Lawyers in Canada: Davis LLP - Legal Advisors Since 1892

The Burning Crusade license granted

Last week, it was reported by Gamasutra.com that NetEase had suspended new user registrations due to its application to the Chinese government for a license to operate the World of WarCraft expansion pack The Burning Crusade. It appears that Chinese regulators are showing concern over the "undesirable content" of online games and are allegedly cracking down on foreign investments in its growing online gaming industry.

On February 16, 2010, Gamepolitics.com reported that China's General Administration of Press and Publication (the "GAPP") has granted the license permitting NetEase to operate The Burning Crusade. While the GAPP reportedly claimed to have previously suspended NetEase's permit for what it allegedly referred to as "gross violations" of regulations, NetEase appears to have always maintained that it did not violate any regulation. The GAPP has reportedly said that it granted NetEase the license because it had "taken necessary corrective measures."

Coverage at Gamasutra and Gamepolitics

Unsatisfied gamer sues Activision Blizzard

Erik Estavillo, the same man who has previously sued Sony Computer Entertainment America (SCEA), Microsoft and Nintendo, has allegedly filed another lawsuit in the Civil Division of the Superior Court of California. This latest suit was filed against Activision Blizzard over the game World of Warcraft.

According to Gamerant.com, Mr. Estavillo sued SCEA after he was banned from the Playstation Network for « inappropriate behaviour ». His lawsuit against Microsoft was for the failure of his Xbox 360 system, which he claims had to be replaced after it displayed the "red ring of death" and he allegedly sued Nintendo for having disabled unauthorized third party programs on the Wii.

It appears that he is now suing Activision Blizzard because he claims that the calculated slow pace at which the player walks or runs in the game leads to longer play time, which then leads to higher subscription revenue for Activision Blizzard, a practice that Mr. Estavillo has allegedly called "sneaky and deceitful practices".

Gamepolitics also reports that Mr. Estavillo, who claims to suffer from Obsessive Compulsive Disorder, Agoraphobia, Panic Disorder, major depression and Crohn's disease, alleges that he relies heavily on video games for the "little ongoing happiness he can achieve in this life" and does not want to end up like other gamers in similar situations who take their own lives.

Escapistmagazine.com reports that Mr. Estavillo is asking the court to order that the game be "fixed", as well as an award of one million dollars in punitive damages "for creating a game which hurts gamers rather than being a bridge of entertainment for them to pursue happiness."

Mr. Estavillo has allegedly also subpoenaed Martin Lee Gore of the band Depeche Mode and Winona Ryder to testify on his behalf regarding the subject of alienation. According to GamePolitics, Mr. Estavillo is claiming that Gore will be testifying with regards to alienation because his song lyrics show that he himself has been alienated and Ryder is to explain the significance of alienation in the book The Catcher in the Rye, for which she has apparently shown an interest, and Mr. Estavillo allegedly expects her testimony to explain how alienation in The Catcher in the Rye can tie to alienation in video games like World of Warcraft as well as in real life.

Coverage at GamePolitics.com, Escapistmagazine.com, and GameRant.com

Online game company sues bot software company and wins

Submitted by Dr. Andreas Lober

In an unprecedented case in German jurisprudence, the operator of an online game sued the provider of a bot software, and won. The court granted a cease and desist order, so the bot must no longer be distributed.

1. Facts of the case:

The plaintiff developed and operates one of the worlds most popular massively multiplayer online brower based strategy games. The plaintiff's online game is free to play in a basic version, but requires purchasing so called premium functions in order for the user to be able to use special and enhanced features of the game. The Terms of Service of the game expressly prohibit the use of cheating software or bot software.

The defendant offered a bot software on the Internet by using a website which was available in German and various other languages. The bot software was specifically configured to interfere with the plaintiff's online game. By using the bot software, the user was enabled to use game functions which the plaintiff's online game either did not have at all or which were only available in the game as a so called premium feature with costs. Therefore, the use of the bot did not only extensively interfere with the gameplay and the game balance of the defendant's online game, but also caused a potential loss of income for the plaintiff because users of the bot did not have to purchase the plaintiff's premium functions anymore.

The use of the defendant's bot software was free for a trial period, but required a license for a valuable consideration after that. On its website, the defendant used the plaintiff's registered trademark and also graphical material which was taken from the plaintiff's online game.

2. The court's decision:

The court held that offering and selling the bot by the defendant constitutes an illegitimate exploitation of the plaintiffs reputation in the sense of "selling of compatible products that interfere with a third party line of products" and an unfair interference with the plaintiff's business model under Section 4 No. 9b and Section 10 the German Unfair Competition Act.

The court was of the opinion that the defendant intentionally undermines the plaintiff's business model which - since the basic version of the game is free to play - is based on selling premium functions for the online game. Users of the defendant's bot software would stop purchasing premium functions for the plaintiff's online game if such functions were also available by using the bot software.

Further, the plaintiff's Terms of Service for the online game expressly prohibit the use of cheating software or bot software. Consequently, the court held that the defendant entices the users of the plaintiff's online game to breach their respective contract with the plaintiff over the use of the game by offering prohibited software and enabling such breach of contract.

Lastly, the court held that by using the plaintiff's trademark and graphical material on the website, the defendant infringes on the plaintiff's trademark rights and on the plaintiff's copyright.

Why play when you can glide? Because...

In 2006, MDY Industries sought a declaration that its "Glider" program that plays World of Warcraft doesn't violate Blizzard's and Vivendi's copyrights. The Arizona District Court ruled in favour of Blizzard and Vivendi, for tortuous interference with contract, contributory copyright infringement, and vicarious copyright infringement. The parties then agreed that the court should hold a bench trial regarding three outstanding issues.

On January 30th, the court released its ruling, concluding that:

1. MDY was trafficking in anti-circumvention technology;

2. the president of MDY should be personally liable because he knew that MDY was infringing Blizzard's and Vivendi's rights, and he supervised the infringing activities, and he profited from them personally; and

3. Blizzard and Vivendi are entitled to a permanent injunction against MDY.

A copy of the order is available here.

Virtual Infidelity Leads to Real Divorce

Amy Taylor, a 28-yeard old British woman, was shocked and distressed when she walked in on David Pollard, her husband of three years, having sex with another woman. This was not the first time she'd caught him in the act, but it was the final straw. Ms. Taylor filed for divorce.

The novel spin on this age-old scenario is that the sex in question was all virtual, carried on by Mr. Pollard through his online avatar in Second Life.

