Intrepid Network Concepts Inc.

1639 Bradley Park Drive Suite 500, PMB 110 Columbus, Georgia 31904
Matthew S. Chan President (706) 341-2575 (888)696-3441 FAX

November 16, 2011 Legal Department  eApps Hosting  7742 Spalding Drive, Suite 363  Norcross, Georgia, USA 30092  FAX: (404) 601‐7454

Dear Eapps Legal Dept: This letter is written in response to your notification to me of a DMCA complaint [LEGAL #CGE-424-69119] received about a web page(s) on my website. The page in question is:,2346.0.html My response to this complaint is as follows: Allegations of Copyright Violation / Digital Millennium Copyright Act The claims of copyright violation should be rejected because: > The original complainant has provided no copyright registration information or other tangible evidence that the material in question is in fact copyrighted, and I have a good faith belief that it is not. The allegation of copyright violation is therefore in dispute, and at present unsupported.  

Because of the nature of the material being reported, I have strong belief that the original complainant (who is a copyright lawyer herself) did not simply make an honest error but has knowingly and willfully filed a false DMCA complaint. She has now exposed herself to potential liability as described in 17 USC 512(f). Let me be very clear. It was an email sent directly to me and my lawyer associate, Oscar Michelen. Every email user in the world much less a copyright lawyer knows that business communications for the intended recipient ARE NOT PROTECTED! If you send email to someone, you take the risk of the receiver openly sharing it! Almost every email user in the world knows this! Quite frankly, I find it outrageous that I have to even write this letter given the material being complained about!

This communication to you is a DMCA counter-notification letter as defined in 17 USC 512(g)(3): I declare, under penalty of perjury, that I have a good faith belief that the complaint of copyright violation is based on mistaken information, misidentification of the material in question, or deliberate misreading of the law. Further, according to 17 USC 512(f), any person who knowingly misrepresents that material is infringing shall be liable for any damages, including costs and attorneys’ fees incurred by me and other related parties as a result of removing or disabling access to hosting services or other materials claimed to be infringing or in replacing the removed material. My name, address, and telephone number are as follows: Matthew Chan 1639 Bradley Park Dr. Suite 500, PMB 110 Columbus, GA 31904 (762) 359-0425 I hereby consent to the jurisdiction of Federal District Court for the judicial district in which I reside. I agree to accept service of process from the original complainant. Having received this counter notification, you are now obligated under 17 USC 512(g)(2)(B) to advise the original complainant of this notice, and to allow us to restore the material in dispute (and not take the material down). Please notify me in writing when you receive this counter-notification letter. Please don’t hesitate to contact me if you have any questions or concerns. Sincerely,

Matthew Chan President