This Material Is Protected by Copyright and Is for the Personal Use of the Individual Smithline Training Subscriber Who Purchased Access to This Episode Only

Home , Duke Nukem (character), Tetris effect, Tetromino

Smithline Training LLC

Presentation Slides

Limited Use Right: This material is protected by copyright and is for the personal use of the individual Smithline Training subscriber who purchased access to this Episode only. Any other use or distribution of this material is strictly prohibited.

This is Not Legal Advice: The information contained in this document is provided for informational purposes only. It should not be considered legal advice or a substitute for legal advice, and does not create an attorney‐client relationship between you and Smithline Training LLC. Because this information is general, it may not apply to your individual legal or factual circumstances. You should not take (or refrain from taking) any action based on the information in this document without first obtaining legal counsel.

Please contact us with any questions or comments: [email protected]

SMITHLINE TRAINING LLC | 300 MONTGOMERY STREET, SUITE 1000 | SAN FRANCISCO, CA 94104

Are the Rules of a Video Game Now Copyrightable?

Smithline Training LLC / smithlinetraining.com Disclaimer

01 Smithline Training LLC is not a law firm

02 Not legal advice

03 No attorney‐client relationship

04 Consult with a lawyer for your particular issues Our 2‐Step Training Approach

1 2 Watch the Episode Attend a Roundtable

Ask questions and share best practices Online or in person in San Francisco Feedback

Feedback, questions or complaints?

[email protected] Tools for this Episode

 Copyright Code Provisions and Case List Today’s Question Today’s Question

In the last few years, two U.S. district courts found video game mechanics or “rules” to be protectable by copyright.

A more recent district court started down the same path before reversing itself.

 So, are the rules of a video game now copyrightable? Today’s Topics

1. What are the Rules of a Video Game? 2. The Historical Approach to Protecting Game Rules 3. The Arcade Game Cases 4. Attack of the Mobile Clones: Tetris and Spry Fox 5. The DaVinci Case 6. Is There Some Other Way to Protect Game Rules? 7. Why Might Video Game Rules be Receiving Greater Protection? 8. Questions from the Roundtable PART 1 What are the Rules of a Video Game? Rules of a Game: Board Game

For a board or card game, rules are:

1. Instructions that explain how to play the game, and

2. Method of playing as expressed through game board, cards or pieces.

These are the rules for Legends of the Three Kingdoms from the Da Vinci case. Rules of a Game: Video Game

For a video game, the “rules” are often the mechanics of the game or “gameplay.”

The functional rules which dictate how your can move a character, how points are scored, when you win and lose. Rules of a Game: Video Game Rules of a Game: Theory

As Bruce Boyden of Marquette Law says:

“Rules establish the game‐space, or ‘magic circle,’ but they do not tell the player what to do inside of it. Indeed, exploring that space, by making moves in the game, is what it means to ‘play’ the game.”

“Games are systems [. . .]. Systems are shells into which users pour meaning. While they may contain expression themselves, that expression is there merely to facilitate the meaning added by the user.”

Games and Other Uncopyrightable Systems, Bruce Boyden, George Mason Law Review, Vol. 18, No. 2, 2011 PART 2 The Historical Approach to Protecting Game Rules Historically, the rules of a game were not protected by copyright. Case Law Case Law

. Foster published multiple books on bridge.

 The particular book at issue in this case was titled:

"Foster's Simplified Auction Bridge (with the New Laws)” Case Law

“In the conventional laws or rules of a game, as distinguished from the forms or modes of expression in which they may be stated, there can be no literary property susceptible of copyright.

Defendant has not infringed, because he has not copied the literary composition of the plaintiff's publication, but, in language quite distinctly his own, has restated the same set of conventional precepts.”

Whist Club v. Foster, 42 F.2d 782 (S.D.N.Y. 1929) U.S. Copyright Code

Copyright subsists in “original works of authorship fixed in any tangible medium of expression” but excludes “any idea, procedure, process, system, method of operation, concept, principle, or discovery. . . “ 17 U.S.C. 102 (a)‐(b) U.S. Copyright Code

 Copyright Infringement Analysis

When comparing two video games for infringement purposes we: 1. Filter out the elements not entitled to copyright. What do we filter out? • Ideas of the game • “Scènes à faire”‐ stock/cliché expressions which necessarily follow from the idea • Rules of a game (either as “ideas” or as a “system”) 2. Compare what’s left to see if it’s “substantially similar.” Copyright Infringement Analysis

 Note also: thin copyright protection for more factual, prosaic expression and stronger protection for more fanciful or unique expression. PART 3 The Arcade Game Cases In the early cases, courts tried hard to sort out underlying mechanics from protected expression. Atari v. Amusement World (D. Md. 1982)

Atari v. Amusement World (D. Md. 1982)

Arcade game released by Atari in 1979, Amusement World, a five‐person arcade game quickly becoming one of the biggest servicing company, releases Meteors in 1981. selling games of its time.

