A safe harbor that cannot inspect what it carries.

AION is in the process of registering its Designated Agent with the U.S. Copyright Office’s DMCA Designated Agent Directory under 17 U.S.C. § 512(c)(2). Filing is paired with the registration of sealedaion.comand the publication of the cryptographic library at the close of Phase 1. Until then, the procedures below are AION’s good-faith equivalent and no public takedown channel is available. The substantive rules — what a notice must contain, what a counter-notice accomplishes, what AION will and will not do — do not change after registration.

Revision:v0.2 · 2026-05-03Status:Pending — domain + Copyright Office filingsChannel today:none published

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.

What AION can do, on receipt of a properly formatted notice, is identify and remove the routing record for a specific Vault by Vault ID, suspend the User’s ability to access the Vault, terminate a User account for repeat infringement, and report aggregate notice volumes in the transparency report. AION cannot confirm what was sealed, cannot produce plaintext, and cannot identify users by 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. No public DMCA channel is available. AION operates no service that hosts third-party-readable content; the Vaults visible to AION are ciphertext that AION cannot inspect. A rightsholder seeking takedown of a specific Vault must wait for the channels below to open.
• After mail routing is verified. dmca@sealedaion.com with the subject line “DMCA Notice — [Vault ID]”. Forwarding may still propagate after MX setup; mail sent before verification may not be received.
• 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; the agent designation is a public record at dmca.copyright.gov.

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. Suspend the User’s access to the identified Vault.
3. Notify the User of the takedown with the complete notice (subject to redaction of the complainant’s contact information per the User’s privacy rights), the Vault ID, and the procedure for filing a counter-notice under § 512(g).
4. If a valid counter-notice is received within ten (10) to fourteen (14) business days, restore access unless the original complainant has filed a court action seeking to restrain the User’s use of the material.
5. Record the notice and resolution in the next transparency report at the aggregate level.

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.

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.

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.