Judgement – Serious doubts about viability of AC TPM claims

46 On the evidence before me there is nothing to indicate whether the anti-cheat tools the respondent admits he interfered with (or circumvented) are access control technological protection measures as defined in s 10 of the Copyright Act. In order for the anti-cheat tools to come within that definition, it would be necessary that they, in the normal course of their operation, control access to copyright works. Based on Mr Anderson’s description of the anti-cheat tools, they do not control access to the work. I therefore accept that the respondent has, at least on the evidence before me, an arguable defence to the claims made against him under ss 116AN and 116AO of the Copyright Act.

69 My present view is that it would not be appropriate to grant the applicants any relief for contravention of either s 116AN or s 116AO of the Copyright Act. On the very limited evidence before me, I am not persuaded that the applicants have shown that they are entitled to any relief for contravention of either of those sections. I am not disposed to grant the applicants the declaratory or injunctive relief they seek in the absence of further evidence which it will be open to them to call at a trial of the proceeding confined to the issues arising under s 116AN and s 116AO of the Copyright Act and the quantification of the applicants’ claims for pecuniary relief.

Full judgement available at


Rockstar’s Secret Technological Protection Measures: Real Time Memory Analysis and Telemetrics

“GTA V Core includes two cheat detection and anti-cheat computer programs named “Real Time Memory Analysis” (RTMA) and “Telemetry”, which operate with Rockstar’s computer servers.”

‘Statement of Claim’, Submission in Take-Two Interactive Software Inc v Anderson, NSD1751/2018, 26 September 2018, [14].

Circumvention of Technological Protection Measures
(an extract from the affidavit of Christopher Anderson).
  1. The (AC) TPMs used by the applicant in the GTA V software are not novel, and in the absence of an authoritative description by the applicants and given paragraph 42 – 43 of their claim regarding what I “ought reasonably to have known”, it does not seem unreasonable for me to outline my understanding of their general operation and the interaction (if any) that Infamous had with each.
  2. The taxonomy of technological protection measures is somewhat malleable, and it is not my intent to assert the technological protection measures described in paragraphs 72.1 and 72.2 below are necessarily AC TPMs and TPMs (respectively) if the applicant’s opine otherwise.
  3. My descriptions of the various elements of what the applicants claim as TPM and AC TPM does not constitute an admittance that any elements so described were employed for the purpose of copyright protection and are therefore TPM or AC TPM in the legal sense.

    72.1. GTA V – Piracy prevention—AC TPM
    (a) Before playing GTA V in any fashion, the user must supply (either from a document within the physically purchased game, or its electronic equivalent if purchased online) a license key embodying proof of legitimate purchase. This token of purchase is then attached to a “Rockstar Socialclub” (“Socialclub”) account, in a fashion similar in concept to that employed by many online services when linking a mobile phone number to a user’s account.

The user is then required to identify and authenticate themselves through this Socialclub account each time they wish to play the game. Identification and authentication are achieved by confirming the email address and password which are associated with said Socialclub account, in a process that is so familiar to anyone of this age that I need not belabour this explanation.
(b) The process described in the above paragraph is so ubiquitous amongst producers of computer software as to embody the concept of AC TPM to enforce licensing in that industry.
(c) The efficacy of such an AC TPM as described is almost as low as it is ubiquitous, as GTA V in its single-player mode of operation does not strictly require any ongoing communication or actual information exchange with Rockstar’s electronic services (though such communication does occur), modified versions of the game (“cracked” copies, in the vernacular of underground software piracy) that do not require the user to authenticate themselves to play the game, therefore negating the requirement for purchase.
(d) The situation described in the paragraph above wherein access control has been circumvented is also of such prevalence in the computer software industry as to be both a textbook description of “software piracy” and “circumvention of an access control technological protection measure.
(e) Infamous did not circumvent this process. Infamous did not negate the requirement of a user to possess an authentic and valid license key or otherwise enable or encourage software piracy.

72.2. GTA V – Strengthening piracy prevention—TPM
(a) For the AC TPM described in 72.1(a) above to have any value, it must itself be protected by one or more TPMs. Rockstar relies on “ProtectIT” and “TransformIT” by American company “Arxan Technologies” (known as “Digital Ai” since 2020) who specialise in DRM and TPM technology. These products are extremely effective at protecting software from unauthorised modifications and preventing reverse engineering of key areas of software. From a technical perspective, they use several techniques including:
i. automatically injecting the software with self-protective mechanisms (“guards”) that make it difficult to tamper with the software and to maliciously modify it; and
ii. keep portions of the software encrypted when not being actively used; and
iii. obfuscate portions of the software to make them difficult to understand (analogous to what contract lawyers do to the English language).
(b) These products are also used by other big-budget gaming software including “Call of Duty 4” by Activision, and by other software for purposes other than acting as a TPM. However, the above paragraph is a reasonable description of how TPM is commonly implemented by the software industry, though the specific products and techniques may vary.
(c) Infamous did not interfere or circumvent any measures such as those described in paragraph 72.2(a) above. Infamous did not negate the requirement of a user to possess an authentic and valid license key or otherwise enable or encourage software piracy.

