Can You Inherit a Steam Account? Digital Asset Inheritance Under US, Chinese, and EU Law

The Inheritance of Licensed Digital Goods: What Steam Accounts and Skins Reveal About Digital-Platform Durability

1. Summary

Mainstream digital goods on storefronts like Steam typically do not pass to heirs as a matter of right, and this non-transferability is not a bug in the business model but a load-bearing structural feature that protects primary-market revenue, which makes it durable and makes the underlying assets unreliable as stores of value. The controlling instrument is contract, not property law: the Steam Subscriber Agreement grants a personal, non-transferable license, states that content is "licensed, not sold," confers "no title or ownership," and provides that Valve "does not recognize any transfers of Subscriptions (including transfers by operation of law) that are made outside of Steam," which is the specific clause that forecloses inheritance [1]. United States law reinforces rather than overrides this: the Revised Uniform Fiduciary Access to Digital Assets Act governs a fiduciary's access to accounts, not ownership or transferability, and expressly subordinates itself to the platform's terms of service where the user leaves no contrary direction [2][3], while copyright law forecloses any general digital resale right because transferring a file necessarily reproduces it [4] and because restrictive licenses defeat the first-sale doctrine [5].

The three jurisdictions diverge sharply, and that divergence is the cross-border risk. China has moved furthest toward recognizing inheritance: Civil Code Article 127 brings network virtual property within civil-law protection and Article 1122 defines an estate broadly, and Chinese courts have begun ordering operators to assist heirs, treating real-name account linkage as a mere identity-management mechanism rather than a personal right [6][7]. The European Union sits between the two poles: exhaustion can apply to downloaded software under UsedSoft, but the Court of Justice declined to extend digital exhaustion to other content types in Tom Kabinet, treating e-book supply as communication to the public [8][9]. The investment implication is that the storefront and live-service models are structurally protected in the US and EU by the suppression of secondary markets, that a large and observable secondary economy in items and skins (the Counter-Strike ecosystem alone crossed a $6 billion market capitalization on October 17, 2025) exists precisely because it is walled inside platform wallets, and that the principal tail risk is legal reform, most advanced in China, that could compress those protections over a multi-year horizon.

2. Background

A digital-goods transaction that a consumer experiences as a purchase is, in the dominant model, the grant of a revocable license to access content the platform continues to control. This distinction is the analytical foundation for everything that follows, because inheritance of a license is a categorically different question from inheritance of property. If a consumer owned a copy the way one owns a physical book, the copy would pass to the estate and the first-sale doctrine would permit its resale; because the consumer holds only a contractual license, the terms of that contract determine what, if anything, survives death, and whether the holder may transfer it at all.

Two further mechanics matter. First, the license is bound to an account, and the account, not the individual title, is the unit platforms refuse to transfer, so a library of hundreds of games and a wallet balance are all trapped behind a single non-transferable credential. Second, licensed access is revocable and contingent on the platform's continued operation, which means the asset can be extinguished by account termination or platform shutdown regardless of what any inheritance law says. These two features, non-transferability and revocability, are what make the legal analysis in Section 4 economically consequential.

3. Key Players and Stakeholders

Valve Corporation, which operates Steam, is privately held and therefore not directly investable, a fact that is itself analytically relevant: the purest expression of the license-and-wallet model sits outside public markets, and investors can gain exposure to the architecture only through other operators whose models rest on the same foundation. Valve's scale is nonetheless the reference point, with over $4 billion in Steam commission revenue in 2025 at a 90-percent-plus gross margin (including the whole of Counter-Strike 2 and Dota 2 takings), per Alinea Analytics estimates cited by SaaStr and Sacra, and an estimated $16.2 billion in Steam game sales from January to mid-November 2025, a platform record, run on a headcount of roughly 350 employees, per Alinea Analytics as reported by Game World Observer, Tom's Hardware, and Dexerto in November 2025 [10].