Atari v. Amusement World (D. Md. 1982)

Similar or identical: Principle of game and 22 design features.

Differences: 9 items, including: • Meteors in color and more “realistic” • Spaceship takes off from Earth • Faster gameplay • Ability to fire continuously Atari v. Amusement World (D. Md. 1982)

NOT INFRINGEMENT: These “similarities are inevitable, given the requirements of the idea of a game involving a spaceship combating space rocks and given the technical demands of

the medium of a video game.” Atari v. Amusement World (D. Md. 1982)

“[T]o put it bluntly, defendants took plaintiff's idea. However, the copyright laws do not prohibit this.”

Atari v. North American Philips (7th Cir. 1982)

Arcade game released by Namco in 1980. Philips released “K.C. Munchkin” for their Magnavox Odyssey home game system.

Licensed exclusively to Atari for U.S. home game market. Atari v. North American Philips (7th Cir. 1982)

SIMILARITIES ALLOWED: “standard game devices” • maze design • scoring table • dots • tunnel exits ‐ “nothing more than the commonly used ’wrap around’ concept adapted to a maze‐chase game” Atari v. North American Philips (7th Cir. 1982)

But, gobbler and ghost monster “characters” INFRINGE: . K.C. Munchkin’s gobbler was “virtually identical” to Pac‐Man: • shape of the body • V‐shaped mouth • distinctive gobbling action and sounds • role reversal and regeneration . K.C .Munchkin’s ghost monsters “appear similar in shape and movement to their PAC‐MAN counterparts.” Atari v. North American Philips (7th Cir. 1982)

Summary: . maze design, scoring table, dots and tunnel exits: . Constitute scènes à faire and protected against only virtually identical copying. . Gobbler and ghost monsters: . Distinct, fanciful “characters” that are fully protected by copyright. Infringement PART 4 Attack of the Mobile Clones: Tetris and Spry Fox In two recent cases involving mobile game clones, courts extended protection to game mechanics that look a lot like “rules.” Tetris Holding v. Xio Interactive (D.C. N.J. 2012)

Originally developed in Soviet Union in mid‐1980’s.

One of the most successful and widely licensed video games of all time.

Tetris Tetris Background

. Puzzle game using polyominos. • A polyomino is plane geometric figure formed by joining one or more equal squares edge to edge.

. Polyomino puzzles date back to the early 1900’s. . Alexey Pajitnov cited playing a plastic pentomino (5 square) game as inspiration for Tetris. . Tetris uses brightly colored tetromino (4 square) pieces. • Tetris uses all seven possible shapes of tetromino: Tetris Holding v. Xio Interactive (D.C. N.J. 2012)

Released for iPhone by small developer Xio in 2009.

Mino Tetris Holding v. Xio Interactive (D.C. N.J. 2012)

 Tetris claims infringement by Mino using broad, functional language.

Tetris Mino Tetris Holding v. Xio Interactive (D.C. N.J. 2012)

Court Rules Out Scènes à Faire . Tetris is a “purely fanciful game, meaning it has no grounding in the real world, unlike a video game simulating a karate match or golf game.”

• Scènes à faire has “little weight in instances such as this because there are no expressive elements ‘standard, stock or common’ to a unique puzzle game that is divorced from any real world representation.”

