Draft — pending legal review. This document is not yet effective and may change before launch.
EAI Young Developer · Digital Millennium Copyright Act (DMCA) Policy
Status: Draft v1.0 (initial publication-ready draft) · pending external counsel review
Effective Date: [TBD upon launch]
Last Updated: 2026-05-29
Version: v1.0 (Initial publication-ready draft, pending external counsel review)
Operator: [FF US Subsidiary Legal Entity Name] (the "Platform," "we," "us," or "our")
Scope: This Policy applies to the website eai-kids.com and all subdomains, applications, and services operated by the Platform, and to all user-generated content ("Skills") published, transmitted, stored, or otherwise made available through those services.
§1. Overview and Safe Harbor Stance
This Policy implements the notice-and-takedown framework of the United States Digital Millennium Copyright Act, 17 USC §512(c) (the "DMCA"). It describes how copyright owners (or their authorized agents) may notify us of allegedly infringing material on the Platform, how we respond, how affected users may counter-notify, and how we handle repeat infringers.
The Platform operates as an "online service provider" within the meaning of 17 USC §512(k) and intends to qualify for the limitation on liability provided by 17 USC §512(c) (the "safe harbor"). To that end, we have designated an agent to receive notifications of claimed infringement, registered that agent with the United States Copyright Office DMCA Designated Agent Directory, adopted and reasonably implemented this Policy (including the repeat-infringer provisions of §6 below), and accommodated standard technical measures, all as required by 17 USC §512(c) and §512(i).
A substantial portion of Platform users are minors between the ages of 5 and 17. We therefore apply heightened review whenever a DMCA notice — or our response to one — may affect a minor user's account, identity, or published work. Section §9 sets out those additional protections.
This Policy is not legal advice. Submitting a DMCA notice or counter-notification carries real legal consequences, including potential liability under 17 USC §512(f) for knowing material misrepresentations. Consult an attorney if you are unsure whether the conduct at issue constitutes copyright infringement.
§2. Submitting a DMCA Infringement Notice
If you are a copyright owner, or an agent authorized to act on behalf of a copyright owner, and you have a good-faith belief that material accessible on or through the Platform infringes your copyright, you may submit a written notification to our Designated Agent (see §3 below).
To be effective under 17 USC §512(c)(3)(A), your notification must include all six (6) of the following elements. A notification that materially fails to comply with these requirements will not be deemed effective and may not give rise to actual or red-flag knowledge on the part of the Platform under 17 USC §512(c)(1).
(a) Signature. A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed. A typed name in an email sent from the address listed under (d) is sufficient.
(b) Identification of the Copyrighted Work. Identification of the copyrighted work claimed to have been infringed. If the notification covers multiple works at a single online site, a representative list may be provided. Where helpful, include registration numbers, publication dates, and the location of an authoritative copy of the original.
(c) Identification and Location of the Allegedly Infringing Material. Identification of the material claimed to be infringing or to be the subject of infringing activity, with information reasonably sufficient to permit the Platform to locate it. Provide the complete URL of each item, in the form https://eai-kids.com/projects/<skill_id> or https://eai-kids.com/users/<username>/projects/<skill_id>, and, where only a portion of a published Skill is alleged to infringe, identify that portion as specifically as possible (for example, the function name, block stack, or code excerpt).
(d) Contact Information of the Complaining Party. Information reasonably sufficient to permit the Platform to contact you, including: a mailing address; a telephone number; and, if available, an electronic mail address.
(e) Good-Faith Statement. A statement that you have a good-faith belief that the use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.
(f) Statement Under Penalty of Perjury. A statement that the information in the notification is accurate, and, under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
Where to send. Notifications may be transmitted by email or by mail using the channels in §3 below. Email is strongly preferred; it accelerates triage and allows us to forward the notice to the affected user (subject to the additional protections in §9) within the timeframe contemplated by the DMCA. Notifications submitted through general support channels, social-media accounts, or web forms other than those designated below may not be reviewed and may not give rise to our processing obligations under 17 USC §512(c).
