Character Names, Copyright, and RPGs #RPG #DnD #ADnD #copyright

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I’m designing a database for 1st Edition Dungeons & Dragons and am close to finishing the data entry on spells. This brought a copyright issue to the forefront. Characters can be copyrighted. This isn’t a controversial position. However, the name of a character is not copyrightable, and unless a name is used as a brand for your line of products, it doesn’t even receive the (much weaker) protection of trademark. So why does everyone remove proper names from spell names when referencing D&D spells?

Copyrighting a Single Word or Short Phrase

While there is no “bright line” rule stating a minimum number of words necessary to secure a copyright, it’s well settled that a short phrase is not copyrightable. Either they lack tiny amount of creativity necessary for copyright (thus likely representing independent creation) or the merger doctrine applies. A simple Google search will uncover a multitude of articles supporting this notion.

Only nothing at all is more minimal than a single word, so there’s no doubt (outside of Poland) that a single word can’t be copyrighted. But even a short phrase, such as the name of a spell, can’t be copyrighted, especially where it’s descriptive of the mechanics of the spell (mostly the case).

The Nichols Case and Copyrighting Characters

The standard for copyrighting characters comes from Nichols v. Universal Pictures Corp., 45 F.2d 119 (2d Cir. 1930), in which the Court stated:

If Twelfth Night were copyrighted, it is quite possible that a second comer might so closely imitate Sir Toby Belch or Malvolio as to infringe, but it would not be enough that for one of his characters he cast a riotous knight who kept wassail to the discomfort of the household, or a vain and foppish steward who became amorous of his mistress. These would be no more than Shakespeare’s “ideas” in the play. . . . It follows that the less developed the characters, the less they can be copyrighted; that is the penalty an author must bear for marking them too indistinctly.

45 F.2d 119, 121 (2d Cir. 1930). This has since become known as the “well delineated character” test.

Can a spy be protected? Of course not. What if that spy uses sex as a tool of the trade? Don’t all spies (at least in fiction) do that? How about if he’s a martini drinker? Hmm, that sounds familiar. “Shaken not stirred”? Well. . . . Eventually, we get to the specific character of James Bond, and he’s certainly a copyrighted character, but it took a bit of detail beyond his name to get there. If I created a fictional character of James Bond who was an accountant, I’d be just fine. In fact, I could even have him joke, “I’m not that James Bond.” I’m not using Ian Fleming’s James Bond, just referencing him, and to the extent James Bond is trademarked, readers will understand from context that I don’t have the endorsement of whoever currently owns the character.

The less common, “story being told” test isn’t relevant here, but in case you’re interested, see Warner Bros. Pictures v. Columbia Broadcasting Sys., 216 F.2d 945 (9th Cir. 1954), cert. denied, 348 U.S. 971 (1955) (“It is conceivable that the character really constitutes the story being told, but if the character is only the chessman in the game of telling the story he is not within the area of the protection afforded by the copyright.”).

Elsewhere when discussing the precise boundaries of copyright as it related to plays, the Nichols Court went on to add that, “[n]obody has ever been able to fix that boundary, and nobody ever can.” Nichols at 121. That makes copyright hard, but it’s not impossible, and sometimes it’s even easy. A name cannot be protected by copyright, even within the context of a spell name of a few words.

Tenser’s Floating Disc

So why do so many of you seem to think that you’re avoiding copyright infringement by avoiding writing, “Tenser’s Floating Disc,” “Mordenkainen’s Magnificent Mansion,” and “Tasha’s Hideous Laughter”? Based solely on the text of the spell as written, can you tell who Mordenkainen is? Is Mordenkainen the wizard that wrote the spell? The wizard’s significant other, child, or pet? The name of the Wizard’s favorite watering hole anthropomorphized into the owner of a mansion? Even if the original spell as written by TSR contained the answers to such questions in sufficient detail to flesh out the character (it didn’t even try), a reproduction of the spell not including such information, but rather limited to the spell’s mechanical effects, wouldn’t infringe on the character of Mordenkainen just by using the name. The name isn’t what’s copyrighted; the combination of several traits defining the character are, but they’ve been left out.

