How the Steam DMCA Process Works
When a Workshop item is taken down under the Digital Millennium Copyright Act, the mod publisher faces a situation that is both time-sensitive and procedurally specific. Getting the response wrong — either by ignoring the notice or by escalating prematurely — produces worse outcomes than following the process correctly. This article documents the Steam Workshop DMCA process as 57 Studios™ understands it from its own experience as a Workshop publisher for Unturned™ mods, combined with the statutory framework that governs all online platform takedowns in the United States.
The article is structured in order: the legal framework first, then the mechanics of a takedown notice, then the counter-notification process, and finally the practical documentation practices that make the whole process manageable. A modder who has never dealt with a DMCA notice before should read this article linearly. A modder who has received a specific notice and needs the counter-notification steps immediately can jump to the Counter-Notification Process section.
The article draws on 57 Studios™' own experience as a Workshop publisher and commercially active Tebex seller. Unturned™ mods distributed through both channels represent meaningful commercial activity, and the legal framework that governs them is not something to navigate informally. This documentation reflects the approach 57 Studios has developed over time through direct engagement with the DMCA process — including cases where notices were received, cases where deficient notices were identified, and cases where counter-notifications were filed and succeeded.
How to use this article
This article is structured for two reading modes. A modder who has never encountered a DMCA notice and wants to understand the framework should read linearly from the beginning. A modder who has received a specific notice and needs to act immediately should jump directly to Counter-notification process, then return to the earlier sections to understand the framework that informs each step.
Key reference materials are in the appendices: Appendix A is the notice elements checklist, Appendix B is the counter-notification elements checklist, and Appendix C is the asset log template that makes future audits faster.
This is not legal advice
This article documents how the DMCA process works based on 57 Studios' experience and the published statutory framework. It is not legal advice and does not create an attorney-client relationship. If you are facing a takedown notice with material financial stakes, consult a qualified attorney before filing a counter-notification.
What the DMCA is and why it applies to Steam Workshop
The Digital Millennium Copyright Act is a United States federal statute enacted in 1998. Among its provisions is a safe harbor framework — codified at 17 USC § 512 — that allows online platforms to host user-generated content without bearing direct liability for copyright infringement, provided the platform meets certain conditions. One of those conditions is maintaining a functioning notice-and-takedown system: when a rights holder sends a qualifying takedown notice, the platform must act expeditiously to remove or disable access to the identified content.
Steam is an online platform operated by Valve Corporation. The Steam Workshop is the user-generated content distribution layer within that platform. When Workshop items include content that a rights holder claims infringes their copyright, the Steam Workshop DMCA process is the mechanism through which that dispute is processed. Valve qualifies for the 17 USC § 512 safe harbor, which means its standard operating procedure is to remove content when it receives a valid notice, without adjudicating the underlying dispute itself.
This is the structural reason why Valve does not perform independent copyright analysis before acting on a takedown notice. The safe harbor requires expeditious removal; it does not require Valve to determine whether the claimed infringement actually occurred. That determination happens later, through the counter-notification process or through litigation — not at the moment of removal.
Elements of a valid DMCA takedown notice
Under 17 USC § 512(c)(3), a takedown notice must contain six elements to be legally valid. If a notice is missing any of these elements, the platform is not required to act on it, and the rights holder cannot claim the platform failed to comply with a qualifying notice.
| Element | What it must contain |
|---|---|
| Identification of the copyrighted work | A description of the work the claimant alleges has been infringed. For a game asset, this typically means the specific asset name, game, and rights holder. |
| Identification of the infringing material | The specific location of the alleged infringing content — the Workshop item URL, item ID, or other identifying information sufficient for Valve to locate it. |
| Contact information | The claimant's address, telephone number, and email address. |
| Good faith statement | A statement that the claimant has a good faith belief the use of the material is not authorized by the copyright owner, its agent, or the law. |
| Accuracy statement | A statement that the information in the notice is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner. |
| Signature | A physical or electronic signature of the person authorized to act on behalf of the copyright owner. |
What to check when you receive a notice
When 57 Studios receives a takedown notice, the first step is to verify whether it contains all six elements. A notice missing the "under penalty of perjury" language in the accuracy statement, or missing the good faith statement, may not be a legally valid notice. Document which elements are present and which are absent before deciding how to respond.
A notice that contains all six elements and results in a takedown is commonly called a "DMCA strike" or "takedown notice" in community shorthand. Those terms are informal; the statutory term is a notification of claimed infringement.
Valve's role as service provider
Valve's legal exposure is defined by its status as a service provider under 17 USC § 512. The safe harbor Valve relies on requires it to:
- Not have actual knowledge that the material is infringing, or not be aware of facts or circumstances from which infringing activity is apparent.
- Upon obtaining such knowledge or awareness, act expeditiously to remove or disable access to the material.
- Not receive a financial benefit directly attributable to the infringing activity.
- Respond expeditiously to remove material identified in a valid notice.
Because Valve's safe harbor depends on expeditious removal, it does not independently adjudicate whether a claim is valid before acting on a qualifying notice. Valve's takedown process is essentially procedural: a compliant notice arrives, the item is removed, the publisher is notified, the statutory clock starts.
What "expeditious" means in practice
Valve does not publish a specific SLA for takedown processing. In 57 Studios' observation, Workshop items identified in valid notices are typically disabled within one to five business days of the notice being processed. The range reflects the volume of notices Valve processes and whether the notice required any clarification.