Mr. Pollard is now engaged to be married (in real life) to his online lover.

Coverage at: Yahoo News

Bot makers: beware!

In March we reported that Vivendi had sued the author of a software tool that automates certain in-game tasks such as fighting in World of Warcraft. Vivendi claimed that the software tool infringed its copyrights because the tool copies game code into RAM in order to avoid cheat-prevention software, and also violates the game's end-user licence agreement.

Earlier this week the United States District Court for the District of Arizona released its decision, granting Vivendi summary judgment regarding copyright infringement and tortious interference. Other claims, such as certain DMCA claims, trade-mark claims and unjust enrichment claims, will be decided later in a full trial.

Coverage here (Virtually Blind)

File Share Beware - IP ID'd

Submitted by Amanda Alfieri, Articled Student

Topware Interactive obtained judgments from a London Court against four individuals for file-sharing . The Court granted interim damages in the amount of £750 per person and the final amount can be up to £2000 per person. The difficulty in successfully suing file sharers is discovering their identity. Internet Service Providers (ISP) give a number to each of their users when they are on-line. This number is referred to as an IP address and the ISP's have been reluctant to divulge the IP addresses of their customers in order for computer experts to be able to identify which IP addresses match file-sharers with illegally obtained copyright material on their computers. However, a UK High Court has ordered the identification of hundreds of users whose computers have been used for illegal game sharing. It will permit Davenport Lyons, the lawyers for Topware Interactive to send lawyer’s letters to all those users. The recipients of the letter must provide a satisfactory response or they shall risk being sued.

Read more at This Is Money.

"Kölner Dom" in Second Life: Copyright Infringement?

To the inhabitants of Cologne, their "Dom" is very dear – and legend says that tourists calling the building "Cathedral" have found themselves thrown into the Rhine. So the judges of the District Court of Cologne will have been very pleased that they have not just rendered what is probably the first German judgement on copyright of Second Life architecture, but that this case refers to the great Cologne landmark.

The applicant claimed copyright in certain textures of the virtual "Kölner Dom", which was partly designed by her, and partly designed by the defendant. While the textures were designed to make the virtual building look like the real one, and photos were taken to achieve this aim, the applicant claimed that her work was protected under copyright law, as she had to adapt colors, brightness, and perspective. After a rather long elaboration of the various types of "work" which can be protected under copyright law, the court found that the textures were not suffiently original for copyright protection.

The underlying contracts between the parties have not been part of the dispute, presumably because they were not very clear on the subject.

This article was kindly contributed by Andreas Lober at SCHULTE RIESENKAMPFF in Frankfurt.

Online game ratings in Germany

Germany is known to have some of the strictest rules for youth protection in computer and video games, which have brought the world interesting features such as green blood.

Whilst these are a nightmare for the creators of first person shooters especially, online games have been pretty much spared: The law requiring an official rating before the game can be sold without too many restrictions applies to games distributed on storage media only. Consequently, operators of games distributed online only currently do not worry too much about youth protection.

This situation may change, though. At the Munich Gaming conference, the issue was discussed. As always, stricter rules have been demanded, and some speakers wanted an independent body online games. It remains to be seen whether a new body for the assessment of online games will be installed, or whether the USK (which is already rating box games) will take over the task. Also, whether such ratings will be compulsory soon is not sure yet, but seems likely.

However, the mere discussion puts online games into the focus, and this means that game publishers or operators should better respect the existing rules. Already now, a company offering online games has to appoint a “youth protection officer” (§ 7 Jugendmedienschutz-Staatsvertrag) and comply with several other rules, which are nothing short of prohibitive for 16+ games (§ 5 Jugendmedienschutz-Staatsvertrag). Any infringement of these rules can be fined up to EUR 500,000. And they also apply to operators abroad as long as they target the German market.
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This article was kindly contributed by Andreas Lober at SCHULTE RIESENKAMPFF in Frankfurt.

Legal Battle Joined over WoW Bot

Vivendi, the parent company of Blizzard Entertainment (the creator of the popular World of Warcraft on-line multiplayer game), has sued the author of a software tool that automates certain in-game tasks such as fighting.

Vivendi and Blizzard claim that the software tool infringes its copyrights (because the tool copies game code into RAM in order to avoid cheat-prevention software) and also violates the game's end-user licence agreement.

The defendant, who claims to have sold more than 100,000 copies of his program, denies there is any copyright infringement.

Both parties have filed written submissions and are awaiting summary judgment in the case.

Coverage on the BBC and at the International Business Times.

Virtual worlds ripe for real-world lawsuits

Today the Financial Post published an interesting article entitled "Virtual Worlds Ripe for Real-World Lawsuits". It discusses topical online legal issues such as IP infringement in Second Life. And it even features a few choice words from one of our resident video game and intellectual property lawyers, Chris Bennett.

Online version is available here.

China to Restrict On-Line Games?

Reported statistics about on-line gaming in China are pretty staggering: there are about 40.2 million on-line gamers, and 2007 on-line game sales exceeded $1.46 billion. The flip side is growing concern about on-line addiction, and the growing trend of blaming much of juvenile crime on on-line gaming obsessions.

In fact, Chinese authorities are apparently considering implementing new rules to restrict "undesirable elements" of on-line games. According to one official, on-line games are a kind of "spiritual opium", and the gaming industry will suffer by being increasingly marginalized if steps aren't taken to control things.

We wonder exactly which "undesirable elements" will be the focus of any government restrictions, and will stay tuned for further details.

Coverage at News.com.

Microsoft Faces XBOX Live Lawsuit

Microsoft's XBOX Live network, an on-line system which allows subscribers to access content and play games over the Internet, experienced difficulties over the holiday season due increased demand. Microsoft has acknowledged that the service problems are not acceptable, and has promised that subscribers will be given a free game to make up for the connection difficulties. However, apparently that is not enough for some -- 3 individuals in Texas have sued Microsoft for breach of contract and negligent misrepresentation over the system outages.

The lawsuit, which is filed on behalf of the individual plaintiffs and other XBOX Live subscribers, alleges that Microsoft should have known that there would be increased usage over the holidays (due in part to new subscribers), and should have made sure there was enough server capacity to keep things running smoothly. The suit claims damages of over $5 million.

