Chilling Effects Clearinghouse > DMCA Safe Harbor > Notices > seoimage.com complains to Google about multiple pages (NoticeID 2681, http://chillingeffects.org/N/2681)

Location: https://www.chillingeffects.org/notice.cgi?NoticeID=2681

seoimage.com complains to Google about multiple pages

October 25, 2005

Sender Information:
SEO Image LLC
Sent by: [Private]
[Private]
Kings Park, NY, 11754, US

Recipient Information:
[Private]
Google, Inc.
Mountain View, CA, 94043, USA

Sent via: fax
Re:

Dear Google Customer Support Professionals,

1) The copyrighted work at issue is the text that appears on: http://www.seoimaqe.com/

2) Search Query:
"offers three powerful and effective marketing services"
http://www.gooqle.com/search?q=%22offers%20three%20powerful%20and%20effective%20marke ting%20services%22&sourceid=groowe&ie=utf-8&oe=utf-8
Infringing Web Pages: http://www.daytech.net/

3) My Contact Information: [private]@seoimage.com
[private](cell)

4) Infringer's Contact Information:
[private]
[private],
Ramat Gan 52521, IL.
Telephone: [private]
FAX: [private]
httpi/www.daytech.net/davtech/contact.asp

5) I have a good faith belief that use of the copyrighted materials described above on the allegedly infringing web pages is not authorized by the copyright owner, its agent, or the law.

Sincerely,
[private]CEO SEO Image LLC
[private]
Kings Park, NY 11754

October 25, 2005
Sender Information:
SEO Image LLC
Sent by: CEO
[private]
Kings Park, NY, 11754, USA

Recipient Information:
Customer Support, DMCA Complaints Google, Inc.
Mountain View, CA, 94043, USA

Sent via: fax
Dear Google Customer Support Professionals,

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/seo_services.html

2) Search Query:
"Can be thought of as a technique of Design, HTML coding, scripting, link"
http://www.google.com/search?q=%22Can+be+thought+of+as+a+technique+of+Design,+HTML+coding,+scripting,+link%22&hl=en&Ir=&filter=0
Infringing Web Pages:
http://www.verydpromotion.com/Search Engine Optimization.htm
http://www.verydpromotion.com/Optimization Ethics.htm
http://www.verydpromotion.com/Search Engine Submission.htm http://www.verydpromotion.com/Optimization_and_Ranking_Processes.htm

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/web_design.html

2) Search Query:
"offers professional web design services by our cutting edge team of designers"
http://www.google.com/search?q= %22ofers%20professional%20web%20design%20services%20b y%20our%20cuttinq%20edge%20team%20of%20designers%22&sourceid=groowe&ie=utf-8&oe=utf-8

Infringing Web Pages: http://www.verydpromotion.com/Website Designing.htm
http://www.verydpromotion.com/powerful_webdesign_and_design_marketing.htm

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/search engine methodology.html
2) Search Query:
"Links will be sought out on the Internet that will benefit the site's ranking on each individual search engine"
http://www.google.com/search?q=%22Links%20wiIl%20be%20sought%20out%20on%20the%20Intern et%20that%20will%20benefit%20the%20site%E2%80%99s%20ranking%20on%20each%20individuaI %20search%20engine%22&sourceid =groowe&ie=utf-8&oe=utf-8
Infringing Web Pages:
http://www.vervdpromotion.com/Optimization and Ranking Processes.htm

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/keyword analysis research.html

2) Search Term:
"will research the keywords that are actually typed by real life users based on your market"
http://www.google.com/search?q=%22will%20research%20the%20keywords%20that%20are%20a ctually%20tvped%20by%20real%20life%20users%20based%20on%20your%20market%22&source id=groowe&ie=utf-8&oe=utf-8

Infringing Web Pages:
http://www.verydpromotion.com/Search Engine Keyword Analysis Research.htm http://www.yerydpromotion.com/Keyword Research.htm

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/link popularity.html

2) Search Term:
"It is vastly becoming one of the most important aspects of search engine optimization"
http://www.google.com/search?q=%22lt+is+vastly+becoming+one+of+the+most+important+aspe cts+of+search+engine+optimization%22&hl=en&Ir=&filter=0

Infringing Web Pages:
http://www.verydpromotion.com/Link_Populararity_Services.htm
1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/meta_taqs-optimization.html

