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2026/09/2026-09-23-redesign.md

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+[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]