Seriously? You think WotC can restrict use of the name, Tasha?

This is as ridiculous as, for example, using the word “Forgeborn” for “Warforged” as if WotC owns the word, “Warforged,” and that use of “Forgeborn” relieves the writer of any infringement of WotC’s text describing the species. Such a writer is focusing on the wrong thing. Think of it this way: If you think that dropping the name off of the spell cures your text of copyright infringement, then you concede my point that spell text describing the mechanical effect of a spell within the context of an RPG isn’t usually copyrightable. Great! However, you then must be thinking** that the name itself is where the copyright lies. That can’t possibly be true. It flies in the face of every knowledgeable commentator (again, outside of Poland) that’s ever addressed the issue.

** Unless, of course, you’re still under the mistaken impression that the OGL is somehow a valid contract, and that its terms, if taken seriously, wouldn’t constitute copyright misuse. But if you really want to know why that’s silly, you’ll have to read that long post.

There’s absolutely no legal reason not to use those names in spells, and it doesn’t hurt WotC at all to use them (other than perhaps robbing their arrogant legal department of their hubris). Why is this important? Because there are too many misconceptions about copyright law that have had far reaching consequences to the gaming industry and the gaming community in general. The text of the Open Gaming License and System Reference Document collectively foster this misinterpretation, and I suspect (can’t prove) that’s an intentional scam. If WotC legal gets you to focus on the word, “Tasha,” but does nothing to stop you from copying the text of the spell, then you still may be infringing whatever copyright they arguably have. If you do something that’s 100% legal later down the road, but it’s something they don’t like, they can go after you for that infringement. As I’ve discussed elsewhere, this can often lead to copyright misuse, but most gamers aren’t sophisticated or wealthy enough to hit back on those grounds. More importantly to the community as a whole, while using these names in spells is not creative on your part, your misconceptions eventually lead down the road of stifling your own creativity. The purpose of copyright is to promote creativity. When copyright law stifles creativity, its entire purpose vanishes, in which case we may as well not even have copyright.

You can’t know what you can’t do unless you also know what you can do.

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Dungeons & Dragons is a trademark of Wizards of the Coast, LLC, who neither contributed to nor endorsed the contents of this post. (Okay, jackasses?)

Why the Death of Humor Is No Laughing Matter @thejoelstein #joke #comedy #humor

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Sorry, but it’s time for another serious and long post.

I came across an article from the Stanford Graduate School of Business last week. It cites a study that demonstrates the importance of humor to the human psyche, which in turn correlates (and presumably is the cause of) health benefits. This doesn’t surprise me at all. The subject of this post is something that wasn’t the immediate concern of the author but is quite important and was lurking in his own text.

Scrolling down a bit, you’ll find a graphic containing four quadrants. I’ve recreated the graphic here using the advanced graphic techniques of MS Word.

This chart sums up the arguments of the author. It says a few things that are relevant. First, it claims that making jokes is a good thing even if you bomb. Everyone bombs, but people respect the effort. As I’ve stated before, I have no disagreement with this. You can and should bomb as long as you learn from the mistake. Second, it states that the degree to which you generate laughter is irrelevant if the joke itself is inappropriate. In theory, I agree with this, but I have a real problem with the direction Americans are going in labeling everything as offensive. Case and point:

Microsoft feels the need to warn you about naughty language.

Clearly, if your audience is a room full of Klansmen, then you can bring down the house and still be a villain as the chart states. However, most audiences aren’t 90% or better Klansmen, yet there’s a horrible trend towards labeling everything as offensive. To justify the position, the habitually-offended simply label anyone that laughs at anything they don’t like as a Klansman, Nazi, or anything else that allows them to mask their unreasonable offense as reasonable. This, of course, leads to real harm to people’s lives, but I’m not going to dive into that. I’m instead going to point out two other consequences that concern me: Killing comedy by limiting its subject matter, and a more general problem (beyond comedy) of reasonableness transforming from a community standard to an individual standard. As to the first issue, no where was this more apparent than the show, Brooklyn 99.

