Riot Games vs. NetEase

Claim No.
IL-2022-000094
IN THE HIGH COURT OF JUSTICE
BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES
INTELLECTUAL PROPERTY LIST (ChD)
B E T W E E N:
(1) RIOT GAMES, INC.

(A company incorporated in the state of Delaware,
USA)
(2) RIOT GAMES LIMITED

(A company incorporated in Ireland)
Claimants
- and -
(1) NETEASE, INC.

(A company incorporated in the Cayman Islands)
(2) UK NETEASE INTERACTIVE ENTERTAINMENT

LIMITED
(3) HONG KONG NETEASE INTERACTIVE

ENTERTAINMENT LIMITED
(A company incorporated in Hong Kong)
(4) NETEASE ENTERTAINMENT LIMITED

(5) NETEASE INTERACTIVE ENTERTAINMENT

PTE LTD
(A company incorporated in Singapore)
Defendants
PARTICULARS OF CLAIM
Valorant and Hyper Front
1. This case concerns two video games known as Valorant and Hyper
Front.
2. Valorant is a free-to-play, first-person-shooter, video game which was

developed initially for play on computers running the Microsoft
Windows operating system.
3. In Valorant (amongst other things)
(1) Teams of 5 players compete against one another in matches

(Matches) in fictional, computer-generated environments
(Maps).
(2) The game is set in a near-future sci-fi world.
(3) Players can select one of a number of characters (Agents) to

play for each Match.
(4) Each Valorant Agent has particular characteristics (Agent

Characteristics) which include having a particular
appearance (Agent Appearance) and a set of special abilities
(Agent Abilities) and having a particular role.
(5) There are several different types of games which are available
for play (Game Modes) comprising (a) a range of Bomb
Defusal games (in which a bomb is planted and must be
defused) and (b) a range of Deathmatch games (fights in which
the winner is determined by number of kills).
(6) In Bomb Defusal games there are 2 sides: attackers are tasked
with planting a bomb and defenders are tasked with preventing
the planting of the bomb or defusing it if it has already been
planted.
(7) At the start of the Unrated, Competitive and Replication

Bomb Defusal games there is a time (Buy Phase) during
which players can purchase weapons (Weapons), equipment
(such as shields) and Agent Abilities before the combat starts.
The amount of money a player has during the Buy Phase
depends on how well they and their team performed in the
previous round. In the Buy Phase players are separated from the
main field of combat by a translucent barrier. A timer ticks down
during this phase. When it ends the barrier dissolves, and the
players can move forward into battle. Halfway through the
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match the teams swap sides and attackers become defenders and
vice-versa.
(8) In the Spike Rush Bomb Defusal game players start each
round with the same randomly allocated Weapon.
(9) In Deathmatch games, the aim is to kill as many other players

as possible. There are 2 ways in which the game can end: (a) a
player reaches a required number of kills or (b) a certain time
has passed. Players are dropped in random positions on the Map.
There is no formal Buy Phase, however, players can change their
Weapons by opening a buy menu.
(10) Players can select from a range of Weapons of particular designs

(Weapon Designs). The Weapons have particular magazine
capacities (Magazine Capacities) and rates of fire (Fire
Rates). Each type of Weapon has a particular fire power such
as the range at which it can operate and the extent of harm it
can cause (Damage Output). Weapons can have different
colour schemes and designs applied to them (Weapon Skins)
and can have a range of decorative items in the form of charms
attached to the side of the weapon (Gunbuddies).
(11) There is a graphical user interface (GUI) which, in addition to

allowing match play, allows players to access other features of
and functions in the game during the pre-match, match and post-
match phases of the game.
(12) The game has particular music and other sound effects.
4. The first claimant started development of Valorant in 2014. In or about

October 2019 it revealed an early version of Valorant to the public under
the code name Project A. On 7 April 2020, Valorant entered a closed
beta phase. On 2 June 2020 Valorant was released and made available
for play worldwide on the Microsoft Windows operating system. It has
been commercially successful and has won and been nominated for
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industry awards (documents evidencing such nominations and awards
are included in the claimants Initial Disclosure).
5. On 2 June 2021, the first claimant announced that it was developing a

version of Valorant for mobile devices.
6. Hyper Front is also a free-to-play, first-person-shooter video game

involving teams of 5 players set in a near-future sci-fi world. It has been
developed and published by the defendants (collectively NetEase)
pursuant to a common design between them.
7. Hyper Front is available for download in the United Kingdom (and in

other jurisdictions of the world) from the Google Play Store (for mobile
devices running the Android operating system) and was available from
the Apple App Store (for mobile devices running the iOS operating
system) until on or about 30 September 2022.
8. As appears more particularly below and in the annexes accompanying

these particulars of claim (the Annexes)
(1) Hyper Front is a copy of substantial parts of Valorant.
(2) Having regard to the extensive similarities between Hyper Front

and Valorant and the timing of the development and release of
Hyper Front and the other matters identified below, it is to be
inferred (and the claimants will contend) that NetEase intended
to produce a game which would offer players essentially the
same game experience, look and feel as Valorant but on a mobile
device.
(3) For example, and without limitation to the claimants case, each
of the aspects of Valorant identified in paragraphs 3(1) to 3(10)
above is present in Hyper Front and substantial parts of the
aspects identified in paragraphs 3(11) and 3(12) above have been
copied in Hyper Front (characters in Hyper Front being known
as Heroes rather than Agents).
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(4) By releasing Hyper Front for download and play in the United
Kingdom NetEase has infringed the first claimants copyrights
which subsist in Valorant.
9. The development and release history of Hyper Front is as follows
(1) Development started in or about March 2020 (after the first

claimants release of Project A referred to above).
(2) An open beta of Hyper Front was published in about August

2021 in Malaysia and the Philippines only under the name
Project M). The claimants will refer to the similarity between
the name Project M and the name Project A in support of
their inference of copying by NetEase.
(3) A closed beta of Hyper Front was subsequently made available

in Canada, Thailand, Japan and Brazil.
(4) On 20 January 2022 Hyper Front was released for download in

Singapore, Malaysia, Thailand and the Philippines.
(5) Following complaints by the first claimant that Hyper Front was
a copy of Valorant, NetEase made modifications to Hyper Front.
10. Valorant was promoted as having amongst other things sharp

gunplay (see https://playvalorant.com/en-gb/a relevant screen shot
will be included in the claimants Initial Disclosure). This is an unusual
term. In a promotional video for Project M accessible at (for example)
https://www.youtube.com/watch?v=RZxD6ShWYNo (a relevant screen
shot will be included in Initial Disclosure), NetEase promoted Hyper
Front as also having sharp gunplay. The claimants will rely upon this
similarity as further evidence in support of their inference of copying by
NetEase.
11. Hyper Front in a modified form was made available for download in the
United Kingdom on Google Play Store from on or about 20 July 2022
and on the Apple App Store from on or about 20 July 2022.
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Defined terms and scope of this claim
12. In these particulars of claim
(1) CDPA means the Copyright, Designs and Patents Act 1988.
(2) Initial Disclosure means the initial disclosure of documents

accompanying these particulars of claim.
(3) In the following, Hyper Front means (except where the

contrary appears) the version of the game made available for
download in the United Kingdom from on or about 20 July 2022.
References to Earlier Versions of Hyper Front are to versions
of the game released before then.
(4) The claimants complaint of copyright infringement concerns

infringement of copyright by NetEase in the United Kingdom
arising from the making of Hyper Front available for download
and play in the United Kingdom from Google Play Store and the
Apple App Store.
(5) The claimants do not complain of infringement of copyright in

the United Kingdom in relation to Earlier Versions of Hyper
Front which were not published or made available in the United
Kingdom but will refer to similarities between Earlier Versions
of Hyper Front and Valorant in support of the inference that
NetEase copied Valorant in creating Hyper Front.
The claimants and the creation of Valorant
13. The first claimant is a company incorporated in Delaware, United

States of America. Its business includes the development and
publication of video games.
14. As more particularly set out below, Valorant comprises works in which
copyright subsists. The first claimant is the owner of such copyrights.
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15. Valorant was first published in the United States of America and,
accordingly, pursuant to section 155 CDPA it qualifies for copyright
protection.
16. Valorant was created by numerous employees of and contractors to the

first claimant (the Developers). For reasons of proportionality, the
claimants do not here identify the Developers by name.
17. As regards the Developers
(1) When they created the aspects of Valorant for which they were
responsible, the Developers who were employees were acting in
the course of their employment by the first claimant under a
contract of service.
(2) The Developers who were contractors to the first claimant were
working pursuant to contracts with the first claimant that
vested the copyright in any works relating to Valorant that they
created in the first claimant.
18. The second claimant is Irish company no. 483483 and is a subsidiary of
the first claimant.
19. The second claimant has an exclusive licence from the first claimant to
publish, use and sell all copyright material concerning Valorant in the
United Kingdom. Documents evidencing the exclusive licence (redacted
to remove irrelevant confidential information) will be provided in the
claimants Initial Disclosure.
20. Accordingly, having regard to section 101 CDPA, the second claimant
has the same rights and remedies arising under the CDPA against all
the defendants as the first claimant.
The defendants: NetEase
21. The first defendant is a company registered in the Cayman Islands. It

is the parent company of the NetEase group of companies which
includes the second to fifth defendants. A relevant screen shot detailing
7
the first defendant’s registration information is included in the
claimants’ Initial Disclosure.
22. The first defendant is named on the footer of both the NetEase games
and Hyper Front websites (www.neteasegames.com and www.hyper-
front.com—the “NetEase Website” and the “Hyper Front website”
respectively). A press release dated 19 July 2022 announcing the launch
of Hyper Front in (amongst other places) Europe states that NetEase
Games is the online games division of the first defendant. Screen shots
from the websites identified above and a copy of the press release
referred to will be included in the claimants’ Initial Disclosure.
23. The second defendant is UK company no. 12274781 incorporated on 22

