Copyright: The Alpha and Omega(verse)

UPDATE 03/15/2019: One of the parties has created a website about the litigation, which posts additional information and some court documents I didn’t have when I wrote this post. I am adding another post as this one is already quite long. See: Not Walking Away From Omegaverse.

As sometimes happens, I was wandering the wilds of Twitter and started running across references to a legal spat between two authors. In this case, two romance authors who both write in the “Omegaverse,” an “alternate universe” or AU, which is used by a large number of writers, both commercial and amateur, as a setting for romance novels of various kinds and levels of explicitness. So be warned: both the case documents (which I’ll be discussing) and the setting and subject matter of the works will produce some very not-safe-for-work results if you search for them. Here, there be monsters. Some literal, as a common element of Omegaverse fiction is werewolves and other shapeshifters.

This spat involves DMCA notices, but as of this writing (3/14/2019,) does not involve a lawsuit for copyright infringement. Instead, the copyright part is a much less common and (to laypeople) much less well-known type of copyright lawsuit called a Declaratory Judgment action. How that works is that someone accuses someone else, not in a lawsuit but just in direct or public communication, of infringing their copyright, and the accused goes to court and files a lawsuit asking the court to rule pre-emptively that their work does not infringe the accuser’s work.

In this case, an author who goes by “Addison Cain,” published by a publisher known as Blushing Books Publishing, accused an author who goes by “Zoey Ellis,” published by Quill Ink Books Limited, both of plagiarizing, and outright infringing on the copyright of, her Omegaverse-setting romance novels. Cain allegedly set some of her fans after Ellis, including inciting them to post bad reviews for Ellis’s books. She (and/or her publisher Blushing Books) also filed Digital Millennium Copyright Act takedown notices (click here for a discussion of the DMCA) against some of the books, allegedly including one which hadn’t even been published yet. As I said in the linked post above, the DMCA is not a Weapon for Great Justice, and trying to use it as one is a Stupid Legal Trick which can backfire on you if you don’t do it appropriately.

By the by, according to Quill Ink (see complaint linked below) one reason Blushing Books’ DMCA notices were iffy is that Blushing Books hasn’t registered the copyrights for two of Cain’s books. I have no idea if this is true, but I hope not, because if so, it makes things even worse for Blushing Books because of the recent “Fourth Estate” decision. Also, it looks bad to be sending legal notices and Cease and Desist letters threatening legal imminent legal action (see below) about copyright infringements when you haven’t got registration certificates. REGISTER YOUR COPYRIGHTS.

Ellis was, understandably, Not Happy about having her books taken down, and filed counter-notices. Eventually, so far as I can tell, all the books got put back up, but it took quite a long time, cost Ellis sales, and probably interfered with the momentum of publishing what is currently a seven-book series with the eighth book pre-announced. Plus, she is now branded a plagiarist and copyright infringer by a prominent genre author, and has received any number of bad reviews spurred by the dispute rather than the actual content and quality of her books. You’d be mad, too.

A rather bluntly threatening email (click here to read it) from the CEO of Blushing Books to Ms. Ellis’s publisher, Quill Ink Books Limited (which to mix things up a bit is a UK entity) was apparently the last straw. I don’t know if the publisher actually consulted with an attorney before sending that email, but if they did I hope the attorney warned them that sending it could cause what happened next to happen. See, normally just casually saying things like “she copied me,” even in public, are not enough to give rise to what we call “standing” to sue for a declaratory judgment. But by sending that email, they may very well have done so. Here’s a quote from a 2007 Supreme Court case called MedImmune, Inc. v. Genentech, Inc. which discusses the standard for declaratory judgment:

“[T]he dispute must be “definite and concrete, touching the legal relations of parties having adverse legal interests,” “real and substantial,” and “admi[t] of specific relief through a decree of a conclusive character, as distinguished from an opinion advising what the law would be upon a hypothetical state of facts.”

Citing even older precedent, the Federal Circuit summarized:

“Basically, the question in each case is whether the facts alleged, under all the circumstances, show that there is a substantial controversy, between parties having adverse legal interests, of sufficient immediacy and reality to warrant the issuance of a declaratory judgment.”

(From: https://www.pharmapatentsblog.com/2012/04/05/federal-circuit-looks-at-requirements-for-declaratory-judgment-jurisdiction/

The email was definite and concrete, and definitely identified an imminent legal controversy. It’s reasonably arguable that it put Ms. Ellis and Quill Ink in fear of a pending lawsuit… and so, gave them standing to ask the court to go ahead and address the dispute. Which she did, in a case now captioned QUILL INK BOOKS LIMITED v. ABCD GRAPHICS AND DESIGN, INC. (USDC for the WD of OK, Case 5:18-cv-00920-G.) You can read the Amended Complaint here:

First Amended Complaint, Quill Ink Books Limited v. ABCD Graphics and Design, Inc.

Now, whether or not they actually intended to file an expensive, burdensome, and quite frankly somewhat iffy Federal lawsuit against Quill Ink, Blushing Books is in one. And one they did not start, which is a tactical disadvantage.

That covers the first interesting legal question, which is how Quill Ink started a copyright lawsuit against Blushing Books when it was Quill Ink who allegedly infringed a copyright. Now the second legal question: what is Quill Ink actually suing about, and are they likely to succeed in suing about it? (Okay that’s two questions.) The answer to the second one is, obviously, “it depends,” but let’s talk about what she’s actually suing over and then get on with the dependanalysis.