• “Xio was free to design a puzzle game using pieces of different shapes instead of using the same seven pieces used in Tetris.” Tetris Holding v. Xio Interactive (D.C. N.J. 2012)

Broad Infringement Ruling Covering Game Mechanics “None of these elements are part of the idea (or the rules or functionality) of Tetris, but rather are a means of expressing those ideas” • “design and movement of playing pieces” including “bright colors, the individually delineated squares within the pieces and the downward lateral, and rotating movement” • dimensions of the playing field (10 x 20) • display of “garbage lines” • the appearance of “ghost” or shadow pieces • display of the next piece to fall • change in color of the pieces when they lock with the accumulated pieces • appearance of squares automatically filling in the game board when the game is over Tetris Holding v. Xio Interactive (D.C. N.J. 2012)

 Ruling was on Summary Judgment  No appeal and case settled. Next came a case about a clone of a “match three” game called Triple Town. Spry Fox v. LOLApps (W.D. Wash. 2012)

Spry Fox successfully released on Kindle.

Tried to hire developer LOLApps to port to Apple’s iOS in 2011.

Spry Fox v. LOLApps (W.D. Wash. 2012)

LOLApps releases Yeti Town for iOS.

Spry Fox v. LOLApps (W.D. Wash. 2012)

 Spry Fox claims Yeti Town infringes its copyright in Triple Town.

Spry Fox v. LOLApps (W.D. Wash. 2012)

 Both games are variations on a “match 3” game.

. 3 grass = a bush . 3 sapling = a tree . 3 bushes = a tree . 3 trees = a tent Spry Fox v. LOLApps (W.D. Wash. 2012)

 Infringement? 1. Different seasons 2. Different art 3. Mostly different characters/objects (or generic) Spry Fox v. LOLApps (W.D. Wash. 2012)

What may infringe? . The “object hierarchy” . The “field of play” Spry Fox v. LOLApps (W.D. Wash. 2012)

“object hierarchy is similar”

Triple Town Yeti Town Grass Sapling

Bush Tree

Tree Tent

Hut Cabin Spry Fox v. LOLApps (W.D. Wash. 2012)

“[T]he object hierarchy coupled with the depiction of the field of play comprise a setting and theme that is similar to Triple Town’s.”

Triple Town Yeti Town

MEADOW “not so different from” SNOWFIELD

BEARS “both wild creatures” YETI

PATCH “plausibly similar to” PLAIN Spry Fox v. LOLApps (W.D. Wash. 2012)

 Court finds sufficient “objective similarities in protected expression” to deny Motion to Dismiss.  No appeal and case settled. THE SITUATION AFTER TETRIS AND SPRY FOX (TRIPLE TOWN):

!"*/ % 0 $ !"#"$% "% 0 $

.--( +

)%*" ,-( (

! ! !

"$&!"$' $ "$&!"$' $

What if you copied all of a game’s rules and none of its expression? PART 5 The DaVinci Case After Triple Town came another case concerned with copyright in the rules of a game, but this time it was a board game. DaVinci Editrice v. Ziko Games (S.D. Tex. 2016)

Wild West‐themed role‐playing card game released by Italian publisher DaVinci in 2002. Bang!

Won multiple “best of” awards and became a top seller. DaVinci Editrice v. Ziko Games (S.D. Tex. 2016)

Released in U.S. by Legends Chinese publisher Yoka through their of the distributor Ziko Three Games. Kingdoms DaVinci Editrice v. Ziko Games (S.D. Tex. 2016)

 DaVinci claims Legends of the Three Kingdoms infringes copyright in Bang!

Legends Bang! of the Three Kingdoms Copyright Infringement?

. Virtually identical rules: character life points, roles, win conditions. . Completely different names, art, setting and other expression: Wild West v. 3rd Century China.

1 2 / 1 2 / Rules: Character and Role Cards

. Each player is randomly dealt one Character and one Role card. . Character: personality, number of life points and special attribute. . Role: Each role has a specific win condition. (Bang!‐ Sheriff, Deputy, Outlaw or Renegade)

)3!) !)!+ !%/ )!+ Rules: Attacking and Healing

. Games have functionally similar cards for weapons, missing shots, healing, and extending range of weapons.

1 2 / Rules: Range of Weapons

. In both games, ability to reach target determined by spaces between players around table.  Example: assume a weapon with 2 strength:

1 2 / Copyright Infringement?

. Nearly identical rules. . Completely different expression.

1 2 / 1 2 / DaVinci (S.D. Tex. 2014)

Infringement Claims Survive Motion to Dismiss.

. Court quotes extensively from Tetris and Spry Fox. . “The seven characters from [Legends] have capabilities and life points that are identical or substantially similar to those of the corresponding seven characters in Bang!” . “Player’s roles” and “interplay of the characters” are protectable expression. DaVinci (S.D. Tex. 2016)

But, court reverses itself on summary judgment: GAME RULES ARE NOT PROTECTABLE EXPRESSION.

