Case 2:21-cv-00195 Document 1 Filed 01/08/21 Page 1 of 24 Page ID #:1
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`
`MARC E. MAYER (SBN 190969)
`mem@msk.com
`MARK C. HUMPHREY (SBN 291718)
`mxh@msk.com
`MITCHELL SILBERBERG & KNUPP LLP
`2049 Century Park East, 18th Floor
`Los Angeles, CA 90067-3120
`Telephone: (310) 312-2000
`Facsimile: (310) 312-3100
`Attorneys for Plaintiffs
`
`
`RIOT GAMES, INC. and BUNGIE,
`INC.,
`
`Plaintiffs,
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
` CASE NO. 2:21-cv-195
`COMPLAINT FOR:
`
`(1) TRAFFICKING IN
`CIRCUMVENTION DEVICES;
`
`(2) INTENTIONAL
`INTERFERENCE WITH
`CONTRACTUAL RELATIONS;
`
`(3) UNFAIR COMPETITION
`
`Demand For Jury Trial
`
`
`
`v.
`CAMERON SANTOS d/b/a
`“GATORCHEATS,” an individual, and
`Does 1 through 10, inclusive,
`Defendants.
`
`
`
`
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`Riot Games, Inc. (“Riot”) and Bungie, Inc. (“Bungie”) (collectively
`“Plaintiffs”) allege as follows:
`
`
`PRELIMINARY STATEMENT
`1.
`Riot and Bungie are the owners and publishers of two of the most
`popular online multiplayer video games in the world: “Valorant” and “Destiny 2”
`(collectively, the “Games”). By this lawsuit, Plaintiffs seek to put a stop to the
`unlawful, for-profit sale and distribution of malicious software products designed
`to enable members of the public to gain unfair competitive advantages (i.e., to
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`Case 2:21-cv-00195 Document 1 Filed 01/08/21 Page 2 of 24 Page ID #:2
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`cheat) in the Games, and, thereby, to impair and destroy Plaintiffs’ Games,
`Plaintiffs’ overall business, and the experience of Plaintiffs’ player community.
`2.
`Defendant Cameron Santos (“Defendant” or “Santos”) is the owner
`and operator of several commercial online business ventures engaged in the
`development, sale, distribution, marketing, and exploitation of a portfolio of
`malicious cheats and hacks for popular multiplayer games, including the Games.
`Among the most prominent of these ventures is “GatorCheats,” which largely
`operates via the website www.gatorcheats.com (the “GatorCheats Website”). Via
`the GatorCheats Website and other related websites and social media accounts,
`Defendant and those working in concert with him sell a Valorant cheat known as
`“Gatorant” and a suite of software cheats for Destiny 2 (the “Destiny 2 Cheats”)
`(collectively, the “Cheating Software”). The Cheating Software enables players to
`manipulate Valorant and Destiny 2 to their personal advantage, such as by
`automatically aiming weapons, revealing the locations of opponents, and allowing
`the player to see a vast array of information that otherwise would be obscured.
`3.
`Defendants’ conduct has caused, and is continuing to cause, massive
`and irreparable harm to Plaintiffs and their business interests. The success of
`Plaintiffs’ Games depends on them being enjoyable and fair for all players, and
`Plaintiffs spend an enormous amount of time and money to ensure that this is the
`case. Defendants’ sale and distribution of the Cheating Software has caused
`Plaintiffs to suffer irreparable damage to their goodwill and reputation and to lose
`millions of dollars in revenue.
`4.
`In creating, marketing, selling, servicing, and distributing the
`Cheating Software, Defendants have engaged in numerous unlawful acts under
`United States and California law. Defendants have violated Section 1201 of the
`Digital Millennium Copyright Act (“DMCA”), 17 U.S.C. § 1201(b)(1), by selling,
`importing, offering, providing, and otherwise trafficking in technologies that
`circumvent or evade anti-cheat technologies used by Plaintiffs to protect the
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`integrity and commercial value of Valorant and Destiny 2. Defendants also have
`knowingly, intentionally, and maliciously interfered with and disrupted the
`contracts Plaintiffs have with their customers in the United States, which explicitly
`prohibit the exact type of cheating that Defendants enable, encourage, and solicit
`by marketing and selling their Cheating Software. Defendants not only know that
`their conduct is unlawful, but they engage in that conduct with the deliberate intent
`to harm Plaintiffs, their businesses, and their player community. Plaintiffs are
`entitled to monetary damages, injunctive and other equitable relief, and punitive
`damages against Defendants.