72.3. GTA V’s Online Mode
(a) In addition to all the technical protections described in paragraph 70 above, playing the Online Mode of GTA V involves – at least conceptually – additional TPMs and AC TPMs (here-in called “The Online AC TMP”), as well as various measures to detect cheating (commonly referred to as “anti-cheat”). The methodology and technology involved with anti-cheat are similar and, in some cases, ostensibly identical to the technologies associated with TPM as described in paragraph 72.2(a) above.

72.4. GTA V’s Online Mode – AC TPM
(a) The role of The Online AC TMP is to ensure enforcement of decisions made by Rockstar (embodied by programs running on computers controlled by the applicants, and by individual human operators in their employee) as to whether users are permitted access to the service provided by GTA V’s Online Mode.
(b) In terms of technical implementation, the AC TPM described herein could be considered:
i. a part of; or
ii. to share many parts with; or
iii. to be another facet of; or
iv. to be another mode of operation of
the AC TPM described in paragraph 72.1(a) above.
(c) In contrast to the mode of operation attributed to the AC TPM described in paragraph 72.1(a) above, The Online AC TMP is closer to what we might consider a standard AC TPM such as would control access to services such as Netflix or other online services with dynamic content.
(d) The key distinction between this mode of operation, and the AC TPM described in paragraph 72.1(a) above being that GTA V’s Online Mode is an online service being continually provided via the Internet (you cannot play GTA V’s Online Mode without continuous internet access), whereas GTA V’s Story Mode can be played without internet access other than that required to establish and periodically re-authenticate your credentials.
(e) Infamous did not interfere or circumvent any of the measures described in paragraphs 72.4(b) – (d) above.
(f) Infamous did not encourage or allow users to access GTA V’s Online Mode if such access had been rescinded by Rockstar.
(g) Infamous did not circumvent any access control mechanism comprising an AC TPM, or any other access control mechanism.

72.5. GTA V’s Online Mode – Anti Cheat
(a) A user who is caught cheating faces the possibility of temporary or permanent loss of access to GTA V’s Online Mode.
(b) Various “anti-cheat” mechanisms are utilised by GTA V’s Online Mode to collect information that aid in assessing the probability that a user is cheating. The applicants have cited Telemetry and RTMA as the relevant mechanisms.

72.6. GTA V’s Online Mode – Anti Cheat (Telemetry)
(a) The usage of the term “telemetry” is comparable to other common forms of telemetry such as may be found in a Formula 1 racing vehicle or modern passenger airline, in that it consists of a constant stream detailing every piece of measurable information.

(b) There are presently more than 400 different types of telemetric information collected by GTA V’s Online Mode.
(c) It is my considered technical opinion that it is unlikely that more than around 20 (or 5 percent) of these are actively employed as “anti-cheat” mechanisms, and almost inconceivable that more than 40 (or 10 percent) were so employed.
(d) Infamous interfered with less than 10 (or 2.5%) of the 400 types of telemetry used by GTA V’s Online Mode. That – in conjunction with the applicants claim they were unable to detect Infamous – is the basis for paragraph 72.6(c) above.

72.7. GTA V’s Online Mode – Anti Cheat (Real Time Memory Analysis)
(a) Real Time Memory Analysis (“RTMA”) is a method by which the presence or absence of certain distinctive sequences of characters (“phrases”) are present at specific locations. A reasonable non-technological analogy would be the act of determining if a bible were of a particular translation by comparing words 17 to 26 in the 3rd book to see if they matched a certain phrase.

(b) This technique is used both to check a handful (usually around 4 at any given time) of locations within the GTA V executable currently running from memory, generally to confirm that no tampering has occurred.

(c) The same technique is also used to check all memory accessible to GTA V – including the contents of programs other than those licensed by the applicants – for phrases known to be associated with specific mod menus such as Infamous. These phrases are obtained by the applicants by reverse engineering and/or copying small sequences (or phrases) sufficient to uniquely identify the mod menu.

(d) Positive identification of a known mod-menu does not necessarily result in the user running such software having their GTA V Online Service suspended. In the period surrounding and following the legal action taken against other persons associated with Infamous, it was observed that at least 1 other mod menu that did not block the RTMA phrases used to identify it, did not have its users banned despite being easily identifiable by the applicant for several months.

