Neutral Citation Number: 2023:DHC:2806 Submissions on behalf of Microsoft 36. Mr. Jayant Mehta, learned Senior Counsel appearing on behalf of Microsoft Ireland Operations Ltd., i.e. Respondent No. 4, has made the following submissions: a. A dedicated webform is available for reporting NCII and any member of the public may use this webform for requesting the removal of a nude or sexually explicit image or video of themselves that may have been shared without their consent. However, Bing (www.bing.com), which is the search engine that is operated by Respondent No.4, does not currently possess any technology for automatically finding and deleting NCII, and can only remove the content globally upon receiving notice of its existence. Further, Bing is not a content-hosting platform and has no control over the information published on third-party web pages. It becomes incumbent upon the user/victim to work with webpage owners to remove the content from the internet in its entirety. b. Though the technology for image scanning exists, its implementation for the purpose of automatically finding and deindexing NCII depends on development of a cryptographic database, interoperability standards, and Application Programme Interfaces (APIs) which can be used to identify duplication of NCII. Microsoft is currently working with a cross-industry coalition of tech Signature Not Verified Digitally Signed By:SHAZAAD ZAKIR Signing Date:26.04.2023 17:19:50 W.P.(CRL) 1505/2021 Page 57 of 88