. “Unlike a book or movie plot, the rules and procedures, including the winning conditions, that make up a card‐game system of play do not themselves produce the artistic or literary content that is the hallmark of protectable expression. See Boyden, 18 Geo. Mason L. Rev. at 466.” DaVinci (S.D. Tex. 2016)

But, court reverses itself on summary judgment: GAME RULES ARE NOT PROTECTABLE EXPRESSION.

. Unlike Legend of Zelda, Bang! falls into a category of games which “have plot progressions and characters who interact in ways that fall short of the expressive character interactions and plot progressions that are protected by copyright law.” DaVinci (S.D. Tex. 2016)

But, court reverses itself on summary judgment: GAME RULES ARE NOT PROTECTABLE EXPRESSION.

. “The effect of a character's special abilities and life points on a player's experience is not helpful [to Plaintiff’s argument] because copyright does not protect game rules, procedures, or winning conditions that create the environment for the expressive elements of the game.” Post Script:

FROM A BUG TO A FEATURE.

. Marketing copy for Legends of the Three Kingdoms: “Legends of the Three Kingdoms (a.k.a. San Guo Sha) is a card game based off the Chinese classical novel, Romance of the Three Kingdoms, and shares many rules with Bang!; the differences are as follows . . ” (Amazon.com 12/2017) A few conclusions on these cases. ARE THE RULES OF A GAME COPYRIGHTABLE?

!"*/ % 0 $ !"#"$% "% 0 $ 1$'2/% 4 5+ # "$)"6

.--( +

)%*" ,-( (

! ! !

"$&!"$' $ "$&!"$' $ $%7"$&!"$' $

% Conclusions on Tetris, Spry Fox and DaVinci

1. In Tetris and Spry Fox the courts struggled to separate game rules from expression. Each gave broad protection to the underlying mechanics or “rules” of a video game. 2. The DaVinci court initially followed Tetris and Spry Fox, but ultimately reversed itself and refused to protect the rules and character mechanics underlying the card game Bang! 3. DaVinci involved board games, not video games. It’s too early to tell whether DaVinci will be a corrective or just a bump on the road on the way to greater protection for game rules in video games. PART 6 Is There Some Other Way to Protect Game Rules? GAME ACHIEVEMENTS SYSTEM U.S. 7,887,419 B2

“Systems and method for providing a game achievements system where players are rewarded with game achievements based on mastering certain in‐game facets of the games they play.” United States Patent No.: US 7,887,419 B2 Issued: 2011 Patents on Game Rules

. Patents protect inventions.

. A process, machine or article of manufacture . . . that is new, useful, and non‐ obvious. 17 U.S.C. 101 et. seq. Patents on Game Rules

 But are patents on game mechanics still enforceable?

. Alice Corp. v. CLS Bank (U.S. 2014). Claims in a patent directed at an abstract idea must contain an `inventive concept' sufficient to `transform' the claimed abstract idea into a patent‐eligible application.

. In re Smith (Fed. Cir. 2016). Disallowing patent claims on a variant of Blackjack because the claims covered only the abstract idea of rules for playing a wagering game and used conventional steps of shuffling and dealing a standard deck of cards. PART 7 Why Might Video Game Rules be Receiving Greater Protection? Why Might Game Rules Be Receiving Greater Protection?

1. Mobile games are (relatively) cheap to make with huge potential upside. • Big hit may gross $1M/day. • Global market for development and sale. • More games = more copying and more cases. 2. The side‐by‐side comparisons look really bad. Glu Mobile v. Hothead Games, Complaint (N.D. Cal. 2014)

The games look very similar.

But: ‐ is what’s copied protectable expression? ‐ do we need to see what came before Deer Hunter? Why Might Game Rules Be Receiving Greater Protection?

1. Mobile games are (relatively) cheap to make with huge potential upside. • Big hit may gross $1M/day. • Global market for development and use. • More games = more copying. 2. The side‐by‐side comparisons look really bad. (But where’s the slide to the left?) 3. Part of larger trend towards stronger and longer copyright: 28, 42, 56, 75, 95 yrs. 4. Copyright, unlike patent, does not have to be novel or non‐obvious. • Only independently created and possess a “modicum of creativity.” 5. Courts are not playing the games. • “Neither Spry Fox nor 6Waves [LOLApps] suggested that the court should compare Triple Town and Yeti Town by actually playing them.” This is not new. % *

Came first in 1972. Subsequently released by Atari. Became first hit video game. Questions from the Roundtable In deciding game rule cases, do courts ever look to sports? Do Courts Look to Sports?