This is a Federal lawsuit and Federal courts have what is called a “notice” pleading standard: the Plaintiff just has to give the Defendant enough notice to understand what they’re being sued for so they can formulate an answer as to whether they want to deny it, deny it’s suitable subject matter for a lawsuit, deny that the court even has jurisdiction over them in the first place, et cetera. So it’s early days. Blushing Books has not filed an answer at all. Quill Ink has filed only the complaint and a few supporting exhibits. All I have to go off of is that and what I’ve picked up from random strangers on the internet. So please understand that this is HIGHLY SPECULATIVE and most CERTAINLY does not constitute legal advice. Thank you.

Quill Ink says it’s “seeking injunctive relief for malicious interference with contract and for copyright misuse; and for damages for misrepresentation of copyright claims under the Digital Millennium Copyright Act, tortious interference with prospective and existing business relationships, defamation, false light, negligence, civil conspiracy; and for declaratory relief.” Whew, that’s a mouthful. But what it all boils down to is that Blushing Books wrongfully claimed that Quill Ink infringed its copyrights in various ways, and by doing so caused Quill Ink harm in various ways. So really the first question to ask is, did Blushing Books wrongfully claim that Quill Ink infringed its copyrights?

As usual in this sort of case, the words “plagiarism” and “copyright infringement” are being used interchangeably by a lot of people (including, allegedly, Blushing Books.) They are NOT interchangeable. A particular act can be both, either, or neither. If I quote an entire chapter of someone’s book in my own book, but give them appropriate credit, by definition that cannot be plagiarism. But it most certainly can be copyright infringement, credit or no. Contrariwise, if I write a scholarly article which quotes extensively the factual research findings of another scholar but doesn’t credit them, that’s plagiarism, but it may or may not be copyright infringement. I am only going to talk about copyright infringement because I’m a lawyer and the law does not recognize (mostly) plagiarism as a legally redressable wrong, only copyright infringement. So please keep that in mind.

In copyright, there is a legal doctrine called “Scènes à Faire,” which translates literally as “scenes to do” but by which we mean “elements which must be included.” It’s more than just scenes: it’s elements. For instance, if you are writing a fairy tale, there must be magic, and there will probably be fairies. Those elements, the Scènes à Faire, are not protected by copyright. You cannot copyright the idea of a fairy tale: you can only copyright the specific expression of the specific fairy tale that you write. That’s why Disney can’t stop Universal from making “Snow White and the Huntsman” even though it has common elements with Disney’s “Snow White,” like a princess usurped by her stepmother, the huntsman sent to kill the princess, her dwarf protectors, et cetera. Those are all ideas, and descend from a much older cultural heritage which belongs to all humankind. If you want to tell a story about Snow White, you have to use them, or it isn’t a Snow White story.

The Omegaverse is a shared universe which individual authors can pick and choose, and to an extent adapt, elements from, but if they want a story to be an Omegaverse story it must contain a certain number of those elements and they must have a relatively limited amount of variation. Prominent romance writer Courtney Milan posted this Twitter thread:

referring to this blog post by author Golden Angel:

https://goldeniangel.blogspot.com/2019/03/drama-in-omegaverse.html

which goes into the differences and similarities between the books in question. Ms. Angel properly differentiates between common elements (the Scènes à Faire ) in the Omegaverse, and what she thinks are the not-so-common elements. This gets complicated quick, not least because historically Omegaverse fiction was primarily about male/male relationships and both Ms. Cain and Ms. Ellis write about male/female relationships and thus the applicable Scènes à Faire are arguably a little less well-defined when it comes to the Omegaverse.

Here’s my take on this particular question after reading Ms. Angel’s well-written blog post: the things she cites as possibly not (yet) Scènes à Faire in Omegaverse fiction may well not be. I wasn’t familiar with the Omegaverse prior to about two days ago. But they are, in my opinion as someone who has read and written romance stories (there’s a lot you don’t know about me) is that they are fairly well-known Scènes à Faire, or “tropes” if you like that better, in romance fiction. Nothing she describes as happening, outside of Omegaverse particulars, in either story is something I haven’t seen happen in one or more non-Omegaverse romance stories. She claims to see similarities “… in both books, scene after scene, beat following beat with only a few differences between the plot structure.” She’s read the books and I haven’t: I can’t and won’t dispute her opinion. But if both books consist of a layer of Omegaverse tropes hand-craftedly laid over a base of romance fiction Scènes à Faire, that is exactly what we would expect to see. And in neither case would copyright protection extend to those elements of the works.

So, knowing only what I know now, and not having read any of the works in question, after reviewing what Ms. Angel does not hesitate to admit (to her credit) to be an analysis sympathetic to Ms. Cain, I still find it unlikely that any significant copyright infringement is occurring here. At least, in my opinion, nobody has alleged facts which support such a theory. This, of course, is bad for Blushing Books if true. The claims of infringement would be unfounded in that case. Which supports the underlying theory of Quill Ink’s lawsuit.