Public exposure to the license architecture runs through several operators. Microsoft (NASDAQ:MSFT) operates the Xbox storefront and Game Pass. Sony Group (NYSE:SONY) operates the PlayStation Store. Apple (NASDAQ:AAPL) and Alphabet (NASDAQ:GOOGL) operate the mobile app stores whose in-app-purchase economies rest on the same non-ownership terms. Tencent (HKG:0700) and NetEase (NASDAQ:NTES) are the two dominant Chinese operators, both heavily dependent on in-game virtual-item sales and both exposed to China's divergent inheritance trajectory. Take-Two Interactive (NASDAQ:TTWO) and Electronic Arts (NASDAQ:EA) are publishers whose live-service titles monetize non-transferable in-game content. Roblox (NYSE:RBLX) operates a closed virtual economy whose currency and items are pure license rights confined to the platform. A separate, largely private, estate-technology and digital-legacy service segment has grown up to help executors navigate fiduciary access, but it monetizes the access problem rather than solving the ownership problem, and its relevance to the investment view is secondary.

In terms of hardware production connected to Valve; they have a partnership with Qualcomm (NASDAQ:QCOM) for the Steam Frame VR headset. Steam is working on an architectural framework that will enable mobile chipsets to run Steam games natively. AMD (NASDAQ:AMD), Nvidia (NASDAQ:NVDA) and Intel (NASDAQ:INTC) are primary hardware incumbents for the PC gaming market.

4. Technical, Operational, and Legal Considerations

4.1 The foundational distinction: license, not ownership

The Steam Subscriber Agreement is the primary text, and it is unambiguous. Valve grants "a non-exclusive license and right, to use the Content and Services" for personal, non-commercial use, states that "The Content and Services are licensed, not sold," and provides that "Your license confers no title or ownership in the Content and Services" [1]. The account itself is personal and non-transferable, and the subscriber "may not reveal, share or otherwise allow others to use your password or Account except as otherwise specifically authorized by Valve" [1]. Steam Wallet funds "do not constitute a personal property right, have no value outside Steam and can only be used to order Subscriptions," and, critically, "Steam Wallet funds that are deemed unclaimed property may be turned over to the applicable authority" [1]. There is no published bereavement or account-succession process; Valve's support staff have confirmed in public correspondence that accounts are non-transferable and cannot be willed [11].

4.2 The inheritance-blocking clause

The specific provision that forecloses inheritance is in the marketplace section of the agreement: subscribers acknowledge that marketplace subscriptions "are license rights, that you have no ownership interest in such Subscriptions, and that Valve does not recognize any transfers of Subscriptions (including transfers by operation of law) that are made outside of Steam" [1]. The phrase "by operation of law" is the operative language, because inheritance is precisely a transfer by operation of law. Valve has drafted the agreement to refuse recognition of exactly the mechanism through which an estate would otherwise pass assets to heirs.

4.3 The US fiduciary layer: access is not ownership

The Revised Uniform Fiduciary Access to Digital Assets Act, promulgated by the Uniform Law Commission in 2015 and now enacted in 46 states plus the District of Columbia (with only Louisiana, Massachusetts, and Oklahoma having adopted neither UFADAA nor RUFADAA, and Delaware retaining its own UFADAA version), is frequently misread as a solution to digital inheritance [2][3]. It is not, and the reason is the load-bearing distinction between access and ownership. RUFADAA governs whether a fiduciary (an executor, trustee, agent, or conservator) may access the digital assets of a decedent or protected person; it does not create ownership, does not confer transferability, and expressly limits the fiduciary to the rights the user held [3]. The Act's own drafting notes state that it applies to electronic records in which the user has a right or interest but "do not include the underlying asset or liability unless it is" itself an electronic record, and that the Act does not confer property ownership on fiduciaries or on those who gain access [2].