October 2019. Its “nature of business” is “Publishing of computer
games”. The NetEase Website states in relation to the second defendant
that “NetEase Games UK Office was established in 2019, focussing on
business development and global production, aiming to bring more
vitality into NetEase Games’ global business”. Relevant screen shots will
be included in Initial Disclosure.
24. The third defendant is a company registered in Hong Kong. It is the

entity listed in the privacy policy for Hyper Front when the game is
installed and viewed on a mobile device. Relevant screen shots will be
included in Initial Disclosure.
25. The fourth defendant is also a company registered in Hong Kong. It is

listed in the privacy policy available on the Hyper Front page of the
Apple App Store and Google Play Store. Relevant screen shots will be
included in Initial Disclosure.
26. The fifth defendant is a company registered in Singapore. It is the

entity listed in the privacy policy and user agreement on the Hyper
Front Website. Relevant screen shots will be included in Initial
Disclosure.
27. Having regard to the foregoing, the claimants infer and will contend
that each of the defendants has acted pursuant to a common design with
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the other defendants to develop Hyper Front and to publish Hyper
Front in the United Kingdom on Google Play Store and the Apple App
Store.
28. Accordingly, each of the defendants is jointly and severally liable to the
claimants in respect of all acts of copyright infringement complained of
in these particulars of claim.
Copyright subsisting in Valorant
29. Valorant comprises the following works which are the subject of
copyright subsisting under the provisions of Part I CDPA (collectively
the Valorant Works)
(1) The works consisting of all the individual frames displayed on

screen when Valorant is played (the Static Graphic Works).
(2) The works comprising the movements displayed on a players

screen caused by the rapid display of a sequence of Static
Graphic Works (Moving Graphic Works).
(3) The works comprising all the visual aspects of the game (the
Visual Works) that is to say all aspects of the game that a
player may see during the play of the game including the Static
Graphic Works and the Moving Graphic Works.
(4) The works comprising the music and sound effects of the game
(Sound Effects).
(5) The work comprising the game of Valorant as a whole, that is to

say all aspects of the game that a player may see, hear or interact
with including the way the game is played, the nature of the
game play, the Visual Works and the Sound Effects (the
Valorant Game).
Further particulars of the aspects of the Valorant Works relied upon are
provided below and in the Annexes.
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30. Each of the Valorant Works is an original work and the creation of each
Valorant Work involved substantial intellectual creativity and required
the expenditure of substantial skill and labour on the part of the
Developers.
31. Each of the Valorant Works has been recorded within the meaning of
section 3(2) CDPA. Such recording consisted at least of storing the game
in electronic form allowing it to be played online by users.
32. Each of the Valorant Works is a work in which copyright subsists

pursuant to section 1 CDPA. In particular
(1) Having regard to the retained case law of the CJEU and other
retained EU law and the provisions of the Berne Convention,
section 1(1)(a) CDPA must be interpreted so that each of the
Valorant Works is of a kind or description in which copyright
may subsist.
(2) The Valorant Works are literary, dramatic, musical and artistic
works (within the meaning of section 1(1)(a) CDPA) as set out
below.
(3) If, contrary to sub-paragraph (2) above, any of the Valorant

Works is not a literary, dramatic, musical or artistic work, such
work is nevertheless a work in which copyright subsists
pursuant to sub-sections 1(1) and 1(1)(a) CDPA (hereafter
Other Copyright Work).
33. With regard to the Valorant Works
(1) The Static Graphic Works are each artistic works within the
meaning of section 4 CDPA.
(2) The Moving Graphic Works are each artistic works within the
meaning of section 4 CDPA and further or alternatively
dramatic works and further or alternatively Other Copyright
Works.
10
(3) The Visual Works are each artistic works within the meaning of
section 4 CDPA and further or alternatively dramatic works and
further or alternatively Other Copyright Works.
(4) The Sound Effects are musical works within the meaning of
section 1(1)(a) CDPA and where they involve speech are also
literary works within the meaning of section 1(1)(a) CDPA.
(5) The Valorant Game as a whole is (a) an original dramatic and

artistic work (b) further or alternatively an original literary and
artistic work (c) further or alternatively an original literary,
dramatic and artistic work (d) further or alternatively an
original literary, dramatic, artistic and musical work and (e)
further or alternatively it is an Other Copyright Work in which
copyright may subsist.
The Valorant Works relied upon and the aspects of Hyper Front
complained of
34. Hyper Front is a copy of each the Valorant Works within the meaning
of section 17 CDPA as more particularly set out below and the Annexes.
The Valorant Game Work
35. Hyper Front is a copy of substantial parts of the Valorant Game. In

particular, the following parts of Hyper Front have been copied from the
Valoran Game (further particulars of the aspects of Valorant Game
relied upon are set out in the Annexes)
(1) The overall type and design of the game: see Annex 1.
(2) The Game Modes: see Annex 1.
(3) The characteristics of the Heroes in Hyper Front are copies of

substantial parts of Valorants Agent Characteristics see:
(a) the comparisons of the Agents and the Heroes in Annexes

1 and 2.
11
(b) the comparisons of the abilities of the Agents and the
Heroes in Annexes 1 and 3.
(4) The Maps: see Annexes 1 and 4.
(5) The Weapons including (a) the Weapon Designs (b) the Magazine
Capacities (c) the Fire Rate (d) the Damage Output (e) the
Weapon Skins and (f) the Gunbuddies: see Annexes 1, 5, 6, 8, 9,
10 and 11.
(6) The practice range: see Annexes 1 and 8.
(7) The GUI: see Annexes 1 and 7 and the other annexes which
concern the visual appearance of the games.
(8) The Sound Effects: see paragraphs 39 and 40 below and Annex
1.
36. In relation to Weapons, an important part of the design of a modern

computer game of the kind in issue is the choice of weapons, their
capacity and destructive effect and the ability of players to withstand
the effects of the weapons. Such affects the balance of play of the game
and as a result the way the game is played. Hyper Front has copied
these elements from Valorant, with the result that the two games play
in a highly similar way.
Static Graphic Works
37. The Static Graphic Works relied upon, and the similarities complained
of, are as follows
(1) The static images comprising the Agent Appearances and the
similarities identified in Annexes 1 and 2.
(2) The static images comprising the appearance of the Agent

Abilities and the similarities identified in Annexes 1 and 3.
(3) The static images comprising the appearance of the Maps and
the similarities identified in Annexes 1 and 4.
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(4) The static images and the similarities concerning Weapons as
follows
(a) the static images showing Weapon Designs as set out in

Annexes 1 and 11;
(b) the static images showing the Weapon Skins as set out in
Annexes 1 and 5;
(c) the static images showing the Gunbuddies as set out in

Annexes 1 and 6;
(d) the static images showing gun aiming and firing and the
practice range as set out in Annexes 1 and 8.
(5) The static images comprising the GUI consisting of the images
relied upon and similarities identified in sub-paragraphs (1) to
(4) above and the further images and similarities identified in
Annex 7.
Moving Graphic Works
38. The Moving Graphic Works relied upon and the similarities complained
of are the Moving Graphic Works relating to Agent Characteristics
including Agent Abilities and the similarities identified in Annexes 1
and 3.
The Sound Effects
39. The Sound Effects relied upon are as follows
(1) The background music played during the matchmaking lobby of

Valorant.
(2) The overall collection of music and other sounds contained in

Valorant (such as the sounds weapons make and the tone of the
in-game voice announcements).
40. The claimants complain of the following
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(1) The background music played during the matchmaking lobby of
Hyper Front is a copy of a substantial part of the background
music played during the matchmaking lobby of Valorant.
(2) The sound effects used in Hyper Front (consisting of the overall
collection of music and other sounds contained in the game) are
a copy of Valorants Sound Effects such that players of Hyper
Front have substantially the same auditory experience as
players of Valorant.
Infringement of copyright in the Valorant Works
41. By making Hyper Front available for download by members of the

public in the United Kingdom from Google Play Store and the Apple
App Store, the defendants have infringed the copyright which subsists
in the Valorant Works by
(1) issuing Hyper Front to the public contrary to sections 16(1)(b)

and 18 CDPA;
(2) performing Hyper Front in public contrary to sections 16(1)(c)

and 19 CDPA;
(3) communicating Hyper Front to the public contrary to sections

16(1)(b) and 20 CDPA;
(4) authorising and procuring and acting pursuant to a common

design with players of Hyper Front in the United Kingdom to
download and play the game, whereby copies of the Valorant
Works are made by such players contrary to sections 16(1)(a) and
17 CDPA.
42. Insofar as the defendants have servers hosting Hyper Front located in
the United Kingdom, the defendants have made copies of substantial
parts of the Valorant Works by hosting Hyper Front on such servers
contrary to sections 16(1)(a) and 17 CDPA.
43. The claimants Initial Disclosure will include screen shots taken in the
United Kingdom showing Hyper Front being made available for
14
download and play by persons in the United Kingdom from the Google
Play Store and the Apple App Store.
Remedies
44. Unless restrained by the court the defendants threaten and intend to
continue to infringe the claimants copyrights subsisting in Valorant in
the manner complained of above whereby the claimants have suffered
and will continue to suffer damage.
45. The defendants have acted in flagrant disregard of the claimants

rights: having regard to the similarities complained of and the timing
of the release of Hyper Front it is to be inferred that the defendants set
out to produce a look alike and play alike mobile version of Valorant
knowing that the claimants were planning to produce their own mobile
version of Valorant. The defendants must have appreciated that such
would (1) give them an advantage in obtaining players for Hyper Front
and (2) would damage the uptake of a future mobile version of Valorant.
46. In the circumstances, the claimants are entitled to and seek and award
of additional damages pursuant to section 97(2) CDPA.
47. The claimants are entitled to interest on all sums found due to them
pursuant to section 35A of the Senior Courts Act 1981 and in the
inherent jurisdiction of the court.
AND THE CLAIMANTS CLAIM
(1) An injunction restraining each of the defendants from infringing the

copyrights which subsist in the claimants game Valorant.
(2) An inquiry as to damages for infringement of copyright (including

damages pursuant to the Intellectual Property (Enforcement, etc.)
Regulations 2006) and additional damages pursuant to section 97(2)
CDPA or, at the claimants option, an account of profits.
(3) An order for payment to the claimants of all sums found due upon
taking such inquiry or account together with interest thereon pursuant
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to section 35A of the Senior Courts Act 1981 or in the inherent
jurisdiction of the court.
(4) An order that, at the claimants’ option and at the expense of the
defendants, appropriate measures are taken (including publication on
the defendants’ websites) for the dissemination and publication of any
judgment or order made in this case finding or recording that the
defendants have infringed any copyright belonging to the first claimant
which subsists in Valorant.
(5) Costs, including interest on costs.
(6) Further or other relief.