Notice on the UGC scope. Every Skill published on the Platform is licensed by its author under the Creative Commons Attribution-ShareAlike 4.0 International License ("CC BY-SA 4.0"); users may download, study, modify, and republish Skills as "Remixes" so long as they preserve attribution and continue to license the resulting work under CC BY-SA 4.0. As a result, many Skills exist as part of a Remix chain in which a single original has been adapted by many authors. If you believe a Skill infringes your copyright, identify the specific node in the chain that is the subject of your complaint; a generic complaint targeting "all Remixes of Skill X" will normally be insufficiently specific under 17 USC §512(c)(3)(A)(iii) and will be returned for clarification. See §4 regarding our treatment of Remix chains during takedown.
Media-upload scope. The Platform does not accept user-uploaded images, video, audio, or 3D models. Users may include only block- or text-based code and references to the Platform-provided preset asset library. Notifications that concern user-uploaded media are unlikely to identify content hosted by the Platform, and we will respond accordingly.
§3. Designated Agent
Pursuant to 17 USC §512(c)(2) and 37 CFR §201.38, the Platform has designated the following individual to receive notifications of claimed infringement. The Designated Agent is registered with the United States Copyright Office DMCA Designated Agent Directory at https://www.copyright.gov/dmca-directory/ and the registration is renewed on the three-year cycle required by 17 USC §512(c)(2)(A) and the Copyright Office's implementing regulations.
| Item | Information |
|---|---|
| Service Provider Name | EAI Young Developer |
| Legal Entity Operating the Service | [FF US Subsidiary Legal Entity Name] |
| Designated Agent Name | [Designated Agent Name] |
| Title | DMCA Designated Agent |
| Mailing Address | [Designated Agent Mailing Address] |
| Telephone | [Designated Agent Phone] |
dmca@eai-kids.com |
|
| Copyright Office Directory Status | Registered; renewed every three (3) years as required by 17 USC §512(c)(2) and 37 CFR §201.38 |
If any of the information above changes, we will update the Designated Agent registration with the Copyright Office and revise this Policy within thirty (30) days of the change. Only notifications delivered to the Designated Agent at one of the channels listed above will be deemed served on the Platform for purposes of the DMCA; notifications delivered to other persons, addresses, or channels may not trigger our processing obligations and may not be timely reviewed.
§4. Response to a Valid Notice
Upon receipt of a notification that, on its face, satisfies the requirements of 17 USC §512(c)(3)(A), the Platform will act expeditiously to remove or disable access to the material identified in the notification, generally within seven (7) business days of receipt.
Promptly after taking down or disabling access to the material, we will:
- Record the takedown in the affected user's account audit log;
- Take reasonable steps to notify the affected user of the takedown, the identity of the complaining party, and the substance of the notification, except to the extent necessary to comply with applicable law or to protect a minor user (see §9 below); and
- Provide the affected user with a copy of this Policy, a summary of the counter-notification procedure in §5 below, and a clear explanation of the user's right to submit a counter-notification.
For accounts belonging to minor users, notice of the takedown and a copy of the DMCA notification (redacted as necessary to protect the minor's identity) will be sent to the registered Parent Email address rather than to the minor user directly. The Parent Email channel is the exclusive channel for DMCA-related communications concerning minor accounts.
Effect on Remix chains. Each Skill is a separate work for purposes of this Policy, even where derived from another Skill through the Remix function. Taking down a parent Skill does not, by itself, take down child Skills derived from it; downstream Remixes are evaluated separately on the facts and on the scope of the underlying notification. Where a Remix chain is implicated, we may (i) label affected chain nodes to indicate that an upstream work is the subject of a pending or completed takedown, (ii) ask the complaining party to clarify which specific nodes are alleged to infringe, and (iii) restrict further Remix branching from an affected node pending resolution.