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`JURISDICTION AND VENUE
`5.
`This is a civil action seeking damages, injunctive relief, and other
`equitable relief under the anti-circumvention provisions of the DMCA, 17 U.S.C. §
`1201, and the laws of the State of California.
`6.
`This Court has subject matter jurisdiction over Plaintiffs’ claims for
`violating the anti-circumvention provisions of the DMCA pursuant to 28 U.S.C. §§
`1331 and 1338(a). Pursuant to 28 U.S.C. § 1367, this Court has supplemental
`jurisdiction over Plaintiffs’ state law claims for intentional interference with
`contract and unfair competition, which are so related to Plaintiffs’ federal claims as
`to be part of the same case or controversy.
`7.
`This Court has personal jurisdiction over Defendants because they
`have purposefully directed their activities at the United States, and at California in
`particular, have purposefully availed themselves of the benefits of doing business
`in California, and have established a continuing presence in California. Plaintiffs
`are informed and believe, and on that basis allege, that, without limitation:
`
`(a) Defendants conduct extensive and ongoing business with users
`in the State of California;
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`(b) Defendants distribute the Cheating Software in the State of
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`California, advertise and market the Cheating Software in the United States and the
`State of California, and communicate directly with users in the United States and
`in the State of California, including for the purposes of soliciting purchases of the
`Cheating Software by such users and providing technical support for the Cheating
`Software;
`(c) Defendants have entered into, and continue to enter into,
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`contracts with individuals in the State of California, including contracts pursuant to
`which these individuals license from Defendants the right to install and use the
`Cheating Software. In return for such licenses, Defendants receive ongoing
`recurring daily, weekly, or monthly payments from individuals in the United States
`and the State of California; and
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`(d) Defendants contract with entities located in the State of
`California in connection with their businesses. This includes, for example, domain
`name registries, hosting or content delivery services, as well as credit card
`processors and merchant banks.
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`(e) Defendants engage in conduct that they know is likely to cause
`harm to Plaintiffs in the State of California, including in this District, where Riot is
`located and has its principal place of business.
`8.
`Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)
`because this is a judicial district in which a substantial part of the events giving rise
`to the claims occurred, and/or in which Plaintiffs’ injury was suffered.
`
`
`THE PARTIES
`9.
`Riot is a corporation duly organized and existing under the laws of the
`State of Delaware, with its principal place of business in Los Angeles, California.
`10. Bungie is a corporation duly organized and existing under the laws of
`the State of Delaware, with its principal place of business in Bellevue, Washington.
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`11. Plaintiffs are informed and believe, and on that basis allege, that
`Defendant Santos is an individual residing in Albuquerque, New Mexico.
`Plaintiffs are informed and believe, and on that basis allege, that Santos is the
`founder, owner, operator, and/or driving force of GatorCheats, is the owner and
`operator of the GatorCheats Website, and at times does business under other
`names, such as “Honeyhacks” and “Voidcheaters.” Under one or more of these
`business names, Santos markets, advertises, promotes, and otherwise facilitates the
`sale of the Cheating Software.
`12. Plaintiffs are informed and believe, and on that basis allege, that
`defendant Doe 1 a/k/a “Hal,” Doe 2 a/k/a “Matt,” and Doe 3 a/k/a “Megan”
`provide or previously provided customer support for GatorCheats customers (i.e.,
`users of the Cheating Software) via various online chat and messaging platforms.
`In that role, these individuals communicate with Plaintiffs’ customers in order to
`support and enable their use of the Cheating Software, and serve as liaison to,
`and/or themselves operate as, developers of the Cheating Software. Among other
`activities, Hal, Matt, and Megan assist customers in operating the Cheating
`Software, give advice to customers as to how to avoid being caught or detected by
`Plaintiffs for using the Cheating Software, and communicate to users about updates
`and improvements to the Cheating Software. The true names and capacities,
`whether individual, corporate, associate, or otherwise, of Hal, Matt, and Megan are
`unknown to Plaintiffs, which has therefore sued said defendants by such aliases
`and fictitious names.
`13. The true names and capacities, whether individual, corporate,
`associate, or otherwise, of the remaining Doe defendants are unknown to Plaintiffs,
`which have therefore sued said defendants by such aliases and fictitious names.