Limiting Subject Matter

After seeing tons of YouTube videos containing various characters’ best moments, I decided Brooklyn 99 was probably my kind of show, so it became the latest binge watch for me. It’s clear that the writers were very talented. There were funny jokes, many characters were endearing, and there were some recurring themes (e.g., the Halloween heists) and wonderful catchphrases that these writers wisely knew not to overdo (a common error among their colleagues).

Bing-pot! - Album on Imgur

That’s great, but after five seasons, Fox cancelled it. Many were incensed, but it was cancelled because the ratings were poor. After a Star Trek-esque fan campaign, it was then picked up by NBC, but the coming 8th season will be its last. This despite the network change inevitably drawing in at least some viewers that had never seen it when it was on Fox. Despite the vocal minority of diehard fans, the show clearly couldn’t keep anyone’s attention for long. Why not? Because, contrary to the assertion of the linked article (citing writer Michael Lewis), writing jokes today absolutely carries a risk, and the writers didn’t want to bear that risk. It was clear that they were going out of their way to walk the tightrope of avoiding outrage at the hands of this vocal, minority (some of whom wouldn’t necessarily be fans of the show), but ultimately that small audience can’t support the show. When the habitually-outraged tie the hands of comedy writers, we get a modified chart.

Very little is considered appropriate by the habitually-outraged, and that small sliver of acceptable comedy that’s left can’t maintain anyone’s interest for very long. I finished it only because I can’t help myself. Once I start a task, whether business or personal, I have to complete it, which is why I generally don’t binge-watch TV shows if I see they have that many seasons. I took a chance on this one and was ultimately disappointed in the last few seasons. Despite its several strengths, it became a chore to finish it, and not because it jumped the shark. It never reached such a height. Rather, it simply grew into a tedious retread of boring, unchallenging stories because the jokes had almost no chance of offending anyone. Even where it comes to non-comedic material, it was predictable. If you didn’t know “whodunnit?” as soon as the bad guy first hit the screen, you’re an idiot. The villains were all telegraphed because the formula was always the same. Moreover, I wanted to throw Charles, Hitchcock, and Scully out a window 30 stories up, though that started within a couple of seasons. They were frustrating characters.

But killing comedy is merely a symptom of an insidious disease.

The Standard of Reasonableness

Everyone is offended by something, and that’s fine, but too often I hear the line, “You have no right to tell me whether I’m offended.” The fact that people say that means they’re missing the point. Absolutely no one is doubting you taking offense. What we’re saying is that you’re being ridiculous for doing so. But even that isn’t the problem. It would be utterly ridiculous for you to be offended by me wearing a blue shirt simply because your dad died while wearing an orange shirt (the other end of the color wheel), but it’s okay if you are. You can’t help that. Humans are emotional creatures, and certain associations will always result in illogical reactions. However, you shouldn’t impose that offense on me by demanding I always wear an orange shirt for the rest of my life.

And that’s the crux of problem. Any one element that’s deemed offensive by the online mob is composed of a miniscule percentage of people (some of whom aren’t tied to the subject matter at hand), but everyone is afraid to incur the wrath of that mob. Moreover, because these internet tough guys aren’t content with just changing the channel, but rather insist everyone get in line with their sensibilities, far too much content is labeled taboo for everyone, and we’re left with the modified chart similar to the one above for all areas of life, not just comedy. If you disobey, you’re given a horrible label that, without being questions, can cause you to lose your job, friends, and even family. This isn’t imposing accountability; it’s imposing the insecurity-driven whims of the individual on all of us. Throughout history, vigilante mobs have always swept up more innocents than the guilty because there are no protections from false accusations.

