Legal Issues with Virtual Worlds and Social Media

On February 3rd, 2010, The George Washington University Law School Cyberlaw Students Association hosted Jim Gatto, head of Pillsbury’s Virtual Worlds and Video Games practice group, who spoke on Legal Issues with Virtual Worlds and Social Media.

There are lots of interesting issues around virtual goods such as: How should we value virtual currency? What about taxation, seizure, property rights, etc...? If virtual goods or avatars have real-world value can companies just up and delete them or take them away without compensation? Are they “assets” if a company goes out of business? What happens to someone’s virtual goods when they die in the real world?

Virtual currency issues and virtual goods issues are covered in pages 35-37 of the presentation. Gatto states that "many virtual currencies will be viewed as 'stored value' or 'gift card' accounts by relevant state and federal regulators."

For further reading/viewing:
"3 Reasons Pay-With-Facebook Won't Squash All The Other Payments Providers", Nicholas Carlson, Business Insider, February 8, 2010
"What Happens to Your Virtual Property When You Die?", Stephen Wu, 3D Internet Law, December 2, 2009
"Intersecting Interests: Virtual Worlds and the Law", Metanomics with Robert Bloomfield, May 20, 2009
"Monetizing the Metaverse", Metanomics with Robert Bloomfield, October 13, 2008
"Taxation of Virtual Worlds", Metanomics with Robert Bloomfield, October 22, 2007

South Carolina: "Gold and Silver Coin as Legal Tender" Act Introduced

By Bill Greene
Constitutional Tender Blog
Saturday, February 6, 2010

http://constitutionaltender.blogspot.com/2010/02/south-carolina-gold-and-silver-coin-as.html

South Carolina has joined the growing ranks of States which have had Constitutional Tender bills introduced!

On February 2nd, 2010, SC Rep. Michael A. Pitts (District 14 - Abbeville, Greenwood & Laurens Cos.) introduced H. 4501, the "Gold and Silver Coin as Legal Tender" Act. This bill would allow "silver and gold" to once again be legal tender in South Carolina, as opposed to the paper bank notes of Federal Government debt.

The language of H. 4501 is different than our model Constitutional Tender Act bill, but the effect would be the same - making gold and silver coin the only thing allowed as payment to and from the State.

We'll take that!

Watch an interview with Rep. Pitts about his bill last year supporting States Rights in South Carolina.

The Constitutional Tender blog was originally set up to facilitate discussion of the "Constitutional Tender Act," which was being proposed in Georgia. Reprinted with permission.

For further reading:
"Bill would ban federal currency in SC" , Adam Fogle, The Palmetto Scoop, February 17, 2010
"States Rights Bills Now Calling for Gold and Silver Money", Aurelia Masterson, AOCS Direct, February 1, 2010

Virtual Law: Navigating the Legal Landscape of Virtual Worlds

The American Bar Association recently published an innovative virtual worlds legal book, Virtual Law: Navigating the Legal Landscape of Virtual Worlds (2008).

From the Reviews:

"The book is timely, circumspect, well written and grounded where it is supposed to be while provocative in areas that it needs to be. The author's experience in virtual world use and commentary shines as he teases out the importance of law to virtual worlds, and vice versa. Benjamin Duranske makes virtual law in concept and practice very tangible and understandable. This book is not only a book introducing Virtual Law -- it is a book of reference for lawyers, virtual world users and virtual world owners alike." -- Taran Rampersad Virtual World/Second Life®/ICT Consultant, KnowProSE.com

"Knowing 'virtually' nothing about Second Life, I finally determined to curl up with Virtual Law as continuing education this weekend. I didn't put it down until I finished it. The comprehensive outline of topics, the accessible language, and spot on exhortations of the relevance of this technological phenomenon should make this a best seller. The book gave me, a total amateur, several business development ideas on first reading, and I look forward to actually spending real dollars, not Lindens, to purchase several more copies for non-lawyers to read." -- Chris Grant , Esq. CEO InfecDetect , LLC Princeton, NJ

"Ben Duranske hits the mark again and again with this clear, straightforward overview of legal issues in virtual worlds. All of the main arguments are here, in a single source, allowing the reader to balance the claims of contract law against those of property law in regulating the toughness of the magic circle. Woven together, these arguments constitute a desperately-needed consensus, one that recognizes the inevitable influence of real-world law on the future of this critical medium, but also its limits." -- Edward Castronova Associate Professor, Indiana University, Bloomington, Indiana