Valve does maintain a designated DMCA agent registered with the United States Copyright Office, as required for service providers claiming the § 512 safe harbor. The agent information is published through the Copyright Office's DMCA Designated Agent Directory — the Steam Workshop DMCA documentation at partner.steamgames.com/doc/features/workshop provides the current contact pathway for submitting notices.
What happens to subscribers when a mod is taken down
When a Workshop item is disabled following a DMCA notice, the effects on subscribers are immediate and significant.
The specific effects on subscribers are:
| Effect | Timing |
|---|---|
| New downloads disabled | Immediately upon takedown |
| Workshop item page made unavailable or marked as removed | Immediately upon takedown |
| Existing local installs on subscriber machines | Not automatically removed — the files already on disk remain |
| Steam Workshop subscription | Subscription record retained; content inaccessible while item is down |
| Automated server content downloads (LGSM, SteamCMD) | Will fail if the item is part of a server download manifest |
| Restoration of access if counter-notification succeeds | After the 10-business-day counter-notification window |
The retention of local installs is a practical point that sometimes creates confusion: subscribers who downloaded the mod before the takedown retain their local copy. Steam does not reach back to subscriber machines and delete previously downloaded content. However, the item cannot be re-downloaded from the Workshop while it is disabled, and new subscribers cannot access it at all.
Server operators
If your Unturned™ server uses SteamCMD or a similar automated content pipeline to download Workshop mods on startup, a DMCA takedown of a required mod will cause server startup failures or incomplete content manifests. Maintaining a local archive of mod files provides a recovery path that does not depend on Workshop availability.
Restoration timelines
The restoration timeline depends entirely on which path the dispute takes after the publisher is notified.
| Scenario | Approximate Timeline |
|---|---|
| No counter-notification filed | Item remains removed indefinitely |
| Counter-notification filed; rights holder files suit within 10 business days | Item remains removed while litigation continues (months to years) |
| Counter-notification filed; rights holder does not file suit within 10 business days | Valve restores item, typically within 10–14 business days of filing the counter |
| Rights holder voluntarily retracts takedown | Valve restores upon receiving retraction; timing varies |
| Notice determined to be non-compliant before action | Item may not be removed at all, or may be restored quickly |
The 10-business-day window referenced above is the statutory period under 17 USC § 512(g)(2)(C): Valve must wait at least 10 business days, but not more than 14 business days, after receiving a valid counter-notification before restoring the content, unless it receives notice that the claimant has filed a lawsuit.
57 Studios' documented experience
In the cases where 57 Studios has filed counter-notifications and the claimant did not pursue litigation, Workshop items have been restored within the 10–14 business day window following the counter. In cases where the takedown notice was missing required elements and 57 Studios documented and communicated those deficiencies, the notices were withdrawn without proceeding to a counter-notification. Documentation practice makes a difference.
Common causes of DMCA takedowns in Unturned modding
Understanding the common causes of takedowns helps publishers identify risk before shipping, rather than after a notice arrives.
Asset reuse without authorization
The most common cause of a valid DMCA takedown against an Unturned™ mod is the inclusion of copyrighted assets without authorization. This includes:
- Textures, models, or audio extracted from another game and incorporated into the mod.
- Stock photography, illustrations, or graphic assets used outside the scope of the license under which they were obtained. "For personal use only" licenses do not typically cover commercial distribution on Tebex.
- Community-created assets (from another modder's Workshop item, a modding forum, or a Discord resource channel) used without the original creator's permission.
The 57 Studios™ asset workflow documented in Asset Licensing and Attribution addresses how to track asset provenance and license scope for every asset in a mod.
Music and audio IP
Music is one of the more consistent sources of automated copyright enforcement in the broader gaming content ecosystem. Mods that include ambient music, loading screen audio, or menu music derived from commercially licensed tracks are vulnerable to automated detection. The Steam Workshop does not use the same Content ID infrastructure as YouTube, but rights holders who discover infringing audio in Workshop items do file manual takedowns.
License scope on audio
Purchasing a "royalty-free" music track does not automatically authorize its inclusion in a redistributed mod on the Steam Workshop. Many royalty-free licenses restrict commercial redistribution. Read the full license terms for every audio asset, not just the headline description.
Real-world brand infringement
Weapon and vehicle mods sometimes incorporate real manufacturer logos, brand names, or trademarked imagery — a rifle texture with a real firearm manufacturer's logo on the receiver, or a truck mod with a real automaker's badge. Trademark law and copyright law both apply here. Rights holders for these brands actively monitor gaming platforms. This exposure is distinct from the game-asset-extraction scenario and does not require the claimant to be another game developer.
False or mistaken claims
Not every takedown notice reflects actual infringement. Automated rights-management systems used by some rights holders generate false positives. Manual notices sometimes identify the wrong Workshop item, or misidentify the copyrighted work. A counter-notification is the appropriate mechanism for addressing a false or mistaken claim. Filing a counter-notification for a claim that is genuinely false does not create liability for the publisher; the penalty-of-perjury language in the statute applies to the claimant, not the responder.
Responding to a takedown notice constructively
The period between receiving a takedown notice and deciding whether to file a counter-notification is where publishers can either reduce the damage or increase it. The following practices are what 57 Studios has documented as effective.
What to do immediately
- Document the notice in full. Copy the text of the notice, the date it was received, the Workshop item(s) identified, and the identity of the claimant (if provided). Store this documentation outside the Steam platform — the Workshop interface may change what you can see after the item is disabled.
