[private]  
tel.: [private]  
e-mail: [private]  
http://www.2gis.ru

April 10, 2018  
COMPLAINT  
Having checked observance of DoubleGIS LLC’ intellectual property rights we discovered the fact of illegal use of the databases https://2gis.ru/ owned by DoubleGIS LLC by user of website https://github.com/. Information about program which help to illegal extract data from databases 2GIS is available in free access in the Internet (https://github.com/abdalovalex/DgdatToXlsx ).  
Since the said "Services" is Russian-speaking and designed for Russian users, hereinafter we will refer to the intellectual property regulations of the Russian Federation. Our intellectual property rights are protected by the Russian Federation civil legislation as well as international rules and treaties.  
DoubleGIS LLC is the owner of the intellectual property rights to “2GIS Information City Directory” software which contains databases of business listings with a rubricator. The said databases are the intellectual property and legally protected items of copyright and related rights in accordance with the Civil Code of the Russian Federation (hereinafter – the Civil Code).  
Under the Russian intellectual property legislation it is not allowed to extract materials from a database and subsequently use the same without consent of the owner. The extraction of materials means transferring full content of any database or a substantial part of materials thereof to another information medium by any means and in any form.  
According to the Civil Code it is not allowed to take any actions aimed at removal of technological protection to use databases. The illegal use of the databases and removal of technological protection measures designed for preventing unauthorized use of the databases cause damage to the owner and make the infringer liable to pay damages or compensation in the amount of up to five million Russian rubles.
Since 2GIS databases have the technological protection from unauthorized access, extraction of materials from such databases may be carried out only with prior permission of the owner.  
Please note that in accordance with the Russian intellectual property legislation the absence of fault of the infringer does not release it from the obligation to terminate the infringement of intellectual property rights, and does not exclude the application of intellectual property protection measures to the infringer. Thus, from the moment of receipt of this complaint you are properly informed of the infringement of the DoubleGIS LLC’ intellectual property rights, as well as of the possibility to be held liable unless you take measures to discontinue the infringement.  
Based on the foregoing, DoubleGIS LLC claims to stop the infringement of its intellectual property rights by deleting all information about program code which help to extract data from databases 2GIS (https://github.com/abdalovalex/DgdatToXlsx) within two (2) days of receipt of this complaint.  
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 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.  
Kind Regards,  
[private]  
Lawyer of legal department  
DoubleGIS LLC  
