**Are you the copyright holder or authorized to act on the copyright owner's behalf?**

Yes, I am authorized to act on the copyright owner's behalf.

**Please describe the nature of your copyright ownership or authorization to act on the owner's behalf.**

I am employed as a Counsel in the Trademarks, Copyright and Designs department for the complainant and copyright owner, Philip Morris Products S.A. (PMPSA). I have full authority to represent PMPSA in all matters pertaining to the protection and enforcement of the copyright works which it owns.

**Please provide a detailed description of the original copyrighted work that has allegedly been infringed. If possible, include a URL to where it is posted online.**

PMPSA commercializes an electronic device for heating tobacco under the trademark IQOS. PMPSA is the owner of the copyright in the IQOS Connect App, which it publishes on the Google Play App store at this URL:

https://play.google.com/store/apps/details?id=com.pmi.store.PMIAPPM05578&hl=en .

The IQOS Connect App allows legal age users of its IQOS device to monitor the performance of the IQOS device, and to find the closest IQOS store, among other features.

“SDK” is a key piece of software which pertains to the IQOS Connect App, and an original copyright work in its own right, which is owned by PMPSA. SKD is software incorporated into the IQOS Connect App which enables the IQOS Connect App to function with the IQOS electronic device.

Both the IQOS Connect App and the "SKD" software (each being original copyright works, of which PMPSA is the copyright owner) have been reproduced in whole or in substantial part on GitHub at the links reported below. In fact, the individual who has posted the copyright works to GitHub has admitted to this copying by making the comment "Its an Phillip morris code not OUR!" on the posting for the reported content.

**What files should be taken down? Please provide URLs for each file, or if the entire repository, the repository’s URL.**

The below links are for the files which PMPSA requires are removed from the repository.

https://github.com/modmyiqos/iqossdk/tree/master/iqossdk

https://github.com/modmyiqos/iqossdk/tree/master/sdk

**Have you searched for any forks of the allegedly infringing files or repositories? Each fork is a distinct repository and must be identified separately if you believe it is infringing and wish to have it taken down.**

PMPSA is not aware of any forks for the reported infringing content. PMPSA will file further complaints if objectionable forks are identified.

**Is the work licensed under an open source license? If so, which open source license? Are the allegedly infringing files being used under the open source license, or are they in violation of the license?**

No, the reported works are not licensed under an open source license.

**What would be the best solution for the alleged infringement? Are there specific changes the other person can make other than removal? Can the repository be made private?**

Given that the reported infringement concerns the reproduction (in whole or in substantial part) of PMPSA's IQOS Connect App and related "SKD" software, the only suitable solution is that the content is immediately removed from the GitHub platform.

**Do you have the alleged infringer’s contact information? If so, please provide it.**

We believe the infringer is [private] named [private] who goes under the GitHub handle "[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.**

**I have taken <a href="https://www.lumendatabase.org/topics/22">fair use</a> into consideration.**

**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 read and understand GitHub's <a href="https://help.github.com/articles/guide-to-submitting-a-dmca-takedown-notice/">Guide to Submitting a DMCA Takedown Notice</a>.**

**So that we can get back to you, please provide either your telephone number or physical address.**

[private]

**Please type your full legal name below to sign this request.**

[private]