- Verify the notice elements. Compare the notice against the six-element checklist in Elements of a valid DMCA takedown notice. Note any missing elements.
- Identify the claimed work. Read the notice carefully to understand what copyrighted work the claimant is asserting you have infringed. This is not always obvious from the notice; some notices identify works vaguely.
- Audit your asset sources. Review your asset documentation for the identified mod. Determine whether any asset in the mod could plausibly be the infringing material.
- Do not contact the claimant directly without legal guidance. Direct communication with a claimant can be used against you. If the claim appears false and you intend to fight it, the counter-notification process is the appropriate channel, not direct outreach.
Time is not unlimited
The DMCA process does not impose a strict deadline on the publisher for filing a counter-notification, but the item remains disabled for as long as no counter is filed. Every day the item is down is a day subscribers cannot access it and new subscribers cannot find it. Do not delay the audit and decision unnecessarily.
What to avoid
- Do not re-upload the mod under a different item ID in an attempt to circumvent the takedown. This is a violation of Steam's Terms of Service and can result in the account being suspended.
- Do not publicly accuse the claimant of fraud before completing the internal audit. If the claim turns out to be valid, public accusations of bad faith create additional legal exposure.
- Do not modify and re-upload a mod that contains genuinely infringing material without first removing the infringing material entirely. The claimant may file an additional notice.
- Do not assume the takedown notice is legally valid without verifying the elements. A deficient notice does not require a counter-notification; it may be addressable through direct communication with Valve.
Counter-notification process
A counter-notification is the formal mechanism under 17 USC § 512(g) through which a publisher disputes a takedown notice and requests restoration of their content. Filing a counter-notification triggers a specific statutory sequence.
Elements of a valid counter-notification
A counter-notification must contain the following elements under 17 USC § 512(g)(3):
| Element | Required content |
|---|---|
| Identification of the removed material | The specific Workshop item(s) removed, with sufficient detail for Valve to identify them (item ID, URL, title). |
| Statement under penalty of perjury | A statement that the subscriber has a good faith belief the material was removed or disabled as a result of mistake or misidentification. |
| Subscriber's contact information | Name, address, telephone number, and email address. |
| Consent to jurisdiction | A statement that the subscriber consents to the jurisdiction of the federal district court for the judicial district where the subscriber is located (or, for subscribers outside the US, any judicial district where Valve may be found). |
| Consent to accept service of process | A statement that the subscriber will accept service of process from the person who provided the takedown notice. |
| Signature | Physical or electronic signature. |
Step-by-step: filing a counter-notification
Step 1: Confirm your basis for filing. A counter-notification may be filed when you have a good faith belief the material was removed by mistake or misidentification. "Mistake" covers situations where the claimant incorrectly identified your item. "Misidentification" covers situations where your item does not actually contain the copyrighted work the claimant identified. Filing a counter-notification for material that genuinely infringes a copyright, and doing so knowingly, creates legal exposure.
Step 2: Draft the counter-notification document. The counter-notification is a written statement containing the six elements above. 57 Studios drafts these as a formal letter rather than an informal email. The document should be precise: name the item by Workshop ID and title, name the claimant, state your basis for the good faith belief that the removal was a mistake or misidentification, and sign with your legal name.
Step 3: Submit the counter-notification to Valve. Valve's designated DMCA agent contact information is available through the Steam Workshop documentation at partner.steamgames.com/doc/features/workshop. Submit the counter-notification via the contact method Valve specifies for DMCA counter-notifications.
Step 4: Document the submission. Keep a copy of the submitted counter-notification, the submission date and method, and any confirmation or acknowledgment from Valve.
Step 5: Wait for Valve to forward the counter to the claimant. Under the statute, Valve must promptly provide the claimant with a copy of your counter-notification and inform the claimant that it will restore the content in 10 to 14 business days.
Step 6: Monitor the 10-business-day window. The claimant has 10 business days from receiving the counter-notification to file a lawsuit in federal court and notify Valve that it has done so. If no lawsuit is filed within that window, Valve will restore the item.
Step 7: Confirm restoration. Once the 10-business-day window passes without a lawsuit, Valve typically restores the item within 14 business days of receiving the counter. Confirm the item is restored and verify that subscribers can access it again.
What happens after restoration
If the counter-notification succeeds and the item is restored, the claimant retains the right to file a lawsuit against the publisher directly. The DMCA counter-notification process concludes with restoration; it does not provide immunity from litigation. In 57 Studios' experience, claimants who do not file suit within the 10-business-day window typically do not pursue litigation afterward — but that outcome is not guaranteed.
SDG-specific context
Unturned™ is published on Steam by Smartly Dressed Games. DMCA notices related to Unturned™ Workshop items are processed through Valve's standard DMCA mechanism, not through SDG directly. SDG's modding policy (documented in Smartly Dressed Games Modding Policy) governs what modders are permitted to do with SDG's assets, but SDG is not the DMCA enforcement authority for Workshop items that infringe third-party IP. A publisher who receives a notice from a claimant other than SDG is dealing with Valve's process, not SDG's.
What 57 Studios has documented from publisher experience
57 Studios™ has operated as a Workshop publisher for Unturned™ mods, including mods distributed commercially through Tebex. The observations in this section reflect patterns documented from that experience. They do not constitute legal conclusions.
Notice quality varies significantly
A meaningful fraction of the DMCA notices 57 Studios has encountered or observed in the Unturned™ modding community have been deficient in at least one statutory element. The most common deficiencies are:
- Missing the "under penalty of perjury" language from the accuracy statement. The good faith statement and the accuracy statement are separate requirements; some notices include only one.