Note, however, that this does not mean that Ms. Cain’s accusations were made in bad faith. Ms. Cain, to my knowledge, is not a lawyer, nor is the person who wrote the threatening letter. The threatening letter claims they got advice from an attorney before writing it. So my presumption is that the claims were made in good faith, even if they were not supported by the facts and the law. (Bad legal advice does not translate to acting in bad faith: acting “with advice of counsel” is a possible defense to a claim bad faith. Yet another reason to talk to a lawyer.) That may very well be relevant here, and very likely is relevant to the claims of defamation in particular.

Let’s assume, then, that Quill Ink’s fundamental allegation is correct: Blushing Books and/or Addison Cain claimed copyright infringement where none exists, acted on those claims, and damaged Quill Ink/Ms. Ellis accordingly. As we say in the legal biz: “So what?” Let’s look at each of the basic elements in Quill Ink’s preamble in turn. These don’t match up exactly with the actual counts set forth in the complaint, but close enough, it hits the high points, and this is already getting kind of long. 🙂

We’re going to do them out of order because the last one is the easiest to discuss.

First: Declaratory Relief

Quill Ink wants the Court to find that Ellis’s books don’t infringe on the copyrights of Cain’s books. We already talked about that: my tentative, totally-prepared-to-be-mistaken view is that they don’t. If the Court agrees, they will issue a declaratory judgment to that effect, which will be binding on Cain and Blushing Books, to varying degrees, in United States courts and at least highly persuasive to other courts throughout the world. If she gets this, Blushing Books/Cain will not be able to sue Quill Ink/Ellis for copyright infringement, because the question will be res judicata, a thing already adjudicated. You can appeal such a finding, but you can’t get another bite at the apple in a different court for the same set of facts. It will prevent any future takedown notices being filed, at least if Blushing Books/Ms. Cain want to avoid being liable for outright perjury. It may also be useful, frankly, as support for the assertion that other takedown notices issued by Blushing Books/Ms. Cain in future should be taken with a grain of salt. That’s not so much a legal problem as a problem of general/business credibility but it is a very real problem.

Second: Malicious Interference with Contract

This is a pretty standard claim (also known as tortious interference) that you make whenever somebody does something that arguably would induce someone to breach their contractual obligations to you. Here, the DMCA notices, and the allegations of copyright infringement, made it more likely that resellers would refuse to stock Ms. Cain’s books – which, in fact, they did, at least temporarily.

In practice, this claim can be very hard to prove, and I’m not licensed in Oklahoma, whose laws will probably govern the determination of the validity of this claim. So I’ll just say that in general, knowing what I know now, I think this claim is a long shot at best. But we usually include it if we can make a colorable claim, and there’s nothing unethical or immoral about doing so as long as the attorney believes a colorable claim exists.

Third: Copyright Misuse

Copyright misuse is, generally, an equitable doctrine that says you can’t enforce a copyright against someone if you’ve acted improperly or inequitably in enforcement. It’s a defense, not an actionable claim itself. This has to do with things like Blushing Books claiming that it had registered copyrights in Ms. Cain’s books when in fact it did not, claiming that it had a registered trademark in its trade name when in fact it did not (By the way, unless I am quite mistaken they most definitely did do this and they still are and wow was THAT a bad idea, where was their counsel?) and a general pattern of allegedly inequitable conduct in enforcing its rights against Quill Ink as well as other authors which was designed to illegitimately stifle competition, not enforce a legitimate right.

There are usually no damages awarded for copyright misuse (although you could always make an equitable argument for sanctions and/or attorney’s fees, which you might get if the conduct was inequitable enough.) It’s just another offered reason for the Court to issue a declaratory judgment that Blushing Books can’t enforce its copyrights against Quill Ink. It should be noted, though, that unlike a defense of non-infringement, a defense of copyright misuse can be overcome later if the copyright owner cleans up its act and the effects of the misuse have dissipated. So if they win this, but not the broader non-infringement ruling, Quill Ink could theoretically be sued at some point in the future.

While we’re on the subject of inequitable conduct: If you were my client – and I’d love to have you – I’d tell you not to post messages like the ones Ms. Cain posts specifically asking her fans to mess with her review scores. Just don’t. Not only is it in my opinion of dubious morality, it’s probably a violation of the Terms of Service of most online resellers like Amazon, B&N, Kobo, and Smashwords. It will be of small consolation to Ms. Cain if she gets out from under this lawsuit with little or no damage but gets a bunch of books (or even herself) permabanned for TOS violations that it brought to light.

Fourth: Misrepresentation of Copyright Claims Under the Digital Millennium Copyright Act

The DMCA provides (in Section 512(f)) that making a knowing and material misrepresentation in a takedown notice, or a counter-notice, is prohibited and if it is done, the person or entity making the representation can be liable for damages caused by the misrepresentation as well as related costs and attorney’s fees. Quill Ink claims that Blushing Books knew darn well that there were no legit copyright infringements when they sent the takedown notices, and therefore they should be held liable for doing so.

It should be particularly troubling here for Blushing Books that they sent a DMCA takedown notice for an unpublished work. The DMCA does not allow for “anticipatory” takedown notices. If the work was not yet published, it is difficult to see how they could have filed a takedown notice in good faith.