RUFADAA resolves conflicts through a three-tier priority order. First priority goes to a platform's online tool for designating a successor (such as an inactive-account manager or legacy contact), if the user set one up; second priority to directions in a will, trust, or power of attorney; and third, in the absence of either, to the platform's terms of service [2][3]. This structure is decisive for Steam: because Valve offers no online succession tool and the Steam Subscriber Agreement prohibits transfer, a user who does nothing lands in the third tier, where the terms of service control and the terms forbid inheritance. Even a fiduciary who obtained lawful access under RUFADAA would, in using the account, violate the Subscriber Agreement, exposing the account to termination. The interaction with the federal Stored Communications Act reinforces the access constraint: that 1986 statute bars custodians from disclosing the content of electronic communications without lawful consent, which is why RUFADAA requires explicit user consent before a fiduciary can reach message content [3]. The net effect is that US law hands the estate, at most, a contingent right of access to an account it cannot own, cannot transfer, and cannot use without breaching the very contract that defines it.

4.4 US copyright: no digital first sale, no free transfer

Two lines of authority foreclose a general digital resale or free-transfer right in the US, which matters because a robust resale right would be the market mechanism most likely to force transferability. In Capitol Records, LLC v. ReDigi Inc., 910 F.3d 649 (2d Cir. 2018), the Second Circuit held that the first-sale doctrine codified at 17 U.S.C. Section 109 does not shield the resale of digital music files, because transferring a file over the internet necessarily creates a new reproduction, which implicates the copyright owner's reproduction right rather than the distribution right that first sale exhausts [4]. ReDigi's forward-and-delete technology, designed to ensure only one copy existed at any moment, did not cure the problem, because the reproduction occurs during transfer regardless [4]. The Supreme Court denied certiorari, leaving the holding intact.

The complementary line is the license-versus-sale distinction typified by Vernor v. Autodesk, Inc., 621 F.3d 1102 (9th Cir. 2010), where the Ninth Circuit held that a software user is a licensee rather than an owner, and therefore cannot invoke first sale, where the copyright owner specifies that the user is granted a license, significantly restricts the ability to transfer, and imposes notable use restrictions [5]. Steam's terms satisfy all three prongs by design. Together, ReDigi and Vernor mean that even if an heir somehow obtained files, reselling or redistributing them would infringe, and the licensee status of the original holder means there was never an owned copy to inherit in the first place.

4.5 China: recognition in principle, unsettled in practice

China presents the most divergent and, for investors, the most consequential trajectory. Civil Code Article 127 provides that "Where the law has provisions on the protection of data or online virtual assets, follow those provisions," bringing data and network virtual property within the scope of civil-law protection [6][12]. Article 1122 defines an estate as "the personal lawful property of a natural person left at the time of his death," using an open, general definition that replaced the old enumerated list and thereby creates the doctrinal hook for virtual property to qualify as inheritable [6]. The scholarly consensus, however, is that Article 127 is a guiding or referential provision that does not itself specify rights attribution, valuation methods, or inheritance mechanics, and Chinese academic writing remains divided among competing theories of the legal nature of virtual property [12][13].

The critical analytical move in Chinese scholarship is the distinction between "carrier-type" and "content-type" virtual property, under which the carrier (the account infrastructure) in principle belongs to the operator while the content (items and value the user created or paid for) in principle belongs to the user [14]. This matters because it means the operator retains ultimate control: platform shutdown can extinguish the asset regardless of any inheritance right, a limitation Chinese commentators acknowledge directly [14]. Chinese courts have nonetheless begun enforcing inheritance in practice. In a case decided by the Beijing Shijingshan District People's Court in 2026, the court ordered a game company to assist a mother in inheriting the 87 real-name-registered game accounts left by her deceased son, holding that the account's link to the decedent's real-name identity "merely served as an identity management mechanism" and did not make the right of use a purely personal right, which was instead "primarily a property interest" because the user had invested time, effort, and money [7]. The court further held that an operator cannot use boilerplate terms to exclude a user's lawful right to inherit the property interest attached to an account, and ordered the company to assist in changing the real-name registration within fifteen days [7]. An earlier and frequently cited precedent involved a rare weapon in the MMORPG Zhengtu valued at around RMB 50,000, which a court treated as property with inheritable value, though that case predated the Civil Code and its precise court and citation are incompletely documented in available sources [7][15]. The honest characterization is that China recognizes inheritability in principle and a growing body of first-instance rulings enforces it, but valuation methodology and inheritance procedure remain unsettled, there is no unified national procedure, and outcomes are determined case by case [6][13].