"Benjamin Duranske's 'Virtual Law' is far and away the most thorough, clear-sighted, and enlightening introduction to the legal implications of virtual worlds that has been written. It is a must-read for anybody -- lawyer, plaintiff, or defendant -- with a stake in the legal system's fast-evolving relationship with this strange new realm of human affairs." -- Julian Dibbell Contributing editor, Wired magazine; co-moderator, Terra Nova collaborative blog; author, Play Money: Or, How I Quit My Day Job and Made Millions Trading Virtual Loot
From Amazon Product Description:

This book introduces readers to the emerging and exciting world of virtual law. It examines current cases and legislation impacting virtual world providers and users, and makes predictions about the future application of current law. It addresses the application of intellectual property law (copyright, trademark, and patent), criminal law, property law, contract law, securities law, tax law, and civil procedure. It also provides practical advice to lawyers who wish to create a virtual world presence for their practice or who have clients with virtual world connections. The book includes extensive appendices listing in-world and web-based resources for practitioners and legal scholars.

For further reading/viewing:

"Metanomics Revisited", Metanomics with Robert Bloomfield, September 22, 2008
"Blawg Review #156", Virtually Blind, April 21, 2008
"Virtual Banking Revisited", Metanomics with Robert Bloomfield, January 14, 2008
"Virtual Banking", Metanomics with Robert Bloomfield, January 10, 2008

Euro Trashed?

By John Browne
Euro Pacific Capital, Inc.
Wednesday, February 10, 2010

http://www.europac.net/externalframeset.asp?from=home&id=18180&type=browne

The European experiment with a trans-sovereign currency is facing its first acid test. The flashpoint today is Greece, which looks set to default on its debt barring some outside intervention. While many commentators have been squawking about the immediate crisis as if it were the end of life on Earth, I would like to zoom out and discuss the history and longer-term outlook for the euro and its parent, the European Union.

The launch of the euro was a major milestone in the sixty year process of European federalization. Economic considerations have always led the charge, from a normalization of tariffs to a free-trade area to a customs union. Still, the launch of a pan-European fiat currency and central bank without a unified political apparatus behind it was always considered a risky move.

Since its launch, the euro has outperformed expectations, establishing itself both as the world’s secondary reserve currency and the second most traded currency after the U.S. dollar. Because of this stellar introduction, the euro has been proposed as the new primary reserve currency in place of a devaluing U.S. dollar. However, its unusual foundation presents risks to which most investors are unaccustomed.

In essence, the euro was created as a lever to encourage a complete European political union rather than as a currency representing a call on an already unified economy, as with the U.S. dollar. Jean Monnet, one of the EU’s founding fathers, is reported as saying, “Europe’s nations should be guided towards the super-state without their people understanding what is happening. This can be accomplished by successive steps, each disguised as having an economic purpose but which will inevitably, and irreversibly, lead to federation.”

The currency has largely succeeded in creating the will for a federal Europe among the member states’ political classes; however, the citizens have voted again and again to maintain their countries’ independence since 2005. Thus, the Union was already losing momentum when the latest financial crisis struck.

The combination of tight credit markets and high debt-to-GDP ratios caused bond yields for the EU members collectively known as PIGS (Portugal, Ireland, Greece, and Spain) to fly upward. As a result, Greece is now in acute jeopardy of officially defaulting on its debts. Because a political union was never implemented, Greece cannot be compelled to slash its budget, nor can it assume the Union will prevent its fiscal failure.

This explains why investors are making short-term trades out of the euro and into the dollar. While the Greek deficit-to-revenue ratio is roughly equal to that of California in 2009, the latter functions with an implicit (although untested) guarantee that the U.S. government will step in before they are forced to default. The EU offers no such backing to its member-states. In fact, recent questions have arisen out of Germany, the primus-inter-pares of EU members, concerning the legality of the European Central Bank (ECB) or the European Union ever giving direct aid to the Greek government.

While many assume that either Germany, an ad-hoc group of European states, or the IMF will bail out Greece, such a result would represent a temporary fix rather than a policy precedent. The move would pose more questions than it answers. If Greece were to be thrown a lifeline what would happen if Portugal, and then Spain, were to ask for equal consideration? Will Greece be spared expulsion from the eurozone if it fails to take the austerity measures necessary to restore solvency? If not, what message does that send to Ireland, which chose to slash its budget rather than wait for a bailout?