`These defendants include individuals whose real identities are not yet known to
`Plaintiffs, but who are acting in concert with one another, often under the guise of
`Internet aliases, in committing the unlawful acts alleged herein. Among the Doe
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`Defendants are developers, resellers, technical support staff, and other individuals
`who have participated in the development, sale, and distribution of the Cheating
`Software. Plaintiffs will seek leave to amend this complaint to state their true
`names and capacities once said defendants’ identities and capacities are
`ascertained. Plaintiffs are informed and believe, and on that basis allege, that all
`defendants sued herein are liable to Plaintiffs as a result of their participation in all
`or some of the acts set forth in this complaint. (All of the aforementioned
`defendants, both the named defendants and the Doe defendants, are referred to
`herein collectively as “Defendants.”)
`14. Plaintiffs are informed and believe, and on that basis allege, that at all
`times mentioned in this complaint, each of the Defendants was the agent of each of
`the other Defendants and, in doing the things alleged in this complaint, was acting
`within the course and scope of such agency.
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`FACTS APPLICABLE TO ALL CLAIMS
`Riot and Valorant
`15. Riot is the developer, owner, and distributor of the popular video
`game “Valorant.” Valorant is an online multiplayer game currently available on
`Windows-based personal computers. Since its release, Valorant has received
`glowing reviews and has consistently ranked among the most popular games
`streaming on the live-streaming platform Twitch. Valorant is offered on a “free-to-
`play” basis, meaning that there is no charge for players to download and play the
`game on their personal computers.
`16. Valorant is a team-based, tactical “first-person shooter” game that
`allows players to play as one of a set of “agents,” pre-designed characters that
`possesses unique attributes, skills, weapons, and other abilities. Players start each
`round with a pistol and a “charge” for one of their signature abilities. Other
`weapons and charges are purchased using in-game currency (awarded based on the
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`outcomes of game rounds). Weapons available to players include automatic and
`semi-automatic guns that have shooting patterns a player must learn and master in
`order to be able to use them properly and accurately.
`17. Valorant matches are intense and highly competitive affairs, with a
`heavy emphasis on teamwork. Teams that do not cohesively work together and
`account for individual players’ strengths and weaknesses have a very hard time
`prevailing, particularly if they come up against a team of dedicated players that is
`working together. Since its release, Valorant has developed a robust and growing
`player community, and is rapidly becoming one of the most important and popular
`competitive “esports.” Valorant is played by casual players, serious amateurs, and
`professional players, including in professional and semi-professional tournaments
`around the world.
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`Bungie and Destiny 2
`18. Bungie is the developer, owner, and distributor of the video game
`titled “Destiny 2.” Destiny 2 is an online multiplayer “first-person shooter”
`currently available on Windows-based personal computers, as well as home video
`game consoles and the Google Stadia cloud gaming service. Destiny 2 originally
`was released on September 6, 2017, for the Sony Playstation 4 and Microsoft Xbox
`One, and on October 24, 2017, for Windows computers. Since the game’s original
`release, Bungie has released for sale multiple expansions or add-ons to the main
`game experience, including, most recently, the “Beyond Light” expansion released
`in November 2020. These expansions typically offer players new quests, weapons,
`game modes, and other additions or revisions to Destiny 2’s core gameplay.
`19. Destiny 2 is an open, “shared-world” multiplayer, “first-person
`shooter” game in which players can see and interact with one another. The game
`offers two main types of activities: player-versus-environment (PvE), in which
`players cooperate to fight against computer-controlled opponents, and player-
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`versus-player (PvP), in which players compete against one another. Players
`generally are free to complete activities in Destiny 2 on their own, or with a team
`of friends (or people randomly assigned to them via matchmaking). Some
`activities, however, require players to team up with others, specifically three-player
`“Strikes” and six-player “Raids,” and some competitive PvP modes in which
`players can obtain extremely rare items and other rewards.
`20. Matches played in Destiny 2’s PvP modes are intense and highly
`competitive affairs. In Destiny 2, competition can be particularly intense due to
`the presence of rare loot which can affect player progression, in addition to the
`prestige of increasing one’s rank and character power. As a result, the demand for
`software that gives players an unfair advantage in Destiny 2’s PvP modes is
`particularly high.
`21. Destiny 2’s PvE modes can also become intense affairs because
`players can obtain special physical merchandise if they earn certain in-game
`“achievements” by completing very challenging content within specific
`timeframes. As such, many players take part in highly competitive “achievement
`hunting” in the hope of obtaining those awards. The idea that players could qualify
`for these difficult-to-obtain awards by using cheat software, or that they are
`progressing more rapidly in order to become competitive by using cheats, cheapens
`the experience for legitimate players.
