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Yahoo Demand Letter to Cryptome Re Posting of Compliance Guide for Law Enforcement 2009

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IBO Connecticut Avenue, NW
Washington, DC 200)6·1795
Tel 202.4293000
Fax 202.4293902
steptoe,com

Michael 1. Gershberg
202.429,6208
mgershberg@steproe,com

December 2, 2009
Via Email and Federal Express
John Young
Cryptome
251 West 89th Street
New York, NY 10024
cryptome @earthlink.net

Re: Infringement of Yahoo! Inc.'s Intellectual Property Rights
Dear Mr. Young:
We write on behalf of our client, Yahoo! Inc. ("Yahoo!"). Yahoo! is the owner of
numerous copyrights, including those covering its internal policies.
It has come to our attention that a copy of a confidential, proprietary, and copyrightprotected Yahoo! document has been posted to xour website at: http://cryptome.orglispspy/yahoo-spy.pdf. The unauthorized use and distribution of this document, Yahoo!'s
Compliance Guide for Law Enforcement, infringes Yahoo!' s intellectual property rights and
constitutes a violation of U.S. copyright law. It also infringes Yahoo!' s trade secrets and
constitutes business interference.

In accordance with the terms of the Digital Millennium Copyright Act ("DMCA"), 17
U.S.C. § 512(c), we are providing you with notice that: (l)Yahoo! is the exclusive owner of the
identified infringing material at the website provided above; (2) Yahoo! has a good faith belief
that use of this material is not authorized by Yahoo!, its agents, or the law; and (3) the
information in this notice is accurate, and under penalty of perjury, we are authorized by our
client to act on its behalf. We request that you cease this unauthorized activity. Specifically, we
request that you immediately remove all infringing material from your website.
Because the identified infringing material infringes our client's rights and is in violation
of U.S. law, we ask that Cryptome immediately remove all such infringing material on its
website. We are sure you appreciate the importance of this matter, as disclosure of this
information will assist criminals to structure their communications to evade apprehension. \Ve
look forward to a quick resolution of this matter, and request that the material be removed from

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your website by no later than 12:00 pm Eastern time on December 3,2009. Yahoo! reserves all
rights and remedies that it may have in connection with this matter.
Thank you for your cooperation in resolving this matter.

Sincerely,

Michael T. Gershberg