MICHAEL HICKS
Statement of truth
The first claimant believes that the facts stated in these particulars of claim
are true. I understand that proceedings for contempt of court may be brought
against anyone who makes, or causes to be made, a false statement in a
document verified by a statement of truth without an honest belief in its truth.
I am duly authorised to sign on behalf of the first claimant.
Signed……………………… Full name: Daniel Chang
Position or office held: General Counsel and Secretary, Riot Games, Inc.
Date: 5 October 2022
Statement of truth
The second claimant believes that the facts stated in these particulars of claim
I am duly authorised to sign on behalf of the second claimant.
Signed……………………… Full name: Alan Bridgeman
Position or office held: Vice President Enterprise EMEA, Riot Games Limited
Date: October 2022
SERVED by Wiggin LLP, Met Building, 22 Percy Street London W1T 2BU,
Ref: 103770.5/SLA/SS
16
to section 35A of the Senior Courts Act 1981 or in the inherent
jurisdiction of the court.
(4) An order that, at the claimants option and at the expense of the
defendants, appropriate measures are taken (including publication on
the defendants websites) for the dissemination and publication of any
judgment or order made in this case finding or recording that the
defendants have infringed any copyright belonging to the first claimant
which subsists in Valorant.
(5) Costs, including interest on costs.
(6) Further or other relief.

MICHAEL HICKS
Statement of truth
The first claimant believes that the facts stated in these particulars of claim
I am duly authorised to sign on behalf of the first claimant.
Signed Full name: Daniel Chang
Position or office held: General Counsel and Secretary, Riot Games, Inc.
Date: October 2022
Statement of truth
The second claimant believes that the facts stated in these particulars of claim
I am duly authorised to sign on behalf of the second claimant.
Signed Full name: Alan Bridgeman
Position or office held: Vice President Enterprise EMEA, Riot Games Limited
Date: 14 October 2022
SERVED by Wiggin LLP, Met Building, 22 Percy Street London W1T 2BU,
Ref: 103770.5/SLA/SS
16
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants
ANNEX 1 TO PARTICULARS OF CLAIM

GENERAL COMPARISON
Topic Comparison
Game Type Both Valorant and Hyper Front—
and Design
a) Are 5 players versus 5 players
b) Are online only (i.e., there is no real single-player mode)
c) Are first-person (i.e., the player experiences the action through the eyes of their character)
d) Focus on ability-based characters (i.e., each character has several abilities which are as important as a player’s
shooting skills), most of which are relatively human in physical appearance
e) Are free-to-play (i.e., there is no up-front cost to download / access the game – instead both games are monetised via
in-app-purchases such as weapon cosmetics)
f) Are tactical (i.e., coordinated team-play is essential)
g) Have very low time-to-kill (i.e., players can often be killed via single / few shots)
h) Feature gun recoil (i.e., guns do not fire at the exact same spot when repeatedly firing)
i) Emphasise fast reaction times (this type of game is often described as ‘twitch’ in nature since it requires fast reflexes
and precision aiming)
j) Emphasise the use of sound (i.e., hearing the footsteps from other players can give a big strategic advantage)
k) Emphasise smart use of angles and sightlines for shooting (i.e., peeking strategically around corners, particularly
crates)
l) Feature a similar movement pace (i.e., the default walking pace is similar and there is no sprint / run button)
m) Are similar in art style (i.e., a mix between realism and cel-shading) and set in a near future sci-fi universe with some
conceptual similarities regarding an accident/anomaly in each game’s universe (i.e., ‘First Light’ in Valorant and a
“spatial anomaly” in Hyper Front)
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Game Hyper Front has a highly similar combination of bomb defusal, deathmatch and training games modes to Valorant—
Modes
VALORANT HYPER FRONT

BOMB DEFUSAL MODES
In bomb defusal modes there are two sides: attackers, tasked with planting the bomb, and defenders, tasked with
preventing the planting of the bomb. On the attacker team, one player picks up the bomb (Valorant) or starcore (Hyper
Front) at the start of the round, which has to be planted. In both Valorant and Hyper Front (other than Spike Rush/Quick
SND), once a match begins, there is a period of time during which players can purchase weapons, equipment, and abilities
before any combat occurs. The amount of ‘money’ a player has during this phase depends on how well they and their
team performed in the previous round. In both games the presentation of available weapons and abilities is highly similar
and presented in a weapon grid system (see Annex 7 (GUI Comparison) for images). During the buy phase, players are
divided from the main field of combat by translucent barriers (see Annex 7 (GUI Comparison) for images). A timer ticks
down as the buy phase ends and the translucent barriers dissolve, allowing the players to move forward into the battle.
Halfway through the match the teams swap sides (i.e., attackers become defenders and vice versa).
Unrated: standard bomb defusal mode. Best of 25 format. Classic: standard bomb defusal mode. Best of 14 format.
Competitive: same as unrated above, but more competitive Classic (ranked): same as classic above, but more
with players competing to improve their persistent league competitive with players competing to improve their
rank. persistent league rank.
Replication: same as unrated above, but all players on a Vs Bots: same as classic above, but players compete
team play as the same agent. Best of 9 format. against computer controlled AI opponents.
Spike Rush: same as unrated, but players start each round Quick SND: same as classic above, but players start each
with the same random weapon. Five random orbs are round with the same random weapon. Five random orbs are
dropped around the map which can be claimed by players to dropped around the map which can be claimed by players
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receive ‘buffs’ for that round (e.g., high damage). All to receive ‘buffs’ for that round (e.g., high damage). All
attackers start with a bomb. Best of 7 format. attackers start with a bomb. Best of 7 format.
DEATHMATCH MODES
In deathmatch, the aim of the game is to get as many kills on other players as possible. There is no bomb to defuse, no
translucent barriers at the start of the match nor is there a formal ‘buy phase’ however players can change their weapons
during a match by opening a ‘buy’ menu. There are two ways the game can end: (1) a player or team reaches the kill
number requirement; or (2) the time for the round ends (which means the player with the highest kills wins). There are no
agent abilities available in these modes (excluding Hyper Front’s Team Mode).
Deathmatch: 12 players are dropped in random positions Deathmatch: 10 players are dropped in random positions
around the map. Each player can choose any weapon they around the map. Each player can choose any weapon they
like in the buy screen. like in the buy screen.
Each player starts with 100 health and 50 armour. If a player Each player starts with 100 health and 50 armour. If a
kills another player, a small green cross orb drops which, if player kills another player, a small green orb drops which, if
picked up, gives the player full health, armour and picked up, gives the player full health, armour and
ammunition again. ammunition again.
Red dots will appear on the mini-map which show the rough Red dots will appear on the mini-map which show the rough
location of other players. location of other players.
The first player to 40 kills wins. If a player is killed, they The first player to 30 kills wins. If a player is killed, they
continue to respawn until one player reaches 40 kills, or the continue to respawn until one player reaches 30 kills, or the
time for the round ends. The round ends after 9 minutes if no time for the round ends. The round ends after 10 minutes if
one has reached 40 kills. no one has reached 30 kills.
4
N/A Team Mode: 5 versus 5 team deathmatch. Each team is
dropped on opposite sides of the map. Agent abilities are
available on this mode.
Each player starts with 100 health and 50 armour. If a

player kills another player, a small gold orb drops which, if
picked up, gives the player full ammunition again (not
health or armour).
The first team to 50 kills wins. If a player is killed, they

continue to respawn until one team reaches 50 kills, or the
time for the round ends. The round ends after 10 minutes if
no team has reached 50 kills.
Escalation: 5 versus 5 team deathmatch. Each team is Arms Race: 10 player deathmatch. Players gain experience
dropped on opposite sides of the map. by defeating enemies and picking up energy orbs, which
can be used to enhance skills and weapons. First player to
Teams race each other to cycle through different weapons get to level 11 and score 2 melee weapon kills wins the
(both teams have to cycle through the same weapon set). game.
Each team has to get 7 kills on each weapon to move up a
level to the next weapon. First team to level 12 wins. If a
player is killed, they respawn in a random place on the map
5
until one team ascends the 12 levels. The round ends after
10 minutes if no team has reached the end of level 12.
TRAINING MODES
Training modes are spaces where players can safely practice their shooting skills and character abilities.
The Range: training gun range area where players can Training: training gun range area where players can
practice various skills (e.g., target practice, planting/defusing practice various skills.
bombs).
Character See Annex 2 (Agents and Heroes Comparison) for visual similarities between characters in Valorant and Hyper Front.
Designs
Generally, in each game the characters are split into different ‘classes’, with each class having attributes which favour a
particular type of gameplay. Although class names differ, the general roles for each are similar (e.g., Valorant’s Initiators and
Hyper Front’s Scouts are both strong at scouting the battlefield). The characters included within each category are also highly
similar across both games when comparing character abilities (e.g., Valorant’s Brimstone agent and Hyper Front’s Storm
champion share multiple similar abilities as shown in Annex 3 (Character Abilities Comparison) and both fall within the
equivalent class categories of Controllers and Tacticians respectively; the same applies to Phoenix and Blast, Reyna and
Blood Raider, Sova and Faith Arrow, Sage and Coldcast). See Annex 3 (Character Abilities Comparison) for further details
regarding character ability similarities.
VALORANT HYPER FRONT
Duelists: “Duelists are self-sufficient fraggers who their team Brawlers: agents with short range fighting abilities most
expects, through abilities and skills, to get high frags and useful in close combat
seek out engagements first”
6
The following agents fall within this category: Jett, Phoenix, The following heroes fall within this category: Blast,
Neon, Raze, Reyna, Yoru. Nemesis, Thunder, Blink, Blood Raider.
Controllers: “Controllers are experts in slicing up dangerous Tacticians: strategists who can use weak points of their
territory to set their team up for success” opponents to their advantage
The following agents fall within this category: Brimstone, The following agents fall within this category: Storm, Veil.
Astra, Omen, Viper.
Initiators: “Initiators challenge angles by setting up their team Scouts: agents who scout the area and find enemy
to enter contested ground and push defenders away” locations so the team can plan their attack accordingly
The following agents fall within this category: Sova, Breach, The following heroes fall within this category: Faith Arrow,
Fade, KAY/O, Skye. Sentinel.
Sentinels: “Sentinels are defensive experts who can lock Guardians: defensive agents who protect their teammates
down areas and watch flanks, both on attacker and defender
rounds”
The following heroes fall within this category: Coldcast,
The following agents fall within this category: Killjoy, Sage, Valkryie.
Chamber, Cypher.
Supports: agents who provide healing abilities to their
teammates and debuff enemies
The following heroes fall within this category: Cure Light.