Facially defective notices. Notifications that are incomplete, ambiguous, or that fail to identify the allegedly infringing material with the specificity required by 17 USC §512(c)(3)(A)(iii) will be returned with an explanation of the deficiency. Such notifications are not effective under the DMCA, do not give rise to actual or red-flag knowledge, and do not, standing alone, result in removal.
§5. Counter-Notification Procedure
If you are a Platform user, and material you posted was removed or disabled in response to a DMCA notification, and you have a good-faith belief that the material was removed or disabled as a result of mistake or misidentification, you may submit a written counter-notification to our Designated Agent.
To be effective under 17 USC §512(g)(3), your counter-notification must include all six (6) of the following elements:
(a) Signature. A physical or electronic signature of the subscriber.
(b) Identification of the Material. Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled.
(c) Good-Faith Statement Under Penalty of Perjury. A statement under penalty of perjury that the subscriber has a good-faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled.
(d) Name, Address, and Telephone Number. The subscriber's name, address, and telephone number.
(e) Consent to Jurisdiction. A statement that the subscriber consents to the jurisdiction of the Federal District Court for the judicial district in which the address is located, or, if the subscriber's address is outside of the United States, for any judicial district in which the Platform may be found.
(f) Consent to Service. A statement that the subscriber will accept service of process from the person who provided notification under 17 USC §512(c)(1)(C), or an agent of such person.
Important warning. Element (e) is a binding consent to United States federal-court jurisdiction. Filing a counter-notification is a serious legal commitment: the original complaining party may file suit against you, and, if they do, you will have agreed in advance to litigate in the specified federal forum. Do not file a counter-notification unless you understand and accept this consequence. Consult an attorney if you are unsure.
Counter-notifications involving minor users. A user under the age of 18 may not, acting alone, submit a binding counter-notification under 17 USC §512(g)(3), because the consent to federal-court jurisdiction in element (e) cannot ordinarily be given by a minor. Where the affected account belongs to a minor user, a counter-notification must be submitted by the registered parent or legal guardian on the minor's behalf, from the Parent Email on file. The counter-notification must state the parent or guardian's name, the minor's account identifier, the parent or guardian's authority to act for the minor, and the parent or guardian's own consent to federal-court jurisdiction.
Where to send. Counter-notifications must be transmitted to the Designated Agent at dmca@eai-kids.com (preferred) or to the mailing address listed in §3.
What happens next. Upon receipt of an effective counter-notification, we will promptly provide a copy to the person who submitted the original notification, advise them that we will restore the affected material or cease disabling access to it in ten (10) to fourteen (14) business days, and restore the material or cease disabling access to it within that window — unless our Designated Agent first receives notice from the original complaining party that they have filed an action seeking a court order to restrain the user from engaging in infringing activity relating to the material on the Platform. If such notice of suit is received, the material will remain removed or disabled pending the outcome of the court proceeding. If no notice of suit is timely received, the material may be restored and the affected user's account will be so notified.
§6. Repeat Infringer Policy (17 USC §512(i))
The Platform has adopted, and reasonably implements, a policy that provides for the termination, in appropriate circumstances, of users who are repeat infringers, as required by 17 USC §512(i)(1)(A). Our standard implementation is a three-strike model. Each "strike" corresponds to a completed takedown in response to a facially compliant DMCA notification that was not successfully reversed by counter-notification or court order.
Strike 1 — Notice and Warning. The material is removed or disabled. The takedown is recorded in the account audit log. A formal warning is delivered to the affected user (for minor accounts, to the registered Parent Email), explaining the strike, the substance of the underlying notification, this Policy, and the user's counter-notification rights.
Strike 2 — Suspension and Escalated Notice. The material is removed or disabled. The account is suspended for seven (7) days, during which the user cannot publish, Remix, or comment. An escalated notice is delivered to the registered email address and, for minor accounts, to the Parent Email, explaining that one further strike will result in permanent termination.
