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646.666.8908 | 16 COURT STREET, 33rd Floor | BROOKLYN, NY 11241
LINDSAY@CAGOLDBERGLAW.COM | WWW.CAGOLDBERGLAW.COM
December 23, 2019
Re: Notice of Copyright Infringement Pursuant to DMCA
To Whom It May Concern
This letter is notice of copyright infringement pursuant to the Digital Millennium Copyright Act (“DMCA”). The content described below is of an intimate nature and has been illegally published on your website without authorization or consent. C.A. Goldberg, PLLC, represent the copyright owner. Each of the required DMCA notice elements is listed below. See 17 U.S.C. § 512(c)(3).
Due to the underlying illegality of hosting these images, immediately remove the content listed in item #3 below, and provide notice to me when you have done so. Failure to comply expeditiously will result in potentially adverse consequences.
Infringement Notice Elements:
1. A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
I am the attorney for the copyright owner, K.W., and duly authorized to act on her behalf. Please see my signature at the end of this letter.
2. Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site.
The works owned by K.W., and that are being infringed on your website, are:
Intimate photos/videos of K.W.
3. Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit the service provider to locate the material.
The infringing content consists of each item identified above. It is located at the following URLs: https://kiwifarms.net/threads/gener...wcBN1qqQEvgOGnY6x2gnAcXcV0pdD1bsK5aHUBu-vHFOQ
Post#1
4.Information reasonably sufficient permit the service provider to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted.
I am the attorney for the copyright owner. I have a good-faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law.
5. A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
Under penalty of perjury, I attest that the information in this notice is accurate, that I am the attorney for copyright owner, and that I am therefore authorized to act on the copyright owner’s behalf.
Sincerely, Lindsay B. Lieberman, Esq.
Lindsay Lieberman, attorney for K.W.
C.A. Goldberg, PLLC
16 Court Street, 33rd Floor
Brooklyn, NY 11241
Tel. (646) 666-8908
Email: dmca.cagoldberglaw@gmail.com
---
Merry Christmas to you too Lieberman.
Your automated system has misidentified something somewhere. I've looked
at it and can't match anything on that page with the alleged source and
they're clearly all edited. Find me the absolute URL, not just a thread
URL with 6 different things on it.
- Josh
LINDSAY@CAGOLDBERGLAW.COM | WWW.CAGOLDBERGLAW.COM
December 23, 2019
Re: Notice of Copyright Infringement Pursuant to DMCA
To Whom It May Concern
This letter is notice of copyright infringement pursuant to the Digital Millennium Copyright Act (“DMCA”). The content described below is of an intimate nature and has been illegally published on your website without authorization or consent. C.A. Goldberg, PLLC, represent the copyright owner. Each of the required DMCA notice elements is listed below. See 17 U.S.C. § 512(c)(3).
Due to the underlying illegality of hosting these images, immediately remove the content listed in item #3 below, and provide notice to me when you have done so. Failure to comply expeditiously will result in potentially adverse consequences.
Infringement Notice Elements:
1. A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
I am the attorney for the copyright owner, K.W., and duly authorized to act on her behalf. Please see my signature at the end of this letter.
2. Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site.
The works owned by K.W., and that are being infringed on your website, are:
Intimate photos/videos of K.W.
3. Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit the service provider to locate the material.
The infringing content consists of each item identified above. It is located at the following URLs: https://kiwifarms.net/threads/gener...wcBN1qqQEvgOGnY6x2gnAcXcV0pdD1bsK5aHUBu-vHFOQ
Post#1
4.Information reasonably sufficient permit the service provider to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted.
I am the attorney for the copyright owner. I have a good-faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law.

5. A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
Under penalty of perjury, I attest that the information in this notice is accurate, that I am the attorney for copyright owner, and that I am therefore authorized to act on the copyright owner’s behalf.
Sincerely, Lindsay B. Lieberman, Esq.
Lindsay Lieberman, attorney for K.W.
C.A. Goldberg, PLLC
16 Court Street, 33rd Floor
Brooklyn, NY 11241
Tel. (646) 666-8908
Email: dmca.cagoldberglaw@gmail.com
---
Merry Christmas to you too Lieberman.
Your automated system has misidentified something somewhere. I've looked
at it and can't match anything on that page with the alleged source and
they're clearly all edited. Find me the absolute URL, not just a thread
URL with 6 different things on it.
- Josh