This is a troubling trend that those currently on that side are blind to. Rather than “reasonableness” being defined by the community, it’s being defined by each person on an individual basis. Going back to my crass example, if Mary’s dad died wearing a blue shirt, and Mary gets to define for me what’s reasonable, then I always have to wear an orange shirt. However, Joe’s dad died while wearing an orange shirt, so Joe demands I always wear a blue shirt. Then there’s Sally, who’s dad died while trying to break the Guinness Book of World Records record for wearing the most shirts at once (it’s 260, and as far as I know, Ted is fine), and she demands I wear no shirt at all. Finally, there’s Aloysius, and he demands I always wear a shirt with both blue and orange in it because of some other insanity I’m too lazy to invent. So, no matter what choice I make, I’m always going to offend three (a majority) of these four people, even though the majority (three) of all five of us aren’t offended by whatever choice I make. This places me in an impossible position, even though I’m not addressing the demands of 7.5 billion humans, 325 million Americans, 8.5 million Virginians, 1.1 million . . . Fairfax Countyans(?), or even 47,000 McLeananites (copyright 2021, me [not really]). Use any of those numbers, and seemingly ordinary actions or words will result in the same sort of no-win scenario. This is precisely why reasonableness must remain a community standard. We, not a few habitually-outraged, internet tough guys, should set that standard.

As bad as tyranny by the majority is, tyranny by the minority is much, much worse. We strike that balance legally by having a Constitutional democracy where a supermajority (still democratic!) creates fundamental rights that supersede the passing whims of the cops or even the legislature, protecting the individual, but still ultimately subjecting us all to the broader strokes of the majority. Your right to impose your insecurities upon the rest of us by suppressing speech is not the sort of fundamental right that’s necessary to preserve your individual dignity. Or at least it shouldn’t be, because it in fact suppresses an actual fundamental right in the internet age, where Town Square is now in the hands of the private sector. But if we can’t enjoy even jokes, there’s no hope for finding compromise on more difficult issues.

If you were looking for a miracle cure for what ails us, you’ve come to the wrong blog, but apparently our lives depend on it.

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@Facebook: See You Next Tuesday #Facebook #censorship

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Well, it’s Tuesday, so my second Facebook suspension is winding down. During this “one-day became three-day became four-day” suspension, I was unable to manage my charitable fundraiser for the Juvenile Diabetes Foundation, all because Facebook is afraid of people having opinions (though my expressed opinion was clearly a joke).

I see no reason to delete my Facebook account, because I’m still able to communicate with people via Messenger. After all, the whole point of social media isn’t to solve the world’s sociopolitical problems, but rather to connect. And share cat memes. However, I’m quickly shifting my focus to MeWe. My profile can be found here: https://mewe.com/i/robertbodine1. The problem with MeWe is that it’s not very good for building networks, which, again, is the point of its existence. The only way to find people is to know they’re there. So please, if you’re considering an alternative to Facebook, give MeWe a try, and invite as many people as you can to do the same. I suspect it’s only a matter of time before Facebook runs afoul of antitrust law. You may find yourself making a change eventually.

Facebook should be ashamed of itself, but it isn’t.

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@Facebook Screws up . . . Again! #Facebook #censorship

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Less than an hour ago, I deleted a post from this Twitter account. It’s my daily, automated paper, and because this account is meant to be fun and/or silly, I use every filter at my disposal to make sure nothing too serious appears in that paper. Unfortunately, that doesn’t always work, and today’s paper included articles I simply didn’t want appearing on this stream. That said . . . .

I have to share this bullshit. I just got this message from Facebook.

This is clearly a joke, I can’t imagine why they would even hide the post, let alone give me a 24-hour ban (UPDATE: 3 days now, including my birthday). Ironically, I received this ban on the day I received my first vaccine shot.

Let me remind you of the problem with Facebook, et al. In the old days, the ordinary citizen’s standard means of political discourse was to stand in the middle of town square, get on a soap box, and bitch. Such acts would result in counterarguments from the crowd, but even more importantly the bystanders got to listen and form opinions somewhere in the middle of the lunatics. Because town square is public property, the Free Speech clause protected such discourse. Now the ordinary citizen’s standard is to use social media, and it’s what everyone relies upon for such discourse. The problem is that social media platforms are private property, and even clear jokes can be censored legally. Speech is going to be chilled at a time when we need reasonable discussion — and a sense of humor — the most. Our only recourse will be antitrust law, and Twitter has certainly flirted with that in the Parler case (see the section entitled This Isn’t the End of the World, but It’s No Small Matter), but it’s going to be a long time before that dust settles and the common person’s everyday speech will once again be free.

