DRAFT, pending counsel review. This document is an internal draft prepared on 2026-04-26 by the engineering team. It has NOT been reviewed by external legal counsel. Do not rely on it for legal advice. Effective date is a placeholder pending sign-off. Apostle Pty Ltd makes no representation that this draft satisfies any specific jurisdictional requirement until counsel-reviewed.

DMCA Policy

Last revised: 2026-04-26 · Version: 0.1.0-draft

Table of contents

1. Introduction and scope
2. Designated agent
3. What a valid takedown notice must contain (§512(c)(3))
4. How to send a notice
5. Our review and removal process
6. Notification to the affected user
7. Counter-notice procedure (§512(g)(3))
8. The 10-business-day forwarding window and restoration policy
9. Repeat-infringer policy (§512(i))
10. Subpoena policy (§512(h))
11. Australian copyright equivalents (Copyright Act 1968)
12. Misrepresentation, perjury and §512(f) liability
13. Audit logging and recordkeeping
14. Mailing address and contact channels
15. Appendix A, Takedown notice form (template)
16. Appendix B, Counter-notice form (template)
17. Contact
18. Version history

1. Introduction and scope

PYLON ("PYLON", "we", "our") is a curated short-film platform operated by Apostle Pty Ltd, an Australian proprietary limited company registered in New South Wales. PYLON respects copyright and follows the notice-and- takedown procedures established by the United States Digital Millennium Copyright Act of 1998 ("DMCA"), 17 U.S.C. §512, and the corresponding provisions of the Australian Copyright Act 1968 (Cth).

This policy applies to every title, image, caption, comment, profile and user-supplied asset published on or hosted by pylon.video and its subdomains, including the iOS and Android applications.

2. Designated agent

PYLON has designated an agent to receive notifications of claimed infringement under the DMCA.

• Designated agent: [USCO Designated Agent: TBD]
• Email: [email protected]
• Postal address: Apostle Pty Ltd, Attn: DMCA Agent, [REGISTERED ADDRESS: TBD], Sydney NSW, Australia
• Phone: [PHONE: TBD]

A USCO Designated Agent registration on dmca.copyright.gov is pending filing. Until that filing is accepted, the email and postal channels above are the operative submission routes; PYLON will treat any timely-served notice that meets §512(c)(3) requirements as effective from the date of receipt regardless of the registration status.

3. What a valid takedown notice must contain (§512(c)(3))

A valid notification of claimed infringement must include all of the following:

1. A physical or electronic signature of the copyright owner, or a person authorised to act on the owner's behalf.
2. Identification of the copyrighted work claimed to have been infringed, or, where multiple works are covered, a representative list of those works.
3. Identification of the material claimed to be infringing, with enough detail to permit us to locate the material, preferably the full URL (https://pylon.video/title/<slug>) and, where known, the internal title_id.
4. Sufficient contact information for the complainant: name, mailing address, telephone number, and a working email address.
5. A statement that the complainant has a good-faith belief that the use of the material in the manner complained of is not authorised by the copyright owner, its agent, or the law.
6. A statement that the information in the notification is accurate, and under penalty of perjury, that the complainant is the copyright owner or is authorised to act on the owner's behalf.

Notices that omit any of items (1)–(6) above may be treated as substantially non-compliant. We may, in our discretion, contact the complainant to request the missing element rather than reject the notice outright; this courtesy is not a waiver of the §512(c)(3) requirements.

4. How to send a notice

The fastest route is email to [email protected] with the subject line DMCA, Takedown, [WORK TITLE]. PDF attachments are accepted; plain text is preferred. Postal notices are accepted at the address in §2.

Do not send takedown notices through the in-app /report flow, the support inbox, or social media, they will not reach the designated agent and the §512(c)(3) clock will not start until a properly-routed notice is received.

5. Our review and removal process

On receipt, the designated agent (or a delegated reviewer with the admin role) opens a triage record in our internal dmca_notices table. Each record carries:

• received_at timestamp;
• the complainant identity and contact details;
• the contested title_id and creator account;
• the verbatim notice text (or attachment URL);
• a status field (received → under_review → actioned / rejected); and
• an audit trail of who reviewed it and when.

A facially-valid notice triggers the following sequence:

1. The contested title is set to a non-public state (server-side flag, no playback signing key is issued; cached entitlements are invalidated). The asset is not deleted; it is preserved in case of a counter-notice or court order.
2. The accused creator is notified by email at the address on file with a copy of the notice and a link to the counter-notice form (/dmca/counter-notice/$id).
3. A strike is recorded on the creator's account (users.dmca_strike_count incremented).
4. The decision is written to the audit log with the actor, the timestamp, and the legal basis.