- Identifying the claimed work with insufficient specificity — naming a general IP (e.g., a game franchise) without identifying the specific work allegedly infringed.
- Providing contact information for the claimant's representative but not for the rights holder itself, when the notice requires the rights holder's information.
A deficient notice is still worth taking seriously because the claimant can refile a compliant notice. However, a deficient notice does not obligate Valve to act, and responding to a deficient notice as if it were valid may not be necessary.
Documentation before the fact is more effective than documentation after
When a takedown notice arrives, the publisher's ability to assess the claim depends entirely on what records exist for the mod's assets. A publisher who can produce a license record, asset provenance log, or attribution file for every asset in the mod is in a fundamentally stronger position than one who must reconstruct that history from memory.
57 Studios maintains an asset log for each mod project that records:
| Field | What it captures |
|---|---|
| Asset name | The filename and a brief description |
| Source | Where the asset was obtained (asset store, commissioned work, self-authored, etc.) |
| License type | The specific license under which it was obtained |
| License scope | Whether the license permits commercial redistribution on the Workshop |
| License document | Where the license file or proof of purchase is stored |
| Date acquired | The date the asset was incorporated into the project |
This log takes less than five minutes to update when an asset is added to a project. Reconstructing it after a notice arrives, from memory, under time pressure, is significantly harder.
False claims do get filed
In the Unturned™ modding ecosystem, as in other game modding communities, there are cases where takedown notices are filed in bad faith or by automated systems that produce false positives. A rights holder who believes a mod competes with their own Workshop item may file a notice claiming infringement of an asset the mod does not actually contain. Automated systems used by some music and media companies have incorrectly identified in-game sounds that do not originate from the claimed work.
Filing a counter-notification in response to a false claim is the correct procedural response. The penalty-of-perjury language in the takedown notice is the statutory deterrent against abusive claims; a claimant who knowingly files a false notice is exposed to civil liability. In practice, this deterrent is imperfect, but it does mean that a bad-faith claimant who receives a counter-notification and knows the claim is false has reason to withdraw rather than file suit.
Counter-notifications with complete documentation fare better
In the cases where 57 Studios has filed counter-notifications, the ones accompanied by complete asset documentation — license records, provenance logs, the specific asset named in the notice and evidence it either was not in the mod or was properly licensed — have resolved more quickly than those that relied on general assertions. The documentation does not need to be submitted with the counter-notification itself (the statutory elements are all that is required), but having it available to provide Valve or the claimant if the situation escalates is materially beneficial.
Responding to a takedown as a Workshop publisher: step-by-step
For a Workshop publisher who has just received a takedown notice, the following sequence covers the complete response process from notification to resolution.
Step 1: Read the notice completely and immediately. Note the date, the claimant's identity, the work claimed to be infringed, the Workshop item(s) identified, and any deadline the claimant mentions.
Step 2: Check the notice for all six statutory elements. Use the checklist in Elements of a valid DMCA takedown notice. If any element is missing, document the absence.
Step 3: Pull your asset log for the identified mod. Review every asset in the mod against the claimant's assertion. Determine whether any asset could plausibly be the one identified.
Step 4: Make a decision. There are three possible paths:
- The claim is valid: the mod contains an asset that was used without proper authorization. Remove the asset, clean up the mod, and refile without it.
- The claim is false or mistaken: the mod does not contain the claimed material, or the license under which the asset was obtained authorizes the use. File a counter-notification.
- The notice is deficient: it is missing required elements. Contact Valve to report the deficiency and document the decision not to file a counter-notification.
Step 5: Execute the chosen path. For a counter-notification, follow the steps in Counter-notification process. For a valid claim, remove the infringing asset before re-uploading.
Step 6: Document everything. Record every action taken, every communication sent, every date. Store this outside the Steam platform.
Step 7: Monitor the outcome. If a counter-notification was filed, track the 10-business-day window. If the item is restored, verify it is fully accessible. If a lawsuit is filed, engage an attorney.
Cross-reference
For guidance on how to structure asset documentation before a notice arrives, see Asset Licensing and Attribution. That article covers how to track license scope, maintain attribution records, and identify assets that require additional authorization before use in a commercially distributed mod.
The DMCA and the Unturned modding ecosystem specifically
The Unturned™ modding community operates within a permission framework established by Smartly Dressed Games (SDG) through its published modding policy. That policy and the DMCA are separate legal instruments that interact in specific ways a Workshop publisher should understand.
SDG's permission grant does not override third-party copyright
The SDG modding policy authorizes modders to create derivative works using the Unturned™ game engine, asset pipeline, and certain SDG-created assets. That permission grant is between SDG and modders. It does not extend to assets that SDG does not own and cannot license.
If a mod contains a texture that a third party — a stock photography company, another game studio, a musician — owns the copyright to, SDG's modding permission does not authorize that use. The third party's copyright exists independently of the SDG permission framework. A DMCA notice from that third party targets the infringement of their copyright, not a violation of SDG's terms.
How this creates confusion
Some modders conflate SDG's modding permission ("SDG says I can make mods using Unturned assets") with a general permission to include any asset in a mod. These are different statements. The SDG permission grant covers SDG's IP within the scope SDG defines. It says nothing about the IP of parties SDG does not represent.