These problems did not spring from the æther. The architects of the euro, in pursuit of their political agenda, willfully disregarded the historical divide between the Nordic economies, which have practiced low inflation and fiscal discipline, and the Mediterranean, high-debt, easy-money economies. While there were strict economic, monetary, and budgetary criteria for entry into the currency, one can reasonably suspect that enforcement was lax or the numbers were fudged. After all, the southern states’ balance sheets tilted deep into the red soon after acceptance in the Union. Now, however, the ECB prevents them from monetizing the debt.

So, we are witnessing the results of this inherent contradiction.

If the EU becomes the “bailout union,” a free-ride area where entitlement spending in Greece is underwritten by German taxpayers, then the euro will stabilize in the short-term, as investors face reduced uncertainty. However, this will lock the Union on a trajectory to gradual monetary collapse – the path currently being followed by the U.S. dollar.

If Greece is left to face the consequences of its profligacy, then the integrity of the euro will be preserved. The key in this scenario is whether Greece leaves the euro, or the Union, when it defaults. If it does, we could see weaker economies cast out one-by-one until Europe returns to a system of national currencies, with perhaps a rump euro uniting the Nordic block. If Greece defaults but remains in the block, then short-term shock will give way to a renewed confidence in the euro as a lasting reserve currency.

The future of the EU is being tested severely, together with much of the wealth of investors who have diversified into its currency. Likely, this crisis will draw the EU member states into a covert political struggle over the future of Europe. As this battle ebbs and flows, both the euro and the U.S. dollar likely will suffer great volatility. Those of us parked in the safe harbor of gold may benefit greatly from this transatlantic turbulence.

John Browne is the Senior Market Strategist for Euro Pacific Capital, Inc. Reprinted with permission.

For a more in-depth analysis of our financial problems and the inherent dangers they pose for the U.S. economy and U.S. dollar, read Peter Schiff's 2008 bestseller "The Little Book of Bull Moves in Bear Markets" and his newest release "Crash Proof 2.0: How to Profit from the Economic Collapse." Click here to learn more.

More importantly, don't let the great deals pass you by. Get an inside view of Peter's playbook with his new Special Report, "Peter Schiff's Five Favorite Investment Choices for the Next Five Years." Click here to download the report for free. You can find more free services for global investors, and learn about the Euro Pacific advantage, at www.europac.net.

For further reading:
"Things Fall Apart in Eurozone", John Browne, Euro Pacific Capital, Inc., January 12, 2010

Vietnam to Devalue Dong 3.4%

By Nguyen Pham Muoi and Patrick Barta
The Wall Street Journal
Wednesday, February 10, 2010

http://online.wsj.com/article/SB10001424052748704140104575057352232145736.html

HANOI—Vietnam said it will devalue its currency for the second time in less than three months as the Southeast Asian nation continues to struggle with a hangover from economic volatility during the past two years.

An increasingly popular destination for Western capital, Vietnam continued to post strong growth rates even through the dark days of last year's global recession. But economists say the country's strong recent performance–including growth of roughly 5.5% in 2009, according to the World Bank—masks serious underlying problems including a large trade deficit, high inflation and a shortage of U.S. dollars needed to keep the financial sector humming.

All that has put severe pressure on the Vietnamese dong as local residents lose confidence in their currency. By contrast, some other Asian countries have seen their currencies rise recently, as their economies regain their footing after the latest global financial crisis.

The State Bank of Vietnam, the country's central bank, said Wednesday it will devalue the Vietnamese dong by 3.4% effective Thursday. That comes on top of a 5% devaluation in November and two other devaluations since June 2008. Now, one U.S. dollar will buy 18,544 dong, compared to 17,941 dong earlier in the week.

The central bank on Wednesday also imposed a 1% ceiling on interest rates on dollar deposits at banks by "economic institutions," not including credit institutions, to try to flush more greenbacks into the market.

The devaluation will help make Vietnam's key exports, which include shoes, coffee and rice, cheaper than those of many other Asian countries, potentially improving its relative position in global trade. That could increase tensions with some neighbors, especially Thailand, with which it competes heavily in global markets. Thailand has already complained that some currencies in the region, including the Chinese yuan, may be undervalued.

