Digital Millennium Copyright Act (DMCA) Policy

1. Purpose

All Things Universal LLC (“ATU,” “Company,” “we,” “our,” or “us”) respects the intellectual property rights of others and expects all users, vendors, merchants, customers, affiliates, advertisers, and visitors to do the same.

This DMCA and Intellectual Property Policy explains how copyright owners, trademark owners, authorized representatives, vendors, users, and other rights holders may report alleged intellectual property infringement on the ATU website, marketplace platform, vendor pages, listings, advertisements, content, tools, and related services, collectively referred to as the “Platform.”

This Policy also explains how ATU may respond to infringement reports, counter-notifications, repeat infringement, counterfeit claims, trademark complaints, and misuse of intellectual property reporting procedures.

This Policy should be read together with ATU’s Terms of Use, Vendor Terms of Service, Privacy Policy, Cookie Policy, Prohibited and Restricted Categories Policy, and any other policies published by ATU.

2. Scope of this Policy

This Policy applies to content, listings, advertisements, images, videos, product descriptions, service descriptions, vendor pages, reviews, logos, brand names, trademarks, copyrighted works, and other materials made available through the Platform.

This Policy covers reports involving intellectual property rights, including:

• Copyright.
• Trademark.
• Counterfeit goods.
• Design rights.
• Patent-related claims.
• Unauthorized use of brand names, logos, images, text, videos, or product packaging.
• Unauthorized copies, replicas, or imitations.
• Misleading claims of brand affiliation, authorized reseller status, warranty coverage, certification, or approval.
• Other intellectual property or ownership rights recognized by applicable law.

The DMCA counter-notification process applies to eligible U.S. copyright claims only. Other intellectual property disputes, including trademark, counterfeit, patent, design, and brand-rights complaints, may be handled through separate review procedures at ATU’s discretion.

3. Copyright and Intellectual Property Compliance

ATU prohibits the unauthorized use, reproduction, distribution, display, publication, sale, promotion, or listing of materials that infringe the intellectual property rights of any third party.

Users and Vendors may not upload, publish, sell, distribute, advertise, or display content that violates another party’s copyright, trademark, patent, design right, publicity right, privacy right, trade secret, contractual right, or other legal right.

Vendors and users are responsible for ensuring that they own or have permission to use all content, images, videos, logos, product descriptions, brand references, catalog information, software, artwork, photographs, product packaging, and other materials submitted to the Platform.

4. Vendor Responsibilities

Vendors are responsible for ensuring that their listings and materials do not infringe the rights of others.

Vendors should not:

• Copy images, videos, text, product descriptions, or graphics from another website without permission.
• Use stock photos without the correct license.
• Use manufacturer images or brand assets without authorization.
• Sell counterfeit, replica, fake, unauthorized, or infringing goods.
• Use another company’s trademark in a misleading way.
• Suggest that Vendor is an authorized dealer, reseller, partner, distributor, or representative if Vendor is not authorized.
• Misrepresent product origin, warranty coverage, certification, licensing, or brand affiliation.
• Upload copyrighted music, videos, images, artwork, software, books, designs, or other works without permission.
• Use third-party logos, marks, brand names, or copyrighted material in a way that creates confusion.

Vendors should create their own original listing text, use their own images where possible, and obtain written permission or licenses for third-party materials before using them on the Platform.

5. ATU’s Role

ATU provides a platform for independent vendors and users.

ATU does not act as a court, judge, arbitrator, or intellectual property ownership authority. ATU does not make final legal determinations about copyright ownership, trademark rights, brand rights, patent rights, or other intellectual property disputes.

ATU may take administrative action based on information provided by the parties, applicable law, Platform policies, risk concerns, and the need to protect users, vendors, rights holders, and Platform integrity.

Actions taken by ATU may include removing content, disabling access, restricting listings, suspending vendor pages, terminating accounts, requesting more information, or declining to process incomplete or abusive reports.

6. Designated Copyright Agent

Copyright infringement notices under the Digital Millennium Copyright Act should be sent to ATU’s designated copyright agent.

ATU should ensure that its designated DMCA agent information is properly registered with the U.S. Copyright Office and kept current.

If the designated agent’s information changes, ATU should update both this Policy and the U.S. Copyright Office designation as required by applicable law.

7. Submitting a DMCA Copyright Notice

A copyright owner or authorized representative who believes that copyrighted material has been infringed on the Platform may submit a written DMCA Notice.

A valid DMCA Notice should include the following:

A. Identification of the Copyrighted Work

A clear description of the copyrighted work claimed to have been infringed.

If multiple copyrighted works are involved, the notice may include a representative list of the works.

B. Identification of the Allegedly Infringing Material

Information reasonably sufficient to allow ATU to locate the material on the Platform, such as:

• URL.
• Listing ID.
• Vendor name.
• Product page reference.
• Service page reference.
• Screenshot.
• Description of where the material appears.
• Any other identifying details.

