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Real examples here?
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But at the same time if the code is properly licensed under an open source license (I would assume/hope NPM didn't allow non FOSS code) then NPM can refuse to take it down. Yes, they put it back up, but I think it's important for public repositories (as in packaged code repositories, not got repositories) to never remove things (barring legal requirements, sure).
For what it's worth, the policy they adopted after the fact seemed pretty sensible. I think it was something like you can't take things down once they have ~100 downloads or x number of dependents.