“The game of basketball,forexample,is not protected by copyright. Nat'l Basketball Ass'n, 105 F.3d at 847. Basketball has a loosely prescribed progression: teams trade offensive possessions over four quarters of play. Players have assigned roles, such as guard, forward, or center, and in those roles interact with each other. But ‘[u]nlike movies, plays, television programs, or operas, [basketball games] are competitive and have no underlying script.’"

DaVinci Editrice v. Ziko Games (S.D. Tex.2016) Any tips for developers seeking to avoid infringement? Game Developer Tips

1. Create your own characters and worlds. 2. If you want to borrow an idea, implement it in your own way. 3. Don’t try to leverage others’ brand names or trade dress. 4. Make yours look different. 5. Make up your own rules. What about copying the “world” of a game as opposed to its rules? Protecting Fictional Worlds

. Issue arises in user generated game levels and fan fiction. . Often implicates a relatively tricky question under copyright law: Does copyright protect individually unprotectable elements of a work when grouped together in such a way as to create a unique fictional world? . Context: Feist v. Rural Telephone Service (U.S. 1991). Selection, coordination, and arrangement of facts may be copyrightable, if sufficiently expressive. Protecting Fictional Worlds

Two cases to consider: 1. Micro Star v. Formgen (9th Cir. 1998)

2. Paramount Pictures Corp. v. Axanar Prods. (C.D. Cal. 2016/7) Fictional Worlds: Duke Nukem User Created Levels

 Micro Star tried to sell a CD full of user‐generated Duke Nukem levels. “The work that Micro Star infringes is the [Duke Nukem] story itself ‐a beefy commando type named Duke who wanders around post‐Apocalypse Los Angeles, shooting Pig Cops with a gun, lobbing hand grenades, searching for medkits and steroids, using a jetpack to leap over obstacles, blowing up gas tanks, avoiding radioactive slime. A copyright owner holds the right to create sequels . . . and the stories told in the [files which map the user created levels] are surely sequels, telling new (though somewhat repetitive) tales of Duke's fabulous adventures. A book about Duke Nukem would infringe for the same reason, even if it contained no pictures.” Micro Star v. Formgen (9th Cir. 1998) Fictional Worlds: Paramount v. Axanar

Paramount Pictures Corp. v. Axanar Prods. (C.D. Cal. 2016/7) Fictional Worlds: Paramount v. Axanar

Paramount Pictures Corp. v. Axanar Prods. (C.D. Cal. 2016/17)

AXANAR “FAN FICTION” MOVIE

• Defendants seek to release feature film set 21 years before first Captain Kirk episode of the original CBS Star Trek television series. • Movie to tell story of “Garth of Izar” during “the war between the Federation and Klingon Empire.” • Garth appears in one episode of the TV series and featured in 2003 novel copyrighted by Paramount. Garth was known for leading the Starfleet in the “Battle of Axanar.” • Sued by CBS (TV series rights) and Paramount (film rights and novels) for copyright infringement. Paramount v. Axanar ‐ 2016 Ruling on Defendants’ Motion to Dismiss

SCÈNES À FAIRE OR UNPROTECTABLE ELEMENTS? • Costumes • Geometric shapes (e.g., the Starfleet command insignia) • Words and short phrases (e.g., the names of planets or races) • Elements of works derived from nature, the public domain, or third party works (e.g., Vulcans' appearance with pointy ears or the concept of warp drive) • Klingon language • Mood or theme of "science fiction action adventure“ • Scènes à faire elements (e.g., staples of science fiction such as starships and medals on uniforms) • Characters identified by Plaintiffs (e.g., Garth of Izar, Soval, and Robau) Paramount v. Axanar ‐ 2016 Ruling on Defendants’ Motion to Dismiss

COURT: DEFENDANTS COPIED ‘STAR TREK WORLD’