SDG assets and DMCA notices
SDG has the right to file DMCA notices for unauthorized use of its copyrighted assets — textures, models, sounds, and other content it created. In practice, SDG does not typically file DMCA notices against modders who are using Unturned™ assets within the published modding permission grant. The modding permission grant is SDG's mechanism for authorizing that use without needing to process individual license requests.
The scenarios where SDG involvement becomes relevant are:
| Scenario | SDG's likely position |
|---|---|
| Modder uses Unturned™ assets within the SDG permission grant | Authorized; no DMCA action expected |
| Modder extracts Unturned™ assets and redistributes them as standalone files outside a mod | Potentially unauthorized; outside scope of permission grant |
| Modder uses Unturned™ assets in a competing standalone game (not a Workshop mod) | Likely unauthorized; consult SDG directly |
| Third party files a notice claiming a mod infringes their IP (not SDG's IP) | SDG is not a party; DMCA process is between modder and Valve |
For detailed guidance on the SDG permission grant and its boundaries, see Smartly Dressed Games Modding Policy.
How Valve fits between SDG and modders
Valve operates the Steam Workshop as a platform service. Valve's contractual relationship with Workshop publishers (through the Steamworks Agreement) and with SDG (as the game's publisher) are separate from the copyright relationships governed by the DMCA. Valve's DMCA obligation runs to whoever files a valid notice — SDG, a third-party rights holder, or another modder who holds copyright in their own creative work.
When Valve receives a valid notice, it acts under the statutory obligation regardless of whether the content falls under SDG's permission grant. The DMCA process does not pause to evaluate whether SDG's modding policy might authorize the use. If the claimant files a valid notice, Valve removes the content. The publisher's remedy is the counter-notification process.
Correspondence with SDG on copyright matters
57 Studios™ has direct contact with Smartly Dressed Games through the developer relations channel. For DMCA disputes that involve SDG's own assets — or where SDG's position on a modding permission question is material to a counter-notification — contacting SDG directly before filing the counter-notification may clarify the situation.
SDG's developer relations contact is not a DMCA agent for the purposes of the statutory process. Correspondence with SDG about a permission question is a business communication, not a legal filing. The DMCA counter-notification must still go through Valve's designated agent pathway as documented at partner.steamgames.com/doc/features/workshop. SDG's clarification of its permission grant provides supporting documentation for the counter-notification; it does not substitute for the counter-notification itself.
Frequently asked questions
What is the DMCA?
The Digital Millennium Copyright Act is a United States federal copyright law enacted in 1998. The section most relevant to Workshop publishers is 17 USC § 512, which establishes the notice-and-takedown system that online platforms like Steam use to process copyright infringement claims.
Does Valve decide whether my mod infringes copyright?
No. Valve processes notices procedurally. When it receives a valid notice, it removes the content. It does not independently determine whether the claim is valid. The counter-notification process is where the publisher has the opportunity to dispute the claim.
How long does it take for a removed mod to come back after a counter-notification?
Under the statute, Valve must wait at least 10 business days after forwarding the counter-notification to the claimant before restoring the item. Valve restores within 14 business days if no lawsuit is filed. In 57 Studios' experience, restoration typically occurs at or shortly after the 10-business-day mark.
Can the same mod be targeted by multiple takedown notices?
Yes. Each notice covers the specific infringing material identified in that notice. A rights holder who believes a mod infringes multiple works can file multiple notices, or one notice identifying multiple works. A publisher who files a counter-notification for one notice is not automatically protected from future notices.
What happens if I re-upload a mod that was taken down without removing the infringing material?
Re-uploading a mod with the same infringing material, or creating a new Workshop item to circumvent a takedown, violates Steam's Terms of Service. Valve may take action against the account, including suspension, in addition to processing any new takedown notices that result.
Does a DMCA counter-notification cost money?
There are no filing fees for a counter-notification. If the situation escalates to litigation, attorney fees are the primary cost. The counter-notification process itself is free.
What is a "deficient" takedown notice?
A deficient takedown notice is one that is missing one or more of the six statutory elements required by 17 USC § 512(c)(3). A deficient notice does not obligate Valve to remove the content, although Valve may choose to act on it anyway. A publisher who receives a deficient notice should document the deficiency.
Can I be sued even if my counter-notification is successful and my mod is restored?
Yes. The DMCA counter-notification process concludes with restoration of the content if no lawsuit is filed within the statutory window. It does not bar the claimant from filing a lawsuit after the window. In practice, claimants who do not file within the window rarely pursue litigation afterward, but the possibility is not eliminated by the restoration itself.
What is 17 USC § 512?
17 USC § 512 is the section of the Digital Millennium Copyright Act that establishes the Online Copyright Infringement Liability Limitation Act (OCILLA) safe harbors for online service providers. It defines the conditions under which platforms like Steam can host user-generated content without direct copyright liability, and it establishes the notice-and-takedown and counter-notification procedures described in this article.
Where can I find Valve's official documentation on Workshop takedowns?
Valve's official documentation for Steam Workshop publisher tools, including the contact pathway for DMCA submissions, is at partner.steamgames.com/doc/features/workshop.
Does this process apply if a fellow Unturned modder claims I copied their mod?
If a fellow modder believes you have copied their work, they can file a DMCA notice if the copied material is copyrighted. Copyright in a mod's original creative content (original textures, models, sounds authored by the modder) belongs to the modder who created it, not to 57 Studios or SDG. A notice from a fellow modder goes through the same Valve DMCA process as a notice from any other rights holder.