UPDATE!!!! Facebook has decided to extend my suspension to three days, which means I won’t be able to thank anyone for all the birthday wishes I’m sure to receive on Monday. If you’re reading this, thanks in advance. Also, my MeWe profile is at https://mewe.com/i/robertbodine1. Just sayin’. No reason.

Side note: I tried to use the back door that used to work but apparently no longer does. I posted to Instagram, which shares to Facebook automatically. Unfortunately, my post violated community standards over there. I’m going to try again but with a picture of a kitten. We’ll see what happens.

Facebook should be ashamed of itself, but it isn’t.

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Litigation Sucks @mc_frontalot #lawyer #litigation

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Sundays are now lazy days for me. Going forward, I’m just going to re-post other people’s work or just do something silly. Today it’s a comic that hits home.

Image

I’ve been there, but the damn judge told me, “Yes, you are. Now get to it.” H/T @mc_frontalot

Litigation sucks. Never again.

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Good Watch: The Trial of the Chicago 7 @SachaBaronCohen @hitRECordJoe @netflix #GoodWatch

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I hate courtroom dramas. While I’m not a litigator, I can spot the nonsense when I see it, and legal dramas are always about “drama” first and “legal” last. The same is true for any industry. Some liberties were taken with the story, but based on a little research, this movie largely gets it right. And that story is frustrating. From Wikipedia:

Based on the story of the Chicago Seven, a group of eight defendants charged by the federal government with conspiracy in 1969 and 1970, inciting to riot, and other charges related to anti-Vietnam War and countercultural protests that took place in Chicago, Illinois, on the occasion of the 1968 Democratic National Convention.

The trial was a mess. The judge (ironically) showed nothing but contempt for the defense. All of the charges, including the numerous contempt charges, were overturned on appeal. The Seventh Circuit ordered a new trial, which the Attorney General declined to pursue.

Sacha Baron Cohen was awesome. Joseph Gordon-Levitt was awesome. Yahya Abdul-Mateen II was awesome. Mark Rylance was awesome. Frank Langella was awesome.

The Trial of the Chicago 7 is streaming on Netflix. There’s no reason not to watch this movie. As always, YMMV.

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The Merger Doctrine of Copyright Law #iplaw #law #copyright

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Blog posts cannot substitute for legal advice. If the topics discussed in this post are relevant to a real case you have, please consult an attorney.

This one’s a little dry, but it’s secretly relevant to the interests of the majority of readers of this blog. Also, it’s short.

A copyright protects the expression of an idea. For example, an author can write a poem about springtime, and because the text is sufficiently complex, it can give rise to a copyright as long as there’s at least some reasonable amount of creativity (a.k.a., originality) in that text. However, that doesn’t mean the author now owns the idea of springtime; the author owns only the particular expression of it (and all “substantially similar” variations of it). The reason the idea isn’t protected, but the expression is, should be obvious: If an author copyrighted the idea, then no one else could write about springtime during the life of the copyright. The public must be able to discuss springtime. It’s part of life. (Note: This is also why a single word is never sufficiently complex to earn a copyright. If someone could copyright the word, “spoon,” then the public couldn’t discuss spoons for quite some time.) On the other hand, the author’s particular expression of springtime can be copyrighted because there are a seemingly infinite number of ways for the rest of the public to write about springtime. That is, there are many other options that will allow others to write about springtime while still allowing the author the sole right to copy and profit off of their particularly clever and enjoyable expression, as well as any substantially similar variations of it. This is the essence of copyright.

However, what if there aren’t a seemingly infinite number of ways to express and idea, or what if all the other ways to express it are all substantially similar to one another? This is where the merger doctrine comes into play. In such a case, the expression is said to merge with the idea, such that the expression cannot be copyrighted regardless of how complex the expression is, and regardless of whether the author was actually the first person ever to express it. (In the case of my example of a poem about springtime, that was first done long before the concept of copyright existed.) This is an important doctrine for the reason given above: If not for the merger doctrine, in situations where there aren’t a reasonable number of options available to express and idea, then no one would be able to express it as long as that copyright exists. That is, the copyright would effectively extend to the underlying idea itself. Under current law, the term of copyright is far too long in my opinion, but even if the term of copyright were more reasonable, any amount of time to prohibit expression of an idea is too long. Fortunately, the law recognizes that.

