Clean-Room Development Statement

Grim Empire — Authorized Reseller
Last Updated: August 6, 2026

This Clean-Room Development Statement (“Statement”) describes the engineering practices, internal controls, and legal compliance procedures followed in the creation of all software, loaders, digital tools, and related technologies (collectively, the “Software”) distributed through Grim Empire. We act as an authorized reseller and distributor of digital access keys for Division software and related products (collectively, the “Services”).

The purpose of this Statement is to affirm that the distributed 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

All distributed Software is developed 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 implemented code is original, independently authored, and not derived from copyrighted game code or protected modules.

2. No Reverse Engineering of Protected Works

The core developers and distribution network 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, and hardware-level behavior available to all applications. The Software does not derive from or replicate any proprietary code.

3. Independent Testing & Observation

3.1 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

The 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.

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

5. No Use of Leaked, Confidential, or Proprietary Materials

The creators and distribution network do 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/anti-tamper vendors (including Denuvo).
  • Access private repositories, insider documentation, or confidential resources.

Developers and contractors are strictly prohibited from using unauthorized materials, and any individual found to have accessed such materials is removed from activities immediately.

6. Intellectual Property Separation

Grim Empire and the core developers ensure strict separation between the distributed Software and the intellectual property of:

  • Facepunch Studios (Rust)
  • Embark Studios (Arc Raiders)
  • Epic Games (Fortnite)
  • Electronic Arts / Respawn Entertainment (Apex Legends)
  • Bohemia Interactive (DayZ)
  • Behaviour Interactive (Dead by Daylight)
  • Any anti-cheat or anti-tamper provider (Denuvo, EAC, BattlEye, Ricochet, Vanguard, etc.)

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

7. Internal Access Controls & Compliance

Internal policies 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.

Logs are maintained demonstrating that the engineering process remains clean-room compliant.

8. No Technological Protection Measure (TPM) Circumvention

The Services do not:

  • Circumvent encryption, authentication, anti-tamper (such as Denuvo), or anti-cheat 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 the Singapore Copyright Act, DMCA §1201, EU Copyright Directive, or any equivalent international statute.

9. Prohibited Users Policy

To further protect development confidentiality and prevent misuse, access to the Software is strictly prohibited for:

  • Developers, staff, contractors, or affiliates of game publishers associated with Rust, Arc Raiders, Fortnite, Apex Legends, DayZ, or Dead by Daylight.
  • All anti-cheat and anti-tamper vendors (including Denuvo) 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

The distributed Software is created solely for:

  • Lawful personal experimentation.
  • External UI-level modification.
  • Non-invasive enhancement tools.

Grim Empire 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 Grim Empire’s Terms of Service, EULA, or Privacy Policy.
  • Exists solely to clarify the development and distribution methodology.

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