While the system difficulties obviously had near devastating impact on the plaintiffs, their claim will have to address the XBOX Live terms of use. This contract, to which all subscribers agree, expressly states that the XBOX Live service is provided "as-is", "with all faults" and "as available", and that Microsoft gives no express warranties, guarantees or conditions. It also limits liability to direct damages, up to an amount equal to one month's service fees. Disclaimers and limitations of liability are not always enforceable, but unexpected network outages and system overloads come with the territory and most on-line agreements contain clauses addressing these issues. The lawsuit seems to have little merit, but it will be some time before there are any further developments.

Coverage at GameSpot.

CBC Article - Davis Video Game Lawyers in Second Life

The CBC recently published an article on Canadian businesses in Second Life. The article, written by Luigi Benetton, mentions Davis LLP's office in Second Life and features some spunky quotes from our Sarah Dale-Harris and Chris Bennett.

The article is available here.

Second Life Currency Open to Theft

A pair of white-hat hackers claim to have found a vulnerability in Second Life (through an issue with QuickTime, which is used to stream videos in SL) that allows them to lift Lindens (SL's in-game currency) from SL residents. This is important because Lindens can be bought and sold for real money, and many (real) people make decent (real) money through SL activities.

The hackers have reported the glitch to Linden Lab, and expect that a simple patch will fix things. Linden Lab has notified SL users, but the fix may depend on Apple changing the QuickTime software rather than Linden Lab fixing SL itself.

Coverage at the San Jose Mercury-News and at Game Politics.

Dave Spratley: second life lawyer extraordinaire

Our Dave Spratley is frequently accosted by paparazzi and admirers as he goes to and from work. Now things will no doubt get worse: Business in Vancouver recently quoted him in an article regarding Second Life. The saga continues...

Manhunt 2 gets hacked - but is it really any surprise?

Isn’t it kind of like getting sued? You know you’ve really hit the big time when someone takes the time to hack your software? Or was this just a stunt to promote game sales? Seriously though, it only took hackers three days to crack the Manhunt 2 software. And there is (or was anyway) a detailed video on YouTube just in case you needed the details. According to reports, the software was to have been modified to remove “ultra-violent… full-color death scenes” in order to comply with an Entertainment Software Ratings Board (ESRB) request. In light of the software’s recent hacking, it would appear however, that the scenes were not removed - just edited by adding a filter, so as to render them black and white. This isn’t the first time the game company has gotten into hot water - or what it “Hot-Coffee” - most recently, for not removing sexually explicit content from one of its games.

“Hackers apparently have altered one of those edits to produce an illegally modified version of the game that can only be played on an unauthorized, modified PlayStation Portable handheld system.”

“All of the game material, and especially these specific edits, was submitted to and reviewed by the ESRB in accordance with requirements regarding disclosure that were enacted two years ago and any contrary suggestion is inaccurate and irresponsible.”
Uh huh. Right. I’ll buy that for a dollar. I would say though that it is time you had some serious hackers on staff guys. And hey, ‘there is no such thing as bad publicity’, right?

You can still find the “death scenes” on YouTube but you are going to have to find them yourselves. And, not surprisingly, you can enter a fake birth date to access age-restricted materials. Trust me - I’m old enough to look - but my mother told me never to tell the truth about my age…

Coverage at Gamasutra and IGN.

Davis LLP opens Second Life office

Davis LLP is excited have opened its office in Second Life. The office was started by the firm's Video Game Law & Interactive Entertainment Group and currently focuses on intellectual property, technology and video game law. The Davis lawyers present in Second Life are represented by avatars, and the virtual office features a lobby, a library with topical legal information, a recruiting centre, and a secure boardroom.

Davis LLP lawyers that are currently residents on Second Life currently include Dani Lemon (avatar: Lemon Darcy), Sarah Dale-Harris (BarristerSolicitor Underwood), Pablo Guzman (PabloGuzman Little), Chris Bennett (IPand Teichmann), David Spratley (DaveS Blackadder), and Chris Metcalfe (IP Maximus).

"The virtual world of Second Life gives us the opportunity to interact with our current and potential clients in a unique way," stated Dani Lemon at Davis LLP. "We also aim to generate business leads and attract job candidates for our bricks-and mortar business through Second Life."

Davis LLP is a leading full-service law firm with more than 220 legal advisors and patent and trade-mark agents across Canada and in Japan. Davis LLP has Canada's first Video Games & Interactive Entertainment Law Group and the world's first Video Game Law blog, http://www.videogamelawblog.com, which has large and loyal international following.

For more information on Davis's presence in Second Life, please contact Dani Lemon in Vancouver at 604.643.6457, Sarah Dale-Harris in Toronto at 416.365.3510 or Pablo Guzman in Montreal at 514.392.8406, and visit http://slurl.com/secondlife/Zurich%20City/99/240/27

Gold Farming: A day in the life

Gold farmers generally have a bad reputation in the world of on-line games. However, Julian Dibbell (the author of "Play Money: Or How I Quit My Day Job and Made Millions Trading Virtual Loot") has written an interesting and insightful article for the New York Times titled "The Life of the Chinese Gold Farmer", which takes a look at gold farming from the perspective of those who spend 12-hour shifts playing WoW to earn miniscule amounts of money. Regardless of where you stand on the issue, the article should be an eye-opener.

The article was published on the New York Times site on June 17, 2007. Registration is required to view the NY Times site.

UK SURVEY OFFERS INSIGHTS INTO VIDEO GAMES

The British Board of Film Classification recently commissioned a survey in which gamers, parents and members of the game industry were interviewed about various aspects of video games. The BBFC is the UK's independent film and video industry regulator, and is also responsible for classifying video games.

The general consensus among the gamers surveyed was that games are a form of entertaining escapism, but do not desensitize players to real-world violence. Nor do gamers lose the awareness that they are playing a game or mistake games for real life.

The survey offers many other interesting insights about games and how parents and gamers (and parents who are gamers) view them.

Survey at: http://tinyurl.com/2q92ne

CONTRACTS IN THE MMO WORLD

We recently co-authored an article on MMO contracts with German lawyer Andreas Lober. The article was published in the CBA National Magazine's Addendum. For your reading pleasure, here's the link: http://tinyurl.com/2yxrsz

WoW LAWSUIT OVER BOT SOFTWARE

A flurry of legal activity has erupted over a piece of software called WoWglider. The software (see here) will play your World of Warcraft character for you while you do other things. WoWglider's FAQ states bluntly that using the software is a violation of WoW's terms of use, and that your WoW account may be closed if you are caught using it. However, the FAQ also points out the various steps taken to make WoWglider difficult to detect.