4.6 EU and comparative: the license-versus-sale line drawn twice

The European Union is the developed comparator, and its case law shows the license-versus-sale dichotomy being drawn twice, with opposite results, along the boundary between software and other content. In UsedSoft GmbH v. Oracle, Case C-128/11 (CJEU, Grand Chamber, 3 July 2012), the Court held that the distribution right in a computer program is exhausted on first sale within the EU even where the program was distributed by download rather than on physical media, provided the rightholder granted a perpetual right of use for remuneration equivalent to the value of a copy, in which case the transaction is a "sale" and the original acquirer must make its own copy unusable on resale [8]. This opened a limited market for used software licenses.

In Nederlands Uitgeversverbond and Groep Algemene Uitgevers v. Tom Kabinet Internet BV, Case C-263/18 (CJEU, Grand Chamber, 19 December 2019), the Court declined to extend that logic to e-books, holding that the supply of an e-book by download for permanent use is an act of "communication to the public" under Article 3 of the InfoSoc Directive rather than an act of distribution under Article 4, so the distribution right is never exhausted and resale requires the rightholder's authorization [9]. The Court thereby confined UsedSoft largely to software governed by the lex specialis Software Directive, and commentators read Tom Kabinet as foreclosing digital exhaustion for e-books, audiobooks, music, and video games alike under the InfoSoc regime [9]. The EU's separate consumer-protection scaffolding, notably the Digital Content and Digital Services Directive (EU) 2019/770, applies maximum-harmonization conformity and remedy rules to digital-content contracts and renders unenforceable any term that derogates from those protections to the consumer's detriment, but it regulates quality, supply, and modification rather than transferability or inheritance, so it does not itself create a right to bequeath [16]. The result is that EU consumers have stronger contractual-conformity protections than US consumers but, outside the narrow software channel, no more of an inheritance or resale right.

4.7 The conflict-of-laws problem

The genuine cross-border dimension is not geopolitical but jurisdictional: which jurisdiction's law governs a cross-border account or estate. The Steam Subscriber Agreement specifies Washington State law and exclusive jurisdiction in King County, Washington, for subscribers outside the EU and UK, while providing that EU and UK consumers are governed by the law of their country of habitual residence [1]. The practical consequence is stark. A Chinese heir may hold a favorable domestic ruling that an account is inheritable, yet the platform's governing-law clause points to Washington, where the terms forbid transfer and where the account may be governed by an arbitration clause; an EU heir may invoke mandatory consumer protections, yet those protections do not reach transferability. Enforcement therefore depends on whether a favorable local judgment can be executed against a platform's local operating entity or assets, which is why the Chinese rulings bite hardest on Chinese operators with Chinese assets and are far less certain against a foreign storefront serving the same user.

5. Economic and Market Dynamics

The economic proving ground for the entire analysis is the in-game item and skins secondary economy, where digital goods carry large, real, observable market value yet remain non-owned, non-inheritable licenses. The Counter-Strike skin economy is the clearest case. Market tracker Pricempire, reported via Dexerto, put the total market capitalization of Counter-Strike 2 skins above $6 billion for the first time on October 17, 2025 ("The CS2 Skins Market Cap has passed the $6 BILLION for the first time"), up from about $4.5 billion in April 2025 [17]. Individual items reach extraordinary prices: an in-game cosmetic sold for over $1 million on June 5, 2024, brokered by collectors Sam "roflm0nster" Alexander and Oliver "zipel" Behrensdorff, reported by Dexerto as "the most expensive skin in Counter-Strike history" [17]. These figures are estimates produced by third-party marketplace analytics firms aggregating Steam Community Market listings, third-party marketplace prices, and peer-to-peer trades, and they should be read as modeled market-tracker estimates rather than audited figures, but the order of magnitude is corroborated across multiple trackers.