We aim to action facially-valid notices within 24 business hours of receipt. We do not guarantee any particular SLA in any individual case.

6. Notification to the affected user

The accused creator receives a single transactional email containing:

• a verbatim copy of the takedown notice (so the creator can identify the work and the complainant);
• the timestamp at which the title was withdrawn;
• the counter-notice URL and the §512(g)(3) statutory elements;
• a plain-language explanation of the 10-business-day forwarding window;
• a link to this policy.

If the creator's email has been hard-bounced (users.email_hard_bounced_at set), we additionally place a notice in the creator dashboard so they will see it on next sign-in.

7. Counter-notice procedure (§512(g)(3))

A creator who believes a title was withdrawn as a result of mistake or misidentification may submit a counter-notice. Submission is via the authenticated form at:

https://pylon.video/dmca/counter-notice/$id

The form requires all of the following statutory elements:

1. The creator's signature (typed full legal name accepted as electronic signature, with timestamp captured server-side).
2. Identification of the material that was withdrawn and the location at which it appeared before withdrawal.
3. A statement, under penalty of perjury, that the creator has a good-faith belief the material was withdrawn as a result of mistake or misidentification.
4. The creator's full name, mailing address, and telephone number.
5. Consent to the jurisdiction of the United States Federal District Court for the judicial district in which the creator's address is located, or, if outside the United States, for any judicial district in which PYLON may be found, and consent to accept service of process from the original complainant.

A counter-notice that omits any of items (1)–(5) is not a valid §512(g)(3) submission and will not start the forwarding clock.

8. The 10-business-day forwarding window and restoration policy

On receipt of a valid counter-notice, the designated agent forwards a copy to the original complainant promptly (target: same business day; no later than two business days). The forwarding email informs the complainant that the material may be restored unless the complainant files an action seeking a court order to restrain the creator from the infringing activity within 10 business days.

If the original complainant does not provide PYLON with notice of such a court action within the 10-business-day window (counted from the date the counter-notice was forwarded), PYLON may, in its discretion, restore the title to a public state. The 10-business-day window can extend up to 14 business days under §512(g)(2)(C); we will not restore before day 11 and may delay up to day 15 to account for weekends and holidays.

We do not guarantee restoration. PYLON reserves the right to leave a title withdrawn if its presence violates any other policy, even where the §512(g) timing entitles the creator to restoration.

9. Repeat-infringer policy (§512(i))

PYLON terminates the accounts of users determined, in appropriate circumstances, to be repeat infringers, consistent with §512(i)(1)(A).

Operationally:

• Each facially-valid takedown that results in withdrawal increments the affected creator's dmca_strike_count field (packages/db/src/schema/identity.ts).
• A successful counter-notice that results in restoration decrements the count.
• On the third strike the creator's account is suspended: users.suspended_at is set, the user's role is captured in role_before_suspension, and the role is downgraded such that no authenticated tRPC procedure will succeed for that account.
• A suspension may be appealed via [email protected]. Appeals are reviewed within 14 calendar days.
• All strikes and suspensions are recorded in the audit_log table with the actor (the reviewing admin), the timestamp, and the underlying notice id.

A "strike" is a unit of repeat-infringer accounting and not a disciplinary penalty in itself. Counter-notices that result in restoration are reflected in the count.

10. Subpoena policy (§512(h))

DMCA §512(h) subpoenas seeking the identity of an alleged infringer must be served at the postal address in §2 and addressed to the designated agent. On receipt of a facially-valid §512(h) subpoena PYLON will:

• Acknowledge receipt within five business days.
• Review the subpoena for facial validity (issued by a US clerk of court; identifies a specific notice; calls for information narrowly tailored to identifying the alleged infringer).
• Where the subpoena is facially valid, produce only the information required by the subpoena.
• Where the affected user has provided contact information, notify the user of the subpoena unless we are legally prohibited from doing so.

For non-DMCA legal process (court orders, search warrants, civil subpoenas), see our Trust & Safety Policy at /legal/trust-and-safety-policy.

11. Australian copyright equivalents (Copyright Act 1968)

PYLON is operated from Australia. The Australian Copyright Act 1968 (Cth) recognises a narrower safe-harbour scheme than the DMCA: the statutory safe harbours in Part V Division 2AA were extended in 2018 to "educational institutions, cultural institutions, libraries, archives, disability organisations and the Crown" but not to commercial intermediaries such as PYLON.