When the creator of WoWglider, Michael Donnelly, received notice that Blizzard and Vivendi considered WoWglider to be a copyright infringement and a violation of the Digital Millennium Copyright Act, he decided to strike first and commenced a lawsuit seeking a declaration that WoWglider does not infringe any rights.

Blizzard and Vivendi have now filed a countersuit claiming various infringements, including violation of WoW's terms of use, copyright and trade-mark infringement, violation of the DMCA (by circumventing copyright protection), unfair competition, and tortious interference with contractual relations. The countersuit alleges that by creating and distributing WoWglider, Donnelly's company is encouraging and enabling WoW subscribers to breach their contracts with Blizzard.

Coverage at: http://tinyurl.com/25h3kp (Gamasutra)

and at: http://tinyurl.com/2m2hys (Game Politics)

WoWglider's Complaint here; Blizzard and Vivendi countersuit here.

EBAY BANS (SOME) VIRTUAL PROPERTY

Online auction giant eBay has banned the trading of in-game property (e.g., characters, items, weapons, player accounts, etc.) from on-line games such as "World of Warcraft". eBay says that it has begun enforcing its rules against virtual property trading in order to protect its users and to provide them with a good eBay experience.

Other commentators suggest additional motives for eBay's decision. Some suggest that eBay is trying to avoid a 2-front battle against game companies and government regulators, both of whom have an increasing interest in virtual property trading. Others suggest that because there's a larger risk of fraud in virtual property transactions, eBay is eliminating the time and expense of dealing with fraudulent transactions.

Interestingly, eBay has specifically exempted trading in "Second Life" property. eBay says that it's not clear whether "Second Life" is a game. Further, "Second Life" involves a thriving functioning economy that depends on the trade of virtual property -- both in the game and in external forums like eBay.

Coverage at: http://tinyurl.com/2zmhqr (News.com)

SOUTH KOREA VIRTUAL PROPERTY LOBBY

Some time ago the South Korean government introduced a bill that would prohibit the real-world purchase and sale of MMO currency (although it would not affect transactions involving other in-game items, apparently). Now South Korean gold farmers have created a trade lobby organization (with the catchy title Digital Asset Distribution Promotion Association) to represent their interests. Given that South Korea's in-game item exchange market is estimated to be worth about US $1 billion, the new organization will undoubtedly have some political clout.

Coverage here: http://tinyurl.com/2cknsr and http://tinyurl.com/2tjj47 (GamePolitics)

SECOND LIFE GOES OPEN SOURCE

Second Life publisher Linden Lab has released virtual world's viewer as open source software, and intends to do the same with the server software that runs the virtual world itself. Linden Lab released the viewer software under the open source General Public Licence (GPL), which allows anyone to view, change and distribute source code, but requires anyone who distributes modified software to make the changes available as well. Linden Lab will require programmers to sign a contributor agreement which gives Linden Lab joint ownership of the software; Linden Lab will also maintain control of an official version of the viewer software.

This is a big step in the games industry, as most large game companies prefer to keep their code proprietary. However, Linden Lab believes that Second Life lends itself to an open source approach, and also believes that it still has significant income potential even if software is open source.

Coverage from News.com here .

Linden Lab press release here .

COPYING POSES THREAT FOR VIRTUAL ECONOMY?

Second Life is a popular virtual world with a thriving economy. Players design, create and sell of in-game items, including clothes, furniture, cars, etc. The items are bought and sold for in-game money, which can be exchanged for real-world money. Each player owns the rights in the content that he or she creates, and many players make modest (or not so modest) real-world profits from their Second Life businesses.

Therefore the creation and dissemination of a software program which can replicate any in-game object, including items created and sold by other players, is causing concern for Second Life's economy. The story sounds familiar to anyone following the digital copying controversy in the music and movie industries "? content owners are concerned that their content can easily be reproduced and distributed without any remuneration or acknowledgement. The same concerns apply in Second Life why should a player purchase a designer (virtual) suit in the game if that player can obtain and use a copy of it for free?

Second Life publisher Linden Lab has presented some solutions to the use of the copying software. First, it advises content creators to rely on the real-world Digital Millennium Copyright Act to prevent the unauthorized copying of their works. Second, it has stated that using an external application to make unauthorized duplicates within the game violates the terms of service, and those who engage in such copying may have their Second Life accounts closed.

This development should come as no surprise "? on-line games involve nothing but digital data, which is of course relatively easy to copy. But as the Second Life controversy demonstrates, the implications of such copying in the context of on-line games and virtual economies are far-reaching and challenging.

Coverage at http://shorl.com/dinatygrofregra (GameSpot)

THE TAX MAN COMETH!

Ever had the feeling that you pay too much tax? Ever escaped to your favourite MMO to avoid the realities of everyday life? Well, a taxing reality may soon catch up with gaming worlds and their economies at least in the US.

A senior economist for the Joint Economic Committee of the U.S. Congress has been quoted as stating that they are considering whether the sale of in-game goods should be taxed and that they are at 'the preliminary stages of looking at the issue and what kind of public policy questions virtual economies raise -- taxes, barter exchanges, property and wealth"?.

The MMO Second Life is cited in the GameDaily article referenced below as an example of a large in-game economy based on the purchase of virtual items like clothing and vehicles, which generates as much as a half million dollars in sales a day.

Will Canada follow suit? Stay tuned.

coverage at http://shorl.com/gevugrabebofro (GameDaily)

For more on the importance of MMOs' economies and the interest that they have generated IRL (both in business and with the tax authorities) you should read The New York Times article at  http://shorl.com/buvelidomapru (registration required)

GAME GUILD TRADE-MARKS NAME

This isn't breaking news, but it's an interesting issue that recently came to our attention. On-line gamers often create what are called 'clans"? or 'guilds"? "? namely, groups of players who game together, and who may have defined goals, rules, etc. (see the Wikipedia entry here ). One large, long-standing guild has gone so far as to register its name ('The Syndicate"?) and its logo as US trade-marks (see US registrations 3,027,852 and 3,027,530). Both marks are registered in association with 'entertainment services, namely, an online gaming guild providing in-game opportunities for proliferating game expertise and camaraderie among games supported by a web site featuring multimedia materials"?.