The revealing structural fact is that this value is trapped. Sale proceeds on the Steam Community Market flow only into the Steam Wallet, whose funds have no cash value and cannot be withdrawn, and Valve takes a transaction fee on each trade [1]. This is why third-party marketplaces exist: they allow cash-out that Steam forbids, at the cost of operating in the grey zone outside Valve's terms. Valve monetizes the walled economy through case-key sales and Community Market fees, a recurring high-margin stream, and the Community Market alone was estimated to have facilitated over five hundred million dollars in transactions in 2024 [10]. The volatility of the economy underscores its fragility as a store of value: the October 23, 2025 update allowing knives and gloves to be obtained via trade-up contracts drove the overall market cap down more than 40 percent (roughly $6 billion to about $4 billion), with the EsportFire 300 Index falling from about $50,000 to $28,062.67 on that tracker's measure [17].

The same architecture underpins the publishers' live-service revenue. Tencent's value-added services revenue, which is dominated by domestic and international gaming, reached RMB 319.2 billion (about $44.7 billion) in 2024, with domestic games revenue of RMB 139.7 billion [18]. NetEase reported games and related value-added services revenue of RMB 83.6 billion (about $11.5 billion) in 2024, with online-game operations, driven by in-game item sales, accounting for roughly 96 percent of that segment [19]. NetEase's own accounting treatment is instructive: revenue from the sale of "permanent" in-game items is recognized ratably over the estimated average playing period of paying players, an implicit acknowledgment that the items are licensed access tied to the life of the service rather than owned property [19]. The entire live-service model, in other words, books as revenue the sale of things the buyer never owns and cannot bequeath.

6. Material Risks

The first material risk is legislative or judicial reform forcing transferability or genuine ownership. The likelihood is moderate and rising in China, low but non-trivial in the EU, and low in the US. The potential impact is significant, because a robust secondary market or a genuine ownership right would cannibalize primary sales: if items and libraries could be resold or inherited freely, buyers would substitute cheaper used goods for new purchases, compressing the primary-market revenue that non-transferability currently protects. The credible mitigation is that platforms retain the contractual and technical levers to respond, including converting sales to explicit subscriptions, tightening account-binding, or, as Chinese rulings contemplate, complying narrowly by assisting real-name re-registration for heirs without opening a general resale market.

The second risk, and the most acute for asset value, is platform-shutdown or license-revocation. The likelihood for any given long-lived platform in a given year is low, but it is a certainty over a long enough horizon, and the impact is total: revocation or shutdown erases the asset regardless of what inheritance law provides, a limitation Chinese commentators concede applies even where inheritance is recognized [14]. There is no mitigation that survives platform failure; the only hedges are diversification away from platform-locked value and preference for DRM-free channels that leave a usable copy.

The third risk is cross-border conflict-of-laws and enforcement uncertainty, of moderate likelihood and moderate impact, arising because a favorable judgment in one jurisdiction may be unenforceable against a platform governed by another jurisdiction's law and arbitration clause [1]. The mitigation is jurisdictional: value tied to locally regulated operators with local assets (the Chinese publishers, for Chinese heirs) is more recoverable than value tied to foreign storefronts.