Character See Annex 3 (Character Abilities Comparison) for similarities between abilities of agents in Valorant and heroes in Hyper
Abilities
Front.
7
Generally, in both games—
a) Characters have a mixture of abilities, which fall into the following 7 broad categories: vision blockers, damage, intel,
healing, empowerment, mobility and site locking (see more details below)
b) Some abilities are available to players automatically at the start of a match while others have to be purchased by
players using in-game currency
c) Each character has an ‘ultimate’ ability which can be earned by defeating enemies, dying, capturing in-game items
and completing a bomb plant or defuse
Ability Type Valorant Ability Hyper Front Ability Annex 3 Reference
Vision Blocker Sky Smoke Tornadoburst Page 3
Vision Blocker Sky Smoke Scorching Sand Page 5
Vision Blocker Leer Blindness Page 13
Vision Blocker Curve Ball Blindness Page 18
Vision Blocker Blaze Shrouding Sandstorm Page 19
Vision Blocker Paranoia Horizon Blocked Page 23
Vision Blocker Dark Cover Dark Oblivion Page 24
Vision Blocker Cyber Cage Area Blockade Page 34
Vision Blocker Poison Cloud Scorching Sand Page 44
Vision Blocker Toxic Screen Shrouding Sandstorm Page 45
Vision Blocker Viper Pit Scorching Sand Page 43
Damage Orbital Strike Tornado Page 4
Damage Hunter’s Fury Flaming Arrow Page 10
Damage Incendiary Triple Shot Page 6
8
Damage Shock Bolt Burning Arrow Page 9
Damage Showstopper Mega Shark Rocket Page 27
Damage Paint Shells Triple Shot Page 26
Damage Nanoswarm Stun Grenade Page 39
Damage Turret Auto Turret Page 40
Damage Overdrive Ion Shock Page 51
Intel Recon Bolt Scouting Arrow Page 8
Intel Owl Drone Drone Page 11
Healing Devour Bloodthirst Page 14
Healing Healing Orb Nano Treatment Page 31
Healing Resurrection Body Reconstruction Page 32
Empowerment Empress Berserk Page 15
Empowerment Dismiss Plasma State Page 16
Empowerment Run It Back Clone Page 20
Empowerment Dimensional Drift Dimension Walk Page 49
Mobility Barrier Orb Ice Barrier Page 29
Mobility Updraft Jetpack Page 36
Mobility Tailwind Lightning Dash Page 37
Mobility Shrouded Step Spacetime Leap Page 22
Mobility Fakeout Void Illusion Page 48
Site Locking Slow Orb Icecore Trap Page 30
Site Locking Snake Bite Quicksand Desert Page 46
Site Locking Lockdown Freezing Storm Page 41
9
Maps See Annex 4 (Maps Comparison) for similarities regarding Maps.
Hyper Front currently has 5 maps, 4 of which are set in the same locations / settings as maps from Valorant—
Valorant Map Name Hyper Front Map Name Real-World Location
Split Momijigawa Japan
Icebox Glacier Exploration Center Arctic
Ascent City of Gardens Venice
Bind Desert Tower Morocco
In both games, when a player is loading into a match they are presented with a loading screen. In both games the loading
screen shows a bird’s-eye view of the selected map with the map name in bold, white lettering and the game type in smaller-
font, bold, white lettering in the top left of the screen.
More generally, both games—
a. Mix historic / current day architecture with architecture that looks more futuristic / sci-fi
b. Have fairly ‘flat’ level design (i.e., the maps tend to have one to two floors – there are no tall buildings that players can
scale and access)
c. Use industrial looking crates as objects to hide behind, particularly in the ‘A’ and ‘B’ bomb sites
d. Are laid out like a series of interwoven corridors (i.e., the rooms and passages are generally narrow – there are
generally few large open spaces)
e. Game maps are generally split into two ‘A’ and ‘B’ sites
Weapons See Annex 5 (Weapon Skins Comparison) for similarities regarding weapon skins.
10
See Annex 6 (Gunbuddies Comparison) for similarities in gunbuddies.
See Annex 8 (Weapon Aiming and Firing Comparison) for similarities between gun aiming and firing.
See Annex 9 (Damage Output Comparison) for similarities in weapon damage output.
See Annex 10 (Weapon Capabilities Comparison) for the similarities between weapon magazine capacities and fire rates.
See Annex 11 (Weapons Comparison) for similarities between the appearances of the weapons.
GUI See Annex 7 (GUI Comparison) for similarities between GUI in both games.
Sound The background music played during the matchmaking lobby in Hyper Front is a copy of a substantial part of the background
Effects
music used during the matchmaking lobby of Valorant.
Hyper Front’s music and other sounds (such as the sounds weapons make and the tone of the in-game voice
announcements) are highly similar to those of Valorant, giving players of the Hyper Front substantially the same auditory
experience as in Valorant.
11
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

AGENTS AND HEROES COMPARISON
Omen (Valorant) / Nemesis (Hyper Front) – Current Design
Both Omen and Nemesis are presented as mysterious, ninja-like stealth characters. Both have rigid hoods with a similar prominent
angular shape and back-length capes. Both outfits are grey / black with similar purple accents, particularly around the hood. The
characters both take a powerful stance. Both characters wear body armour, including textured pauldrons and diagonally wrapping
belts. Neither character’s face is clearly visible and both have glowing eyes.
Omen (Valorant) Nemesis (Hyper Front)
2
Omen (Valorant) / Nemesis (Hyper Front) – Earlier Version
The earlier version of Nemesis is shown below, and includes for example similar body shapes, ethereal face designs, skin-tight
clothing and arm-highlights.
Omen (Valorant) Nemesis (Hyper Front)
3
Sage (Valorant) / Cure Light (Hyper Front)
Both Sage and Cure Light are presented as healing / support type characters. Both outfits revolve around cool-tones with a silver /
off-white base featuring blue / green accents. Both have angular pauldrons / shoulders. The characters have similar body types and
styled jet-black hair.
Sage (Valorant) Cure Light (Hyper Front)
4
Sage (Valorant) / Elixir (Hyper Front) – Earlier Version
The Hyper Front character Cure Light replaced an earlier Hyper Front character known as Elixir. Elixir’s character design was very
similar to Sage’s current design: for example that both characters appeared of East-Asian origin with similar body types, pose, outfit
design and colour choice.
Sage (Valorant) Elixir (Hyper Front)
5
Killjoy (Valorant) / Sentinel (Hyper Front)
Both characters convey a similar laid-back attitude. Both adopt a similar stance, with weight distributed primarily onto one leg. Both
outfits are based on snowboarder / streetwear fashion, including a large puffer-jacket with upright collar, thick-rimmed eyewear, a
scarf, gloves with unusually thick wrist-bands and ripped skinny jeans. Both outfits feature crosses prominently, with Killjoy having
these over the jacket and Sentinel having them on goggles and the left kneepad. Both outfits include black skinny jeans with green
and yellow as other prominent colours.
Killjoy (Valorant) Sentinel (Hyper Front)
6
Reyna (Valorant) / Blink (Hyper Front)
Both characters convey a similar confident and deadly attitude. Both prominently feature the colour purple. Both have shoulder-length
hair with purple elements and are wearing earrings. Both feature skin-tight body-suits. Both adopt the same stance with one hip jutting
to the side. Both outfits feature exposed shoulders.
Reyna (Valorant) Blink (Hyper Front)
7
Jett (Valorant) / Thunder (Hyper Front)
Both Jett and Thunder are presented as confident, lean characters. Both outfits are grey / black with teal / blue upper portions and
highlights, featuring sleeveless cut-offs and angular collars.
Jett (Valorant) Thunder (Hyper Front)
8
Phoenix (Valorant) / Blast (Hyper Front)
Both Phoenix and Blast are young male characters with similar faces, spiky hair and general physique. Both wear semi-military casual
clothing. Both outfits focus on white, yellow and black colour schemes with orange accents. Blast also appears to have elements
similar to Raze, including colour scheme, stance, and attire, in particular cargo trousers and utility belts. Both Raze and Blast also
have a large weapon slung over their shoulders.
Phoenix & Raze (Valorant) Blast (Hyper Front)
9
Skye (Valorant) / Valkyrie (Hyper Front)
Both Skye and Valkyrie are young female characters with similar faces, side-swept hair and general physique. Both wear semi-
military casual clothing. Both outfits focus on green and grey colour schemes, with stylised cropped chest, arm and leg armour,
necklaces, combat boots and side pouches. Both characters stand flexing their arms with clenched right fists and extended left arms.
Skye (Valorant) Valkyrie (Hyper Front)
10
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

CHARACTER ABILITIES COMPARISON
BRIMSTONE
2
Brimstone’s (Valorant) Sky Smoke / Storm’s (Hyper Front)
Tornadoburst
ABILITY TYPE – VISION BLOCKER
Description Prepare Release Effect
Valorant
Equip a tactical map.

Select up to three
locations to deploy
smoke clouds to block
enemy vision.
Hyper Front
Select up to three
locations to deploy
clouds to block enemy
vision.
3
Brimstone’s (Valorant) Orbital Strike / Storm’s (Hyper Front)
Tornado
ABILITY TYPE – DAMAGE
Valorant

Fire to launch a lingering,
circular orbital strike
laser at select location
doing damage over
time.
Hyper Front

Fire to launch a lingering,
circular EMP strike at
select location doing
damage over time.
4
Brimstone's (Valorant) Sky Smoke / Veil's (Hyper Front)
Scorching Sand
Valorant
Equip a tactical
map. Select locations to
deploy globe-shaped
smoke clouds to
block enemy vision.
Hyper Front
Select a location to
create a globe-shaped
sand cloud to block
enemy vision.
5
Brimstone’s (Valorant) Incendiary / Blast’s (Hyper Front)
Triple Shot
Valorant
Equip a grenade
launcher to fire a
grenade that detonates
on the floor.
Hyper Front
Equip a grenade
launcher to fire three
grenades that detonate
on the floor.
6
SOVA
7
Sova’s (Valorant) Recon Bolt / Faith Arrow’s (Hyper Front)
Scouting Arrow
ABILITY TYPE – INTEL
Valorant
Fire a recon bolt,

activating upon
collision and revealing
the location of nearby
enemies.
Hyper Front
Fire a recon bolt,
activating upon
collision and revealing
the location of nearby
enemies.
8
Sova’s (Valorant) Shock Bolt / Faith Arrow’s (Hyper Front)
Burning Arrow
Valorant
Fire an arrow that

generates a burst of
electricity on hit.
Hyper Front
Fires an arow that
generates a burst of
flame on hit.
9
Sova’s (Valorant) Hunter’s Fury / Faith Arrow’s (Hyper Front)
Flaming Arrow
Valorant
Fires a long-range
wall-piercing energy
blast dealing damage
and revealing enemy
locations.
Hyper Front
Fires a long-range wall-
piercing energy blast
dealing damage and
revealing enemy
locations.
10
Sova’s (Valorant) Owl Drone / Sentinel’s (Hyper Front)
Drone
ABILITY TYPE – INTEL
Valorant
Deploy a drone which

can be manually
controlled for a short
period of time.
Hyper Front
Deploy a drone which
can be manually
controlled for a short
period of time.
11
REYNA
12
Reyna’s (Valorant) Leer / Blood Raider’s (Hyper Front)
Blindness
Valorant
Release a
floating projectile to
restrict nearby enemy
sight.
Hyper Front
Release a bouncing
projectile to restrict
nearby enemy sight.
13
Reyna’s (Valorant) Devour / Blood Raider’s (Hyper Front)
Bloodthirst
ABILITY TYPE – HEALING
Valorant
Defeated enemies drop