C. Contact Information

The complaining party’s contact information, including:

• Full legal name.
• Mailing address.
• Telephone number.
• Email address.
• Company name, if applicable.

D. Good Faith Statement

A statement that the complaining party has a good faith belief that use of the material is not authorized by the copyright owner, the copyright owner’s agent, or applicable law.

E. Accuracy and Authority Statement

A statement that the information in the notice is accurate, and under penalty of perjury, that the complaining party is the copyright owner or is authorized to act on behalf of the copyright owner.

F. Signature

A physical or electronic signature of the copyright owner or authorized representative.

8. Incomplete or Invalid Notices

ATU may decline to process, delay processing, or request additional information for notices that are incomplete, inaccurate, unclear, unsupported, fraudulent, abusive, submitted by an unauthorized party, or otherwise legally insufficient.

ATU may request additional documentation, including:

• Proof of copyright ownership.
• Proof of authorization to act for the rights holder.
• Identity verification.
• Explanation of the claimed infringement.
• Additional URLs or listing details.
• Evidence supporting the claim.

Failure to provide requested information may result in ATU taking no action.

9. ATU’s Review of DMCA Notices

Upon receipt of a valid DMCA Notice, ATU may:

• Review the submission.
• Request additional information.
• Remove or disable access to allegedly infringing content.
• Restrict or suspend the related listing, vendor page, or account.
• Notify the affected user or Vendor.
• Record the complaint for compliance purposes.
• Take additional action where required or permitted by law.

Removal or restriction of content does not mean ATU has made a final legal determination that infringement occurred.

10. Notice to Affected User or Vendor

Where appropriate, ATU may notify the affected user or Vendor that content has been removed or restricted due to an intellectual property complaint.

ATU may provide the affected user or Vendor with:

• A copy or summary of the complaint.
• The name and contact information of the complaining party.
• Identification of the removed or restricted material.
• Information about available response procedures.
• Instructions for submitting a counter-notification, where applicable.

By submitting a DMCA Notice, the complaining party acknowledges that ATU may share information from the notice with the affected user or Vendor, legal counsel, service providers, authorities, or others as required or permitted by law.

11. DMCA Counter-Notification Procedure

If a user or Vendor believes that material was removed or disabled due to mistake or misidentification, the user or Vendor may submit a DMCA Counter-Notification where permitted by applicable law.

A valid Counter-Notification should include:

A. Identification of Removed Material

A description of the material that was removed or disabled and the location where the material appeared before removal.

B. Good Faith Statement

A statement under penalty of perjury that the user or Vendor has a good faith belief that the material was removed or disabled as a result of mistake or misidentification.

C. Contact Information

The user’s or Vendor’s contact information, including:

• Full legal name.
• Mailing address.
• Telephone number.
• Email address.

D. Jurisdiction Consent

A statement consenting to the jurisdiction of the appropriate federal court as required under applicable law.

For users located outside the United States, this may require consent to jurisdiction in a U.S. federal judicial district where ATU may be found, subject to legal counsel’s review.

E. Signature

A physical or electronic signature of the user, Vendor, or authorized representative.

12. Review of Counter-Notifications

Upon receipt of a valid Counter-Notification, ATU may:

• Review the submission.
• Forward the Counter-Notification to the original complaining party.
• Maintain removal or restriction of the content.
• Restore the content where legally permitted.
• Continue suspension or restriction where other policy violations, legal risks, or Platform concerns exist.
• Request additional information before taking action.

Where required by applicable law, ATU may restore removed material after the applicable waiting period unless the original complaining party notifies ATU that legal action has been filed to restrain the user or Vendor from restoring or relisting the material.

ATU is not required to restore content if the content also violates another ATU policy, creates legal risk, involves counterfeit goods, concerns non-copyright intellectual property rights, or otherwise threatens Platform trust or safety.

13. Withdrawals of Complaints

A complaining party may withdraw an intellectual property complaint by providing written notice to ATU.

A withdrawal should clearly identify:

• The original complaint.
• The affected user or Vendor.
• The specific listing, content, or URL.
• The complaining party’s name and contact information.
• A clear statement that the complaint is withdrawn.

ATU may verify the withdrawal before restoring content or changing account status.

Withdrawal of a complaint does not guarantee restoration of content, removal of enforcement history, or reinstatement of an account.

14. Trademark, Counterfeit, and Other Intellectual Property Complaints

Trademark owners, brand owners, authorized representatives, and other rights holders may submit complaints involving:

• Trademark infringement.
• Counterfeit goods.
• Unauthorized replicas.
• Unauthorized brand use.
• Misleading reseller claims.
• Unauthorized use of logos, brand names, or trade dress.
• False claims of partnership, certification, sponsorship, distribution, or authorized reseller status.
• Patent, design, or other intellectual property concerns.

Trademark, counterfeit, patent, design, and non-copyright complaints should be submitted to:

ATU may request proof of ownership, proof of authorization, trademark registration details, product authenticity evidence, brand enforcement documentation, or other information needed to review the complaint.