If Quill Ink wins on this count, they can get damages they can reasonably prove (lost sales, costs of preparing and filing the counter-notices, etc) as well as potentially getting attorney’s fees. That latter is a serious issue for Blushing Books, as the fees involved are likely to be many tens of thousands of dollars even if Quill Ink can only prove nominal damages.

Fifth: Tortious Interference with Prospective and Existing Business Relationships

Basically see Item Two above, only this is about making it so that other people are less likely to want to contract with the plaintiff generally, and not just in relation to breach of a specific contract. Again, not licensed in Oklahoma, not familiar with the laws, but as a general principle, iffy but probably a colorable claim at this stage.

Sixth: Defamation

Quill Ink claims that Ms. Cain, and other currently unnamed parties, published false and defamatory statements about the alleged plagiarism and copyright infringement which caused Quill Ink damage. (“Defamation” is the general case of “libel,” which is what pedantic lawyer types would call this.)

Once more: Not licensed in OK, not familiar with their laws. In general, you can only be found liable for making defamatory statements in the US if the statements are not true and you knew or should have known that they were not true. So this falls back, once again, on the state of mind of Blushing Books/Ms. Cain, as well as the actual truth of the statements. If the Court finds that the statements were true, or that the Defendants didn’t know and had no reason to believe that they were false, there can be no liability. If both of those things are not true, then there very well might be, though damages would be tricky to prove.

I will say that in general, sending your Internet Minions to attack people is a very bad idea, and you should not do it, both for moral reasons and for legal ones.

Seventh: False Light

See Defamation above. Same sort of thing with some different parameters, and not really within the scope of this discussion.

Eighth: Negligence

Negligence, generally, is failing to act with reasonable care and causing damage to another person or entity thereby. If you act negligently, you are usually liable for the damages you cause. Here, the argument is that even if the takedown notices were not knowingly sent in bad faith, no reasonable rightsholder would have sent them, or acted the way Blushing Books/Ms. Cain did in general, that their unreasonable actions caused damage to Quill Ink, and therefore they should be liable.

Yet again, not licensed in Oklahoma, not familiar with their negligence laws, and this is a ways removed from our general topic of copyright infringement and the DMCA. Generally speaking, though, I don’t see this having much chance of success. If Blushing Books knew what they were saying was false, then they are probably liable for it on one or more theories. But if they didn’t, then I don’t know I would agree that they acted all that unreasonably, especially if they did in fact act with advice of counsel.

Ninth: Civil Conspiracy

Conspiracy, legally speaking, is just two or more people working in common cause to do something illegal or unlawful. The thing about conspiracy is that it doesn’t require that they succeed or even make a serious attempt to do the illegal thing, only that they work together and take some material action in furtherance of the illegal/unlawful acts.

This is way, way outside the scope of this post, so I’ll just say that a) If any of the above torts were in fact committed and people worked together to commit them, a conspiracy could theoretically exist, b) civil conspiracy is another claim that we often enter if we can at least sorta kinda justify it but which rarely pans out, and c) I’m not licensed in Oklahoma and have no idea what their civil conspiracy jurisprudence looks like.

Having recited all those things, Quill Ink goes on to ask for injunctions to stop the Defendants from continuing to make improper copyright claims, defaming it, breaking laws, being bad, et cetera, for damages for the things damages can be awarded for, punitive damages for being such naughty little monkeys, attorney’s fees and costs of suit, and whatever else the Court might be pleased to award it. The End.

WOW, that got long. (It’s almost TWICE as long as my initial #Cockygate post!) There’s a lot going on here. As far as how it’s going to come out? Who knows? Not me, that’s for sure. But if you want a summary of my highly tentative, not-at-all-in-any-way-shape-or-form-legal-advice opinions about the matter, here they are:

A) If the things in that complaint are even within hailing distance of the truth, Blushing Books was in no way in the proper position to send that email to Quill Ink, and they should not have done it.

B) With the same caveat, those DMCA takedown notices were a colossal mistake, especially the one against the allegedly then-unpublished book.

C) Based on what I know now and with the disclaimer that I will change my opinion in a hot minute if and when more information comes to light, I don’t think that Blushing Books has or ever had a significant copyright infringement claim against Quill Ink. And if so, unless the case goes away first (which I think is more likely than not for multiple reasons) Quill Ink may very well get at least the injunctive relief it seeks.

D) I also think it’s more likely than not that if the case went to trial, Quill Ink would not get significant damages based on what I know now. But they might very well get some. And I see multiple ways that they could get fees and costs, which could be catastrophically expensive for Blushing Books.

E) Don’t stir up Internet mobs and don’t encourage people to violate TOS when your livelihood depends on the good will of the Internet in general and the entities whose TOS are potentially being violated in particular.

By the way, while I love doing this sort of education and outreach, I’m trying to start a law practice here, and it really helps encourage me if people express their appreciation tangibly, so to speak. So if you could see your way fit to dropping me a Ko-Fi donation or two (click here to send) I would really appreciate it. If you can’t, I understand and I still hope you found this interesting and educational. And of course if you are in need of legal services, please reach out! (Information on retaining me is here: Hiring Me As Your Attorney.)

As always, questions and comments are welcome here, on Twitter (@legalinspire) or by email (marc@legalinspiration.com). Thanks for reading!