Read the rest of the article.

For further reading:
"Vietnam Devalues Dong Again, This Time by More Than 3%", John Ruwitch, Reuters via Interactive Investor, February 10, 2010

Russian Banks on the Offensive to Stop E-Money Issuers

By Daniel Gusev

Retail Banking in Russia: Innovation Unfolded
Monday, February 8, 2010

http://valuedrivenbanking.blogspot.com/2010/02/banks-are-on-offensive-to-stop-emoney.html

The bill on national payments system was leaked to the press - where it became clear that banks want to take away the emoney issuance function away from emoney operators. What gives?

Emoney was and is pretty much the single factor developing ecommerce and motivating "web entrepreneurship" between uninstitutionalized agents. Cost effective clearing mechanism enabled new "grey merchants" to launch into business and promoted trade - since most emoney schemes, i.e. Yandex Money, in Russia are part of search engines. Emoney was a tool of content monetization. From here, how strong can the anti-emoney movement be?

According to the bill - only credit money institutions can be held liable against money issued - so emoney issuance should be their exclusive prerogative. The institution may then establish relationship with a payment agent who will on his part be able to offer operational and clearing services to the end users. In fact - the whole emoney will likely be rendered into prepaid schemes - where liabilities would be issued by banks and emoney will become agents "connecting the dots". Ability to pay without KYC principles will be kept for sums lower than RUB 15 000.

It's hard to say, whether the whole idea will work - it may kill illegitimate and illiquid emoney schemes and promote the use of major virtual currencies - since the operators would still be in control of the dots - no matter they will act more like agents than issuers. The bill still proves a major conclusion: banks see a big business in emoney.

Daniel Gusev is the publisher of Retail Banking in Russia: Innovation Unfolded. Reprinted with permission.

For further reading:
"Emoney in Russia - the Dark Side of the Moon for (most) banks", Retail Banking in Russia: Innovation Unfolded, January 18, 2010
"Emoney iPhone apps win over banking - but are not on the top 100 list", Retail Banking in Russia: Innovation Unfolded, December 27, 2009
"Banks are scared of emoney - because they will end up with loosing contact with customers", Retail Banking in Russia: Innovation Unfolded, December 24, 2009
"Non Bank Payments with Webmoney Transfer (part 1)", Mark Herpel, October 16, 2009
"Non Bank Payments: America vs. Russia (part 2)", Mark Herpel, October 16, 2009
"Non Bank Payments: Pay Pal or WebMoney (part 3)", Mark Herpel, October 19, 2009
"Webmoney Russian Non Bank Products & Services (part 4)", Mark Herpel, October 19, 2009
"Non Bank Payments: Webmoney & Plastic Cards (part 5)", Mark Herpel, October 19, 2009
"The Webmoney Purse, One Size Does Not Fit All (part 6)", Mark Herpel, October 19, 2009

Virtual Goods and Real Money Trade from the European Perspective

By Petteri Günther
Virtual Economy Research Network
Friday, February 5, 2010

http://virtual-economy.org/blog/virtual_goods_and_regulatory_i

Article by Petteri Günther on EU regulatory issues in connection with real-money trade on digital items in virtual worlds. Reprinted with permission.

Introduction

Virtual worlds, for example various massively multiplayer online role playing games (MMORPGs) are becoming increasingly real to many people around the world. This emerging field of digital economy within virtual worlds has made us to face the interdependence of those and “real” offline worlds. This occurs e.g. in form of real-money trade (RMT) on digital items, while the question on property rights over digital items remains basically unresolved in Europe, although the US and the rest of the world are pretty much in the same situation.

In this blog post I concentrate particularly on issues that have risen from economic activity in connection with virtual worlds as well as online gaming frauds, in which other players often target other MMORPG end-users. The purpose is to provoke discussion on whether these developments should cause legislators to become more interested in what happens in cyberspace as RMT in virtual worlds is a wide-spread phenomenon and generates considerable economic values on a global scale. Many virtual world service providers are rather unwilling to recognize players’ rights to in-game assets, as they probably worry about liability issues, e.g. when it comes to online-world frauds that, nevertheless, are reality. Also European courts have addressed this matter quite recently.

