CLEAN-ROOM DEVELOPMENT STATEMENT

Division

Last Updated: December 9, 2025

This Clean-Room Development Statement (“Statement”) describes the engineering practices, internal controls, and legal compliance procedures followed by Division (“Company,” “We,” or “Us”) in the creation of all Software, loaders, digital tools, and related technologies (collectively, the “Software”).

The purpose of this Statement is to affirm that Division’s Software is independently developed through lawful means and does not rely on, incorporate, or interact with proprietary, copyrighted, or protected materials owned by any game publisher, developer, or anti-cheat provider.

1. CLEAN-ROOM ENGINEERING METHODOLOGY

Division develops all Software using a clean-room methodology, which includes:

  • Independent engineering without access to proprietary game source code

  • Use of publicly available information only

  • Strict separation between factual observation and implementation

  • Avoidance of reverse engineering, decompilation, or disassembly of protected works

  • Complete isolation from leaked assets, internal tools, or non-public SDKs

All code implemented by Division is original, independently authored, and not derived from copyrighted game code or protected modules.

2. NO REVERSE ENGINEERING OF PROTECTED WORKS

Division and its developers do not:

  • Reverse engineer, decompile, or disassemble game executables

  • Inspect or analyze encrypted, obfuscated, or protected binaries

  • Access or replicate anti-cheat logic, algorithms, or internal data structures

  • Interact with proprietary files, algorithms, or protected memory regions

Development is conducted solely through:

  • Operating system APIs

  • Allowed external observations

  • Public documentation

  • Hardware-level behavior available to all applications

Division’s Software does not derive from or replicate any proprietary code.

3. INDEPENDENT TESTING & OBSERVATION

3.1 Division engineers test the Software exclusively using lawfully obtained game copies.

3.2 Any behavioral observations made during testing:

  • Do not involve inspection of protected executable code

  • Do not involve analysis of encrypted or monitored memory regions

  • Are limited to externally observable UI behavior, system responses, and public OS-level information

3.3 No protected technological protection measures or anti-cheat systems are bypassed or tampered with during development or testing.

4. NO INTERACTION WITH PROTECTED MEMORY OR GAME CODE

Division Software operates solely externally, meaning:

  • It does not inject into any game process

  • It does not access internal process memory

  • It does not modify, overwrite, or read protected binary structures

  • It does not hook or patch game functions

  • It does not circumvent access controls or verification systems

Division Software communicates only through lawful, OS-permitted external mechanisms.

5. NO USE OF LEAKED, CONFIDENTIAL, OR PROPRIETARY MATERIALS

Division does not and will never:

  • Use leaked game source code

  • Refer to or use proprietary development kits

  • Employ internal debugging tools belonging to publishers or anti-cheat vendors

  • Access private repositories, insider documentation, or confidential resources

Employees and contractors are strictly prohibited from using unauthorized materials.

Any individual found to have accessed such materials is removed from development activities immediately.

6. INTELLECTUAL PROPERTY SEPARATION

Division ensures strict separation between its Software and the intellectual property of:

  • Facepunch Studios

  • Embark Studios

  • Epic Games

  • Electronic Arts / Respawn Entertainment

  • Bohemia Interactive

  • Behaviour Interactive

  • Any anti-cheat provider (EAC, BattlEye, Ricochet, Vanguard, etc.)

The Software does not replicate, emulate, or imitate the internal logic of any game or anti-cheat system.

7. INTERNAL ACCESS CONTROLS & COMPLIANCE

Division maintains internal policies to ensure legal compliance, including:

  • Restricted access to internal code repositories

  • Mandatory compliance training for developers

  • Documentation of all development sources and methods

  • Verification that no engineer accesses proprietary materials

  • Role-based access ensuring separation between testing and implementation

Division also maintains logs demonstrating that the engineering process remains clean-room compliant.

8. NO TECHNOLOGICAL PROTECTION MEASURE (TPM) CIRCUMVENTION

Division does not:

  • Circumvent encryption, authentication, or anti-tamper systems

  • Disable, bypass, or interfere with anti-cheat enforcement

  • Provide mechanisms designed to avoid detection or enforcement

The Software operates only within the boundaries permitted by the operating system and does not defeat technological protection measures under:

  • Singapore Copyright Act

  • DMCA §1201

  • EU Copyright Directive

  • Any equivalent international statute

9. PROHIBITED USERS POLICY

To further protect development confidentiality and prevent misuse, Division prohibits access to the Software by:

  • Developers, staff, contractors, or affiliates of game publishers associated with Rust, Arc Raiders, Fortnite, Apex Legends, DayZ, or Dead by Daylight

  • All anti-cheat vendors and their employees, agents, investigators, or affiliates

  • Individuals acting in investigative, auditing, or security-research capacities

  • Anyone located in or accessing the Software from Sweden

Users must certify they are not prohibited parties as a condition of use.

10. PURPOSE OF THE SOFTWARE

Division creates Software solely for:

  • Lawful personal experimentation

  • External UI-level modification

  • Non-invasive enhancement tools

Division does not encourage or endorse the misuse of Software to violate game Terms of Service or third-party agreements.

11. LIMITATION OF STATEMENT

This Statement:

  • Does not confer any rights to Users

  • Does not alter Division’s Terms of Service, EULA, or Privacy Policy

  • Exists solely to clarify Division’s development methodology

If any conflict arises between this Statement and other Division policies, the Terms of Service and EULA control.