Hello,

This is an official message from Easy Solutions, on behalf of our client Activision Blizzard, Inc.
We have identified that a website hosted on your servers is performing acts of infringement of
copyrighted material of our client, Activision Blizzard, Inc.

We request your cooperation in removing an emulated server site which is performing acts of
infringement of copyrighted material of the game “World of Warcraft”(the copyrighted material) also
known as “WoW’, where you are providing hosting services.

I. We fill in this copyright claim in accordance with the Berne Convention, the WIPO Copyright treaty, and the trade related aspects of intellectual property rights (TRIPS) of the World Trade Organization and the following considerations:

1. The material used by the websites hosted on your servers infringes the moral and patrimonial rights of the Copyright’s owner, described on the point II., below.

2. All authors and owners of copyrighted material shall be protected by all the contracting parties of the Berne Convention, the WIPO Copyright Treaty and the World Trade Organization.

3. The country where the hosting is located has signed the Berne Convention and/or the WIPO Copyright Treaty and/or is a party of the World Trade Organization.

4. The copyrighted material has been dully registered before the United States Copyright Office.

5. The infringement and unauthorized use of the copyright material leads to economic liability, in order to repair all the economic damages caused to the copyrighted owner.

6. We request that you immediately (A) remove from your servers the unlawful use of the copyrightedmaterial and (B) provide us with prompt written assurance that the unauthorized use of the copyrighted material was effectively removed from your servers.

II. Below you find the information needed to perform this copyright claim.

1.An electronic signature of the Copyright’s Owner, or a person authorized to act on behalf of the owner of an exclusive copyright that has allegedly been infringed. (See Blizzard Authorization attachment)

[private] | Fraud Inteligence Agent

Main: [private]

[private] | www.easysol.net

2.The Copyrighted material infringed is located at the following URL(s):

Legitimate site for the game: http://us.blizzard.com/en-us/games/wow/  

Legitimate site for the service: https://us.battle.net/login/en/index?ref=http://us.battle.net/wow/en/&app=com-wow  

Blizzard copyright notices: http://us.blizzard.com/en-us/company/about/copyrightnotices.html

3.The infringing material is located at the following URL(s):

Infringing site: http://www.wowgaming.org/

IP: 151.101.33.147

The website reported is using the World of Warcraft's logos and characters without authorization, as you can see in the image below. Although they added a clarification note in their site, they are not authorized to use those images or offer complements for the game, therefore, we request for the removal the whole infringing content in this URL's

http://www.wowgaming.org/home.html

http://www.wowgaming.org/wotlk.html

http://www.wowgaming.org/addons-335a-collection/

https://wowgaming.altervista.org/aowow/

https://wowgaming.altervista.org/wp/wotlk-home/

[private]

Additional, you can check the Legal Terms of Blizzard in order to understand better this issue.

You can found it in this links:

http://us.blizzard.com/en-us/company/legal/trademarks.html

http://us.blizzard.com/en-us/company/legal/eula.html

In the last URL, please checks the sections 1.C.i and 1.C.ii.4

"C. License Limitations. Blizzard may suspend or revoke your license to use the Platform, or parts, components and/or single features thereof, if you violate, or assist others in violating, the license limitations set forth below. You agree that you will not, in whole or in part or under any circumstances, do the following:

i. Derivative Works: Copy or reproduce (except as provided in Section 1.B.), translate, reverse engineer, derive source code from, modify, disassemble, decompile, or create derivative works based on or related to the Platform.

ii. Cheating: Create, use, offer, promote, advertise, make available and/or distribute the following or assist therein: cheats; i.e. methods, not expressly authorized by Blizzard, influencing and/or facilitating the gameplay, including exploits of any in-game bugs, and thereby granting you and/or any other user an advantage over other players not using such methods; bots; i.e. any code and/or software, not expressly authorized by Blizzard, that allows the automated control of a Game, or any other feature of the Platform, e.g. the automated control of a character in a Game; hacks; i.e. accessing or modifying the software of the Platform in an manner, not expressly authorized by Blizzard; and/or any code and/or software, not expressly authorized by Blizzard, that can be used in connection with the Platform and/or any component or feature thereof which changes and/or facilitates the gameplay or other functionality"

The only authorized service for the game is run by the copyright holder (Activision Blizzard, Inc.) at Battle.net. Your customer's service for the copyrighted game "World of WarCraft" competes with and diminishes the potential market of the copyright holder's own service.

Your customer does not have our client’s (the copyrights owner) consent to be running this service for the game. Copyright law protects the entirety of the computer code that creates the game and no one can legally use it without the permission of the copyright owner. Our client has not designated this game as open source nor licensed it to the general public to use it and make changes to the original code. Furthermore, any open source software emulator for the server will still require the use of Blizzard game assets in order to run a World of WarCraft server.

4.You can contact us through:

Email Address: [private]

Physical Address:

8550 NW 33 Street, Suite 101, Doral, FL 33122, United States

Latin America - K 13 A 98 21 OF 401, Bogotá, Colombia

Phone numbers:

USA: Tel/Fax. [private]

Colombia: Tel. [private] / Fax [private]

5.We state and declare, that we have a good faith belief that the use of the copyrighted material in the manner described in this cease and desist letter is not authorized by the Copyright’s Owner, its agent, or the law.

6.We state and declare that the information contained in this cease and desist letter is accurate and under the penalty of perjury, we state and declare that Activision Blizzard, Inc. is the owner of an exclusive right that is allegedly infringed.

Thank you for your cooperation.

Security Operation Center | Easy Solutions  
Main: [private]  
[private] | www.easysol.net
