4.5.1 United Kingdom, India, Canada and United States of America
Apart from the framework set forth under the ECD, which does not provide for the signature
of the claimant being a mandatory part of the notice all other regimes under the study, do
specify the claimant’s signature as proof. Only the Indian regime and the US regime create
provisions for the appointment of a designated officer to administer takedowns.233 While
under the DMCA the officer must be registered with the government, there is no such
requirement under the Indian legislation.