DMCA counter-notification rights may not apply to trademark, counterfeit, patent, design, or non-copyright complaints.

15. Repeat Infringer Policy

ATU maintains a repeat infringer policy.

ATU may suspend, restrict, or terminate users or Vendors who are subject to repeated or multiple intellectual property complaints, repeated takedowns, repeated counterfeit claims, repeated copyright reports, repeated trademark complaints, or other repeated rights violations.

ATU may consider the following when evaluating repeat infringement:

• Number of complaints.
• Nature of the alleged infringement.
• Seriousness of the violation.
• Pattern of conduct.
• Whether complaints were resolved or withdrawn.
• Whether the Vendor cooperated.
• Whether the Vendor attempted to relist removed content.
• Whether related accounts were used to avoid enforcement.
• Whether the Vendor submitted false or misleading information.

ATU may also restrict or terminate accounts that ATU believes are associated with or controlled by a previously terminated or suspended user or Vendor.

16. Anti-Counterfeit and Marketplace Integrity

ATU prohibits counterfeit, fake, replica, unauthorized, stolen, or infringing goods.

Vendors must ensure that all products they list are authentic and lawfully sourced.

ATU may remove listings, request invoices or supplier records, require authenticity documentation, suspend Vendor accounts, restrict categories, or terminate Vendors where ATU suspects counterfeit or infringing activity.

Vendors may not use phrases such as “replica,” “copy,” “inspired by,” “mirror quality,” or similar wording to avoid responsibility for counterfeit or infringing listings.

17. Misuse of Reporting Procedures

ATU prohibits misuse of intellectual property reporting procedures.

A party may not submit false, fraudulent, abusive, bad-faith, misleading, incomplete, or retaliatory complaints or counter-notifications.

ATU may take action against parties who misuse this Policy, including:

• Rejecting the complaint or counter-notification.
• Suspending accounts.
• Terminating accounts.
• Restricting Platform access.
• Referring the matter to legal counsel.
• Seeking damages or other legal remedies where permitted by law.

A party who knowingly submits a false DMCA Notice or Counter-Notification may be liable for damages under applicable law.

18. No Legal Advice

ATU does not provide legal advice to users, Vendors, rights holders, or complaining parties.

Users and Vendors should consult qualified legal counsel if they are unsure whether their content, listings, products, services, trademarks, images, text, videos, software, music, artwork, or brand references infringe another party’s rights.

19. Record Retention

ATU may retain records relating to:

• DMCA Notices.
• Counter-Notifications.
• Intellectual property complaints.
• Trademark complaints.
• Counterfeit reports.
• Vendor responses.
• Withdrawals.
• Investigations.
• Enforcement actions.
• Account suspensions or terminations.
• Communications with parties.
• Legal or compliance review.

Records may be retained for legal, compliance, audit, accounting, security, fraud prevention, dispute resolution, and business purposes.

20. Privacy and Information Sharing

ATU may share information from DMCA Notices, Counter-Notifications, intellectual property complaints, and related communications with:

• The affected user or Vendor.
• The complaining party.
• ATU’s legal counsel.
• ATU’s service providers.
• Payment processors or platform partners, where relevant.
• Law enforcement, regulators, courts, or government authorities where required or permitted by law.

Information may be processed in accordance with ATU’s Privacy Policy.

21. Safe Harbor Compliance

ATU intends to maintain compliance with applicable safe harbor provisions of the Digital Millennium Copyright Act and similar notice-and-takedown frameworks where applicable.

Nothing in this Policy creates any obligation beyond those required by applicable law or expressly accepted by ATU in writing.

ATU reserves all rights, defenses, remedies, and protections available under applicable law.

22. Limitation of Liability

To the maximum extent permitted by law, ATU shall not be liable for:

• Removal of content.
• Disabling access to content.
• Refusal to remove content.
• Delay in processing notices.
• Delay in processing counter-notifications.
• Account suspension.
• Account termination.
• Listing restrictions.
• Vendor disputes.
• Rights holder disputes.
• Mistaken or fraudulent complaints submitted by third parties.
• User or Vendor intellectual property violations.

Users, Vendors, and rights holders are responsible for resolving ownership, licensing, authorization, and infringement disputes directly where appropriate.

23. Changes to This Policy

ATU may update or modify this Policy from time to time.

When changes are made, ATU may update the “Last Updated” date, post the revised Policy on the Platform, and take any other steps required by applicable law.

Continued use of the Platform after changes are posted constitutes acceptance of the revised Policy.

24. Governing Law

This Policy shall be governed by the laws of the State of Delaware, applicable United States federal intellectual property laws, and any other laws that may apply based on the rights asserted, the parties involved, or the location of the activity.

25. Contact Information

Questions about this Policy may be directed to:

Copyright complaints should be sent to ATU’s designated copyright agent listed in Section 6.

Trademark, counterfeit, and other intellectual property complaints should be sent to the Intellectual Property Compliance Department listed in Section 14.