Strike 3 — Termination. The material is removed or disabled. The account is permanently terminated. The registered email address and, where applicable, the underlying device fingerprint are added to a registration blacklist designed to prevent the same user from creating a replacement account. The terminated user's previously published Skills may be removed or relabeled, with appropriate respect for the rights of downstream Remixers.
Rescission. Where a strike was assessed in response to a takedown later reversed by a successful counter-notification under §5 or by a court order, the strike is rescinded and removed from the account's strike count. If rescission causes an active suspension or termination to fall below the threshold for that consequence, the suspension or termination is lifted as promptly as reasonably practicable.
Egregious or commercial-scale conduct. The Platform reserves the right, in its sole discretion, to terminate immediately, without prior warning or progressive discipline, accounts engaged in egregious, willful, or commercial-scale infringement — including coordinated mass-republication of third-party works, circumvention of prior takedowns, or use of the Platform as a redistribution channel for known pirated materials.
Coordination with Community Guidelines. This repeat-infringer policy is a separate enforcement track from the moderation regime in Community Guidelines, which addresses safety, harassment, and other non-copyright conduct under 47 USC §230 and our internal standards. A DMCA strike is not, by itself, a Community Guidelines violation, and vice versa. Where a single course of conduct gives rise to both, each track proceeds independently and consequences may be cumulative.
Account-level escalation interlocks. Where a Strike 2 or Strike 3 outcome affects a minor user's account, the appeals procedure in Youth Developer Agreement §5A is available to the registered parent or legal guardian with respect to the account-level consequence (suspension or termination), without prejudice to the user's separate counter-notification rights under §5. The §5A procedure does not extend the statutory ten-to-fourteen-business-day counter-notification window; the two tracks proceed in parallel.
§7. Misrepresentation Liability (17 USC §512(f))
Under 17 USC §512(f), any person who knowingly materially misrepresents (i) that material or activity is infringing, or (ii) that material or activity was removed or disabled by mistake or misidentification, is liable for any damages, including costs and attorneys' fees, incurred by the alleged infringer, by any copyright owner or its authorized licensee, or by the Platform, as a result of the Platform's reliance on that misrepresentation.
We take §512(f) seriously. Where the Platform itself incurs damages or costs from a knowing material misrepresentation in a DMCA notice or counter-notification, we may seek to recover them directly. We may also refer the matter to affected copyright owners or users so that they may pursue their own §512(f) remedies, and we may decline to process future notifications from a sender we have determined to be a repeat misrepresenter.
§8. Trademark, Patent, and Other Intellectual Property Complaints
This Policy implements the notice-and-takedown procedure of the DMCA, which addresses copyright infringement only. It does not govern, and is not the correct channel for, complaints concerning:
- Trademark infringement (including allegations that a username, project name, or in-Skill text infringes a registered or unregistered trademark);
- Patent infringement (including allegations that a Skill implements a method or system covered by a patent);
- Right of publicity or privacy (including allegations that a Skill uses the name, likeness, voice, or other indicia of identity of a real person without consent);
- Trade-secret misappropriation; or
- Other forms of intellectual-property or proprietary-rights complaints not arising under United States copyright law.
Please direct complaints of these kinds to legal@eai-kids.com. To allow us to process such a complaint efficiently, include at minimum: (i) the identity of the right-holder; (ii) the specific right asserted and, where applicable, the registration or application number; (iii) the URL or other identifying information for the specific Platform content alleged to violate the right; (iv) a clear description of the violation; (v) a good-faith statement that the use is not authorized by the right-holder, its agent, or the law; and (vi) the complainant's contact information and signature. We may request additional information before acting.
§9. Special Considerations for Minor Users
A substantial portion of Platform users are minors between the ages of 5 and 17. We apply the following additional protections to any DMCA matter that involves a minor user, in coordination with our COPPA Direct Notice and Privacy Policy.