The fourth risk is consumer-backlash and reputational exposure tied to the "you do not own your games" narrative, of high likelihood but modest financial impact. California's AB 2426, effective 1 January 2025, prohibits sellers of digital goods from using terms like "buy" or "purchase" unless they obtain affirmative acknowledgment that the transaction is a license or provide a clear and conspicuous disclosure to that effect, backed by false-advertising and unfair-competition remedies [20]. The law was prompted in part by high-profile episodes of storefronts removing purchased content and a game becoming inaccessible after purchase [20]. The impact is primarily disclosure-and-friction rather than a threat to the model, and the mitigation is straightforward compliance, but the trend signals regulatory attention that could escalate.

The fifth risk is escheat and unclaimed-property exposure on trapped wallet balances, of low-to-moderate likelihood and contained impact. The Steam Subscriber Agreement itself contemplates that wallet funds deemed unclaimed property may be turned over to the applicable authority [1]. US unclaimed-property law is fragmented: all fifty states have escheatment regimes for intangible property, but a majority exempt gift-card-type instruments where they do not expire or carry fees, while jurisdictions including Delaware, New York, and New Jersey do require escheatment of unredeemed balances, typically after a three-to-five-year dormancy period, and priority defaults to the holder's state of incorporation where no owner address is on record [21]. A dormant wallet balance on a deceased user's account is a live candidate for escheat, which is a compliance burden and a small balance-sheet liability for operators rather than a threat to the model.

7. Implications for the Investor

The durability of the storefront and live-service models is, on the present law, structurally sound, and the mechanism is precisely the non-transferability that consumers dislike. The following is a forward-looking assessment and should be read as such. The core assumption is that primary-market monetization depends on the suppression of secondary markets: because a licensed game or skin cannot be resold or inherited, each unit of demand must be satisfied by a new primary sale rather than by a used-goods transaction, so non-transferability functions as a permanent brake on the cannibalization that afflicts markets for transferable goods. On that assumption, the US and EU legal architecture, which forecloses digital first sale [4][5], confines exhaustion to a narrow software channel [8][9], and subordinates fiduciary access to platform terms [2][3], is a durable moat for operators whose revenue rests on it, including Microsoft, Sony, Apple, Alphabet, Take-Two, Electronic Arts, and Roblox. The investment inference is that the license architecture supports revenue durability in these names to the extent their monetization depends on non-transferable digital content, and that Valve's private status means the purest expression of the model cannot be bought directly.

The fragility of digital libraries and items as stores of value points the opposite way and is the mirror image of the same facts. A forward-looking judgment, dependent on the assumption that platforms retain unilateral revocation and shutdown rights, is that any thesis treating skins, game libraries, or wallet balances as durable stores of value is mispriced, because the assets are revocable licenses trapped inside platform wallets, exposed to policy changes that can erase more than 40 percent of a market's value overnight [17], and non-inheritable in the jurisdictions that govern most Western storefronts [1]. The multi-billion-dollar skin market is a high-volatility, platform-contingent collectibles market, not an asset class with the permanence its market-capitalization headlines imply.

The principal tail risk is legal reform that compresses these structural protections, and its timing and locus are the variables to watch. The forward-looking claim, assuming current trajectories continue, is that China is the leading indicator: Article 127 plus an open Article 1122, combined with a growing body of first-instance rulings ordering operators to facilitate inheritance and invalidating boilerplate no-transfer clauses [6][7], creates a possibility that the Chinese publishers (Tencent, NetEase) will face a domestically mandated inheritance and re-registration regime before any Western jurisdiction does. The near-term revenue impact is likely small, because assisting heirs with real-name re-registration is not the same as opening a resale market, but the direction of travel compresses the operator's contractual freedom. European consumer-law pressure is the second vector, more likely to expand conformity and disclosure obligations than to create transferability, and US state-level action, exemplified by California's AB 2426 [20], is for now a disclosure regime rather than a property-rights intervention. The benchmark that would change this assessment is any move from access or disclosure rules toward a mandated transferability or ownership right in a major Western market, or a Chinese national-level procedure (as opposed to case-by-case rulings) that binds foreign operators; absent those, the structural protections hold, and the assets remain licenses, not property.

