| Date | 2026-08-24 01:01:04 |
| Submitter Name | Luna Delrey |
| Submitter Email | legal@nekrova.com |
| Provide a description of the content in question: | Original visual artwork created and owned by our artist and previously published by our artist on Cara.app. Representative examples: https://cara.app/post/5dcb4f18-752f-403f-a2f1-8dd5a4240598 https://cara.app/post/ed2513be-d47e-4287-83fb-20dcabef624e https://cara.app/post/18d3637a-e585-482b-94ef-65122e1e4ef3 https://cara.app/post/1a22f6ba-847c-4e53-83c1-92b1c99323d5 https://cara.app/post/3aa7b7ad-6110-4ce2-a003-09f81d2aaca6 These examples are representative and are not intended to constitute an exhaustive list of all of the copyrighted works contained in the dataset. |
| How are you authorized to make the request? | We are an authorized agent acting on behalf of the copyright owner d.b.a AriaNotto |
| How is the content not covered under the Fair Use Act sections 107 or 108? | The complained of activity involves the reproduction and public redistribution of complete, full-resolution copies of our copyrighted visual artwork. Under 17 U.S.C. §107, the copyrighted works are highly creative visual works. The dataset reproduces the works in their entirety rather than using limited excerpts. Complete copies are then made available to third parties through BitTorrent as a downloadable dataset. Although the dataset describes research, computer-vision, machine-learning, AI classification, and related purposes, describing a collection as being intended for research does not automatically make the copying and public redistribution of complete copyrighted works fair use. Our complaint specifically concerns the unauthorized reproduction and distribution of complete copies of our artwork. 17 U.S.C. §108 does not provide a general authorization for the creation and unrestricted public BitTorrent distribution of a collection of copyrighted artwork. We have not authorized this reproduction or distribution. We therefore have a good-faith belief that the reproduction and distribution complained of is not authorized by us, our agents, or the law. |
| Provide a statement that the complaining party has a good faith belief. | I have a good-faith belief that the reproduction, redistribution, and public availability of my copyrighted artwork in the manner complained of is not authorized by me, my agent, or the law. |
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