I was once the registered DMCA agent for a large organization. All of the registered agents are listed on the US Copyright's Office website so that rights holders can look-up the names and addresses to send notices when an IP address within that organization is found to have content that is thought to be infringing (P2P, music, movies, etc).
Fewer than 1 in 10 came to me (the person registered to receive the notices). Subcontractors working on behalf of rights holders would send notices to any email address that they could find. Some went to retired employees, transferred employees, etc. It got so bad that we put a comment in ARIN that specified the agent's contact address to try and stop it. Didn't work.
The DMCA requires a proper notice be sent to the registered agent and grants the organization safe-harbor. It is very well defined. Here is the official list of registered agents (the one and only list... but DMCA subcontractors don't read it):
Most of them are bots, and I doubt your note in ARIN was even being read. They seem to love to look up the abuse contact for an email address, and send their notices there. A large number of them make no attempt to find the registered agent. Sadly, this works for them, since I would imagine most ISP's just forward on the notice to the registered contact.
I wonder what would happen if you ignored a DMCA notice sent to the wrong contact. Would it be invalid?
The entire purpose of the portion of the law (DMCA) requiring valid notices be sent to registered agents is so that notice is given to the correct person at the organization so that swift action may be taken to investigate and potentially remedy the alleged copyright violation. How else do you think the organization would know to respond?
Rights holders and their subcontractors can't just email anyone in your domain (the janitor's office) and expect action to be taken. The law (DMCA) is very explicit about this. Notice must be given to the registered agent (PERIOD). However, you should ask your legal counsel what they which to do with invalid notices. Some will want the organization to respond anyway, others won't. It depends on whether or not they wish to waste money spending time following-up on invalid notices. I can tell you this though, a notice sent to janitor@domain.com is not going to stand up in court unless janitor@domain.com is indeed the registered agent.
The point is that if they can't be bothered to obey the DMCA and take the time to look-up the proper published registered agent, why should new laws be considered that let them get away with even worse laziness and accusations?
Fewer than 1 in 10 came to me (the person registered to receive the notices). Subcontractors working on behalf of rights holders would send notices to any email address that they could find. Some went to retired employees, transferred employees, etc. It got so bad that we put a comment in ARIN that specified the agent's contact address to try and stop it. Didn't work.
The DMCA requires a proper notice be sent to the registered agent and grants the organization safe-harbor. It is very well defined. Here is the official list of registered agents (the one and only list... but DMCA subcontractors don't read it):
http://www.copyright.gov/onlinesp/list/a_agents.html