(e) From 3:40am 22 March 2018 AEDT to 1:29am 31 March 2018 AEDT – 9 days – an error in the applicant’s usage of RTMA caused every legitimate user who played GTA V’s Online Mode during that time to be mistakenly identified as running software which had tampered with a section of memory associated with GTA V commonly modified by cheating users. While this did cause a not unsubstantial number of people to have their access to GTA V’s Online Mode suspended, the number of people affected was small enough that it took 9 days for the applicants to recognise that this was a legitimate error on their part. If RTMA was indeed used to automatically suspend access to GTA V’s Online Mode, then there would simply have been no online players left, a situation which would not have gone unnoticed for 9 days.

(f) From approximately 1 January 2018, Infamous did interfere with the RTMA process as to do otherwise would have jeopardised the ability of Infamous to function. We did so only to prevent GTA V’s Online Mode from reading the contents of memory created by and containing the intellectual property of, Infamous.

Take-Two Interactive Software Inc v Christopher Anderson

Legal Take-Two

Speed Kills

Just a reminder that CV-19 isn’t the only danger out there, we should all watch out for Abstract Mode‘s dangerous drifting.

Here’s an old YouTube video made in late 2018 to remind everyone: sometimes modding is just modding, and ‘aint nothing wrong with that.


An Anonymous Apology from a Former GTAV Mod Menu Developer

Hello everyone,

I was a bad gta player.
I actually was more than just that.
I started as a bad player, though.

I had always been a computer enthusiast.
Relatives and friends were always asking me for help when something was wrong with their computers at least since I was 11 years old.
I was helping people to upgrade from windows 7 to windows 8 (or downgrade, you know…) while still using a Windows XP computer as my main.

Some years ago, when I was 15, I went from a 2007 Pentium 4 desktop computer to an Intel i5+Nvidia GTX one.

That’s how it all started.
It was mind-blowing.

Now I was able to play real 3d games instead of those crappy 2d flash games that we have all played online at least once.

I still remember that I felt so guilty at first because my parents had already spent a lot of money for my computer and I didn’t want to ask them more to buy games

At the same time I didn’t want to crack anything, both for the risk of malware and the inability to play cracked multiplayer games.

So I ended up buying, during a steam sale, GTA IV+SA for a very low price, even if I was not that happy considering that I could have run GTA V, which was already out.

Months passed and I couldn’t resist more, so I grabbed my parent’s credit card and I bought GTA V.

I bought GTA V.
Remove that action from my life and I would be happy today.
And I would have been happy yesterday and every day for the last few years.

At first it felt gorgeous.
That graphics, oh my gosh.
It was unbelievable for someone like me, who was dreaming to play Minecraft a few weeks before but was unable to do so because his windows xp machine didn’t have a graphic card.

Then my hacker (cracker, or whatever you want to call it) soul started to be interested into this game.

After playing online many hours I started to ask myself: “Why am I always being trolled by those modders? They never get banned…maybe I should join the other side to have more fun”.

Imitating others sometimes is not a bad idea, especially if you then become worse than them.

At that time I was barely a script kiddie.
But I was already very curious about everything related to technology.

So I started learning.
I realized that to make mods everyone was using C++…I knew it a little bit because I had red a book about it when I was 12 but I had to study it from scratch again…and so I did.

Then I found tools like cheat engine, ida pro, binary ninja, reclass…so many pieces of software that I considered amazing (and I still do actually, it all depends on how you use them).

With great power comes great responsibility.

Yes, that sounds correct: If you ask a 15-year-old to kill a man in real life he would probably say no.
But if you ask that same young guy if coding a .dll file after school and injecting it by using the load library method into GTA5.exe to get some cool cheats to be better than other players in gta online, he may not realize the consequences of his actions (or extremely underestimate them).

And that’s exactly what happened to me.
I started coding a mod menu for fun, just to experiment stuff.
Then I sent it to some friends for free.
They were interested.
I felt cool because in my crew I was considered a hacker and a gta geek.

Ì was spending 8-10 hours a day on my barely working mod menu, sacrificing my school marks.
After some months I started to realize that my software was getting good (even if now I can definitely say that it still was crap, code-wise and purpose-wise).

So again I was hyped and I wanted to become more famous.
What did I do? Well I released my mod menu on a popular forum where many people upload and talk about free cheats.

I suddenly started to get attention.
Today I can say for sure that the huge attention I was getting came because it was just the right software released at the right moment…combined with way too much griefing features.

After some months someone gave me the idea to start selling the mod menu (to reduce banwave rates) and I accepted, even if I didn’t know how to do it but for that someone offered me his help.