2) Search Term:
"While meta tags are not considered as important today as in the past, there are some search engines that rely mainly on them"
http://www.google.com/search?q=%22 While%20meta%20tags%20are%20not%20considered%20a s%20important%20today%20as%20in%20the%20past%2C%20there%20are%20some%20search %20engines%20that%20rely%20mainly%20on%20them%22&sourceid=groowe&ie=utf-8&oe=utf-8

Infringing Web Pages: http://www.verydpromotion.com/Meta_Tags.htm

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/search_engine_consulting.html

2) Search Term;
"We recommend resources and programs that are suitable for your company's niche on the Internet" http://www.google.com/search?q=%22We%20recommend%20resources%20and%20programs%20 that%20are%20suitable%20for%20your%20company's%20niche%20on%20the%20Internet%22&s ourceid=groowe&ie=utf-8&oe=utf-8

Infringing Web Pages:
http://www.verydpromotion.com/Consulting_Services.htm
1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/title tag optimization.html
2) Search Term:
"will optimize your title tags for optimum ranking"
http://www.google.com/search?hl=en&Ir=&q=%22will+optimize+your+title+tags+for+optimum+ranking%22&btnG=Search
Infringing Web Pages: http://www.verydpromotion.com/Title_Tags.htm
3) My Contact Information: [private]@seoimage.com
[private] (cell)

4) Infringer's Contact Information:
No Whois data available
[private]@verydpromotion.com
http://www.verydpromotion.com/general_enquiry.htm
5) I have a good faith belief that use of the copyrighted materials described above on the allegedly infringing web pages is not authorized by the copyright owner, its agent, or the law.

6) I swear, under penalty of perjury, that the information in the 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.

Sincerely,

[private] CEO SEO Image LLC
[private]
Kings Park, NY 11754 And
[private]
New York, NY 10022

October 25, 2005
Sender Information:
SEO Image LLC
Sent by: CEO
[private]
Kings Park, NY, 11754, USA
Recipient Information;
Customer Support, DMCA Complaints Google, Inc.
Mountain View, CA, 94043, USA

Sent via: fax

Dear Google Customer Support Professionals,

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/link_popularitv.html

2) Search Query:
"Link Popularity is one of the most important features of any search engine optimization campaign"
http ://www.google.com/search?q=%22 Li nk%2OPopularity%20is%20one%20of%20the%20most%2 0important%20features%20of%20any%20search%20engine%20optimization%20campaign%22&so urceid=groowe&ie=utf-8&oe= utf-8

Infringing Web Pages:
http://webdesiqnsbyjeffrey.com/article-print-12.htmi http://webdesiqnsbvjeffrey.com/article-cateaorv-5.html https://www.webdesiqnsbyjeffrey.com/content-15.html http://webdesignsbyjeffrev.com/alticle-topic-2.html,
http://www.webdesignsbyjeffrey.com/modules.php?name=News&new_topic=2
3) My Contact Information: [private]@seoimage.com
[private] (cell)
4) Infringer's Contact Information:
[private]
[private]
Dracut, MA 01826, US
[private] [private] [private]@comcast.net
http://www.webdesignsbyjeffrey.com/modules.php?name=Feedback
5) I have a good faith belief that use of the copyrighted materials described above on the allegedly infringing web pages is not authorized by the copyright owner, its agent, or the law.

6) I swear, under penalty of perjury, that the information in the 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.

Sincerely,
[private] CEO SEO Image LLC
[private] Kings Park, NY 11754 And
[private]
New York, NY 10022

October 25, 2005

Sender Information:
SEO Image LLC
Sent by: CEO
[private]
Kings Park, NY, 11754, USA

Recipient Information:
Customer Support, DMCA Complaints Google, Inc.
Mountain View, CA, 94043, USA

Sent via: fax

Dear Google Customer Support Professionals,

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/search engine marketing.html

2) Search Query:
"Search Engine Marketing is a strategic combination of several techniques" http://www.google.com/search?q=%22Search%20Engine%20Marketing%20is%20a%20strategic% 20combination%20of%20several%20techniques%22&sourceid=groowe&ie=utf-8&oe=utf-8

Infringing Web Pages: http://www.birbals.com/promotion2.html http://www.birbals.in/promotion2.html

3) My Contact Information: [private]@seoimage.com
[private] (cell)

4) Infringer's Contact Information:
[private]
[private]
chandigarh UT,160036 IN
Tel. +91.1725155237
[private]@gmail.com
[private]@birbals.com
http://www.birbals.com/contact.html

5) I have a good faith belief that use of the copyrighted materials described above on the allegedly infringing web pages is not authorized by the copyright owner, its agent, or the law.