What is the Steam Workshop Steamworks documentation link?
Valve's Steamworks documentation for the Workshop, including publisher guidelines and DMCA contact information, is at partner.steamgames.com/doc/features/workshop. The Unturned store page on Steam is at store.steampowered.com/app/304930/Unturned/.
How does 57 Studios protect its own mods from infringement by others?
57 Studios™ holds copyright in the original creative work it authors: custom textures, custom models, custom sound design, and original code authored for its mods. When 57 Studios discovers unauthorized use of its original content in another publisher's Workshop item, it has the same DMCA notice option that any rights holder has. A notice submitted through Valve's designated DMCA channel, containing all six statutory elements, triggers the same Valve response described in this article — from the other side.
57 Studios does not routinely monitor the Workshop for unauthorized use. When unauthorized use is discovered — through community reports, accidental discovery, or automated search — the decision to file a notice goes through the same internal review described in this article. The same documentation discipline that protects 57 Studios as a respondent to notices also supports its position as a claimant when its own IP is at issue.
Copyright in 57 Studios' original mod content is not contingent on registration. Copyright in the United States attaches at the moment of creation and fixation in a tangible medium. A custom texture authored in Substance Painter, a custom model exported from Blender, or an original sound design authored in a DAW and incorporated into a mod is protected by copyright from the moment it exists as a file. Registration with the Copyright Office provides additional benefits (including the ability to recover statutory damages and attorney's fees in litigation) but is not required to hold the copyright or to file a DMCA notice.
DMCA and Tebex commerce: the downstream implications
A DMCA takedown on a Workshop item does not automatically affect the corresponding Tebex listing for that mod. The Workshop item and the Tebex product are two separate distribution channels, and a removal from one does not automatically remove the other. However, the practical and legal implications of a Workshop takedown do extend to Tebex in ways that require attention.
Access fulfillment breaks immediately
Most Unturned™ mods sold on Tebex are delivered to buyers through a Workshop subscription mechanism. The buyer purchases access on Tebex, receives a Workshop subscription grant (or a download link that depends on the Workshop item being publicly available), and installs from the Steam Workshop. When the Workshop item is disabled by a DMCA takedown, buyers who attempt to follow that fulfillment path cannot access the mod they purchased.
Chargebacks and refund pressure
When buyers cannot access content they paid for, chargeback pressure follows. Tebex has a dispute and chargeback process that penalizes sellers with elevated chargeback rates. A Workshop takedown that leaves a Tebex product live and unfulfillable can produce chargeback claims that affect Tebex account standing independently of the underlying DMCA dispute.
The correct response to a Workshop takedown when a corresponding Tebex product exists is:
- Immediately mark the Tebex product as out of stock or temporarily unavailable.
- Communicate to recent buyers that access is temporarily unavailable due to a platform issue (without making statements about the DMCA dispute that could be used against you).
- Determine whether refunds or purchase credits are appropriate based on the expected resolution timeline.
- If the counter-notification is expected to succeed, communicate a realistic timeline for restoration.
Infringing content sold on Tebex
If the DMCA claim is valid — the mod does contain copyrighted material used without authorization — then the Tebex product that delivered that mod to buyers has also delivered infringing material. This is a separate exposure from the Workshop takedown. Tebex's seller terms address prohibited content and reserve the right to act on reports of infringing products.
Resolving the underlying copyright issue — by removing or replacing the infringing asset — is the correct path before re-enabling the Tebex product. Continuing to sell access to a mod that contains infringing material after becoming aware of the claim creates knowing infringement exposure, which is legally more serious than the original unknowing infringement.
Maintaining Tebex good standing during a dispute
A DMCA dispute can take days to weeks to resolve. Maintaining Tebex account standing during that period requires proactive management of the affected product. 57 Studios™ has found the following approach effective:
- Mark affected products as temporarily unavailable rather than deleting them. Deletion loses the product configuration, subscriber list, and historical transaction data that may be needed later.
- Process refund requests promptly for buyers who request them. Proactive refunds cost less than chargebacks both financially and in terms of account standing.
- Document all buyer communications in writing, referencing the product name and transaction IDs. This documentation becomes relevant if Tebex opens a seller investigation.
Section 512(f): misrepresentation liability for claimants and publishers
17 USC § 512(f) is the provision of the DMCA that creates civil liability for misrepresentation in the DMCA process. It applies to both directions: a rights holder who knowingly materially misrepresents that material is infringing, and a publisher who knowingly materially misrepresents that material was removed by mistake or misidentification.
This provision is what gives the penalty-of-perjury language in both notices and counter-notifications legal force. A claimant who files a knowingly false takedown notice — for example, to suppress a competitor's mod rather than to protect a legitimate copyright interest — is exposed to § 512(f) liability. A publisher who files a counter-notification for material they know infringes is similarly exposed.
Practical deterrence
In the Unturned™ modding ecosystem, § 512(f) claims between modders and claimants are rare. The legal cost of asserting a § 512(f) claim exceeds the value at stake in most Workshop disputes. The practical deterrent function of § 512(f) is primarily in the penalty-of-perjury language itself — a claimant who knows the false-notice risk is more likely to withdraw a questionable claim when a well-documented counter-notification arrives, rather than risk a § 512(f) exposure by filing suit.
| Act | Who bears the § 512(f) exposure |
|---|---|
| Filing a takedown notice for material that does not infringe, with knowledge that it does not infringe | The claimant (rights holder or their agent) |
| Filing a counter-notification for material that does infringe, with knowledge that it does infringe | The publisher (mod author) |
| Filing a takedown notice that is mistaken but not knowingly false | No § 512(f) liability; mistake does not create liability |
| Filing a counter-notification that turns out to be wrong but was filed in good faith | No § 512(f) liability; good faith protects the publisher |
The "knowingly" element is the critical qualifier. Good faith errors in either direction do not create § 512(f) liability. This is why the good faith language in both the notice and the counter-notification has statutory significance — it is not merely a formality.