This is interesting for at least two reasons. First, it shows how on-line communities are beginning to act like many other real-world associations and entities. Second, The Syndicate explains that it registered the trade-marks in order to protect its reputation (most of which is based on in-game activities). Admittedly, the Syndicate guild is a particularly active and well-established one, and is involved in various real-world activities such as contributing to game development books, creating game guides, holding annual conventions, etc. Still, the fact that it decided to register trade-marks to protect its brand (and to prevent other guilds from using confusing names) is an interesting development indeed.
The Syndicate's explanation of its trade-marks is here http://shorl.com/hafrefanugriry

PLAYERS LOSE VIRTUAL FORTUNES IN ON-LINE BANK SCAM

Here's another dispatch from the wacky world of virtual property. Various players in the on-line game 'Eve Online"? gave large amounts of in-game currency to another player who operated an in-game on-line bank. The purported banker then made off with all the money, which caused quite a stir in the Eve Online community. However, the game's terms of use and EULA are permissive, and allow all sort of cons, swindles and thefts.

The interesting question is whether in-game activities like the bank con (which are permitted by the game's EULA) should have any real-world consequences. Arguably they shouldn't, seeing as how it's all part of a game and doesn't involve real money. The flip side, of course, is that in-game items and currency (including Eve Online currency) can be bought and sold outside of the game for real-world money. Did the victims of the scam lose something with real-world value? Should they be entitled to seek real-world remedies? If so, from whom? We don't have quick answers for these questions, but this story is another good example of the issues raised by virtual property.

Coverage at  http://shorl.com/fefruminosapy (News.com)

SQUARE-ENIX SUED FOR ROYALTIES

Reputedly the largest Chinese video game publisher, Soft-World International has sued Square-Enix for reimbursement of US$3.78 million in paid royalties based on the alleged breach of a MMORPG distribution contract.

 
coverage at http://shorl.com/behustabryfreti (gameindustry.biz)

Microsoft Security Engineer Warns "Those Of You Who Are Working On MMOGs, Organized Crime Is Already Looking At You!"

More than a little distress was caused this week when Microsoft security development engineer Dave Weinstein told developers at the Microsoft Gamefest that criminal elements are hacking into MMORPGs, stealing MMORPG account information, and selling it on the black market, effectively kidnapping and killing characters.

Weinstein outlined the following modus operandi taking advantage of chinks in a game's security software, criminals acquire account information and then illegally access accounts. Then, either the account information is sold on the black market or, more commonly, coveted in-game items and currency are stolen and turned into actual cash via online auction sites.

Virtual 'muggings"? also appear to be a problem in some MMOGs, where the aggressor uses software "bots" (thus making himself unbeatable) to beat up and then subsequently rob characters. The stolen virtual possessions were then exchanged for real cash. (see example here ). This, of course, is only possible in games where the victor of a fight can take the items of a fallen character, such is the case with Lineage II.

MMOG and MMORPG players spend at lot of time creating and building up their characters. With monthly subscriptions to games like World of Warcraft (paid) and Guild Wars (free) bringing an unending flow of new adventures, players spend hundreds of hours completing quests, accumulating experience, and acquiring gold and items. "For a lot of the customers out there, there is more store value on their MMOG characters than there is on the credit card with which they pay for the account.", Weinstein said.

Though most MMOG publishers are aware of such problems, Weinstein underscored the fact that real-world authorities are often unresponsive to in-game theft. "The police are really good at understanding 'Someone stole my credit card and ran up a lot of money,'" he said. "It's a lot harder to get them to buy into, 'Someone stole my magic sword.'"

Late last year, Square Enix dealt with a similar issue by banning 800 people from playing Final Fantasy XI, after it was found out that they were auctioning 'stolen"? items.  Another good way for online gaming companies to protect themselves is to ensure their license agreements and online terms of use agreements adequately deal with potential liability issues such as cheating, hacking, viruses and service interruptions.

Coverage at http://shorl.com/gigudatarudru

TABLE OF VIDEO GAME CASE LAW

We're pleased to report that our blog now contains a table of video game law cases.  It's a work in progress (we have a bunch more cases to add) but we're so excited that we just can't wait to share.  So here's the link  http://www.davis.ca/community/blogs/video_games/files/blogtable.htm

Keep checking back for updates.  There's also a link on the homepage of the blog. 

GAME BREACH HIGHLIGHTS PRIVACY CONCERNS

The developer of Xenepic Online, a popular Japanese MMOG, announced recently that players' personal information was inadvertently compromised. Information relating to almost 300,000 players was mistakenly stored on an open download server, making it easily accessible to hackers. The information included user names, passwords, and other account information, but apparently not credit card information.

Although this episode does not seem particularly serious, it highlights the fact that game providers who collect players' personal information must be very careful about protecting that information from unauthorized access or disclosure. Consumers are increasingly aware of privacy issues, especially as fears about identity theft become more widespread and information security breaches are more widely publicized (e.g., there has been a great deal of news about the recent the US Veterans Affairs episode, in which a laptop containing personal information, including social security numbers, of millions of US veterans and military personnel was stolen). Privacy laws requiring the protection of personal information exist in many jurisdictions, and game providers should make sure that they protect and keep secure any personal information that they collect. To do otherwise risks, at best, some bad publicity and, at worst, regulatory fines or civil suits.

Coverage at http://shorl.com/guvetrarobiba (GameSpot)

SQUARE ENIX CRACKS DOWN ON REAL MONEY TRANSACTIONS

Square Enix is taking steps to stop the trading of in-game currency (called "gil") from Final Fantasy XI online multiplayer game for real money (artfully referred to as Real Money Trading, or RMT). The game's user agreements expressly prohibit players from engaging in RMT activities.

According to Square Enix, a detailed investigation identified a group of players who were using 'illicit methods"? to produce large amounts of gil and then selling that in-game currency for real-world money. As a result, Square Enix has terminated 250 user accounts and removed more than 250 billion gil from circulation.

Square Enix announcement at http://shorl.com/dotubrostutuse

Square Enix statement about RMT (December 2004) at http://shorl.com/fusafastosodra

Coverage at http://shorl.com/byrutogijusti (GameSpot)

VIRTUAL PROPERTY - RSS FEED

Our blog has over two dozen categories of video game law material, including advertising law, IP law, privacy law and more. We now have a new category and RSS feed for virtual property in video games. This is a hot topic in the video game law world, and we have lots to say about it. 