. “When viewed in a vacuum, each of these elements may not individually be protectable by copyright.“ . “Even if each individual element were not protected by copyright, unprotectable elements "may gain some protection in combination with each other. . .” . “. . . Defendants copied each of these elements and combined them together in such a way that recreates the Star Trek world.” Paramount v. Axanar – 2017 Ruling on Summary Judgment

SUBSTANTIAL SIMILARITY? . “Garth of Izar, Klingons and Vulcans constitute characters which are protectable expression under D.C. Comics v. Towle (9th Cir. 2015) . Costumes, settings and “mood and theme” of the Star Trek works as a “military space drama,” at least as combined together, constitute protectable expression. . Court finds Defendants’ works objectively substantially similar (extrinsic test), noting that the Defendants had “achieved their goal of creating authentic Star Trek films and script.” . Issue of subjective substantial similarity (intrinsic test) left for jury, but case settled. Fictional Worlds

But keep in mind . . .

“Upon any work, and especially upon a play, a great number of patterns of increasing generality will fit equally well, as more and more of the incident is left out. The last may perhaps be no more than the most general statement of what the play is about, and at times might consist only of its title; but there is a point in this series of abstractions where they are no longer protected, since otherwise the playwright could prevent the use of his "ideas," to which, apart from their expression, his property is never extended.” Nichols v. Universal Pictures Corp. (2nd Cir. 1930) Even if game rules are being “over‐protected,” what’s the downside? The Cost of Overprotection

Thanks for Watching | What’s Next?

Participate

Join a Roundtable to Send feedback to discuss this Episode [email protected] Sources and Further Reading

Articles Copyright Law and Video Games: A Brief History of an Interactive Medium, Greg Lastowka, 2013, available at SSRN: http://ssrn.com/abstract=2321424 Games and Other Uncopyrightable Systems, Bruce Boyden, George Mason Law Review, Vol. 18, No. 2, 2011 Why Copyright Law Excludes Systems and Processes from the Scope of Its Protection, Pamela Samuelson, 85 TEX. L. REV. 1921, 1942‐44 (2007) Cases Atari v. Amusement World, 547 F. Supp. 222 (D. Md. 1982)(Asteroids v. Meteors) Atari v. North American Philips, 672 F.2d 607 (7th Cir. 1982)(PAC‐MAN v. K.C. Munchkin) DaVinci Editrice. v. Ziko Games, 2016 U.S. Dist. LEXIS 56188 (S.D. Tex. 2016)(Bang! v. Legends of the Three Kingdoms) Glu Mobile v. Hothead Games, Complaint for Copyright and Trade Dress Infringement, N. District of California, November 5, 2014 • Settled August, 2015 under terms requiring Hothead to make payments to Glu Sources and Further Reading

Cases (Cont.) Spry Fox, LLC v. LOLApps, Inc., 2012 U.S. Dist. LEXIS 153863 (W.D. Wash. 2012)(Triple Town v. Yeti Town) • Plaintiff Spry Fox survived LOLApps’ motion to dismiss for failure to state a claim on copyright claims (Rule 12(b)(6)). Case settled with transfer of all Yeti Town IP to Spry Fox. Tetris Holding v. XIO Interactive, 863 F.Supp.2d 394 (D.C. N.J. 2012)(Tetris v. Mino) • Court granted summary judgment in favor of Tetris Holding. Case proceeded no further. Whist Club v. Foster, 42 F.2d 782 (S.D.N.Y. 1929) Sources and Further Reading

History of Video Games “All Your Base are Belong to Us: How Fifty Years of Videogames Conquered Pop Culture” by Harold Goldberg (2011) “Blood, Sweat and Pixels” by Jason Schreier (2017) “Extra Lives: Why Video Games Matter” by Tom Bissell (2011) “Replay: The History of Video Games” by Tristan Donovan (2010) “The Tetris Effect” by Dan Ackerman (2016) “The Ultimate History of Video Games” by Steven L. Kent (2001)

• Additional facts from Wikipedia

 Thank you to all of our sources! “Are the Rules of a Video Game Now Copyrightable?” by Smithline Training Presented by: Todd Smithline Version 1.0 (2/18) Copyright © 2018 Smithline Training LLC. All rights reserved.

These materials are licensed on an individual user basis. Except for any tools we designate for sharing within your organization, please do not share the presentation or materials with anyone else. For more information: [email protected]

Smithline Training LLC 300 Montgomery Street, Suite 1000 San Francisco, California 94104 www.smithlinetraining.com