Copyright infringement is defined by statute thus:

> Anyone who violates any of the exclusive rights of the copyright owner as provided by sections 106 through 122 or of the author as provided in section 106A(a), or who imports copies or phonorecords into the United States in violation of section 602, is an infringer of the copyright or right of the author, as the case may be.

( https://www.law.cornell.edu/uscode/text/17/501 )

At least one of the following exclusive rights have to be violated:

> (1) to reproduce the copyrighted work in copies or phonorecords;

> (2) to prepare derivative works based upon the copyrighted work;

> (3) to distribute copies or phonorecords of the copyrighted work to the public by sale or other transfer of ownership, or by rental, lease, or lending;

> (4) in the case of literary, musical, dramatic, and choreographic works, pantomimes, and motion pictures and other audiovisual works, to perform the copyrighted work publicly;

> (5) in the case of literary, musical, dramatic, and choreographic works, pantomimes, and pictorial, graphic, or sculptural works, including the individual images of a motion picture or other audiovisual work, to display the copyrighted work publicly; and

> (6) in the case of sound recordings, to perform the copyrighted work publicly by means of a digital audio transmission.

( https://www.law.cornell.edu/uscode/text/17/106 )

Contributory infringement isn't listed.

The Supreme Court held in the Grokster case:

>[...] One infringes contributorily by intentionally inducing or encouraging direct infringement, and infringes vicariously by profiting from direct infringement while declining to exercise the right to stop or limit it. Although “[t]he Copyright Act does not expressly render anyone liable for [another’s] infringement,” Sony, 464 U.S., at 434, these secondary liability doctrines emerged from common law principles and are well established in the law

( https://www.law.cornell.edu/supct/html/04-480.ZS.html )

So I don't think it is justified to say that contributory infringement is covered by the statutory DMCA takedown notice procedure, and if it is justified, the source would be a court precedent from the past 15 years which we haven't found yet.

Back to the question of the validity of this particular DMCA takedown notice: None of the works or actions found at the GitHub URLs in the complaint were movies. Nobody was performing a movie at the GitHub URL for a JS source code file. None of those files were a reproduction of a movie, in whole or in part. The only action happening at those particular URLs was public display and distribution of files, and the thing being publicly displayed at each of those URLs was JS source code, which is not a match for the works that the studios claimed ownership of. This DMCA complaint does not provide "information reasonably sufficient to permit" GitHub to find movie piracy on GitHub, unless the studio wants to claim that the source code is a rip-off inspired by something out of a movie. But if that were the case, they could have been a lot more specific about which movie.

GitHub is probably safe regardless. But the studios will only win a lawsuit by making a substantially different claim from the claim that the JS code is infringing on multiple movies.