To prove it, here's a great overview of the subject written by our Dave Spratley (the guy who insanely believes that an Imperial Star Destroyer could take the USS Enterprise an in a one-on-one fight)  http://www.davis.ca/community/blogs/video_games/files/virtual_property.pdf

He's obviously off his rocker on Star Wars vs. Star Trek issues, but fortunately for him he's a great writer. An abbreviated version of the article was published in the April 21, 2006 issue of The Lawyers Weekly

MICROSOFT GETTING MASSIVE?

We've talked before about in-game advertising (for example, here  and here ). One of the leaders in this field is Massive Inc., a New York firm that has developed technology that lets dynamic advertisements be inserted into video games.

There are now reports that computer giant Microsoft is in negotiations to purchase Massive (perhaps for as much as $400 million). Microsoft has not confirmed these reports. If such an acquisition takes place, Microsoft will be able to increase and improve the in-game ads in its on-line XBOX games.

Coverage at http://shorl.com/fagydrypribrynu (E-Commerce Times)

CHINESE COURT UPHOLDS CONVICTION FOR STEALING VIRTUAL PROPERTY

Last year a Chinese court convicted a man for selling passwords and in-game property which he had stolen from players of the online game "Da Xihua Xiyou". Another court has just upheld the initial decision, stating that the robbed players had spent time, energy and money acquiring and adding value to their virtual property. The accused had sold the stolen (virtual) goods for about $500; he was fined about $620 for his illegal activities.

Coverage at http://shorl.com/henumuhyropri (ZDNet)

ENTERPRISE VS. STAR DESTROYER, PART II

In an earlier post some of us speculated that the USS Enterprise could defeat an Imperial Star Destroyer. (To be fair, it wasn't an a unanimous judgment, but we cleverly neglected to post the dissenting opinion).

Well, the debate has reopened--now that developer Bethesda Softworks has announced that it owns the exclusive licence to develop Star Trek games in all formats. 

This is interesting for two reasons first, it's unexpected because just last year, Activision (the previous licensee) settled its dispute with Viacom. The prevailing wisdom at the time was that Activision would keep the licence for several more years. 

The other reason this development is interesting is because Bethesda's exclusive licence apparently does not include MMORPGs.  And (here's the interesting part), this appear to be a trend. According to Gamasutra, other licensors are taking a similar approach and treating MMORPG licences separately from other game licences. 

Coverage here  http://www.shorl.com/jebrojuganodu

WoW CRACKDOWN CONTINUES

We reported several months ago (see post ) about how Blizzard was scanning the hard drives of World of Warcraft players, trying to prevent hacking and cheating. Blizzard is obviously keeping on top of things, as it has announced that over the past three months is has permanently closed more than 18,000 WoW accounts for violating the Terms of Use.

Most of the closed accounts were using third-party programs to collect gold and items for sale in the real world.

Blizzard's report at http://shorl.com/fastynobrobradri

Coverage at http://shorl.com/hagrivakedygro

SUPERHERO SETTLEMENT

A year ago Marvel sued NCsoft Corp. and Cryptic Studios Inc. over "City of Heroes", claiming that the game's character customization function allowed players to create superheroes that closely resemble trade-marked Marvel comic characters (see our post ). More than half of Marvel's claims were dismissed a few months later, including its claim for trade-mark infringement (see our post ).

NCsoft now reports that the parties have reached a settlement which will let 'City of Heroes"? continue unchanged. As a result, the parties (and us) are spared a judicial decision dealing with player-created content.

However, the settlement does not mean that all is hunky-dory between Marvel and NCsoft "? Marvel and Microsoft are pairing up to make an XBOX 360 MMO based on the Marvel superhero universe, which will compete directly with 'City of Heroes"? (as will Sony's recently-announced MMO based on the DC Comics universe).

Coverage at http://shorl.com/dimefyprugesty

SONY ANNOUNCES PARENTAL CONTROLS

Sony has announced that its next-generation Playstation 3 will contain controls which allow parents to restrict their children's access to video games or movies with certain ratings, and to control access to on-line gaming.

Nintendo has announced similar plans for its next-generation Revolution, and Sony's Xbox 360, released last week, already has such controls built in.

Coverage at http://shorl.com/hykyhubronule

LIABILITY IN THE MMO WORLD

We just published an article in theLawyers Weeklyregarding unexpected potential liability in the online gaming world. 

Here's the link  http://www.shorl.com/gorufebradrome

WHAT HAPPENS IF YOU KILL AN MMO GAME?

EA Japan has decided to stop supporting Star Wars Galaxies in Japan. Gamers in Japan can apparently transfer their accounts to other servers; however, the shut-down still raises an interesting question what would happen if a game company were to completely kill an MMO game?

Game companies need to plan for this possibility before launching an MMO game. The concern is that gamers spend money on the games--expecting to be able to play them online. This expectation might be factored into the purchase price of the game. 

In addition, gamers spend money each month to gain access to the online portion of the game. They also spend countless hours building up virtual property in the game (which has a real world value and can be sold on online auction sites).

The loss of the MMO portion of the game could therefore result in the loss of gamers' time and money. And this could result in a damages claim against a gaming company.

That's why it's important for gaming companies to deal with this possibility in advance. End User Licence Agreements and Online Terms of Use should address MMO termination. It would also be a good idea to discuss this possibility in the user documentation for the game. 

Star Wars Coverage at  http://www.shorl.com/gygrestitejose

W.O.W. VIRUS AND MMO LIABILITY

Earlier this month, Blizzard added a new dungeon (Zul'Gurub) to World of Warcraft. Dwelling in the dungeon is a monster called Hakkar, who has the ability to infect players with a virus called 'corrupted blood"?. 

It appears that Blizzard intended to limit the infection to characters near Hakkar's corpse; however, the infection has spread to other parts of the game (through a virtual pet!) and has affected hundreds of players. 

Blizzard is attempting to resolve the problem, but this raises an interesting issue for video game lawyers to what extent can online gaming companies be held liable for damage or destruction caused to online players or their virtual property? 

The Blizzard case is probably not a big deal (players are resurrected in Warcraft), but there have been other cases where the potential for liability seemed much higher, such as when there's cheating or theft involved. 

Earlier this year, Square Enix dealt with these issues by banning 800 people from playing Final Fantasy XI. Another good way for online gaming companies to protect themselves is to ensure their licence agreements and online terms of use agreements adequately deal with potential liability issues such as cheating, hacking, viruses and service interruptions.