M

Published by

Marc Whipple

I'm from Iowa: I only work in cyberspace. :) But seriously, if you are looking for a blurb for a panel or other event, here's a suggested bio. Marc Whipple grew up in Iowa and has a degree in Physics and Math from Drake University. After receiving his J.D. from John Marshall, he became the General Counsel for Meyer/Glass Design, a Chicago invention studio descended from the legendary innovation firm Marvin Glass & Associates. When Meyer/Glass started an interactive division, he helped set up, grow, and eventually spin off the software studio. After his work at Meyer/Glass, he became the General Counsel of Incredible Technologies, Inc., and helped it take its first steps into regulated casino gaming as well as providing legal support for its famous GOLDEN TEE video golf worldwide tournament network. Marc is now Of Counsel to Crawford Intellectual Property, LLC, based in Barrington, IL. He provides experienced support for patent, trademark, copyright, and technology issues as well as advising creatives at every level from startup to established studio. Marc is licensed to practice law in the state of Illinois and before the United States Patent and Trademark Office as a Registered Patent Practitioner.

177 thoughts on “Copyright: The Alpha and Omega(verse)”

  1. Interesting read and thank you for the analysis. I read both of these series, Addison Cain’s first before Zoey Ellis’s and I never saw any issue or plagiarism. I was surprised when I joined Ms. Cain’s FB group and they were trashing Ms. Ellis’s books as being ripoffs. I didn’t find them similar at all except for the omegaverse tropes. After reading all the legal documents and both authors sides I honestly think Addison Cain is being a bully and just trying to use her weight to hurt other successful authors in this genre. You can’t own/copyright I genre. I’m sure in all books about highlander warriors they are all rough alphas wearing kilts and calling the ladies “lass” and probably have red hair. Or in darker books where the Alpha Dom says, “[Edited – it was something very Dom-ly.]” doesn’t mean all these authors are plagiarizing each other. I mean come on we all know we read the same phrases and situations in books all the time. This was a huge over reach. Ms. Cain’s books were about a future dystopian city where convicts rise up and overthrow the gov’t and the MC finds an omega female he keeps for himself. Ms. Ellis’s is about an army of warriors in a land of magic wielders that take over and unite the east lands so they can find omega females for all and restore humanity back to what it was. These were night and day except for Aggressive Alpha males finding omega females that want to effect change in their world, and the other omegaverse tropes (knotting, nesting, heat, calming omega through purr and smell, and forcing bonding).

  2. Hello there, I discovered your web site by means of Google
    whilst looking for a comparable topic, your site got here up, it appears great.

    I’ve bookmarked it in my google bookmarks.
    Hi there, simply was alert to your blog thru Google, and
    found that it’s truly informative. I am going to watch
    out for brussels. I will be grateful should you continue this in future.
    Lots of other people can be benefited from your writing.
    Cheers!

    Here is my webpage … стрейч пленка упаковочная

  3. Hey there! This is my 1st comment here so I just wanted to give a
    quick shout out and tell you I truly enjoy reading your blog posts.
    Can you recommend any other blogs/websites/forums that go over the same subjects?

    Thank you so much! gozo vacation

  4. I have been exploring for a little for any high-quality
    articles or weblog posts on this kind of area .
    Exploring in Yahoo I finally stumbled upon this web site.
    Reading this information So i am glad to show that I’ve a
    very good uncanny feeling I discovered exactly what I needed.
    I so much definitely will make certain to do not disregard this
    web site and give it a glance on a relentless basis.

    Also visit my blog post … стретч пленка упаковочная

  5. I have been exploring for a little bit for any high-quality articles or weblog posts on this sort of space . Exploring in Yahoo I finally stumbled upon this site. Reading this information So i am satisfied to show that I’ve a very just right uncanny feeling I discovered exactly what I needed. I such a lot surely will make certain to don?¦t fail to remember this website and give it a look regularly.

  6. What i don’t understood is if truth be told how you are now
    not actually a lot more smartly-preferred than you may be right
    now. You’re so intelligent. You realize therefore considerably when it comes to this subject, made me
    in my view consider it from numerous various
    angles. Its like women and men aren’t interested except
    it’s something to do with Lady gaga! Your own stuffs excellent.
    At all times handle it up!

    My web-site; мешки для сбора мусора

  7. Wow, wonderful blog layout! How long have you been blogging for? you made blogging look easy. The overall look of your website is great, let alone the content!

  8. Wow, superb blog layout! How long have you been blogging for? you made blogging look easy. The overall look of your website is excellent, as well as the content!

  9. Very interesting info !Perfect just what I was searching for! “All the really good ideas I ever had came to me while I was milking a cow.” by Grant Wood.

  10. Good post. I study one thing tougher on different blogs everyday. It can at all times be stimulating to read content from other writers and observe a bit of something from their store. I’d desire to make use of some with the content on my weblog whether or not you don’t mind. Natually I’ll give you a link in your net blog. Thanks for sharing.

  11. Hey There. I discovered your blog using msn. This is an extremely smartly written article. I will be sure to bookmark it and come back to read more of your helpful information. Thank you for the post. I will definitely comeback.

  12. Thanks a bunch for sharing this with all of us you really know what you are talking about! Bookmarked. Kindly also visit my site =). We could have a link exchange contract between us!