Soul Orbs. Activate to
consume a nearby Soul
Orb to regain health.
Hyper Front
Defeated enemies
provide charges for this
ability. Activate to gain
extra health recovery
for a short time.
14
Reyna’s (Valorant) Empress / Blood Raider’s (Hyper Front)
Berserk
ABILITY TYPE – EMPOWERMENT
Valorant
Enter a frenzy
increasing firing speed.
Defeating enemies
renews the duration.
Hyper Front
Turn berserk. Restores
health and allows
player to enter
a ‘downed’ state when
injured.
15
Reyna’s (Valorant) Dismiss / Thunder’s (Hyper Front) Plasma
State
Valorant
Activates after a
kill/assist. Reyna
becomes immune, if
Empress is active also
becomes invisible.
Hyper Front
Activates after a
kill/assist. Transform
into an immune state at
the expense of not
being able to attack.
16
PHOENIX
17
Phoenix’s (Valorant) Curve Ball / Blood Raider’s (Hyper Front)
Blindness
Valorant
Release a flare orb that

takes a curved path
when thrown to
detonate and blind
nearby players.
Hyper Front
Release a bouncing
projectile to detonate
and blind nearby players.
18
Phoenix’s (Valorant) Blaze / Veil’s (Hyper Front)
Shrouding Sandstorm
Valorant
Fire to create a flame

wall that moves
forward, creating a wall
that blocks vision and
damages players
passing through it.
Hyper Front
Select a map location to
generate a fracture
which can be activated
to create a visual
obstruction.
19
Phoenix’s (Valorant) Run It Back / Nemesis’ (Hyper Front) Clone
Valorant
Place a marker at
current location which
Phoenix will teleport
back to on death or
when timer expires.
Hyper Front
Activate a controllable
clone. Nemesis will
teleport back to his
original body on death.
20
OMEN
21
Omen’s (Valorant) Shrouded Step / Blink’s (Hyper Front)
Spacetime Leap
ABILITY TYPE – MOBILITY
Valorant
Select a location in
front of Omen and
teleport to that location
after a brief ability
channel.
Hyper Front
Select a location in
front of Blink and
teleport to that location
after a brief ability
channel.
22
Omen’s (Valorant) Paranoia / Blink’s (Hyper Front)
Horizon Blocked
Valorant
Fire a projectile
forwards that reduces
the vision of players it
touches.
Hyper Front
Fire a static projectile
which limits the visions
of enemies who see it.
23
Omen’s (Valorant) Dark Cover / Nemesis' (Hyper Front)
Dark Oblivion
Valorant
Create a long-lasting
shadow sphere at
target location to block
vision. Enemies
inside the sphere are
visible.
Hyper Front
Create a long-
lasting shadow sphere
at current location
to block vision. Enemies
inside the sphere
are visible.
24
RAZE
25
Raze’s (Valorant) Paint Shells / Blast’s (Hyper Front) Triple Shot
Valorant
Release a cluster
grenade which
explodes and creates
smaller grenades upon
detonation.
Hyper Front
Fire three grenades
that detonate on the
floor.
26
Raze’s (Valorant) Showstopper / Blast’s (Hyper Front)
Mega Shark Rocket
Valorant
Equip a rocket launcher

which shoots a rocket
that does massive area
damage on contact.
Hyper Front
Equip a rocket launcher
which shoots a rocket
that does massive area
damage on contact.
27
SAGE
28
Sage’s (Valorant) Barrier Orb / Coldcast’s (Hyper Front)
Ice Barrier
Valorant
Create a solid barrier

wall at targeted location
(can be rotated 90
degrees prior to
releasing).
Hyper Front
Create a solid barrier
wall at targeted location
(can be rotated
90 degrees prior
to releasing).
29
Sage’s (Valorant) Slow Orb / Coldcast’s (Hyper Front)
Icecore Trap
ABILITY TYPE – SITE LOCKING
Valorant
Throw a slowing orb

that detonates upon
landing, creating a
lingering field that
slows players.
Hyper Front
Throws a trap which

creates a lingering field
slowing players once
detonated.
30
Sage’s (Valorant) Healing Orb / Cure Light’s (Hyper Front)
Nano Treatment
Valorant
Equip a healing orb

which can heal an ally,
or Sage herself, over
time.
Hyper Front
Release nanobots
which can heal an ally,
or Cure Light herself,
over time.
31
Sage’s (Valorant) Resurrection / Cure Light’s (Hyper
Front) Body Reconstruction
Valorant
Revive a fallen
teammate to full
health.
Hyper Front
Revive a
fallen teammate to
full health.
32
CYPHER
33
Cypher’s (Valorant) Cyber Cage / Cure Light’s (Hyper Front)
Area Blockade
ABILITY TYPE – VISION BLOCKING
Valorant
Toss a cyber cage that

blocks vision and slows
enemies inside.
Hyper Front
Toss a blockade that
blocks vision and slows
enemies inside.
34
JETT
35
Jett’s (Valorant) Updraft / Blast’s (Hyper Front)
Jetpack
Valorant
Instantly propel Jett

upwards.
Hyper Front
Instantly propel Blast
upwards.
36
Jett’s (Valorant) Tailwind / Thunder’s (Hyper Front)
Lightning Dash
Valorant
Dash Jett in the direction

she is moving.
Hyper Front
Dashes towards the
target.
37
KILLJOY
38
Killjoy's (Valorant) Nanoswarm / Sentinel's (Hyper Front)
Stun Grenade
Valorant
Throw a grenade which

damages players over
time.
Hyper Front
Throw a grenade
which slows enemies.
39
Killjoy's (Valorant) Turret / Valkyrie's (Hyper Front)
Auto Turret
Valorant
Deploy a turret that
automatically fires at
enemies.
Hyper Front
Deploy a turret
that automatically fires
at enemies.
40
Killjoy's (Valorant) Lockdown / Coldcast's (Hyper Front) Freezing
Storm
Valorant
Plant a lockdown device
that slows all enemies in
its radius.
Hyper Front
Releases an ice
energy that freezes all
enemies within its
radius.
41
VIPER
42
Viper's (Valorant) Viper Pit / Veil's (Hyper Front) Scorching Sand
Valorant
Create a large vision-

blocking poison cloud
that blocks vision and
reduces the health of
players inside it.
Hyper Front
Select a location
to create a globe-
shaped sand cloud
to block enemy vision
and inflict vulnerability
on players inside it.
43
Viper's (Valorant) Poison Cloud / Veil's (Hyper Front)
Scorching Sand
Valorant
poison cloud to block
enemy vision and
damage enemies.
Hyper Front
sand cloud to block
enemy vision.
44
Viper's (Valorant) Toxic Screen / Veil's (Hyper Front)
Shrouding Sandstorm
Valorant
Deploys a line of gas

cannisters which emit a
poison wall once
activated.
Hyper Front
Select a map location to
generate a fracture which
can be activated to create a
visual obstruction.
45
Viper's (Valorant) Snake Bite / Veil's (Hyper Front)
Quicksand Desert
Valorant
Fire a chemical canister

which shatters and
creates a chemical zone
that damages and slows
enemies.
Hyper Front
Summon a gradually
expanding quicksand
area which will
damage and slow
enemies.
46
YORU
47
Yoru's (Valorant) Fakeout / Nemesis’ (Hyper Front) Void Illusion
Valorant
Transform Yoru into mirror
image that moves forward.
Mirror images explode in a
blinding flash when
destroyed by enemies.
Hyper Front
Transform Nemesis into
a mirror image that
moves forward. Tap to
swap position with the
mirror image.
48
Yoru's (Valorant) Dimensional Drift / Blink’s (Hyper Front)
Dimension Walk
Valorant
Equip a mask which grants
Yoru the ability to move
around the map without
being seen or hit by
enemies.
Hyper Front
Jump into the digital
world to move around
the map without being
seen or hit by enemies.
49
NEON
50
Neon's (Valorant) Overdrive / Thunder’s (Hyper Front) Ion Shock
Valorant
Fire to channel a blue
lightning beam from
hands.
Hyper Front
Fire to channel a blue
ion beam from hands.
51
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

MAPS COMPARISON
Split (Valorant) / Momijigawa (Hyper Front)
Load Screen Map In-Play 1
Split
(Valorant)
Momijigawa
(Hyper Front)
Both maps are set in East Asia – apparently Japan. Both use a colour palette featuring rich reds, greens and browns. Both prominently feature
buildings with wooden / bamboo panelling (see In-Play 1). Both maps feature many slim corridors leading on to wider, more spacious rooms /
spaces.
2
Split (Valorant) / Momijigawa (Hyper Front) (cont.)
In-Play 2 In-Play 3 In-Play 4
Split
(Valorant)
Momijigawa
(Hyper Front)
Both maps feature Japan-themed plant life throughout (see In-Play 2). Both maps feature Japanese style pagoda temples and hutongs (see In-Play 2
and 3). Both include a mix of traditional residential and contemporary commercial buildings (see In-Play 2-4). Both commercial buildings appear to be
train stations or similar (see In-Play 4).
3
Split (Valorant) / Momijigawa (Hyper Front) (cont.)
Split Momijigawa
(Valorant) Game Map (Hyper Front)
The Hyper Front map has been

flipped 180 degrees so that the
attacker side is north and defender
side is south on both maps.
Both maps are roughly square in shape. Attackers and defenders are positioned at the top and bottom of both maps. Both maps feature
bomb sites on the left and right lower half of the map, each positioned in larger, open square environments. Walking routes of maps are
highly similar – both feature three core ‘lanes’ for players to travel through. Both maps are grey, with location names identified in white
writing on darker grey backgrounds and bomb sites displayed in yellow.
4
Icebox (Valorant) / Glacier Exploration Center (Hyper Front)
Load Screen Map In-Play 1
Icebox
(Valorant)
Glacier
Exploration
Center
(Hyper Front)
Both maps are based in wintery conditions with backdrops showing wintery mountains / glaciers (see Load Screen). Icebox is set in an expedition
centre while Glacier Exploration is set on / adjacent to an expedition ship. Both use a colour palette of cool-tones of whites, blues and orange
accents.
5
Icebox (Valorant) / Glacier Exploration Center (Hyper Front) (cont.)
Icebox
(Valorant)
Glacier
Exploration
Center
(Hyper Front)
Both maps have a focus on large, futuristic central buildings with the outdoor being a storage space for containers. Buildings in both maps are either
metallic (see In-Play 3) or pure white with orange detailing (see In-Play 3 and 4).
6
Icebox (Valorant) / Glacier Exploration Center (Hyper Front) (cont.)
Icebox Glacier Exploration Center


