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"13. The Plaintiffs suffers incalculable damage to its intellectual property rights and business on account of various forms of piracy in its software programs. End-user piracy is the most damaging form of software piracy affecting Plaintiffs and occurs in the following manner:

a. When the number of software copies installed on the computers of an organization or a company exceed the number of copies permitted or authorized by the license agreement, commonly known as the End User License Agreement (EULA) or the Customer License and Online Services Agreement (CLOSA) held by the organization or the company; or b. When the organization avoids paying maintenance and updates its software with the latest version of the software by using illegal methods such as cracking, hacking and the like; or c. When the software is installed and copied from pirated CD ROMs containing single or multiple pirated or unlicensed versions of software programs onto the computers used by an organization or a company; or d. When an unlicensed/pirated version of the software is installed using licenses generated through fake license key generators colloquially referred to as a 'keygen' so as to misrepresent to the serial-key security mechanism of the software that the software has been installed using a valid license key; or e. When academic or other restricted or non-retail software is acquired without a license and used for commercial purposes; or f. When advantage of upgrade offers is taken without having a legal copy of the version to be upgraded."