No public exposure of minor identity. We will not publish a DMCA notification, counter-notification, or related correspondence in a form that reveals the identity of a minor user. Where we maintain a public-facing record of takedowns (for example, in transparency-reporting or audit-log surfaces), entries that concern minor accounts are redacted to remove the minor's username, real name, parent name, email addresses, and any other reasonably identifying information.
Segregated handling of minor-user records. Identifying information of minor users in DMCA records is held separately from the public-facing audit log and is accessible only to personnel with a legitimate need to know for purposes of compliance, dispute resolution, or response to lawful process.
Parent Email is the exclusive channel. All DMCA-related communications concerning a minor account — including takedown notices, requests for additional information, transmittal of the complaining party's notification, and strike-assessment notices under §6 — are routed to the registered Parent Email. In-Platform notifications to the minor are limited to neutral statements that a parent communication has been sent and that the affected work is currently unavailable.
Parent-led counter-notification and appeals. Counter-notifications on behalf of a minor user must be submitted by the registered parent or legal guardian from the Parent Email on file (see §5). The account-level consequences of Strike 2 and Strike 3 — suspension and termination, as distinct from the underlying takedown — may be appealed by the parent or guardian under Youth Developer Agreement §5A. That procedure does not affect the user's separate counter-notification rights or the statutory timetable under 17 USC §512(g); the two tracks proceed in parallel.
Coordination with COPPA disclosures. Information collected or retained in the course of processing a DMCA matter involving a minor user is treated as personal information of that minor under our COPPA-compliant practices and is disclosed and retained on the bases set forth in our Privacy Policy and COPPA Direct Notice.
§10. Policy Modifications
We may modify this Policy from time to time, including in response to changes in applicable law, Platform operations, or industry best practices. Modifications take effect on the Effective Date stated in the revised Policy's header. We will post the revised Policy at the Platform's standard policy URL not less than seven (7) days before the new Effective Date, except where a shorter notice period is required by law or to address an urgent legal, security, or child-safety concern.
Where a modification materially affects user rights or obligations — including changes to the repeat-infringer thresholds in §6, the Designated Agent in §3, or the minor-user protections in §9 — we will additionally notify registered users by in-account notice and, for minor accounts, by email to the Parent Email on file. Continued use after the new Effective Date constitutes acceptance. The version history is maintained in the Platform's policy archive and is available on request from legal@eai-kids.com.
§11. Contact
DMCA Designated Agent (for copyright matters only).
| Item | Information |
|---|---|
| Service Provider | EAI Young Developer |
| Legal Entity | [FF US Subsidiary Legal Entity Name] |
| Designated Agent | [Designated Agent Name] |
| Mailing Address | [Designated Agent Mailing Address] |
| Telephone | [Designated Agent Phone] |
dmca@eai-kids.com |
|
| U.S. Copyright Office Directory | https://www.copyright.gov/dmca-directory/ |
General intellectual-property contact (for non-DMCA matters, including trademark, patent, publicity-rights, and trade-secret complaints): legal@eai-kids.com.
Companion documents.
- Terms of Service
- Privacy Policy
- COPPA Direct Notice
- Community Guidelines
- Cookies Notice
- Youth Developer Agreement
- Youth Developer Code of Conduct
Version and Effective Date
| Field | Value |
|---|---|
| Version | v1.0 (Initial publication-ready draft, pending external counsel review) |
| Status | Draft — Pending Final Review and Sign-Off by External Counsel |
| Effective Date | [TBD upon launch] |
| Last Updated | 2026-05-29 |
| Operator | [FF US Subsidiary Legal Entity Name] |
| Contact | dmca@eai-kids.com (copyright matters) · legal@eai-kids.com (other IP matters) |
This Policy is a publication-ready draft prepared for external counsel review. Placeholders bracketed in [ ] must be populated by the legal entity before publication. This Policy does not constitute legal advice.