Virtual Worlds and the EU regulatory Framework

The European Network and Information Security Agency (ENISA), which is an EU agency created to advance the functioning of the internal market, has estimated that the worldwide annual RMT of virtual goods amount to nearly 1,5 Billion Euro. [1] ENISA has reported in its 2008 report, Virtual Worlds - Real Money [2], that “the failure to recognize the importance of protecting real-money value locked up in this grey-zone of the economy has lead to a 'year of online-world fraud'.” A survey, which is included in the ENISA report, indicated that 30% of users have lost some form of virtual property through online gaming frauds targeting virtual world end-users. [3]

McInnes et al. divide regulation of virtual worlds regulation of the world itself and transactions of digital items. [4] A digital item can be defined as ”an image created by a service provider and tracked through a database that can be transformed and exchanged among users. Its value is decided through rarity, utility, and resulting demand.” [5] From a legal point of view the virtual world service providers purport to "legally link" the online and the real-life world by means of contract law through their end-user license agreements (“EULA”) and thus create private rules to compensate the somewhat absent regulation, and thus enable the potential development of "self-regulatory structures on the net." [6] In practice, this could mean industry self-regulation with respect to virtual worlds.

For the purposes of analogy to a property-style regime, we can take the International Corporation for Assigned Names and Numbers (”ICANN”) [7] as an example. It is an organization that acts as a global coordinator for internet addresses, domain names. With the aid of adopting this system, there are clearly defined property forms associated with domain names, which can also be termed as virtual property in the sense that they also are intangible assets but mimic certain characteristics of real-world assets, like exclusive ownership, persistence of rights and transfer of rights by agreement. Some online resources, such as digital items and powerful characters in massively-multiplayer online games, as well as domain names – just to point out a few, are almost identical to some physical goods in that sense that only one person at a time can control that particular resource.

There is a recent case [8] from the Netherlands where the defendants had used physical violence and thus forced the victim to hand over virtual goods in a MMO game RuneScape. The virtual goods, a mask and an amulet, were transferred from the victim’s account to the other defendant’s account in RuneScape. The court confirmed in its verdict that the said virtual goods qualify as goods under Dutch law. This was a prerequisite for the actions by the defendants, forced transfer of the virtual goods by using physical violence on the victim, to qualify as robbery (diefstal met geweld) under Article 312 of the Dutch Criminal Code.

In Finland a player had sold his World of Warcraft account to another player and, after two years used a master password to regain control of the account. The perpetrator was accused of criminal damage [9] and unauthorised use [10]. The parties settled the case later and the charges were thus dropped, so there was no final verdict on the merits of the case.

Conclusions

The concept of virtual worlds and virtual property is novel: there are precedents, neither in law nor in practice, to provide guidance. The real-money trade of virtual property is an example which shows that the real and virtual worlds are interdependent. And, while that interdependence is recognized, at the same time property rights over digital items have not yet been determined in Europe. Hence, currently it is possible to assume that there is inefficiency in allocation of rights in virtual property.

How should law treat intangible code that has been coded to resemble tangible? There are many ways to approach this question and different views are presented depending on whom you ask this question. According to Lastowka and Hunter a property system is central to the functioning of most contemporary virtual worlds. [11] But on one hand virtual world service providers assume contractual freedom by default to confirm their control over the MMORPGs and make certain their protection later on. Terms for entry to virtual worlds is regulated by EULAs, which specify the Terms of Service to declare the company’s claims regarding ownership and intellectual property rights over both game content – such as characters or items – and activity by players – the end-users. On the other hand economically efficient use of online resources would, based on Lastowka’s and Hunter’s assertions above, call for exclusive ownership, persistence of rights, transfer of rights by agreement, as well as a currency system to facilitate transactions on virtual property. [12]

Nevertheless, the volume and monetary value of RMT makes it a public policy issue of a broad impact. One solution to this situation in European context would be to apply the European mixed mode of regulation comprising industry self-regulation, such as codes of conduct for virtual worlds and establishing harmonizing regulatory instruments at the Union level to protect the rights of those within the virtual worlds as well as to support the development of virtual worlds.

A good approach, as envisioned in the Virtual Worlds - Real Money report, would be to address certain policy issues e.g. by setting up a forum for virtual world service providers to establish best practices [13]. But, if industry self-regulation finally proves inefficient to provide sufficient level of protection for users, many of whom have recently lost some form of virtual property through fraud, and where the service provider has been reluctant to address the matter and referred to their ToS banning RMT on digital items, the need for regulatory actions should be considered to clarify the issues in order to protect users.