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`Plaintiffs’ Business Model
`22. Plaintiffs’ success rests in large part on their ability to offer
`consistently compelling player experiences so that customers remain invested in
`the Games and play them for a sustained period of time. Retaining and satisfying
`their player communities is an acute concern for Plaintiffs because much of the
`revenue Plaintiffs earn from their Games is from dedicated or long-term players
`who enjoy the Games and wish to enhance their experience with the Games by
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`investing in “virtual goods” (such as new characters, new weapons, and cosmetic
`upgrades such as distinctive “skins” or clothing) or purchasing expansion packs
`that offer new facets to the game experience.
`23. Both Valorant and Destiny 2 are offered to the public for free. Thus,
`in order to play the Games, a member of the public need only register an account
`with Plaintiffs, download the respective Game software, and connect to Plaintiffs’
`multiplayer servers. Should a player wish to purchase optional in-game items,
`unlock new characters, or gain access to exclusive content, he or she may do so by
`purchasing in-game currency (known as “Valorant Points” in Valorant and
`“Silver” in Destiny 2.) Additionally, Bungie creates and makes available for sale
`Destiny 2 “expansions,” which offer new content and new game modes.
`24. The revenue from the sale of virtual currency and digital
`enhancements or expansions is what enables Plaintiffs to maintain, update, service,
`and develop the Games and their online services. Accordingly, it is paramount to
`Plaintiffs’ business models that the Games retain the interest of their respective
`user bases for sustained periods of time, so that players will remain dedicated to
`the Games, recommend the Games to friends and family, and continue to purchase
`virtual items and expansions. A vital part of the player experience is the fairness
`and integrity of the Games, and thus Plaintiffs invest an enormous amount of time
`and money to ensure that all players stand on equal footing and have a fair chance
`of progressing in the Games. If players perceive that others are cheating or have
`an unfair advantage, they will grow frustrated with the Games and stop playing.
`That, in turn, could disrupt and/or destroy the Games’ player communities and
`severely harm Plaintiffs’ ability to generate revenue and to maintain, improve, and
`expand the Games.
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`Plaintiffs’ Efforts To Protect Against Hackers And Cheaters
`25. Because Valorant and Destiny 2 are such popular games,
`unscrupulous individuals and companies such as Defendants seek to exploit the
`games for their own personal gain and profit by selling cheats, hacks, and other
`malicious software, knowing that they are ruining the experience for other players
`and harming Plaintiffs. For this reason, Plaintiffs undertake enormous effort to
`protect the integrity of the Games through both technical and contractual means.
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`Technical Protection
`26.
`In order to protect the Games from cheating or unauthorized
`exploitation, Plaintiffs employ a variety of anti-cheat technologies. Riot, for
`example, uses a custom game security software called “Vanguard.” Vanguard is
`installed on a player’s computer system when the Valorant game is installed.
`Vanguard is designed to detect, and effectively detects, when players are using
`software that allows them to cheat in the game and Vanguard prevents
`unauthorized access to Valorant by those players. Bungie employs similar anti-
`cheat software with Destiny 2. It is not possible to play the Games without
`installing Plaintiffs’ anti-cheat technologies.
`27. Because both Plaintiffs employ effective anti-cheat technologies, in
`order for any hack or cheat software to operate, it must be designed to prevent or
`avoid detection by the anti-cheat software, such as by concealing itself or by
`disabling the anti-cheat technology. Otherwise, the cheat will be detected and the
`user will be denied access to the Games.
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`Contractual Protection
`28.
`In order to access, download, or play the Games, users must create
`and register accounts with Riot or Bungie. Upon downloading the Games and
`beginning installation, users must expressly manifest their assent to Riot’s Terms
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`of Service (collectively, the “TOS”) or to Bungie’s Limited Software License
`Agreement (“SLA”).1 The entire text of the License Agreements is displayed to
`each user at the time that player first accesses his or her Riot or Bungie account
`while installing the Games; in the case of Valorant, the installation pauses and will
`not progress until the user assents to the TOS. If the user refuses to consent to the
`License Agreements, installation halts and the programs immediately close. Riot’s
`TOS is available in its entirety online at riotgames.com/en/terms-of-service, while
`Bungie’s SLA is available at bungie.net/7/en/Legal/SLA.