PYLON nonetheless adopts the DMCA-style notice-and-takedown procedure in this document as a matter of policy and operational discipline. We treat properly-served notices under Australian law (including notices under the Copyright Act 1968 or the Online Safety Act 2021) with the same urgency as DMCA notices, and we follow an equivalent counter- notice flow.

Australian rights-holders may serve notice using the same email and postal channels in §2. We accept Australian-form sworn statements (including statutory declarations under the Statutory Declarations Act 1959 (Cth)) as the equivalent of the §512(c)(3)(A)(vi) "under penalty of perjury" element.

12. Misrepresentation, perjury and §512(f) liability

Submitting a takedown notice or counter-notice that knowingly materially misrepresents that material is infringing (or was withdrawn by mistake or misidentification) is unlawful under §512(f) and may expose the submitter to liability for damages, costs and attorney's fees. PYLON cooperates with civil proceedings arising under §512(f).

In Australia, false statements made in a statutory declaration are an offence under the Statutory Declarations Act 1959 (Cth), s 11 (up to four years' imprisonment).

13. Audit logging and recordkeeping

Every receipt, review action, withdrawal, counter-notice, forwarding email, and restoration is recorded in the immutable audit_log table with actor, timestamp and reasoning. Records are retained for the longer of: (a) seven years from the action, or (b) the duration of any related legal proceeding. This is a deliberate choice to support both §512(g) defence and §512(i) repeat-infringer accounting.

14. Mailing address and contact channels

• Email: [email protected] (preferred)
• Postal: Apostle Pty Ltd, Attn: DMCA Agent, [REGISTERED ADDRESS: TBD], Sydney NSW, Australia
• Counter-notices: /dmca/counter-notice/$id (authenticated)
• Trust & Safety, non-copyright reports: /report and [email protected]
• Subpoena service: postal address only

15. Appendix A, Takedown notice form (template)

TO:     Apostle Pty Ltd, Designated DMCA Agent
EMAIL:  [email protected]
DATE:   [YYYY-MM-DD]

1. IDENTIFICATION OF COPYRIGHTED WORK(S)
   Title:               [____]
   Registration no.:    [____ if registered]
   Year first published: [____]
   Brief description:   [____]

2. IDENTIFICATION OF INFRINGING MATERIAL ON PYLON
   URL(s):              [https://pylon.video/title/__]
   Internal title id:   [optional]

3. CONTACT INFORMATION
   Name:                [____]
   Title / role:        [____]
   Company:             [____]
   Address:             [____]
   Phone:               [____]
   Email:               [____]

4. GOOD-FAITH BELIEF STATEMENT
   "I have a good-faith belief that the use of the copyrighted material
   described above is not authorised by the copyright owner, its agent,
   or the law."

5. ACCURACY AND AUTHORISATION (UNDER PENALTY OF PERJURY)
   "I swear, under penalty of perjury, that the information in this
   notification is accurate and that I am the copyright owner or am
   authorised to act on behalf of the owner of an exclusive right that
   is allegedly infringed."

6. SIGNATURE
   Signature (physical or electronic): [____]
   Printed name:                       [____]

16. Appendix B, Counter-notice form (template)

TO:     Apostle Pty Ltd, Designated DMCA Agent
DATE:   [YYYY-MM-DD]

1. IDENTIFICATION OF MATERIAL
   Title:           [____]
   Internal id:     [____]
   URL before withdrawal: [https://pylon.video/title/__]

2. GOOD-FAITH BELIEF STATEMENT (UNDER PENALTY OF PERJURY)
   "I swear, under penalty of perjury, that I have a good-faith belief
   the material identified above was removed or disabled as a result
   of mistake or misidentification of the material to be removed or
   disabled."

3. CONTACT INFORMATION
   Full legal name: [____]
   Address:         [____]
   Phone:           [____]
   Email:           [____]

4. CONSENT TO JURISDICTION
   "I consent to the jurisdiction of the Federal District Court for
   the judicial district in which my address is located, or, if my
   address is outside the United States, for any judicial district
   in which Apostle Pty Ltd may be found, and I will accept service
   of process from the person who provided notification under
   17 U.S.C. §512(c)(1)(C) or that person's agent."

5. SIGNATURE
   Signature (physical or electronic): [____]
   Printed name:                       [____]

Contact

• DMCA agent: [email protected]
• Counter-notices: /dmca/counter-notice/$id
• Postal: Apostle Pty Ltd, Attn: DMCA Agent, [REGISTERED ADDRESS: TBD]

Version history

Version	Date	Author	Summary
0.1.0	2026-04-26	engineering	Initial standalone draft. Supersedes apps/web/src/routes/dmca.tsx v1.1 inline copy.