Repeat infringer policies and account standing
Valve maintains a repeat infringer policy as a condition of its § 512 safe harbor. Service providers that do not have and implement a policy for terminating the accounts of repeat infringers lose access to the safe harbor, which means they risk direct copyright liability for content their users post. Valve's repeat infringer policy is not fully public in its operational details, but its existence and enforcement are facts of the Workshop publishing environment.
Multiple strikes
A Workshop publisher who receives multiple valid DMCA strikes — particularly across multiple distinct copyrighted works, or across multiple Workshop items — faces escalating account-level risk beyond the individual item takedowns. A single valid strike is a resolved incident. Multiple valid strikes suggest a systemic asset practice problem that Valve may treat as a repeat infringer situation.
The practical implication for 57 Studios™ is that asset documentation and license compliance are not merely procedural preferences — they are account-protection measures. A publisher who can demonstrate consistent due diligence in asset sourcing and licensing is in a materially different position with Valve than one who cannot.
What counts as a "repeat infringer" situation
Valve does not publish specific thresholds, but the DMCA safe harbor case law provides context. Courts have generally held that a repeat infringer policy must be implemented in a non-arbitrary, non-pretextual way. A platform that ignores multiple valid takedown notices targeting the same account would face challenges to its safe harbor claim. This means Valve has structural incentive to treat accounts with multiple valid strikes more seriously than first-time strike recipients.
The cleanest protection against repeat infringer exposure is to avoid valid strikes in the first place by maintaining asset documentation that makes it possible to audit every mod's content before publishing. The second-best protection is to respond to any valid claim by removing the infringing material and auditing all other active mods for similar issues before a second claim arrives.
How 57 Studios handles a DMCA notice: the complete workflow
The following workflow documents 57 Studios™' internal response process for a DMCA takedown notice. It is provided as a reference for other Workshop publishers who want a complete procedural model.
Phase 1: Receipt and triage (day of notice)
Action 1.1 — Identify the notice source. DMCA notices may arrive through the Steam Workshop interface (a notification on the affected item's page), through a Steamworks account email, or occasionally through direct correspondence forwarded by Valve. Identify where the notice came from and whether it is the complete notice or a summary.
Action 1.2 — Retrieve the complete notice. If only a summary is available, request the complete notice text through the appropriate Valve channel. A summary is not sufficient for a legal analysis of element completeness.
Action 1.3 — Create a case folder. Create a dedicated folder for this notice in the project documentation. Everything related to this incident goes in the case folder: the notice text, correspondence, the asset log review, the counter-notification draft, and any Valve communications.
Action 1.4 — Complete the six-element checklist. Run the notice against Appendix A. Note which elements are present and which are absent.
Action 1.5 — Identify the claimed work and the specific mod. Note the Workshop item ID, the name of the copyrighted work the claimant identifies, and the claimant's identity.
Phase 2: Asset audit (within 24-48 hours)
Action 2.1 — Pull the asset log. Open the asset log for the identified mod.
Action 2.2 — Map the claim to the asset log. Compare the claimant's description of the infringing material to the assets in the log. Determine whether any asset in the log matches the claimed work.
Action 2.3 — If a match is found, verify the license. Confirm the license under which the asset was obtained. Confirm whether that license authorizes the current use (commercial redistribution on the Steam Workshop and/or Tebex).
Action 2.4 — If no match is found, document the absence. Record specifically which assets are in the mod, their sources, and why none of them matches the claimed work.
Action 2.5 — If the audit is inconclusive, extend it. A thorough audit of every asset in a complex mod may take more than 24 hours. An inconclusive audit should err toward a conservative response: do not file a counter-notification until the audit is complete and the basis is clear.
Phase 3: Decision and response (within 48-72 hours)
Action 3.1 — Document the decision. Whatever path is chosen, record the reasoning in the case folder. The decision memo does not need to be formal; it needs to explain why the chosen path was selected and what the factual basis was.
Action 3.2A — Valid claim path. Remove the infringing asset from the mod. Re-upload the cleaned mod. Notify buyers through available channels. Update the Tebex product status. Close the case folder with a note on the resolution.
Action 3.2B — False or mistaken claim path. Draft the counter-notification using the Appendix B checklist. Have the draft reviewed before submission. Submit to Valve through the designated DMCA contact channel.
Action 3.2C — Deficient notice path. Document the deficiencies. Contact Valve's designated agent to note the deficiency. Do not file a counter-notification (not required for a non-compliant notice). Monitor whether the claimant refiles a compliant notice.
Phase 4: Monitoring and closure
Action 4.1 — Track the counter-notification window. If a counter was filed, log the submission date and calculate the 10-business-day and 14-business-day marks.
Action 4.2 — Confirm restoration. When the window passes, confirm the Workshop item is restored and accessible to subscribers.
Action 4.3 — Restore Tebex product if applicable. Re-enable the Tebex product and notify buyers who were affected by the temporary unavailability.