Both maps are wider at the bottom than the top. Attackers and defenders are positioned at the top and bottom of both maps. Both
maps feature bomb sites on the left and right lower half of the map. The left side bomb site on both maps has three entrances and the
bomb site on the right also has three entrances. Walking routes of maps are highly similar. Both maps divide into a right and a left
side, with a connection in the middle, a narrow pointed extension at the top and bottom and a wider pointed extension at the bottom.
Both maps are grey, with location names identified in white writing on darker grey backgrounds and bomb sites displayed in yellow.
7
Ascent (Valorant) / City of Gardens (Hyper Front)
Load Screen In-Play 1 In-Play 2
Ascent
(Valorant)
City of
Gardens
(Hyper Front)
Both maps are Venetian-inspired in terms of setting and general building architecture. Both maps are based in the centre of a large city with a tall,
imposing structure in the middle (resembling St Marks’ Campanile) surrounded by buildings with red roofs (see Load Screen and In-Play 1).
8
Ascent (Valorant) / City of Gardens (Hyper Front) (cont.)
Ascent
(Valorant)
City of
Gardens
(Hyper Front)
The predominant colour of buildings within both maps is off-white and light blue. Buildings are in the style of real world buildings with typical roads /
pavements as would be found in real life.
9
Ascent (Valorant) / City of Gardens (Hyper Front) (cont.)
Ascent City of Gardens


Both maps are wider at the bottom than the top, adopting a ‘reverse T’ shape. Attackers and defenders are positioned at the top and
bottom of both maps. Both maps feature bomb sites on the left and right lower half of the map. Walking routes of maps are highly
similar. Both maps divide into a right and a left side with a connection in the middle with multiple branching paths. Both maps are grey,
with location names identified in white writing on darker grey backgrounds and bomb sites displayed in yellow.
10
Bind (Valorant) / Desert Tower (Hyper Front)
Load Screen In-Play 1 In-Play 2
Bind
(Valorant)
Desert Tower
(Hyper Front)
Both maps are set in a desert landscape (see Load Screen). Both heavily feature Moroccan-inspired architecture. Both use a colour palette of
yellows, soft oranges and browns.
11
Bind (Valorant) / Desert Tower (Hyper Front) (cont.)
Bind
(Valorant)
Desert Tower
(Hyper Front)
Both feature mosaic archways and corridors (see In-Play 3). Both feature collisions of traditional Moroccan residential architecture combined with
industrial refinery machinery. Both maps feature a large, grey refinery structure in the background.
12
Bind (Valorant) / Desert Tower (Hyper Front) (cont.)
Bind Desert Tower


Both maps are generally rectangular in shape with extensions at the top and bottom. Attackers and defenders are positioned at the top
and bottom of both maps. Both maps feature bomb sites on the left and right lower half of the map. Walking routes of maps are highly
similar. Both maps are grey, with location names identified in white writing on darker grey backgrounds and bomb sites displayed in
yellow.
13
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

WEAPON SKINS COMPARISON
General Skin Comparison
Valorant Hyper Front Valorant Hyper Front
2
Nebula (Valorant) / Romantic (Hyper Front)
Both guns’ skins are an array of pink and purple hues in a camouflage-style pattern.
Nebula on ‘Phantom’ (Valorant) Romantic on ‘AK’ (Hyper Front)
3
Oni (Valorant) / Roaring New Year (Hyper Front)
Both guns’ skins are a ‘toy soldier’ theme with red and black elements and gold highlighting and ‘piping’ around the key design lines of
the guns. Brown, red, gold and black are key elements of the design.
Oni on ‘Phantom’ (Valorant) Roaring New Year on ‘M4A1’ (Hyper Front)
4
Artisan (Valorant) / Particle Engine (Hyper Front)
Both guns’ skins have a futuristic design with angular elements and lightly-coloured white / cream and gold / yellow elements.
Artisan on ‘Ghost’ (Valorant) Particle Engine on ‘USP’ (Hyper Front)
5
Serenity (Valorant) / Inheritor (Hyper Front)
Both guns use predominantly the same colours of emerald green and gold. The green colour is mottled and has a gem-like surface in
both guns.
Serenity on ‘Ghost’ (Valorant) Inheritor on ‘USP’ (Hyper Front)
6
Celestial (Valorant) / Forest Labyrinth (Hyper Front)
Both guns’ skins have a camouflage-style design which exists as swirls / diagonal lines across the guns. The predominant colours in
both guns are black, brown, yellow / gold and copper.
Celestial on ‘Phantom’ (Valorant) Forest Labyrinth on ‘AK’ (Hyper Front)
7
Sovereign (Valorant) / Particle Engine (Hyper Front)
Both guns use predominantly the same colours of light grey and gold.
Sovereign on ‘Ghost’ (Valorant) Particle Engine on ‘USP’ (Hyper Front)
8
Recon (Valorant) / Tenderness (Hyper Front)
Both guns’ skins are a metallic-effect gold colour with black areas.
Recon on ‘Spectre’ (Valorant) Tenderness on ‘Vector’ (Hyper Front)
9
Doodle Buds (Valorant) / Doodle Style (Hyper Front)
Both guns’ skins have a graffiti / street style design with light and black colours mixed with hand-drawn style drawings or graffiti and
touches of neon green and yellow colours.
Doodle Buds on ‘Ares’ (Valorant) Doodle Style on ‘M249’ (Hyper Front)
10
Magepunk (Valorant) / Alchemy (Hyper Front)
Both guns’ skins have an old-fashioned / rustic design with metallic elements across the body of the gun and intricate patterning in
some areas of the gun. Black and gold / copper are the predominant colours.
Magepunk on ‘Ares’ (Valorant) Alchemy on ‘Knight’ (Hyper Front)
11
Magepunk (Valorant) / Mechanism (Hyper Front)
Both guns’ skins have an old-fashioned / rustic design with metallic elements across the body of the gun and intricate patterning in
some areas of the gun. Black and gold / copper are the predominant colours.
Magepunk on ‘Spectre’ (Valorant) Mechanism on ‘Vector’ (Hyper Front)
12
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

GUNBUDDIES COMPARISON
GL Have Cat Buddy (Valorant) / Maneki-Neko (Hyper Front)
Both gunbuddies hang from a red / pink-coloured string which attaches to the gunbuddy via a metallic-looking wire ring and loop on
the head of the gunbuddy. Both gunbuddies are white cats, and both cats have smiling faces with eyes drawn in the closed position
using an upside down curved line. Both cats have collars around their necks, and have a gold metallic-looking ornament (a bell on the
collar in the case of GL Have Cat Buddy and a dog tag in the case of Maneki-Neko).
GL Have Cat Buddy (Valorant) Maneki-Neko (Hyper Front)
2
Bullet Buddy (Valorant) / Breakthrough (Hyper Front)
Both gunbuddies are bullets with very similar shapes (including the small ring, an indentation at the top of the bullet, and the
proportions of the main part of the bullet and the pointed part of the bullet).
Bullet Buddy (Valorant) Breakthrough (Hyper Front)
3
Xpert Comms Buddy (Valorant) / Tranquility (Hyper Front)
Both gunbuddies are over ear-type headphones.
Xpert Comms Buddy (Valorant) Tranquility (Hyper Front)
4
Arcane Cupcake Buddy (Valorant) / Macaron (Hyper Front)
Both gunbuddies are sweet baked goods which one would typically associate with afternoon tea and are brightly coloured. The
Arcane Cupcake Buddy is hanging from a fork, and the Macaron is hanging from what appears to be a type of cutlery, possibly a fork
or spoon.
Arcane Cupcake Buddy (Valorant) Macaron (Hyper Front)
5
Valorant Go! Vol. 1 Jett Buddy (Valorant) / Mia – Cute (Hyper Front)
Both gunbuddies are female cartoon / ‘chibi’ style characters with anime-like appearances (such as their hair and outfits). Both
gunbuddies have electric blue elements. Different gunbuddies are available for different game characters.
Valorant Go! Vol. 1 Jett Buddy (Valorant) Mia – Cute (Hyper Front)
6
Donut Buddy (Valorant) / Cookie (Hyper Front)
Both gunbuddies are sweet baked goods which one would typically associate with casual eating with hot drinks and are dark in
appearance. Both gunbuddies have a bite taken out of them.
Donut Buddy (Valorant) Cookie (Hyper Front)
7
Old Salt Buddy (Valorant) / Carnival Mask (Hyper Front)
Both gunbuddies are outlandish clothing accessories / fancy dress items decorated with brightly coloured feathers. The Old Salt
Buddy has two feathers in a bright green colour which is the same as, or very similar to, the bright green feathers found on the
Carnival Mask.
Old Salt Buddy (Valorant) Carnival Mask (Hyper Front)
8
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