For counsel, the operative points are stated in Section 4, namely that RUFADAA secures at most access and not ownership, that a will should use a platform online tool where one exists and otherwise cannot override contrary terms of service, and that clients should be advised that Steam and comparable accounts cannot reliably be bequeathed.

References

[1] Valve Corporation. 2025. "Steam Subscriber Agreement." store.steampowered.com/subscriber_agreement/.

[2] Uniform Law Commission. 2015. "Revised Uniform Fiduciary Access to Digital Assets Act (2015)." Drafting and prefatory notes. Kentucky Legislative Research Commission reproduction.

[3] LegalClarity. 2024. "Revised Uniform Fiduciary Access to Digital Assets Act (RUFADAA)." legalclarity.org. State-adoption tally corroborated by Trust & Will and Bequest.

[4] Capitol Records, LLC v. ReDigi Inc., 910 F.3d 649 (2d Cir. 2018).

[5] Vernor v. Autodesk, Inc., 621 F.3d 1102 (9th Cir. 2010).

[6] Civil Code of the People's Republic of China (2020), Articles 127 and 1122. China Law Translate.

[7] Zhang, Jingshu. 2026. Report on the Beijing Shijingshan District People's Court ruling on inheritance of 87 game accounts. The Beijing News (新京报), bjnews.com.cn.

[8] UsedSoft GmbH v. Oracle International Corp., Case C-128/11, EU:C:2012:407 (CJEU, Grand Chamber, 3 July 2012).

[9] Nederlands Uitgeversverbond and Groep Algemene Uitgevers v. Tom Kabinet Internet BV, Case C-263/18, EU:C:2019:1111 (CJEU, Grand Chamber, 19 December 2019).

[10] Alinea Analytics estimates, as reported by Game World Observer, Tom's Hardware, and Dexerto (November 2025); Sacra, "Valve revenue, funding & growth rate," sacra.com/c/valve/; SaaStr, "5 Interesting Learnings from Valve."

[11] Warr, Liam. 2024. "No leaving a Steam account in a will after you die according to Valve." GamingOnLinux.

[12] "The Civil Law Protection of Virtual Property Rights in Online Games." Francis Academic Press.

[13] "Research on the Legal Issues of Inheritance of Virtual Property on the Internet." Journal of Humanities, Arts and Social Science, Hill Publishing Group.

[14] Xu, Yuyuan. 2024. "Discussion on legal issues of inheritance of virtual property in network." International Journal of Frontiers in Sociology 6 (3): 13-20.

[15] DeHeng Law Offices. "Can virtual property be inherited?" (虚拟财产能否继承？) dehenglaw.com, recounting the Zhengtu 屠龙刀 dispute reported by Xinmin Evening News, 6 June 2010.

[16] Directive (EU) 2019/770 of the European Parliament and of the Council of 20 May 2019 on certain aspects concerning contracts for the supply of digital content and digital services. EUR-Lex.

[17] Pricempire, reported in Dexerto. 2025. "Counter-Strike 2 skins market value hits new all-time high," and "The most expensive skin in Counter-Strike history was sold today for $1 million" (June 5, 2024); SteamAnalyst, "CS2 Skin Market Report 2025"; EsportFire 300 Index tracking (October 2025 update).

[18] Tencent Holdings Limited. 2025. "Tencent Announces 2024 Annual and Fourth Quarter Results." Full-year value-added services and gaming revenue figures.

[19] NetEase, Inc. 2025. Form 20-F for fiscal year 2024. U.S. Securities and Exchange Commission, EDGAR.

[20] California Assembly Bill 2426 (Irwin), Chapter 513, Statutes of 2024, adding Section 17500.6 to the Business and Professions Code; analysis by Sidley Austin LLP and Greenberg Traurig LLP.

[21] Alston & Bird. 2025. "How Changes In State Gift Card Laws May Affect Cos. In 2025." Law360.