Coverage at http://www.shorl.com/bidobresiprofry

MAN ARRESTED FOR VIRTUAL MUGGINGS

We're all aware that people sometimes get mugged for their flashy possessions "? an iPod, say, or an expensive pair of shoes. This sad trend has now made its way into the virtual world. A Japanese man suspected of conducting on-line muggings in the game Lineage II has been arrested. The man allegedly used software bots to attack and rob characters in the game, then sold the virtual possessions for real cash through an auction website.

Coverage at http://shorl.com/banudryledryve

A BLIZZARD OF PRIVACY QUESTIONS

Blizzard Entertainment is receiving flack from some players for scanning players' computers for illegal cheats and hacks relating to the massively multiplayer online game World of Warcraft. Some players claim that preventing cheating and hacking is not a sufficient excuse to impinge on their privacy. Blizzard, on the other hand, says that looking for hacks in the actual game itself is not unreasonable, and points out that World of Warcraft's end-user licence agreement (which players must review and acknowledge before playing) explicitly states that Blizzard reserves the right to scan for hacks and cheats.

Putting information about the scans in the EULA is a good move (Sony ran into trouble with Everquest players because it performed similar scans without giving notice to its players), and this story highlights the importance of actually reading software licence agreements instead of just scrolling through and hitting 'I accept"?.  Personal hard drives are increasingly open to prying eyes "? readers may recall that Microsoft generated much discussion when it announced new measures to verify that users seeking upgrades actually had legitimate copies of its operating system -- and it is a good public relations move to be as open about such activities as possible.

Coverage at http://shorl.com/bogatygravuge

DEATH ATTRIBUTED TO EXCESSIVE GAMING

CBC reports that a 28-year-old South Korean man has died after gaming almost continually for 50 hours. South Korean officials say that the man (who apparently quit his job in order to have more time to play games) is presumed to have died from heart failure due to exhaustion.

There must be more to this story (for example, was the man suffering from bad health to begin with?), but it serves as a reminder that all things, including video gaming, are best taken in moderation.

Coverage at http://shorl.com/bifropopymufri

CHINA SETS NEW GAMING REGULATIONS

The Chinese government has issued several new regulations relating to the on-line gaming industry. Chief among these is a new policy that prohibits minors (under 18) from playing on-line games in which players are able to kill other players. This regulation could have a very significant impact on the Chinese game industry China has an estimated 20 million on-line gamers, a substantial portion of which are under 18.

Other new regulations require game operators to implement timing systems that automatically log players off of on-line games after a set period of continuous play and create a requirement that a company trying to become a licensed on-line game operate must have registered capital of at least US $1.23 million.

Coverage at http://shorl.com/dutrevastikubra

BLAM! POW! SONY AND MICROSOFT IN SUPERHERO SHOWDOWN

Microsoft has joined forces with Marvel Enterprises to develop a massively multiplayer online game featuring Marvel's cast of superheroes (which includes Spider-Man, the Hulk, the Fantastic Four and the X-Men). Not surprisingly, this is a response to a similar deal reached last month between Sony and DC Comics (whose superhero stable includes Batman, Superman and Wonderwoman)

The entertainment industry is starting to recognize the commercial potential of MMOs, and these agreements reflect that understanding. Currently, the most successful MMOs are PC-based and generally require powerful (and expensive) home computers. However, both Sony's and Microsoft's next-gen consoles will support MMOs, and breaking into that market (especially in Asia, where MMOs are hugely popular) is an important part of their marketing strategy.

Coverage at http://shorl.com/dodrojanemoje

BATTLENET APPEAL

You can stop holding your breath today's the day that the Battlenet appeal gets heard in St. Louis. 

As we reported last year, Blizzard Entertainment won its lawsuit against Internet Gateway Inc. and various individuals who reverse engineered Blizzard's software and protocols to create the bnetd project, a free and unregulated alternative to Blizzard's Battle.net arena.  The court ruled that the defendants' activities violated US copyright law and also violated Blizzard's software licences and online terms of use.

Now the bnetd folks are appealing, claiming that the decision "could dramatically impact consumers' ability to customize software and electronic devices and to obtain customized tools created by others". 

It's true this is an important decision. Stay tuned for the results.
Coverage at  http://www.shorl.com/gigalapranyjo

REAL-LIFE KILLING OVER VIRTUAL SWORD

A disturbing episode in China highlights how seriously some people take on-line games. Qiu Chengwei spent hours playing Legend of Mir III and eventually obtained one of the game's most powerful weapons, the dragon sabre. Qiu then lent the virtual sabre to Zhu Caoyuan, who proceeded to sell it for real money. Chinese police did nothing when Qiu complained, taking the position that the virtual sword was not property that could be stolen. Qiu eventually attacked and killed Zhu. He has been sentenced to death for murder, although the Chinese court has suspended that sentence for two years and the sentence may eventually be reduced to prison time.

This episode raises many questions, including the treatment of virtual "property" and the social consequences of excessive on-line gaming.

Coverage at http://shorl.com/fefustustidremu

And at http://shorl.com/babuhufryfrake

THERE'S A STORM BREWING ON BATTLE.NET

Blizzard has shut down over 50,000 Battle.net accounts for cheating. It also suspended over 8,000 CD keys and permanently banned over 3,000 CD keys.

Cheating is no fun for gamers, so it's obviously bad for business. It's also an area of potential liability for gaming companies who are easier to sue than the cheaters.
Coverage at http://www.shorl.com/hyjastegrifuha

THE ONLY THING BETTER THAN A PORTABLE VIDEO GAME...

...is apparently a portable video game with ads. The Tiger Telematics' portable video game console "Gizmondo," which is expected to be released in North America later this year, has developed an interesting approach to keeping the unit affordable. Up to three times a day, a Gizmondo will play an ad beamed to it by Tiger and which is tailored to each individual user. Our prediction? Lots of ads for video games.

Full coverage at http://www.shorl.com/jefysyprusute

GAMING'S PROHIBITIVELY HIGH EXCHANGE RATES

Blizzard Entertainment, the publisher and developer of the hit massively multiplayer "World of Warcraft," has permanently suspended more than one thousand "gold farming" users from the game. Blizzard claims that gold farming, whereby a user sells her online character's "gold" to another user in exchange for real world "dollars", damages World of Warcraft's in-game economy.

Apparently, Blizzard hopes its users will find gold through actually playing its game, rather than paying someone else to play it for them.