GUI COMPARISON
Matchmaking Lobby
The matchmaking lobby is where players wait and form groups before joining matches. Both lobbies feature backgrounds containing
a range of blue hues including darker and lighter elements. The lighter elements of both backgrounds evoke an ‘aurora’ of light. The
upper centre of both lobbies feature an isosceles trapezium-shaped button which contains text. The upper left hand side of both
screens feature a left-facing arrow shape, each of which consists of two arrows, one inside the other, pointing in the same direction.
In the centre of each lobby is a prominent array of 5 rectangular boxes denoting the players in the current match. Players already in
the match are denoted by a box containing an image and the player’s user name shown. Empty boxes which allow players to add
other players to the match contain lightly-coloured ‘+’ symbols in the middle of each box. Both games use pale yellow colouring
around the area containing the user name, as well as a diamond-shaped symbol at the top of boxes containing player details. The
bottom of both screens feature long, rectangular buttons containing text including the text ‘START’ which is used to start the match.
Both games feature player ‘friend lists’ on the right hand side.
Valorant Hyper Front
2
Weapon Selection Screen
In some game modes players are provided with the opportunity to purchase weapons via a weapon selection screen. The weapon
selection screens in both games feature a grid pattern of several boxes containing weapons information laid in a semi-translucent
manner over the live in-game content. The weapons boxes are laid out in columns which correspond to various categories of guns
(e.g., SMGs / Sub-Machine Guns and Rifles). Each box contains a monochromatic image of the relevant weapon along with the
name of the weapon and its purchase price. All the weapon images in Valorant point to the right hand side and in Hyper Front point
to the left hand side. Both games feature a ‘x’ close button in the top right hand side of the screen. Both games contain a section
showing the user’s current coin balance and minimum coins required for the next round in the game (in Valorant this is located on the
upper left hand side and in Hyper Front this is located in the upper right hand side of the screen). The current coin balance in both
games is shown in bright yellow. The minimum coins required for the next round in the game is displayed with the text “min next
round” in both games. The shield icons underneath the heading armour in both games are similar in that one design is a shield with
wings with white infill and the other design is a shield with a shape in the middle with white outline.
3
Gameplay UI
Both games feature similar player user interfaces during general gameplay. Both feature a circular, grey-scale minimap in the top left with
the player’s own icon shown in yellow. The upper middle of both screenshots contain a horizontal column-shaped device with three main
areas: one central area displaying the reverse timer countdown of the time remaining in the match, which has a translucent grey colour,
and two areas to the left and right of the central area, one for each team in the match. Each player’s character’s headshot is displayed
until the player is eliminated from the round. In both games, one team’s area is coloured red (on the right hand side) and the other is
coloured blue / green. When a player eliminates another player a circular symbol is displayed at the lower centre of the screen in both
games – a skull surrounded by a circle for Valorant and a diamond surrounded by a circle for Hyper Front. Both games feature highlighted
areas around the circular symbol – green in Valorant and yellow in Hyper Front. Both games feature a display showing when a player
defeats another player and which gun they used (top right for Valorant and beneath the minimap for Hyper Front). The Hyper Front user
interfaces includes a number of icons not contained in the Valorant user interface (e.g., bullets, stance indicators) because Hyper Front is
played on a touch-screen mobile device whereas Valorant is player with a keyboard and mouse, so on-screen buttons are not required.
4
Gameplay UI (cont.)
When a player eliminates another player a circular symbol is displayed at the lower centre of the screen in each game – a skull (or custom
image chosen by the player, as in the screenshots below) surrounded by a circle for Valorant and a diamond surrounded by a circle for
Hyper Front. Both games feature highlighted areas around the circular symbol – green in Valorant and yellow in Hyper Front. The number
and positioning of these highlighted areas is the same in both games and increases depending on the number of kills obtained.
Valorant
Hyper Front
5
Post-Match Scoreboard Screen
The post-match scoreboard screen in both games feature a similar colour palette – light green / blue and red in Valorant and light
blue and red in Hyper Front. The words displaying match outcome are displayed in the upper centre of the screen in both games
(depending on the result of the previous match), along with the overall score for each team in the respective colours to the left and
right of this word. Below this are a series of ‘tabs’ which can be selected to view different sets of information – two tabs in Valorant
and three in Hyper Front. These tabs are underlined with a thick coloured line in both games, if selected. Below the tabs in both
games are tables populated with results and scoreboard information for the previous match. For the ‘scoreboard’ table in Valorant
and the ‘results’ table in Hyper Front, each row contains a ‘headshot’ of the player’s Agent / Hero on the left hand side as well as
several numbers corresponding to match data which are lightly coloured. Both games feature backgrounds containing a range of blue
hues including darker and lighter elements. The lighter elements of both backgrounds evoke an ‘aurora’ of light.
6
Post-Match Scoreboard Screen (cont.)
Both games feature a post-match screen showing detailed team performance statistics throughout the match. Both post-match
screens show whether the bomb was planted or defused in a particular round. Both screens also display blue and red bar charts
indicating the average equipment value (i.e., cost of all guns, abilities and armour purchased that round) per round.
7
Logo
The Valorant and Hyper Front logos both feature slanted, angular, sans-serif typeface in capital lettering. The ‘R’, ‘N’ and ‘T’ feature
similar slants and cut-aways.
8
Loading Screen
Players are presented with a loading screen when entering a match. In both games, the name of the relevant map is displayed in
light coloured capital letters. The map layout in both games is shown in a light grey colour with an outline in a different, lighter colour.
The ‘A’ and ‘B’ sites of the map (where the respective teams have to destroy or defend) are shown in yellow in both games. In both
games, images of the Agents / Heroes who are members of the two teams are shown at the side of the map layout and highlighted
with red or blue colouring depending on their respective team.
9
In-Game Maps
In addition to the permanent minimap located in the top left of the screen, players can pop-up a larger, more detailed map during
gameplay. This map in both games is light grey in colour with an outline in a different, lighter colour. Map location text is shown in
white on a darker grey background. The ‘A’ and ‘B’ sites of the map (where the respective teams have to destroy or defend) are
shown in yellow in both games. In both games, the location of the players in the match are highlighted with red or blue colouring
depending on their respective team. Coloured green and red lines are used to indicate where the translucent start-of-match barriers
are located.
10
Character Selection Screen
The character selection screen in both games features the Agent / Hero in a central position on screen standing on a helipad-type
structure which occupies the foreground of the screen, with dramatic landscape behind occupying the background of the screen. The
bottom of the screen in Valorant and the left of the screen in Hyper Front features ‘headshots’ of the various Agents / Heroes
available to choose from in square boxes which can be selected by the user. Those boxes containing Agents / Heroes which are not
yet available to the user in the game are marked with a locked padlock symbol. A list of the confirmed players and their selected
Agents / Heroes is to the left of the screen in Valorant and the right if the screen in Hyper Front. The list has square boxes for each
player containing a ‘headshot’ of their chosen Agent / Hero along with their user name to the side of the box. The user name of the
player is coloured yellow. The Agent / Hero displayed in the centre of the screen occupies a similar field of vision in both games. The
particular Agent’s / Hero’s abilities are depicted with translucent circular pictograms with white graphics positioned to the right hand
side of the screen in Valorant and to the bottom of the screen in Hyper Front.
11
In-Game Objects – Translucent ‘Wall’
At the start of each round in the bomb defusal mode, teams are initially separated by translucent, coloured barriers. The barriers in
both games are generally transparent but contain highlights such as lines and bullet holes / constellation patterns.
12
In-Game Objects – Bomb Site Crates
Both games feature crates located at an area of the map where players must place a bomb. The crates both use light green and grey
colouring.
13
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

WEAPON AIMING AND FIRING COMPARISON
Aiming Firing
Both games by default feature a digital-only, Both games include shooting-range maps which prominently feature a large, grey
orange gun reticle. shooting target with orange dividing lines. Both targets are circular in nature but placed
on a square board with different texture corner pieces.
Preparing Firing
Valorant
Hyper
Front
2
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

DAMAGE OUTPUT COMPARISON
Name Distance Damage Name Distance Damage
Head Body Legs Head Body Legs
Sidearms
Classic 0-30m 78 26 22 M92 0-20m 79 27 23
Shorty 0-7m 24 12 10 Sawed-Off 0-7m 50 25 21
Frenzy 0-20m 78 26 22 CZ75 0-15m 74 25 21
Ghost 0-30m 105 30 25 USP 0-20m 106 31 25
Sheriff 0-30m 159 55 46 Heavy Pistol 0-30m 159 56 46
Sub-Machine Guns
Stinger 0-20m 67 27 22 UMP 0-20m 90 30 25
Spectre 0-20m 78 26 22 Vector 0-15m 77 25 20
Uzi* 0-20m 51 29 26
P90* 0-15m 76 26 22
Shotguns
Bucky 0-8m 40 20 17 M870 0-8m 70 35 30
Judge 0-10m 34 17 14 AA12 0-8m 58 29 24
Rifles
Bulldog 0-50m 115 35 29 QBZ 0-50m 115 34 29
Guardian 0-50m 195 65 48 MK14 0-50m 196 66 50
Phantom 0-15m 156 39 33 M4A1 0-15m 152 38 32
Vandal 0-50m 160 40 34 AK 0-50m 155 40 32
FAL 0-50m 125 37 31
SCAR* 0-30m 160 40 34
Sniper Rifles
Marshal 0-50m 202 101 85 R93 0-50m 200 100 84
Operator 0-50m 255 150 120 Barrett 0-50m 256 151 128
SVD* 0-50m 156 100 56
Machine Guns
Ares 0-30m 72 30 25 Knight 0-30m 70 28 26
Odin 0-30m 95 38 32 M249 0-30m 94 37 33
UltiMax* 0-30m 72 30 25
Melee
Knife N/A N/A N/A N/A Knife N/A N/A
* Weapons shown in green are only available via Hyper Front’s ‘Weapon Research’ functionality whereby guns are unlocked once players have completed certain in-game missions.
Even where there are differences in damage numbers, these are often minimal and will have little / no actual impact on gameplay. For example, while the Vandal in Valorant has a headshot
damage of 160 but the AK in Hyper Front only does 155 headshot damage, both will kill an enemy in a single headshot (when wearing full armour, players in both games have only 150 units
of health / armour).
2
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