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Rob Bodine is a Virginia attorney focusing his practice on real estate and intellectual property law. He’s currently Virginia counsel with Cardinal Title Group, a Virginia title insurance and settlement company. Rob is also a licensed title insurance agent in Maryland and Virginia.

The First Sale Doctrine #iplaw #law #copyright

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Blog posts cannot substitute for legal advice. If the topics discussed in this post are relevant to a real case you have, please consult an attorney.

A copyright is a bundle of exclusive rights, including the right to make copies of an item, However, once someone purchases a copy of a copyrighted work, the purchaser owns that specific copy of that work. For example, if Ann purchases a copy of Bob’s book, Ann may not make copies of that book, but she may resell the specific copy she purchased without fear of infringement.

This gets a bit more complicated with respect to the resale of software. Most software comes with a “shrinkwrap license,” which is a contract packaged with the software. Under the terms of such a contract, just using the software is considered acceptance of the terms of that contract, and those terms indicate that software is merely licensed to rather than owned by the purchaser. If there isn’t actually a sale, then does the “no transfer” clause in the license prevent resale?

In Vernor v. Autodesk, Inc., Vernor was reselling unused copies of Autodesk’s “Release 14” auto-cad software on eBay. In determining that Vernor was a licensee rather than an owner of a copy, the Court developed and applied a three-part test: (i) whether the copyright owner specifies that a user is granted a license; (ii) whether the copyright owner significantly restricts the user’s ability to transfer the software; and (iii) whether the copyright owner imposes notable use restrictions.

Note that this is an exception applicable to digital works. In the context of nondigital, copyrighted works, the first-sale doctrine still applies but may be limited in cases involving illegally obtained goods. If you steal it, you can’t resell it.

Summary

  1. Once you purchase a copy, the First Sale doctrine allows you to dispose of that particular copy as you see fit.
  2. Most software is licensed, not sold, so the First Sale doctrine doesn’t apply.
  3. You can’t rely on on the First Sale doctrine when selling stolen goods.

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Rob Bodine is a Virginia attorney focusing his practice on real estate and intellectual property law. He’s currently Virginia counsel with Cardinal Title Group, a Virginia title insurance and settlement company. Rob is also a licensed title insurance agent in Maryland and Virginia.

Pinned Post: Looking at My Stats and Revisiting My #RPG #Copyright Posts

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The quarantine has me doing a bit of blogging lately, which means I’m also looking at my stats. With respect to my posts regarding copyright and RPGs:

The posts are broken into two separate issues. Part 1 and part 2 are about the copyrightability of RPG stat blocks, and part 3 (not relevant here) is about the OGL. As to the first issue, to date, part 1 represents ~30% of text by page count and has 17,037 hits (edit 10/20/2020: 17,667 hits), whereas part 2 (70%) has only 704 hits (edit 10/20/2020: 802 hits). Moreover, part 1 spends much of its text on going over basic copyright principles that don’t represent the actual argument. It’s clear by the stats and the basis of the criticism itself (often peppered with personal insults) that the vast majority of (non-lawyer) criticism I’ve received is from people that have read only 30% (at most) of that argument. I know it’s long, convoluted, and at times poorly written (mostly because it targets two very different audiences); and you’re under no obligation to read it (or even care about it). However, it’s all connected, and if you’re going to criticize it, you should probably understand it first.

Or not. Free speech and all that.

Endnotes:

  • Part 3 has only 703 hits (edit 10/20/2020: 849 hits), which is surprising. I thought it would be the most read post.
  • Part 3.5 provides necessary clarification and correction to Part 3.
  • Part 4 answers frequently ask questions and addresses frequently raised issues.
  • Over on a lawyers-only subreddit, the attorneys seemed to want to discuss only my side note on patentability of the Shadow of the Demon Lord initiative system. I guess it’s great that they all agree that my argument is trivially correct, but Rob Schwalb has seriously hijacked my glory. I let him have it when I saw him last February.
  • Stat blocks for the 5e Monster Manual are here.

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