DMCA Agent Process

This standard states how the Company receives, records, reviews, and acts on copyright notices under the Digital Millennium Copyright Act, 17 U.S.C. §512. The safe harbor in §512 protects a marketplace that hosts material uploaded by others, provided the Company maintains a designated agent, a public intake, and a working notice-and-takedown procedure. The customer-facing rule is stated in DMCA and Copyright Policy, which governs; the seller-facing rule is stated in Copyright and DMCA Policy. This standard states the internal procedure and does not restate either rule differently.

Roles and duties

• The Legal function is responsible for the designated agent registration, for the completeness standard applied at intake, and for every decision to restore material after a counter-notice.
• Support Operations operates the intake: it files each notice as a case, sends the acknowledgment, and keeps the correspondence on the case record.
• Trust & Safety decides takedown on the substance of a complete notice, notifies the uploader, and records any repeat-infringer consequence against the seller record. Intake staff do not remove material.

The intake: /dmca

The public form at /dmca collects a notice as structured information

1. The complainant: full name, email address, mailing address, and telephone number, plus a statement of any copyright owner the complainant represents as an authorized agent.
2. The copyrighted work: a description of the work, and optionally the address where the original may be seen.
3. The material complained of: the addresses or listing and photo identifiers for the material on the Platform, one per line.
4. Statements and signature: a good-faith statement, a statement under penalty of perjury, and a typed signature giving the full legal name.

Procedure: filing a notice

1. Check the email address. A valid complainant email address is the one hard requirement, because the acknowledgment must be able to reach the complainant. A submission without one is refused.
2. Assess completeness. Check the filing against the six elements §512(c)(3)(A) requires: signature, identification of the copyrighted work, identification of the material complained of, complainant name, address and telephone number, the good-faith statement, and the perjury statement: and record exactly which elements are present and which are missing. Completeness is assessed from the filing, never assumed.
3. Open the case. Open a support case for the notice, marked as coming from an external rights holder (who usually has no Platform account), categorized as a DMCA notice, and given high priority. Attach the full notice text as the inbound message.
4. Create the notice record. Record the complainant's identity, the signature text and signing time, the work description and its address, the addresses complained of, both statements, which elements were complete and which were missing, the case state, and the acknowledgment time.
5. Acknowledge. Send the acknowledgment email and return the case reference to the complainant. Sending the acknowledgment is best effort: if it fails, the filing has still been made, the case exists, and the bounce is noted on the case.
6. If filing itself fails, nothing is written and the notice does not exist as a case. The form tells the complainant the submission failed and asks for a retry. This is the only path on which a notice is not recorded.

Procedure: a notice that is missing elements

A notice missing elements is filed, not refused and not discarded, and no material is removed on it.

1. Record the filing as needing information, with the missing elements listed on the notice record.
2. In the acknowledgment, name exactly what is missing and how to supply it: reply to the confirmation email quoting the case reference. The complainant does not need to file again.
3. Act only when the missing elements are supplied and the notice is complete.

Under §512(c)(3) the Company has no duty to act on a notice that does not substantially comply, but nothing requires the notice to be discarded. Filing it creates the record that shows the notice was received and answered in good faith.

Procedure: review and takedown on a complete notice

1. Confirm the substance. Trust & Safety confirms that the work description identifies an actual copyrighted work, that the addresses resolve to actual Platform content, and that the complainant, or the owner the complainant represents, is plausibly the rights holder.
2. Locate the material. Match the addresses and identifiers to listings, images, or descriptions, and identify the seller who uploaded them.
3. Remove the material. Remove or disable access to the identified material without delay. Record what was removed, when, and under which case.
4. Notify the uploader. Tell the affected seller what was removed and why, and that a counter-notice may be filed. This notice is required by §512(g); it is not a courtesy.
5. Update the case. Move the notice record through the review states and keep all correspondence on the case.

Procedure: counter-notice and restoration

1. Receive the counter-notice on the same case, so the matter stays in one file. A counter-notice must carry the elements §512(g)(3) requires: signature, identification of the removed material, a good-faith statement that the material was removed by mistake or misidentification, consent to jurisdiction, and contact information.
2. Forward the counter-notice to the original complainant.
3. Wait 10 to 14 business days. If the complainant files a court action seeking to restrain the material, the material stays down. If no such action is filed in that window, restore the material. The window is set by the statute; the Company does not shorten it or lengthen it.
4. Record the forwarding date, the expiry of the window, and the restoration, or the court filing, on the case.

The designated agent

1. The Legal function maintains the Company's designated agent registration with the U.S. Copyright Office and publishes the agent's contact information as the DMCA and Copyright Policy provides.
2. Legal notices, including DMCA notices sent outside the intake form, are directed to legal@aapawz.com.
3. The registration renewal is a row on the Compliance Calendar. An expired designation puts the safe harbor at risk and is treated as an urgent lapse.

Repeat infringers

The safe harbor also requires a policy for terminating repeat infringers, applied in practice and not only stated. Trust & Safety records each sustained infringement finding against the seller record, and a takedown against a seller with earlier findings escalates faster. Record the count on the case itself: for example, "this is the second sustained finding": so the count is never reconstructed from memory later. Seller consequences are governed by Copyright and DMCA Policy, which controls.

Particular cases

• A notice aimed at a first-party listing. Copyright takedown is not a brand-control tool. If a listing sold by Pawz Shop uses a brand's product images lawfully: supplier-provided or licensed assets: the notice fails on substance. Do not use the DMCA queue to work around brand authorization, which does not reach first-party inventory.
• Addresses that do not resolve. File the notice as needing information and ask for working identifiers. Identification of the material is the complainant's duty.
• A complainant who is the seller's competitor. Motive does not invalidate a notice, and it does not lower the standard of review. Verify the substance in the usual way. Section 512(f) liability for knowing misrepresentation runs against a bad-faith complainant, and the Company's records are what prove what was known at the time.
• Bulk notices from enforcement vendors. Assess each notice on its elements. A bulk filing with 200 addresses and one work description receives the same element check as a single notice, applied to each address.

Records created and where they are kept

This standard creates the notice record, the support case and its messages, the acknowledgment record, takedown and restoration records, counter-notice records, and the repeat-infringer count on the seller record. Notice records and cases are kept in the support system, retained under Record Retention, and preserved in full when a Legal Hold (Legal Holds) applies: a court action over a takedown is a common trigger.

Escalation

A court filing, a counter-notice, a notice directed at first-party inventory, a claim of misrepresentation, and any request from a court or regulator are escalated to the Legal function at legal@aapawz.com on the day they are received. Routine operational questions about a case in progress go to support@aapawz.com.

Review cadence

The Legal function reviews this standard, the designated agent registration, and a sample of closed cases once a year, and reviews the procedure against what actually happened after the first notice in each new category is handled.