  13. Hey there I am so happy I found your website, I really found you by error, while I was looking on Digg for something else, Nonetheless I am here now and would just like to say many thanks for a marvelous post and a all round entertaining blog (I also love the theme/design), I don’t have time to browse it all at the minute but I have bookmarked it and also added your RSS feeds, so when I have time I will be back to read much more, Please do keep up the fantastic job.

  14. Howdy would you mind letting me know which web host you’re using? I’ve loaded your blog in 3 completely different internet browsers and I must say this blog loads a lot quicker then most. Can you recommend a good internet hosting provider at a honest price? Cheers, I appreciate it!

  15. Somebody essentially help to make seriously posts I would state. This is the first time I frequented your website page and thus far? I surprised with the research you made to make this particular publish incredible. Fantastic job!

  16. Hiya very nice blog!! Man .. Excellent .. Wonderful .. I will bookmark your web site and take the feeds additionally…I’m satisfied to seek out so many useful information here in the submit, we need develop more strategies on this regard, thanks for sharing.

  17. Hi there! This post couldn’t be written any better! Reading through this post reminds me of my previous room mate! He always kept talking about this. I will forward this article to him. Pretty sure he will have a good read. Thank you for sharing!

  18. I’d have to examine with you here. Which is not one thing I usually do! I take pleasure in reading a post that may make folks think. Additionally, thanks for permitting me to comment!

  19. Excellent read, I just passed this onto a friend who was doing some research on that. And he actually bought me lunch as I found it for him smile Thus let me rephrase that: Thanks for lunch!

  20. I just like the valuable info you provide for your articles. I’ll bookmark your weblog and test once more here frequently. I am relatively certain I’ll be informed many new stuff right here! Good luck for the following!

  21. What i do not understood is in fact how you are no longer really much more neatly-preferred than you may be right now. You’re so intelligent. You understand therefore considerably relating to this matter, made me in my opinion believe it from numerous varied angles. Its like women and men are not involved except it?¦s something to accomplish with Woman gaga! Your own stuffs great. At all times deal with it up!

  22. Hi there! I just wanted to ask if you ever have any problems with hackers? My last blog (wordpress) was hacked and I ended up losing several weeks of hard work due to no data backup. Do you have any solutions to protect against hackers?

  23. Please let me know if you’re looking for a article author for your weblog. You have some really good posts and I think I would be a good asset. If you ever want to take some of the load off, I’d absolutely love to write some content for your blog in exchange for a link back to mine. Please send me an e-mail if interested. Thanks!

  24. Good day! Do you know if they make any plugins to protect against hackers? I’m kinda paranoid about losing everything I’ve worked hard on. Any tips?

  25. I have been browsing on-line more than three hours nowadays, but I never discovered any fascinating article like yours. It’s lovely value enough for me. Personally, if all website owners and bloggers made excellent content as you probably did, the web shall be much more helpful than ever before.

  26. Thanks for some other informative site. The place else may just I am getting that kind of information written in such a perfect means? I’ve a venture that I’m just now operating on, and I have been at the look out for such info.

  27. Unquestionably believe that which you said. Your favorite reason appeared to be on the internet the simplest thing to be aware of. I say to you, I certainly get irked while people think about worries that they just don’t know about. You managed to hit the nail upon the top and defined out the whole thing without having side effect , people can take a signal. Will likely be back to get more. Thanks

  28. 1WIN KZ – ставки на спорт в букмекерской конторе Казахстана. Скачать приложение для ставок. Вход и регистрация личного

  29. fantastic points altogether, you simply gained a emblem new reader. What might you recommend in regards to your submit that you just made a few days ago? Any sure?

  30. When I originally commented I clicked the -Notify me when new comments are added- checkbox and now each time a comment is added I get four emails with the same comment. Is there any way you can remove me from that service? Thanks!

  31. Very nice info and right to the point. I am not sure if this is really the best place to ask but do you people have any thoughts on where to employ some professional writers? Thank you 🙂

  32. Nice post. I study something more difficult on completely different blogs everyday. It’s going to all the time be stimulating to learn content from other writers and observe a bit one thing from their store. I’d desire to make use of some with the content material on my blog whether you don’t mind. Natually I’ll provide you with a link on your internet blog. Thanks for sharing.

  33. I’ve been exploring for a bit for any high quality articles or blog posts in this kind of house . Exploring in Yahoo I at last stumbled upon this website. Reading this information So i am happy to convey that I’ve a very excellent uncanny feeling I came upon just what I needed. I most indubitably will make sure to don’t omit this web site and provides it a look regularly.

  34. I’m impressed, I must say. Really hardly ever do I encounter a blog that’s both educative and entertaining, and let me tell you, you could have hit the nail on the head. Your idea is excellent; the issue is one thing that not sufficient individuals are speaking intelligently about. I’m very joyful that I stumbled throughout this in my seek for something regarding this.

  35. It’s a shame you don’t have a donate button! I’d certainly donate to this excellent blog! I suppose for now i’ll settle for bookmarking and adding your RSS feed to my Google account. I look forward to brand new updates and will talk about this site with my Facebook group. Chat soon!

  36. I would like to thank you for the efforts you have put in writing this web site. I’m hoping the same high-grade website post from you in the upcoming also. Actually your creative writing skills has inspired me to get my own web site now. Actually the blogging is spreading its wings quickly. Your write up is a great example of it.