`29. Riot’s TOS includes a limited license agreement between Riot and its
`users. Under the TOS, Riot grants to users a limited license to use and enjoy its
`services and games for “individual, non-commercial, entertainment purposes
`only,” expressly conditioned upon the user’s compliance with the TOS. Among
`other provisions, the TOS expressly prohibits players from “[u]sing any
`unauthorized third party programs, including mods, hacks, cheats, scripts, bots,
`trainers and automation programs that interact with [Valorant] in any way, for any
`purpose,” or from “[a]voiding, bypassing, removing, deactivating, impairing,
`descrambling or otherwise circumventing any technological measure implemented
`by Riot or any third party to protect [Valorant].”
`30. Bungie’s SLA also includes a limited license agreement between
`Bungie and its users. Under the SLA, users are required to agree not to, among
`other things, “hack or modify [Destiny 2], or create, develop, modify, distribute, or
`use any unauthorized software programs to gain advantage in any online or
`multiplayer game modes.” Users also are required to agree not to “receive or
`provide ‘boosting services,’ to advance progress or achieve results that are not
`solely based on the account holder’s gameplay.”
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`1 Riot’s TOS and Bungie’s SLA are at times referred to collectively herein as the
`“License Agreements.”
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`31. The Games are made available to the public exclusively through
`Plaintiffs’ proprietary servers and matchmaking systems. Thus, it is not possible
`for a user to lawfully obtain access to or play the Games without expressly
`consenting to the License Agreements.
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`Defendants And Their Unlawful Conduct
`32. Plaintiffs are informed and believe, and on that basis allege, that
`Defendants are engaged in developing, updating, marketing, distributing, selling,
`and supporting cheating software, including Gatorant and the Destiny 2 Cheats. At
`all times relevant herein, Defendants have developed, updated, marketed,
`distributed, sold, and supported the Cheating Software. They have done so, and
`continue to do so, via the GatorCheats Website, email, and communication
`platforms such as the instant messaging service “Telegram” and, at one time, the
`online “chat room” system known as “Discord.”
`33. The GatorCheats Website claims that it is “the best website for safe
`and secure video game cheats,” that it sells “high quality cheats and services for
`the most popular games on the market,” and that it is “the only provider on the web
`who will do [the customer’s] personal service without any chance of ban.”
`GatorCheats also openly states that its “mission is to help people who do not have
`time to gain skill on video games legitimately but still want to find enjoyment
`playing video games regardless.”
`34. Additionally, according to the GatorCheats Website, GatorCheats’
`products and services:
`• Are “known to launch first and remain undetected the longest.”
`• “[H]ave the best uptime out of any provider in this market.”
`• “[H]ave auto update functionalities that cover most all game
`updates, so you can keep cheating as it should be!”
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`35. Plaintiffs are informed and believe, and on that basis allege, that in
`addition to marketing and distributing cheats (including but not limited to the
`Cheating Software), Defendants provide extensive and ongoing customer support
`and technical assistance. The GatorCheats Website advertises such services, which
`Plaintiffs are informed and believe, and on that basis allege, are provided via
`GatorCheats’ private communications with users via email, Telegram, and,
`previously, Discord.
`
`
`Gatorant
`36. Among the products currently offered for sale by GatorCheats is
`“Gatorant,” a cheat designed to be used with Valorant. According to the
`GatorCheats Website, Gatorant injects a menu into Valorant (via GatorCheats’
`“most secure loader to date”) that purports to enable Valorant players to cheat in
`the game by, inter alia, automatically aiming a player’s weapon, expanding a
`player’s field of vision, illuminating opponents, and displaying information such as
`the locations and health status of hidden or obscured opponents or the location of
`valuable items.
`37. Defendants specifically advertise Gatorant as being “undetected” by,
`and “secure” from Vanguard. For example, Santos has posted the following on the
`GatorCheats Website:
`
`
`GATORANT, created by GatorCheats. Purchase one
`month of my undetected, all in one, cheat and spoofer for
`Valorant. My cheat is a menu injected via my most
`secure loader to date. My menu is compatible with
`Windows 10, any processor, and any GPU. My menu
`includes a very powerful and customizable aimbot with
`aim key, visibility checks, aim at enemies, aim at friends,
`aim bone selection, smoothness customization, recoil
`control, and FOV customization (please visit F.A.Q. for
`the full feature list, more details, and media). My menu
`also includes flawless ESP: show enemies, show friends,
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`Mitchell
`Silberberg &
`Knupp LLP
`12724040.4
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`

`

`Case 2:21-cv-00195 Document 1 Filed 01/08/21 Page 14 of 24 Page ID #:14
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`
`FOV drawing toggle, show names, show boxes, show
`bones, show health, and show equipment (please visit
`F.A.Q. for the full feature list, more details, and media).