Sincerely,
[private] CEO SEO Image LLC
[private]
Kings Park, NY 11754 And
[private]
New York, NY 10022

October 25, 2005
Sender Information:
SEO Image LLC
Sent by: CEO
[private]
Kings Park, NY, 11754, USA
Recipient Information:
Customer Support, DMCA Complaints Google, Inc.
Mountain View, CA, 94043, USA
Sent via: fax

Dear Google Customer Support Professionals,

1) The copyrighted work at issue is the text that appears on: http:/.www.seoimage.com/
http://www.seoimage.com/seo services.html http://www.seoimage.com/search-engine-optimization.html
2) Search Query:
"can mean the difference between a company that has the ability to succeed and the one that might never have a chance"
http://www.google.com/search?q=%22can%20mean%20the%20difference%20between%20a%20c ompany%20that%20has%20the%20ability%20to%20succeed%20and%20the%20one%20that%20 might%20never%20have%20a%20chance%22&sourceid=groowe&ie=utf-8&oe=utf-8

Infringing Web Pages:
http://www.opalinfotech.com/search engine optimization.html
3) My Contact Information: [private]@seoimage.com
[private] (cell)

4) Infringer's Contact Information:
[private],
[private]
[private]
Satellite
Ahmedabad, Gujarat 380 015
IN
+91-[private]
[private]@vsnl.net
http://www.opalinfotech.com/web design contact.html

5) I have a good faith belief that use of the copyrighted materials described above on the allegedly infringing web pages is not authorized by the copyright owner, its agent, or the law.
6) I swear, under penalty of perjury, that the information in the notification is accurate and that I am the copyright owner or am authorized to ad on behalf of the owner of an exclusive right that is allegedly infringed.

[private] CEO
SEO Image LLC
[private] Kings Park, NY 11754 And
[private]
New York, NY 10022

October 2S, 2005

Sender Information:
SEO Image LLC
Sent by: CEO
[private]
Kings Park, NY, 11754, USA

Recipient Information:
Customer Support, DMCA Complaints Google, Inc.
Mountain View, CA, 94043, USA

Sent via: fax

Dear Google Customer Support Professionals,

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/seo services.html

2) Search Query:
"Can be thought of as a technique of Design, HTML coding, scripting, link popularity building" http://www.google.com/search?q=%22Can%20be%20thought%20of%20as%20a%20technique%2 Oof%20Design%2C%20HTML%20coding%2C%20scripting%2C%20link%20popularity%20buildinq% 22&sourceid=groowe&ie=utf-8&oe=utf-8

Infringing Web Pages:
http://www.creativatorz.com/search-engine-optimisation.htm http://www.creativatorz.com/search-engine-optimization.htm http://www.creativatorz.com/search-engine-optimization-india.htm
1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/web design.html

2) Search Query:
"In Fact, some companies use us just for our quality web design and hosting services" http://www.google.com/search?q=%22In%20Fact%2C%20some%20companies%20use%20us%20j ust%20for%20our%20quality%20web%20design%20and%20hosting%20services%22&sourceid=gr oowe&ie=utf-8&oe= utf-8

Infringing Web Pages:
http://www.creativatorz.com/website-design-development.htm http://www.creativatorz.com/website-design-development.html

3) My Contact Information: [private]@seoimage.com
[private] (cell)

4) Infringer's Contact Information: Monga, Rishu
[private]s
[private] [private]
Kanpur 208006
India
[private]
[private]@creativatorx.com
[private]@rediffmail.com
http://www.creativatorz.com/contact.htm

5) I have a good faith belief that use of the copyrighted materials described above on the allegedly infringing web pages is not authorized by the copyright owner, its agent, or the law.