  37. I’m still learning from you, as I’m trying to reach my goals. I definitely enjoy reading everything that is written on your site.Keep the stories coming. I loved it!

  38. An interesting discussion is worth comment. I think that you should write more on this topic, it might not be a taboo subject but generally people are not enough to speak on such topics. To the next. Cheers

  39. Thanks for sharing excellent informations. Your web-site is very cool. I’m impressed by the details that you have on this web site. It reveals how nicely you perceive this subject. Bookmarked this web page, will come back for extra articles. You, my friend, ROCK! I found simply the information I already searched everywhere and just couldn’t come across. What a perfect website.

  40. Hi my family member! I wish to say that this article is awesome, great written and include approximately all significant infos. I?¦d like to look extra posts like this .

  41. hey there and thank you on your information – I’ve definitely picked up anything new from proper here. I did alternatively experience a few technical issues using this site, as I experienced to reload the site a lot of times prior to I may get it to load properly. I were wondering if your web host is OK? Now not that I am complaining, however slow loading cases times will sometimes impact your placement in google and could damage your high quality score if ads and ***********|advertising|advertising|advertising and *********** with Adwords. Anyway I’m including this RSS to my email and can glance out for a lot extra of your respective intriguing content. Make sure you replace this again soon..

  42. I liked as much as you will obtain performed right here. The caricature is tasteful, your authored material stylish. nevertheless, you command get got an nervousness over that you wish be handing over the following. ill for sure come more in the past again as exactly the same just about very steadily inside case you defend this increase.

  43. Great blog right here! Additionally your website loads up very fast! What host are you using? Can I get your associate hyperlink to your host? I desire my site loaded up as quickly as yours lol

  44. Thanks for all of your efforts on this site. My daughter loves making time for research and it’s really obvious why. Most of us notice all of the powerful means you create functional suggestions by means of your web site and therefore cause contribution from other ones about this matter while my simple princess has been starting to learn a whole lot. Take advantage of the rest of the new year. You’re carrying out a really great job.

  45. Greetings from Idaho! I’m bored to death at work so I decided to check out your website on my iphone during lunch break. I love the information you present here and can’t wait to take a look when I get home. I’m amazed at how fast your blog loaded on my phone .. I’m not even using WIFI, just 3G .. Anyhow, great blog!

  46. Thanks for another informative site. Where else could I get that kind of information written in such an ideal way? I’ve a project that I am just now working on, and I’ve been on the look out for such info.

  47. With havin so much written content do you ever run into any issues of plagorism or copyright infringement? My website has a lot of completely unique content I’ve either authored myself or outsourced but it looks like a lot of it is popping it up all over the web without my permission. Do you know any solutions to help reduce content from being ripped off? I’d certainly appreciate it.

  48. I simply wanted to construct a simple note in order to express gratitude to you for these fabulous recommendations you are giving out on this site. My extended internet search has now been paid with beneficial facts to share with my visitors. I would believe that most of us visitors are definitely lucky to dwell in a useful place with very many special people with useful principles. I feel pretty lucky to have discovered your site and look forward to plenty of more entertaining minutes reading here. Thanks a lot once again for everything.

  49. I’ll right away take hold of your rss feed as I can not find your email subscription hyperlink or e-newsletter service. Do you’ve any? Kindly permit me realize so that I may just subscribe. Thanks.

  50. 娛樂城
    福佑娛樂城致力於在網絡遊戲行業推廣負責任的賭博行為和打擊成癮行為。 本文探討了福友如何通過關注合理費率、自律、玩家教育和安全措施來實現這一目標。

    理性利率和自律:
    福佑娛樂城鼓勵玩家將在線賭博視為一種娛樂活動,而不是一種收入來源。 通過提倡合理的費率和設置投注金額限制,福佑確保玩家參與受控賭博,降低財務風險並防止成癮。 強調自律可以營造一個健康的環境,在這個環境中,賭博仍然令人愉快,而不會成為一種有害的習慣。

    關於風險和預防的球員教育:
    福佑娛樂城非常重視對玩家進行賭博相關風險的教育。 通過提供詳細的說明和指南,福佑使個人能夠做出明智的決定。 這些知識使玩家能夠了解他們行為的潛在後果,促進負責任的行為並最大限度地減少上癮的可能性。

    安全措施:
    福佑娛樂城通過實施先進的技術解決方案,將玩家安全放在首位。 憑藉強大的反洗錢系統,福友確保安全公平的博彩環境。 這可以保護玩家免受詐騙和欺詐活動的侵害,建立信任並促進負責任的賭博行為。

    結論:
    福佑娛樂城致力於培養負責任的賭博行為和打擊成癮行為。 通過提倡合理的費率、自律、玩家教育和安全措施的實施,富友提供安全、愉快的博彩體驗。 通過履行社會責任,福佑娛樂城為其他在線賭場樹立了積極的榜樣,將玩家的福祉放在首位,營造負責任的博彩環境。

  51. 娛樂城
    娛樂城
    福佑娛樂城致力於在網絡遊戲行業推廣負責任的賭博行為和打擊成癮行為。 本文探討了福友如何通過關注合理費率、自律、玩家教育和安全措施來實現這一目標。