`38. Access to Gatorant is offered for sale on the GatorCheats Website at
`the following rates: one month of access for $90.00, three months for $250.00, and
`lifetime (of the cheat) for $500.00. GatorCheats also offers an “upgrade” to users
`with the three-month subscription to the lifetime tier, for an additional payment of
`$200.00.
`39. Riot is informed and believes, and on that basis alleges, that Gatorant
`has been downloaded and used by Valorant players thousands of times, including
`by players residing in the United States. Riot also is informed and believes that
`Defendants have made tens or hundreds of thousands of dollars from their
`distribution and sale of Gatorant.
`
`
`The Destiny 2 Cheats
`40. Until recently, Defendants publicly offered for sale on the
`GatorCheats Website a suite of software cheats designed to be used with Destiny 2.
`These cheats were advertised as “the best Destiny 2 cheat that money can buy” (the
`“Destiny 2 Cheats”). According to the GatorCheats Website, the Destiny 2 Cheats
`were accessible via “a menu injected via [GatorCheats’] secure loader” that
`included a “powerful and customizable aimbot,” “flawless ESP,” and a vast
`number of other features.
`41. Access to the Destiny 2 Cheats was offered for sale on the
`GatorCheats website at the following rates: three months of access for $100.00 and
`lifetime (of the cheat) for $200.00. GatorCheats also offered an “upgrade” to users
`with the three-month subscription to the “lifetime” tier, for an additional payment
`of $115.00.
`42. Bungie is informed and believes, and on that basis alleges, that the
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`Mitchell
`Silberberg &
`Knupp LLP
`12724040.4
`
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`

`

`Case 2:21-cv-00195 Document 1 Filed 01/08/21 Page 15 of 24 Page ID #:15
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`Destiny 2 Cheats were downloaded and used by Destiny 2 players thousands of
`times, including by players residing in the United States. Bungie also is informed
`and believes that Defendants have made tens or hundreds of thousands of dollars
`from their distribution and sale of the Destiny 2 Cheats.
`43. On November 11, 2020, Bungie’s legal counsel served defendant
`Santos, GatorCheats’ principal, with a cease and desist letter regarding the Destiny
`2 Cheats. On November 14, 2020, Santos notified GatorCheats users on Telegram
`that he had received the letter from Bungie, and that he would be removing the
`Destiny 2 Cheats within the timeframe specified in the letter. Shortly after sending
`this message, however, he stated through Telegram that he would be continuing to
`support the Destiny 2 Cheats for users who already had purchased a license:
`
`
`I am getting a lot of angry messages so I’m just going to
`spell it out. I am not going to stop support for the D2
`cheat. I am just going to stop selling it. So if you are a
`lifetime user, you should have no grievance to settle with
`me.
`44. On or around November 18, 2020, the Destiny 2 Cheats were
`removed from public-facing pages of the GatorCheats Website. However,
`Plaintiffs are informed and believe, and on that basis allege, that Defendants
`continue to offer the Destiny 2 Cheats, or some derivation thereof, for sale in a
`“private” section of the GatorCheats Website open to members of the public that
`inquire about certain software products. Moreover, despite the public removal of
`the Destiny 2 Cheats from the GatorCheats Website, information about the Destiny
`2 Cheats remained accessible on the GatorCheats Website for weeks thereafter.
`Plaintiffs also are informed and believe, and on that basis allege, that Defendants
`continue to support the Destiny 2 Cheats (and other cheating software that has been
`removed from public-facing pages of the GatorCheats Website) for players that
`previously purchased that software.
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`Mitchell
`Silberberg &
`Knupp LLP
`12724040.4
`
`
`

`

`Case 2:21-cv-00195 Document 1 Filed 01/08/21 Page 16 of 24 Page ID #:16
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`Defendants’ Unlawful Activities
`45. Plaintiffs are informed and believe, and on that basis allege, that in
`order for the Cheating Software to operate with the Games, the Cheating Software
`necessarily includes technology that primarily is designed to avoid, bypass, evade,
`or otherwise circumvent Plaintiffs’ anti-cheat technologies, including in particular
`Riot’s Vanguard anti-cheat technology. Accordingly, each time Defendants sell a
`license to the Cheating Software they are trafficking in technology that controls
`access to the Games.
`46. Defendants specifically and aggressively advertise and promote the
`Cheating Software as having been designed to circumvent Plaintiffs’ anti-cheat
`software. For example, on the GatorCheats website, Santos touts that among the
`“features” of Gatorant is GatorCheats