6) I swear, under penalty of perjury, that the information in the 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.
Sincerely,
[private] CEO SEO Image LLC
[private]
Kings Park, NY 11754 And
[private]
New York, NY 10022

October 25, 2005

Sender Information:
SEC Image LLC
Sent by: CEO
[private]
Kings Park, NY, 11754, USA

Recipient Information:
Customer Support, DMCA Complaints Google, Inc.
Mountain View, CA, 94043, USA

Sent via: fax

Dear Google Customer Support Professionals,

1) The copyrighted work at issue is the text that appears on: http://www.seoimage.com/

2) Search Query:
"takes into account all the elements of optimization"
http://www.google.com/search?q=%22takes%20into%20account%20all%20the%20elements%20of%20opti mization%20%22&sourceid=groowe&ie=utf-8&oe= utf-8

Infringing Web Pages:
http://www.rainmaker-partners.com/SEOApproach.htm

3) My Contact Information: seo

image

FAQ: Questions and Answers

[back to notice text]

Question: Why does a search engine get DMCA takedown notices for materials in its search listings?

Answer: Many copyright claimants are making complaints under the Digital Millennium Copyright Act, Section 512(d), a safe-harbor for providers of "information location tools." These safe harbors give providers immunity from liability for users' possible copyright infringement -- if they "expeditiously" remove material when they get complaints. Whether or not the provider would have been liable for infringement by users' materials it links to, the provider can avoid the possibility of a lawsuit for money damages by following the DMCA's takedown procedure when it gets a complaint. The person whose information was removed can file a counter-notification if he or she believes the complaint was erroneous.

Question: What does a service provider have to do in order to qualify for safe harbor protection?

Answer: In addition to informing its customers of its policies (discussed above), a service provider must follow the proper notice and takedown procedures (discussed above) and also meet several other requirements in order to qualify for exemption under the safe harbor provisions.

In order to facilitate the notification process in cases of infringement, ISPs which allow users to store information on their networks, such as a web hosting service, must designate an agent that will receive the notices from copyright owners that its network contains material which infringes their intellectual property rights. The service provider must then notify the Copyright Office of the agent's name and address and make that information publicly available on its web site. [512(c)(2)]
Finally, the service provider must not have knowledge that the material or activity is infringing or of the fact that the infringing material exists on its network. [512(c)(1)(A)], [512(d)(1)(A)]. If it does discover such material before being contacted by the copyright owners, it is instructed to remove, or disable access to, the material itself. [512(c)(1)(A)(iii)], [512(d)(1)(C)]. The service provider must not gain any financial benefit that is attributable to the infringing material. [512(c)(1)(B)], [512(d)(2)].

Question: What are the provisions of 17 U.S.C. Section 512(c)(3) & 512(d)(3)?
Answer: Section 512(c)(3) sets out the elements for notification under the DMCA. Subsection A (17 U.S.C. 512(c)(3)(A)) states that to be effective a notification must include: 1) a physical/electronic signature of a person authorized to act on behalf of the owner of the infringed right; 2) identification of the copyrighted works claimed to have been infringed; 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; 4) information reasonably sufficient to permit the service provider to contact the complaining party (e.g., the address, telephone number, or email address); 5) a statement that the complaining party has a good faith belief that use of the material is not authorized by the copyright owner; and 6) a statement that information in the complaint is accurate and that the complaining party is authorized to act on behalf of the copyright owner. Subsection B (17 U.S.C. 512(c)(3)(B)) states that if the complaining party does not substantially comply with these requirements the notice will not serve as actual notice for the purpose of Section 512.
Section 512(d)(3), which applies to "information location tools" such as search engines and directories, incorporates the above requirements; however, instead of the identification of the allegedly infringing material, the notification must identify the reference or link to the material claimed to be infringing.

Question: Does a service provider have to follow the safe harbor procedures?
Answer: No. An ISP may choose not to follow the DMCA takedown process, and do without the safe harbor. If it would not be liable under pre-DMCA copyright law (for example, because it is not contributorily or vicariously liable, or because there is no underlying copyright infringement), it can still raise those same defenses if it is sued.

Question: How do I file a DMCA counter-notice?
Answer: If you believe your material was removed because of mistake or misidentification, you can file a "counter notification" asking the service provider to put it back up. Chilling Effects offers a form to build your own counter-notice.

For more information on the DMCA Safe Harbors, see the FAQs on DMCA Safe Harbor. For more information on Copyright and defenses to copyright infringement, see Copyright.

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