Petteri Günther, LL.M, LL.M. (Law and IT), graduated from the University of Helsinki in 2006 and from the Stockholm University in 2007. In his master thesis (LL.M. in Law and IT) at the Stockholm University, upon which this article is based, he delved into real-money trade of virtual goods from the European perspective. The author is currently working as an associate lawyer at Lexia Ltd, a Finnish, Helsinki-based law firm, and focuses on IT and intellectual property law.

References

1 ENISA, Press Release (20.11.2008), Virtual Worlds - Real Money, http://www.enisa.europa.eu/media/press-releases/2008-prs/virtual-worlds-real-money (accessed 15.1.2010).

2 The report, Virtual Worlds - Real Money, available at http://www.enisa.europa.eu/act/it/oar/massively-multiplayer-online-games-and-social-and-corporate-virtual-worlds/security-and-privacy-in-virtual-worlds-and-gaming (accessed 15.1.2010).

3 ENISA, Press Release (20.11.2008), Virtual Worlds - Real Money, http://www.enisa.europa.eu/media/press-releases/2008-prs/virtual-worlds-real-money (accessed 15.1.2010).

4 MacInnes, Ian, Park, Y.J. and Whang, Leo Sang-Min (2004). Virtual World Governance: Digital Item Trade and its Consequences in Korea. Presented at Telecommunications Policy Research Conference, Arlington, VA. Available online at: http://web.si.umich.edu/tprc/archive-search-abstract.cfm?PaperID=382, p. 2. (accessed 15.1.2010).

5 MacInnes, Ian, Park, Y.J. and Whang, Leo Sang-Min (2004). Virtual World Governance: Digital Item Trade and its Consequences in Korea. Presented at Telecommunications Policy Research Conference, Arlington, VA. Available online at: http://web.si.umich.edu/tprc/archive-search-abstract.cfm?PaperID=382, at 5.

6 See: David R. Johnson & David Post, Law and Borders – The Rise of Law in Cyberspace, 48 Stan. L. Rev. 1367, at 1370-76 (1996) (where the authors discuss the difficulties in real world jurisdictions).

7 Internet Corporation for Assigned Names and Numbers (ICANN): http://www.icann.org/ (accessed 15.1.2010).

8 RuneScape, LJN: BG0939, Rechtbank Leeuwarden , 17/676123-07 VEV: http://zoeken.rechtspraak.nl/resultpage.aspx?snelzoeken=true&searchtype=ljn&ljn=BG0939&u_ljn=BG0939 (accessed 14.1.2010).

9 Criminal Code (Act 39/1889) Chapter 35 - Section 1 - Criminal damage (vahingonteko).

10 Criminal Code (Act 39/1889) Chapter 28 - Section 7 - Unauthorised use (luvaton käyttö).

11 Lastowka, F. Gregory and Hunter, Dan (2004). The Laws of the Virtual Worlds. 92 California Law Review 1, at 37.

12 Lastowka, F. Gregory and Hunter, Dan (2004). The Laws of the Virtual Worlds. 92 California Law Review 1, at 37.

13 Cf. Safer Social Networking Principles for the EU: the Commission convened various stake holders with respect to Europe's major social networks, and as a result, guidelines for the use of social networking sites by children developed voluntarily by the European industry. http://ec.europa.eu/information_society/activities/social_networking/eu_action/selfreg/index_en.htm (accessed 17.1.2010).

For further reading:
"The rise of goldfarming", Greedy Goblin, February 5, 2010
"Developers Should Open Virtual Goods Markets", Pixels and Policy, January 24, 2010
"How Can Developers Combat Secondary Loot Markets?", Pixels and Policy, January 20, 2010
"Keeping the gold farmers at bay: An interview with Fallen Earth's Colin Dwan", Shawn Schuster, Massively, January 4, 2010
"Real Money, Real Problems", Scott Jennings, MMORPG.com, November 18, 2009
"Digital Goods getting aisle attention", CIOL, October 30, 2009
"The fight against RMT in EVE Online", James Egan, Massively, August 11, 2009
"Debate Over the Justification and Legality of RMT", Gamerates, July 21, 2008