Action 4.4 — Conduct a post-incident review. After the incident is closed, review the asset documentation practices that contributed to it. Update the asset log for all active mods to address any gaps. Apply any lessons to the onboarding process for new mod projects.
Action 4.5 — Archive the case folder. Store the complete case folder — notice, audit, decision memo, counter-notification if filed, and outcome — in a location that will persist beyond the active project. A DMCA incident becomes part of 57 Studios™' compliance history.
Why document even closed incidents
The case folder for a resolved DMCA incident is useful long after the incident closes. If the same claimant files a future notice targeting a different mod, the prior case folder demonstrates the publisher's history of good faith responses. If a similar asset source appears in a future mod, the prior audit results accelerate the new audit. Documentation compounds in value over time.
Appendix A: DMCA notice elements checklist
Use this checklist when evaluating a takedown notice you have received, or when constructing a notice you intend to submit on behalf of 57 Studios™.
| # | Element | Statutory basis | Present in notice? |
|---|---|---|---|
| 1 | Identification of the copyrighted work claimed to be infringed | 17 USC § 512(c)(3)(A)(i) | ☐ |
| 2 | Identification of the infringing material with sufficient information to locate it | 17 USC § 512(c)(3)(A)(ii) | ☐ |
| 3 | Claimant contact information (address, phone, email) | 17 USC § 512(c)(3)(A)(iii) | ☐ |
| 4 | Good faith belief statement | 17 USC § 512(c)(3)(A)(v) | ☐ |
| 5 | Accuracy statement under penalty of perjury | 17 USC § 512(c)(3)(A)(vi) | ☐ |
| 6 | Physical or electronic signature | 17 USC § 512(c)(3)(A)(vi) | ☐ |
A notice with all six boxes checked is a compliant notice that obligates the platform to act. A notice with any box unchecked is deficient. Retain this checklist in the case folder created in Phase 1 of the response workflow.
Appendix B: Counter-notification elements checklist
Use this checklist when drafting a counter-notification.
| # | Element | Statutory basis | Included? |
|---|---|---|---|
| 1 | Identification of removed material and its prior location | 17 USC § 512(g)(3)(A) | ☐ |
| 2 | Good faith belief statement (mistake or misidentification) under penalty of perjury | 17 USC § 512(g)(3)(C) | ☐ |
| 3 | Subscriber name, address, telephone number, email | 17 USC § 512(g)(3)(A) | ☐ |
| 4 | Consent to jurisdiction of federal district court | 17 USC § 512(g)(3)(D) | ☐ |
| 5 | Consent to accept service of process from claimant | 17 USC § 512(g)(3)(D) | ☐ |
| 6 | Physical or electronic signature | 17 USC § 512(g)(3)(B) | ☐ |
Penalty of perjury
The good faith belief statement in a counter-notification must be made under penalty of perjury. Filing a counter-notification for material that you know infringes a valid copyright is a serious legal risk. Do not file a counter-notification unless you have a genuine good faith belief the removal was a mistake or misidentification.
Appendix C: Asset log template
The following fields represent the minimum asset documentation 57 Studios™ maintains for each mod project. Maintain one log per mod in the project's working directory.
| Field | Description | Example |
|---|---|---|
| Asset name | Filename and brief description | assault_rifle_diffuse.png — primary texture for AR-7 mod |
| Source | Where the asset was obtained | Purchased from XYZ Asset Store, order #12345 |
| Author | Who created the asset | External artist; commissioned work |
| License type | The license name or type | Commercial License, Single Product |
| Commercial redistribution permitted | Whether the license allows this use explicitly | Yes — confirmed in license §3.2 |
| License document storage | Where the license file or proof of purchase is stored | /project/AR-7/licenses/xyz_ar7_texture_license.pdf |
| Date acquired | When the asset was brought into the project | 2025-11-14 |
| Notes | Anything else relevant to the asset's legal status | Commissioned work; full rights transferred per contract |
This log does not need to be formatted or polished. Its purpose is to make the asset's provenance and license status unambiguous and quickly retrievable. A plain text file, a spreadsheet row, or a note in the project documentation all serve the purpose equally.
Keep the log current
Update the log every time an asset is added to the project, not at the end of production. Reconstructing asset provenance from memory under time pressure after a notice arrives is significantly more difficult than maintaining the log incrementally.
Related articles in this section
The DMCA article covers the procedural mechanics of receiving and responding to takedown notices. The other articles in the Legal section address the substantive questions that determine whether a notice is valid in the first place.
| Article | How it connects to this article |
|---|---|
| Asset Licensing and Attribution | Documents how to track license scope so that the asset audit in Phase 2 of the response workflow can be completed quickly and accurately. |
| Derivative Works and Unturned Modding | Explains how copyright law characterizes Unturned mods as derivative works, which affects what assets can be included and how they can be used. |
| Smartly Dressed Games Modding Policy | The SDG permission grant that covers use of SDG's own assets within the Workshop — the primary authorization framework for Unturned mod content. |
| Tebex Commerce Terms for Mod Sellers | Details the Tebex obligations that activate when a DMCA takedown affects a commercially listed mod, including chargeback exposure and product status management. |
| Trademark and Brand Use | Covers the trademark dimension of brand infringement claims, which may accompany or precede a copyright-based DMCA notice for mods with real-world brand imagery. |
| Reverse Engineering and Decompilation Limits | Documents which asset-access approaches carry legal risk that could generate DMCA exposure — relevant context for understanding how to avoid infringement before it happens. |