Coverage at http://shorl.com/hibabredapody

HEROS ONE; MARVEL ZERO

Last year, in an article (brilliantly, we think) entitled 'Maybe Modding Isn't So Marvellous"?) we reported that Marvel Comics had sued the publisher and developer of City of Heros. Marvel claimed that the character customization functionality in the game allows players to create superheroes that closely resemble trade-marked Marvel comic characters like "The Incredible Hulk" and the "X-Men".

Marvel's lawsuit recently suffered a major setback more than half of Marvel's claims were dismissed"?including Marvel's claim that the defendants had directly infringed Marvel's registered trade-marks.

On the copyright issue, the judge concluded that the character customization feature has a substantial non-infringing use (for example, making superheros who look like lawyers). This meant that the defendants shouldn't be held liable for contributory copyright infringement.

Coverage at  http://shorl.com/bestebribymeste
And at  http://shorl.com/fytugreprynuvy

MONOPOLIZING MONSTERS GROUNDS FOR EXILE

More than 800 Final Fantasy XI players have had their on-line accounts permanently deleted for violating the game's user agreement.  For example, some of the players monopolized monsters (to prevent other players from accessing the monsters' treasure, which of course has great in-game value) and harassed and killed other players' characters.  The terms of service specifically prohibit such activities, which may disturb the enjoyment of other users.  The fact that monster-monopolizing might be enjoyable doesn't matter.Coverage at  http://shorl.com/hatotresekodru

NINTENDO GETS PICKY ABOUT WIKI

Nintendo has warned Webzen (the publisher of MU Online) that some of the characters in Webzen's new online game, Wiki, are similar to those in The Legend of Zelda The Wind Waker.  Nintendo says it will wait until Wiki is finalized before deciding whether to start a lawsuit.  Coverage at http://shorl.com/hastefrejybofi

DON'T ATTACK ME - I'M ORDERING PIZZA

Two recent stories address the development of in-game advertising and product tie-ins.  First, Sony's new Everquest II on-line multiplayer game has a built-in function that lets players access the Pizza Hut website and order pizza without leaving the game (the game does not pause during the transaction, however, so players are cautioned only to order pizza while in a safe place).  Sony also plans to integrate the pizza function even further, so that players can charge their pizza purchases to their monthly game subscription bill.  How Sony plans to deal with the resulting waste issues remains to be seen.Second, Swedish game publisher Funcom has entered into a new deal with Massive which will see Massive stream advertising into the Anarchy Online gameworld.  As discussed in Issue 1.1 of the Video Game Law Report, this in-game advertising trend will only get bigger as advertisers catch on to the fact that a key market demographic is shifting from television to video games for entertainment.Coverage at  http://shorl.com/badekogryfose http://shorl.com/fastidynidobru

AND WATCH OUT FOR THOSE ANCIENT GREEKS!

There's more to watch out for online than upset ex-girlfriends. A new Trojan horse called "LegMir-Y" is also out to steal usernames and passwords for Lineage. And as it turns out, real-world crime is not new to the Lineage arena online gamers have been hacking into other users' accounts, stealing other users' online identities and fraudulently selling virtual weaponry for years.     

Coverage at http://shorl.com/jabralofrofije And at http://shorl.com/byfrylevobrifri

REVERSE ENGINEERS LIABLE

(This is an archived case summary)

Davidson & Associates v. Internet Gateway, et al
US Court of Appeal for the 8th Circuit (2005) No. 04-3654

The plaintiffs do business as Blizzard Entertainment, and make and sell computer games such as StarCraft and WarCraft. Blizzard launched an online service, Battle.net, that allowed gamers to play with each other over the Internet. Blizzard has valid copyrights on all of its games.

Blizzard took steps to avoid piracy by creating various safeguards in its software. For example, when a user connects with the Battle.net server, the server performs a "secret handshake" with the game to verify if the game is an authorized version. Furthermore, in order to play a Blizzard game users must install the game and agree to comply with the End User Licence Agreement and Terms of Use (both of which prohibit reverse engineering).

The defendants created a similar server to Battle.net and reverse engineered the Blizzard software to allow users to play both real and pirated versions of the Blizzard games online. The most significant difference was that the defendants' server read every code as an "ok" when performing the "secret handshake" and allowed users to log on regardless of the status of their software.

The Court of Appeal upheld the District Court's finding of copyright infringement, circumvention of copyright protection systems, trade-mark infringement and breach of the user agreements.

REVERSE ENGINEERING BREWS UP A STORM ON BATTLE.NET

Blizzard Entertainment recently won its lawsuit against Internet Gateway Inc. and various individuals who reverse engineered Blizzard's software and protocols to create the bnetd project, a free and unregulated alternative to Blizzard's Battle.net arena. The court ruled that the defendants' activities violated US copyright law and also violated Blizzard's software licences and online terms of use.  

Other software publishers should take note that the court was impressed by the following (a) Blizzard's licence agreement explicitly prohibited reverse engineering, (b) the software boxes and packaging stated that the customers' use of the software and Battle.net were subject to a licence agreement and terms of use; (c) the pop-up licence agreement and terms of use gave users explicit notice that their use of the software and Battle.net was governed by the agreement and that the users could return the software for a full refund if they didn't agree to the terms; (d) users would not be able to use the game if they did not consent to the agreement and the terms by clicking "I Agree".

Coverage at http://shorl.com/dujenanurata

BANNED FOR HALF-LIFE

Half-Life 2 maker Valve has hit back at players who obtained pirated copies of its popular new game. To be able to play, players must set up an account on Steam, Valve's online gaming community. Steam then verifies whether the player's game is legitimate or pirated. Valve has now shut down close to 20,000 Steam accounts on the grounds that the account holders obtained the game illegally. Valve maintains that this system makes it easy to trace and confirm which accounts use pirated copies, but some banned users claim they are innocent. Clearly there are some wrinkles to be ironed out, but Valve's approach may be a significant new development in copyright protection for video games.

Coverage at http://shorl.com/gesavakymutra

IN-GAME ADVERTISING THE NEXT BIG THING

Video games are growing in popularity and pulling audiences away from more traditional forms of entertainment such as movies and television. And where audiences go, advertisers are quick to follow -- advertisements in video games are on the rise, as are advertising revenues for video game publishers. In fact, a newly-created video game advertising network lets advertisers deliver new ads directly into games through online connections, and allows advertisers to measure the exposure of each ad. In-game advertising is therefore a trend that video game publishers (and developers) must recognize and take into consideration as it becomes a regular and important aspect of the video game business.

Coverage at http://shorl.com/fuprobrugalygry