WEAPON CAPABILITIES COMPARISON
Name Type Magazine Size Fire Rate Name Type Magazine Size Fire Rate
(round/s) (round/s)
Sidearms
Classic Pistol 12 6.75 M92 Pistol 12 6.6
Shorty Sawed-Off Shotgun 2 3.33 Sawed-Off Sawed-Off Shotgun 2 3.3
Frenzy Semi-auto Pistol 13 10 CZ75 Semi-auto Pistol 13 10
Ghost Silenced Pistol 15 6.75 USP Silenced Pistol 15 6.6
Sheriff Revolver 6 4 Heavy Pistol Revolver 6 4
Sub-Machine Guns
Stinger Regular SMG 20 16 UMP Regular SMG 25 10
Spectre Silenced SMG 30 13.33 Vector Silenced SMG 28 13.3
Uzi* Regular SMG 20 17.9
P90* Regular SMG 50 14.2
Shotguns
Bucky Pump-action shotgun 5 1.1 M870 Pump-action shotgun 6 1.1
Judge Automatic Shotgun 7 3.5 AA12 Automatic Shotgun 7 3.5
Rifles
Bulldog Full auto rifle 24 10 QBZ Full auto rifle 24 9.1
Guardian Single shot rifle 12 5.25 MK14 Full auto silenced rifle 12 5.2
Phantom Full auto silenced rifle 30 11 M4A1 Full auto silenced rifle 30 11.1
Vandal Full auto rifle 25 9.75 AK Full auto rifle 30 10
FAL Full auto rifle 20 7.6
SCAR* Full auto rifle 25 9
Sniper Rifles
Marshal Bolt action (1 zoom 5 1.5 R93 Bolt action (1 zoom 5 1.4
level) level)
Operator Bolt action (2 zoom 5 0.6 Barrett Bolt action (2 zoom 5 1
levels) levels)
SVD* Full auto sniper rifle (2 20 4
zoom levels)
Machine Guns
Ares Full auto machine gun 50 13 Knight Full auto machine gun 50 6.6-13.3
Odin Full auto machine gun 100 12 M249 Full auto machine gun 80 8.3-15.6
UltiMax* Full auto machine gun 50 5-13.3
Melee
Knife N/A N/A N/A Knife N/A N/A N/A
* Weapons shown in green are only available via Hyper Front’s ‘Weapon Research’ functionality whereby guns are unlocked once players have completed certain in-game missions.
2
Claim No. IL-2022-000094
B E T W E E N:

USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED



PTE LTD
Defendants

WEAPONS COMPARISON
Classic (Valorant) / M92 (Hyper Front)
Classic (Valorant) M92 (Hyper Front)
2
Shorty (Valorant) / Sawed-Off (Hyper Front)
Shorty (Valorant) Sawed-Off (Hyper Front)
3
Frenzy (Valorant) / CZ75 (Hyper Front)
Frenzy (Valorant) CZ75 (Hyper Front)
4
Ghost (Valorant) / USP (Hyper Front)
Ghost (Valorant) USP (Hyper Front)
5
Sheriff (Valorant) / Heavy Pistol (Hyper Front)
Sheriff (Valorant) Heavy Pistol (Hyper Front)
6
Stinger (Valorant) / UMP (Hyper Front)
Stinger (Valorant) UMP (Hyper Front)
7
Spectre (Valorant) / Vector (Hyper Front)
Spectre (Valorant) Vector (Hyper Front)
8
Bucky (Valorant) / M870 (Hyper Front)
Bucky (Valorant) M870 (Hyper Front)
9
Judge (Valorant) / AA12 (Hyper Front)
Judge (Valorant) AA12 (Hyper Front)
10
Bulldog (Valorant) / QBZ (Hyper Front)
Bulldog (Valorant) QBZ (Hyper Front)
11
Guardian (Valorant) / MK14 (Hyper Front)
Guardian (Valorant) MK14 (Hyper Front)
12
Phantom (Valorant) / M4A1 (Hyper Front)
Phantom (Valorant) M4A1 (Hyper Front)
13
Vandal (Valorant) / AK (Hyper Front)
Vandal (Valorant) AK (Hyper Front)
14
Marshal (Valorant) / R93 (Hyper Front)
Marsal (Valorant) R93 (Hyper Front)
15
Operator (Valorant) / Barrett (Hyper Front)
Operator (Valorant) Barrett (Hyper Front)
16
Ares (Valorant) / Knight (Hyper Front)
Ares (Valorant) Knight (Hyper Front)
17
Odin (Valorant) / M249 (Hyper Front)
Odin (Valorant) M249 (Hyper Front)
18
Knife (Valorant) / Knife (Hyper Front)
Knife (Valorant) Knife (Hyper Front)
19
Claim No. IL-2022-000094
B E T W E E N:

(A company incorporated in the state of Delaware, USA)

Claimants
- and -
(1) NETEASE, INC.


LIMITED


(5) NETEASE INTERACTIVE ENTERTAINMENT PTE LTD

Defendants
_______________________________________________
CLAIMANTS’ INITIAL DISCLOSURE LIST

_______________________________________________
Pursuant to Paragraph 5.1 of CPR Practice Direction 57AD – Disclosure in the Business and
Property Courts, the Claimants list below the key documents on which they have relied (expressly
or otherwise) in support of the claims advanced in their Particulars of Claim (“PoC”) and the key
documents that are necessary to enable the Defendants to understand the claim they have to meet.
All documents listed below are provided herewith.
Document Document Document Name/Description PoC

No. Date Paragraph
1. 03.10.2022 Screenshots evidencing nominations and 4
awards
2. 22.09.2022 Screenshot of playvalorant.com showing 10
promotion of “sharp gunplay”
3. 14.09.2022 Screenshot of YouTube video of promotional 10
video for “Project M” showing promotion of
“sharp gunplay”
4. 10.10.2013 CONFIDENTIAL Intercompany Agreement 14 / 19
5. 31.12.2019 CONFIDENTIAL Intercompany Agreement 14 / 19
6. 08.04.2020 US Copyright Registration (no. PA 2-237-813) 15
for Valorant in the name of the First Claimant
9. 05.09.2022 Cayman Islands Search Report for First 21
Defendant
10. 08.09.2022 Screenshot of www.neteasegames.com showing 22
name of First Defendant in footer
11. 08.09.2022 Screenshot of www.hyper-front.com showing 22
name of First Defendant in footer
12. 19.07.2022 Press release – launch of Hyper Front in 22
Europe
13. 08.09.2022 Screenshot of Companies House records for the 23
Second Defendant
14. 08.09.2022 Screenshot of www.neteasegames.com showing 23
description of the NetEase UK office
15. 06.09.2022 Hong Kong Document Index Search for Third 24
Defendant
16. 26.11.2021 Annual Return of Third Defendant 24
17. 20.09.2022 Screenshot of Privacy Policy and User 24
Agreement available in iOS version of Hyper
Front showing name of Third Defendant
Agreement available in Android version of
Hyper Front showing name of Third Defendant
19. 06.09.2022 Hong Kong Document Index Search for Fourth 25
Defendant
20. 22.07.2022 Annual Return of Fourth Defendant 25
Agreement available on Hyper Front page of
Apple App Store showing name of Fourth
Defendant
Agreement available on Hyper Front page of
Google Play store showing name of Fourth
Defendant
23. 22.09.2022 Business Profile of the Fifth Defendant 26
Agreement on Hyper Front website showing
name of Fifth Defendant
25. 20.09.2022 Screenshots of Hyper Front being made 43
available for download and play in the UK via
Apple App Store
26. 20.09.2022 Screenshots of Hyper Front being made 43
available for download and play in the UK via
Google Play store

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Riot Games vs. NetEase

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Claim No.

(1) RIOT GAMES, INC.

(2) RIOT GAMES LIMITED

(1) NETEASE, INC.

(2) UK NETEASE INTERACTIVE ENTERTAINMENT

(3) HONG KONG NETEASE INTERACTIVE

(4) NETEASE ENTERTAINMENT LIMITED

(5) NETEASE INTERACTIVE ENTERTAINMENT

Valorant and Hyper Front

2. Valorant is a free-to-play, first-person-shooter, video game which was

(1) Teams of 5 players compete against one another in matches

(2) The game is set in a near-future sci-fi world.

(3) Players can select one of a number of characters (Agents) to

(4) Each Valorant Agent has particular characteristics (Agent

(7) At the start of the Unrated, Competitive and Replication

(9) In Deathmatch games, the aim is to kill as many other players

(10) Players can select from a range of Weapons of particular designs

(11) There is a graphical user interface (GUI) which, in addition to

4. The first claimant started development of Valorant in 2014. In or about

5. On 2 June 2021, the first claimant announced that it was developing a

6. Hyper Front is also a free-to-play, first-person-shooter video game

7. Hyper Front is available for download in the United Kingdom (and in

8. As appears more particularly below and in the annexes accompanying

(1) Hyper Front is a copy of substantial parts of Valorant.

(2) Having regard to the extensive similarities between Hyper Front

9. The development and release history of Hyper Front is as follows

(1) Development started in or about March 2020 (after the first

(2) An open beta of Hyper Front was published in about August

(3) A closed beta of Hyper Front was subsequently made available

(4) On 20 January 2022 Hyper Front was released for download in

10. Valorant was promoted as having amongst other things sharp

12. In these particulars of claim

(2) Initial Disclosure means the initial disclosure of documents

(3) In the following, Hyper Front means (except where the

(4) The claimants complaint of copyright infringement concerns

(5) The claimants do not complain of infringement of copyright in

The claimants and the creation of Valorant

13. The first claimant is a company incorporated in Delaware, United

16. Valorant was created by numerous employees of and contractors to the

17. As regards the Developers

The defendants: NetEase

21. The first defendant is a company registered in the Cayman Islands. It

23. The second defendant is UK company no. 12274781 incorporated on 22

24. The third defendant is a company registered in Hong Kong. It is the

25. The fourth defendant is also a company registered in Hong Kong. It is

26. The fifth defendant is a company registered in Singapore. It is the

Copyright subsisting in Valorant

(1) The works consisting of all the individual frames displayed on

(2) The works comprising the movements displayed on a players

(5) The work comprising the game of Valorant as a whole, that is to

32. Each of the Valorant Works is a work in which copyright subsists

(3) If, contrary to sub-paragraph (2) above, any of the Valorant

33. With regard to the Valorant Works

(5) The Valorant Game as a whole is (a) an original dramatic and

The Valorant Game Work

35. Hyper Front is a copy of substantial parts of the Valorant Game. In

(2) The Game Modes: see Annex 1.

(3) The characteristics of the Heroes in Hyper Front are copies of

(3) Players can select one of a number of characters (Agents) to

(4) Each Valorant Agent has particular characteristics (Agent

(7) At the start of the Unrated, Competitive and Replication

(9) In Deathmatch games, the aim is to kill as many other players

(11) There is a graphical user interface (GUI) which, in addition to

9. The development and release history of Hyper Front is as follows

(2) An open beta of Hyper Front was published in about August

(3) A closed beta of Hyper Front was subsequently made available

10. Valorant was promoted as having amongst other things sharp

12. In these particulars of claim

(2) Initial Disclosure means the initial disclosure of documents

(3) In the following, Hyper Front means (except where the

(4) The claimants complaint of copyright infringement concerns

17. As regards the Developers

(2) The works comprising the movements displayed on a players

33. With regard to the Valorant Works

39. The Sound Effects relied upon are as follows

40. The claimants complain of the following

45. The defendants have acted in flagrant disregard of the claimants

AND THE CLAIMANTS CLAIM