[IAC#RG] Fwd: COMPLAINT for illegal content concerning minors, violation of child rights etc.
2014-10-23 16:58:13 GMT
---------- Forwarded message ----------
Date: Thu, Oct 23, 2014 at 9:47 PM
Subject: Re: COMPLAINT for illegal content concerning minors, violation of child rights etc.
To: legal-reports-AeOJrEpdGNeGglJvpFV4uA@public.gmane.org, legal <at> wikimedia.org
Designated Legal Agent
Wikimedia Foundation Inc
Lila Tretikov, Designated Legal Agent
c/o CT Corporation System
818 West Seventh Street
Los Angeles, California 90017
Phone: +1 (415) 839-6885
Facsimile number: +1 (415) 882-0495
21 October 2014
Dear Legal Agent,
COMPLAINT for illegal content concerning minors, violation of child rights including breach of privacy rights and cyber defamation, and concerning on-line pornography.
I am the Intellectual Property Agent and authorized representative of M/s Intervacy Protection Services, contacting you regarding the invasive usage of online content which violates the privacy rights of members of their principals M/s AAP Volunteers Action Manch, B-11 South Ex Plaza II, Masjid Moth, New Delhi 110049, India, also widely known as "AVAM" having websites : "www.avam.in" etc.
It has come to AVAM's attention that minors, being Aam Aadmi Party ("AAP") junior / "sub-teen" volunteers, invited to attend a Republic Day celebration on 26 January 2013 at Pune, India as part of their school curriculum, were deceptively made to sit through a multi-media program known as "Wikipedia India Education Program (2013)" or suchlike and later induced by "Wikimedia Ambassadors" there to open anonymous user accounts on Wikimedia Foundation Inc's (WMF) computer servers without their parent's knowledge or consent.
There are reports in circulation in public domain, including on WMF computer servers, to suggest that these junior AAP volunteers, as also other minors present at the venue, were granted access to high definition grossly obscene pornographic images and media hosted on WMF computer servers in USA under the website URL : http://commons.wikimedia.org and accessible from the .IN domain name http://live.wikimedia.in in various Indic languages.
It has also come to AVAM's attention that very high definition digital photograph's / images clearly identifying alleged AAP minor volunteers have been uploaded to WIMF's servers in the public domain and are being attributed to WMF and circulated with captions like "Aam Aadmi Party kids enjoy Wikipedia at WIEP 2013", "Did Aam Aadmi Party schoolkids also enjoy 'wikiporn' at WIEP 2013 ?" etc. These captions emanate from emails to WMF publicly accessible on WMF servers pertaining to this program asking WMF
"for discussing the issue of Indian school children editing at Wikipedia and being provided computers on which high-definition pornography from Wikimedia Commons was accessible as part of the program."
Accordingly, my principals, and on behalf of all AAP volunteers, require that all content capable of breaching privacy and morals of Indian children / minors situated on WMF computer servers be immediately deleted or disabled. Some of these content / images as presently identified by us are listed below.
[NB: PDF of the article is attached for your information and record]
[NB: Example of grossly obscene commercial pornography hosted on WMF servers freely made accessible to Indian minors by WMF]
As a good faith belief is held that the above mentioned image use and content is not authorized or in accordance with law, we require that the infringing content be immediately removed.
Under penalty of perjury I state that the information provided in this notice is accurate, and that such notice may be submitted on behalf of AVAM.
This electronically signed notice is issued without prejudice solely as a courtesy to afford the Wikimedia Foundation Inc., being a hosting provider having servers in the USA and elsewhere, limited protection from claims based on the activity of its users should you chose to avail it.
A response within 5 business days from the date of this email is expected to confirm the above required removal has taken place. In the event that the content is not removed by then for any reason, my principal requests that WMF promptly discloses the complete particulars of (a) all the infringing user/s and (b) all the persons below age of 18 years shown in these images as available to you along with the records of all their past transactions using your organization's servers.
Thank you for your time.
All rights reserved
Intellectual Property Agent
for "Intervacy Protection Services"
email : toby.dollmann-Re5JQEeQqe8AvxtiuMwx3w@public.gmane.org
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