    理性利率和自律:
    福佑娛樂城鼓勵玩家將在線賭博視為一種娛樂活動,而不是一種收入來源。 通過提倡合理的費率和設置投注金額限制,福佑確保玩家參與受控賭博,降低財務風險並防止成癮。 強調自律可以營造一個健康的環境,在這個環境中,賭博仍然令人愉快,而不會成為一種有害的習慣。

    關於風險和預防的球員教育:
    福佑娛樂城非常重視對玩家進行賭博相關風險的教育。 通過提供詳細的說明和指南,福佑使個人能夠做出明智的決定。 這些知識使玩家能夠了解他們行為的潛在後果,促進負責任的行為並最大限度地減少上癮的可能性。

    安全措施:
    福佑娛樂城通過實施先進的技術解決方案,將玩家安全放在首位。 憑藉強大的反洗錢系統,福友確保安全公平的博彩環境。 這可以保護玩家免受詐騙和欺詐活動的侵害,建立信任並促進負責任的賭博行為。

    結論:
    福佑娛樂城致力於培養負責任的賭博行為和打擊成癮行為。 通過提倡合理的費率、自律、玩家教育和安全措施的實施,富友提供安全、愉快的博彩體驗。 通過履行社會責任,福佑娛樂城為其他在線賭場樹立了積極的榜樣,將玩家的福祉放在首位,營造負責任的博彩環境。

  52. I am extremely impressed with your writing skills and also with the layout on your blog. Is this a paid theme or did you modify it yourself? Either way keep up the nice quality writing, it is rare to see a great blog like this one today..

  53. Howdy! Do you know if they make any plugins to safeguard against hackers? I’m kinda paranoid about losing everything I’ve worked hard on. Any recommendations?

  54. I have not checked in here for some time because I thought it was getting boring, but the last several posts are good quality so I guess I will add you back to my daily bloglist. You deserve it my friend 🙂

  55. Appreciating the time and energy you put into your site and detailed information you present. It’s good to come across a blog every once in a while that isn’t the same out of date rehashed material. Wonderful read! I’ve saved your site and I’m including your RSS feeds to my Google account.

  56. Kuliah Online
    Kuliah Online
    UHAMKA memberikan kemudahan bagi calon mahasiswa baru/pindahan/konversi untuk mendapatkan informasi tentang UHAMKA atau melakukan registrasi online dimana saja dan kapan saja.

  57. 線上賭場
    台灣娛樂城/線上賭場(現金網)的特殊稱呼以及其歷史:

    台灣對於線上賭場的特殊稱呼是「娛樂城/線上賭場(現金網)」。這種稱呼的背後有其原因,主要是因為線上賭場在台灣架設及經營是違法的。在早期經營線上博弈被抓的風險非常高,因此業者採用了「娛樂城」這樣的模糊代稱,以規避警方的注意。當時的網絡搜尋引擎尚未普及,這樣的代稱在一定程度上能夠達到避免被發現的效果。

    台灣娛樂城/線上賭場的歷史可以分為幾個時期:

    1. 網路未興盛時代:
    – 現場賭場時期(1980年代):賭博活動主要發生在實體賭場,包括家庭電話上的BB CALL呼叫器、六合彩、大家樂等方式。
    – 電銷賭場時期(21世紀):隨著手機的普及,人們開始使用手機進行博弈,主要包括中華職棒簽賭和六合彩等。

    2. 線上博弈時期(2013年開始):
    – 網際網路普及後,原本的信用版博弈業者開始轉戰線上賭場(娛樂城),開啟了線上博弈的時代。
    – 由於在台灣,線上賭場架設和經營是違法的,合法的線上賭場通常選擇在合法的國家進行架設。
    – 開設線上賭場主要採用「現金儲值」的方式,以規避法律風險。玩家將現金兌換成賭資,進行投注。

    3. 娛樂城商業模式的轉變:
    – 早期的娛樂城業者往往將客服人員與金流(出入款)的職責綁在一起,

    容易成為執法機關定罪的基礎。
    – 現代的娛樂城業者開始將客服人員、金流服務商以及廣告行銷外包,以降低定罪風險。
    – 由於遠端工作的普及以及區塊鏈技術的應用,未來娛樂城業者可能更加難以被追查,這也凸顯了博弈產業合法化的必要性。

    娛樂城業者面臨的風險主要來自以下幾個方面:

    – 架站主機:娛樂城業者通常在合法的國家進行架設,使執法機關難以從此方面下手追查。
    – 客服人員:娛樂城業者可能在台灣設立辦公室提供客服服務,這也是執法機關可能進行搜索的目標之一。
    – 金流(出入款):娛樂城業者使用人頭帳戶進行金流操作,以規避監管機構的追蹤,但也存在風險。
    – 行銷推廣:娛樂城業者需要進行廣告推廣來吸引玩家,行銷推廣方式也可能成為執法機關追查的一環。

    娛樂城業者商業模式的轉變也反映了博弈產業的發展趨勢。隨著網路技術的成熟和商業模式的創新,博弈產業可能朝著合法化和監管的方向發展,以確保公信力、保護玩家權益並徵收相應的稅收。
    http://www.sexysuche.de/cgi-bin/autorank/out.cgi?id=freegal&url=https://rg8888.org/娛樂城大解析/

Leave a Reply

Your email address will not be published. Required fields are marked *