Sales were getting better and better every day (if we ignore the days when the website was online thank to DDoS guys – damn you, you should have DDoS-ed us more often to keep us offline every day).
Anyway, it was fun until it lasted.
I was also very proud of me because not many people at my age were making so much money.

What did I do with those money? Well, I spent a large part of those buying personal stuff. Another big part was spent by helping people. Even if I was a f*cking gta griefer I helped a friend to pay his bills and I bought some phones for friends who could not afford new ones although they really needed them.
Then in the last part we have money spent to pay the server and the website, various software needed for the job and other random stuff that were inevitable.
I was not a bud guy in real life, I just liked to blow up people when I was playing GTA, even if I gotta say that sometimes I was very generous with other players and I used to make them really happy.

I would have happily skipped this money section, but I want to make sure that you understood one thing: I made a lot of money coding and selling a mod menu, but I am going to pay A LOT MORE (money, health, social life, reputation and time), now that Take Two is after me.

So if you are a little guy thinking about coding a small menu to make money, even by keeping it private not to get caught do me a favor: please stop now.
Really, stop.
And yes, even if you live in Antarctica.
It’s not gonna work.

You probably can’t understand how bad I felt in these past few years.
Every day I wake up and I think about Take Two.
When I am not lucky I think about Take Two even when I am sleeping.
When I get an email notification I am scared to open it since it may be something from lawyers.
When after a week it’s Saturday I thank God (even if I don’t believe in it) because I know that nothing bad can happens during the weekend.
Committing suicide? Already considered. It can’t work because it would only make my parents’ lives even worse than now.
And they are not responsible for this. They can barely use a smartphone and they didn’t even buy me GTA V.

I see no way this story could possibly end well.
And I have been thinking about it for a few years by now.

In the best possible scenario my life will be ruined and my parents’ lives too. That’s it.

Sometimes I can’t understand how this all happened since I am now so much different from that 15/16/17 years old guy coding mods for fun and profit.

But it happened and so no big deal.

“This [is] … about some people who were punished entirely too much for what they did. They wanted to have a good time, but they were like children playing in the street; they could see one after another of them being killed—run over, maimed, destroyed—but they continued to play anyhow. We really all were very happy for a while, sitting around not toiling but just bullshitting and playing, but it was for such a terrible brief time, and then the punishment was beyond belief: even when we could see it, we could not believe it…. For a while I myself was one of these children playing in the street; I was, like the rest of them, trying to play instead of being grown up, and I was punished.”

Philip K. Dick (In Memoriam, A Scanner Darkly)

If you have been teleported somewhere in the map, It may have been my fault.
If you have been teleported to an apartment, after the first method teleport had been patched, it may have been my fault.
Other stuff that I am not proud of include: remote ranking, remote (and self) money to the bank, money drop, a wild variety of cages, instant and delayed crash methods, blamed explosions, freezed characters, remote bounties, removed weapons and more

For all of that I am here to apologise.
It was childish and I will never be proud of that as a (wannabe) software engineer.
But at least I did that when I was young.

What sometimes makes me feel weird and sad at the same time is that this could have never happened if Take Two had designed gta online a bit better.
Something like the ability to add unlimited money just by sending some requests from the client to the server (which doesn’t verify those request at all) should have never been possible.
“Never trust the client” is the first rule that every online developer should be well aware of.
If you go to a real bank to deposit $10 million cash money, they will probably check and count them all before adding 10 million dollars to your bank account (chances are those money could be much less, if not 0).
Everyone keeps saying me that if you see an open door you are not supposed to get into the apartment to steal everything.
That’s correct I guess but I truly believe it doesn’t work in the gta context where most players are kids and also you don’t steal anything real (or you can’t directly see it).

If you are still reading, thanks for reading my post till the end.
Again I apologise to all the people who have been damaged by my software.
I also want to apologise to Take Two and GTA’s developers: even if you could have been smarter and maybe a bit more kind I know that in the end it’s my fault.

What I am trying to achieve by writing this? I actually don’t know.
I am not hoping to improve my current situation, at least on a financial level.
Writing this was surely helpful as an outlet…it’s getting harder every day but I learn to deal with it…kind of.

I will be very happy to answer to any questions you have (if possible).

One last thing: if you managed to figure out who I am (should not be very hard) please don’t write it down here in the next posts… really it’s not a good idea.

Thank you all

Edited August 10 by WhiteHackGuy


[ed: Thank-you Gena Feist for helping yet another 16 year-old discover the joys of life-long therapy. You wrote him a letter, and he took his site down immediately — but that just wasn’t good enough for you. This is (at least) the 3rd male minor you have commenced legal action against [with relation to GTAV], one can only speculate about your own formative experiences at that age. “.. best served cold” ?]