A safe harbor that cannot inspect what it carries.

The Operator has not yet registered a Designated Agent with the U.S. Copyright Office’s DMCA Designated Agent Directory under 17 U.S.C. § 512(c)(2), and so does not yet claim the § 512(c) safe harbor. Until that registration is filed, the procedures below are a good-faith interim process, not a statutory safe harbor. The substantive rules — what a notice must contain, what a counter-notice accomplishes, what the Operator will and will not do — do not change after registration; only the safe-harbor status does.

Revision:v0.3 · 2026-05-29Status:Not registered — § 512(c) safe harbor not yet claimedChannel today:mail@sealedaion.com (interim)

AION cannot identify the work allegedly infringed. AION holds ciphertext, not plaintext. The Vault stores an AES-256-GCM-encrypted blob whose key is split across seven sovereign holders; AION’s servers cannot reconstruct the key, cannot decrypt the blob, and cannot inspect the contents. This is established by the cryptographic primitives at the commit hash recorded in the User’s Gate acceptance and is asserted at Terms § 3 as the Cryptographic Incapacity Doctrine.

In the current client-only release the Operator hosts no accounts and no server-side Vault storage. The only material the Operator actually hosts is its own website pages, and a takedown can reach only material the Operator in fact hosts. When accounts and server-side routing ship (Phase 3), the Operator will additionally be able to remove the routing record for a specific Vault by Vault ID, suspend a User’s ability to access a Vault, terminate a User account for repeat infringement, and report aggregate notice volumes in a transparency report. In every case the Operator cannot confirm what was sealed, cannot produce plaintext, and cannot identify users by the content of their Vaults.

The DMCA Designated Agent for AION is the Maintainer of Record. Notices must be in writing and include each element listed in § 3. Acceptable channels:

• Today (interim). Send notice to mail@sealedaion.com with the subject line “DMCA Notice”. The current client-only release hosts no accounts or server-side Vault storage; a takedown can reach only material the Operator in fact hosts, such as a website page. Vault ciphertext is not inspectable and cannot be selectively removed by content.
• When provisioned. A dedicated dmca@ agent address and a U.S. Copyright Office designated-agent filing will be published here; until then the interim address above is the live channel.
• Mail. Postal address will be filed with the U.S. Copyright Office Designated Agent Directory when the legal/mail channel is ready and republished here on filing.

The Designated Agent fee is paid annually to the Copyright Office, and the agent designation becomes a public record at dmca.copyright.gov, once the Operator files its registration. That filing has not yet been made.

Pursuant to 17 U.S.C. § 512(c)(3), a valid notice must include each of the following elements. A notice missing any element will be acknowledged but not acted on, and the deficiency will be identified.

1. A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
2. Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works.
3. Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit the service provider to locate the material — for AION, this is the Vault ID.
4. Information reasonably sufficient to permit the service provider to contact the complaining party (an address, telephone number, and, if available, an electronic mail address).
5. A statement that the complaining party has a good-faith belief that use of the material in the manner complained of is not authorized 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 complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

AION’s response on receipt of a complete notice:

1. Acknowledge receipt to the complainant within five (5) working days, with a notice ID for tracking.
2. Disable access to or remove the identified material that the Operator in fact hosts (today, a website page). When server-side Vaults ship (Phase 3), this step also suspends access to the identified Vault.
3. Where there is an affected User to notify (Phase 3), notify that User of the takedown with the complete notice (subject to redaction of the complainant’s contact information per the User’s privacy rights), the affected location or Vault ID, and the procedure for filing a counter-notice under § 512(g).
4. Promptly forward any valid counter-notice to the original complainant. Under § 512(g)(2)(C), the Operator then restores the material in not less than ten (10) nor more than fourteen (14) business days after forwarding, unless the original complainant first notifies the Operator that it has filed a court action seeking to restrain the User’s infringing activity.
5. Record the notice and resolution at the aggregate level in a transparency report once such reporting exists (Phase 3).

AION will not voluntarily disclose plaintext, keys, or memory answers in connection with a notice; AION cannot. If a User wishes to demonstrate non-infringement, the User may unseal their own Vault and provide the plaintext to the complainant directly. AION’s role ends at the routing record.

Pursuant to 17 U.S.C. § 512(g)(3), a counter-notice must include:

1. The User’s physical or electronic signature.
2. 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 — for AION, the Vault ID.
3. A statement under penalty of perjury that the User has a good-faith belief that the material was removed or disabled as a result of mistake or misidentification.
4. The User’s name, address, and telephone number, and a statement that the User consents to the jurisdiction of the federal district court for the judicial district in which the address is located, or, if the User’s address is outside of the United States, for any judicial district in which AION may be found, and that the User will accept service of process from the original complainant or its agent.

A material misrepresentation in either a notice or a counter-notice is actionable under § 512(f). AION will cooperate with such actions to the limited extent technically possible.

Once accounts ship (Phase 3), a User account associated with three (3) substantiated DMCA notices within twelve (12) months will be terminated. “Substantiated” means the User did not file a valid counter-notice, or filed a counter-notice that was followed by a court order preserving the takedown. The underlying ciphertext remains subject to the same Sunset on Notice and Cessation Protocol rules as any other Vault — no special disposition. In the current client-only release there are no accounts to terminate; this policy takes effect when accounts exist.

The DMCA was written for visible content. AION is built so that no content is visible to the operator. AION honors the framework on its terms, but a complainant seeking to use AION for content moderation will find the tooling unhelpful: AION cannot tell whether a given Vault contains the work claimed. The notice procedure produces removal of the routing record, not removal of infringing material as such. The complainant who needs content removed must reach the User who sealed it.

This is not a defect of AION’s implementation. It is the consequence of operating a privacy-preserving cryptographic substrate at all. The framework is honored because the statute requires it; the framework is honest because AION cannot pretend otherwise.