relevant to any +Company Interest that is not generally publicly known” constitutes “Proprietary Information.” + +(EIPIA § 3a.) [private] agreed that, upon termination of his employment, he would “promptly +identify and, as directed by the Company, destroy, delete or return to the Company all items +containing or embodying Proprietary Information (including all original or copies of content, +whether in electronic or hard-copy form).” (EIPIA § 3b.) He further agreed to “provide to the +Company all . . . codes and similar items, and agree[d] not to use such information or items +following termination except at the specific request of the Company.” (EIPIA § 3b.) + +[private]’s employment with the Company ended on April 15, 2024. At that time, he executed +a Layoff Agreement and General Release (the “Layoff Agreement”).2 + In the Layoff Agreement, +he “expressly agree[d] and acknowledge[d] that [the EIPIA] remains in full force and effect” +following [his] termination. (Layoff Agreement § 5.) He also explicitly “acknowledge[d] and +agree[d]” that he “no longer ha[d] possession of any Proprietary Information” or that he had +“returned any such Proprietary Information to the Company.” (Layoff Agreement § 12.) + +[private] breached both the Layoff Agreement and the EIPIA by, at a minimum, unlawfully +retaining and publishing the Stolen Material, all of which is “Proprietary Information” under the +EIPIA and Layoff Agreement, on GitHub. + +[private]’s misconduct is not limited to violating the EIPIA and Layoff Agreement. Among +other statutes, as GitHub is aware, the federal Defend Trade Secrets Act, 18 U.S.C. § 1831 et seq. +and analogous state statutes prohibit the theft and publication of Redesign’s proprietary +information on sites such as GitHub. + +[private]’s publication of Redesign’s Proprietary Information in violation of his contractual +duties, the Defend Trade Secrets Act, state analogues, and other common law duties clearly +violates GitHub’s Acceptable Use Policies and Terms of Service. Accordingly, we request that +GitHub immediately remove all Stolen Material published by [private] from GitHub, including +the entirety of the repository titled “rh-nx-monorepo.” + +Please do not hesitate to contact me if you have any questions or need further information. + +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 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 fair use into consideration. I have read and understand GitHub’s Guide to Submitting +a DMCA Takedown Notice. + +Very truly yours, +/s/ [private] +[private]