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Kardashian Kase – Kontracts KontrolPosted: August 7, 2017 Filed under: Business Law, Cases, Intellectual Property, Licensing | Tags: beauty, breach of contract, contracts, cosmetics, Kardashian, license agreements, licensees, licensors, Ninth Circuit, trademarks, U.S. Court of Appeals for the Ninth Circuit Comments Off on Kardashian Kase – Kontracts Kontrol
Recently, the Federal Court of Appeals for the Ninth Circuit upheld an injunction issued for the benefit of members of the Kardashian family against their cosmetic products licensee.
The Kardashians had terminated the license agreement due to the licensee's alleged failure to pay royalties, among other alleged breaches. The licensee continued to exploit the license and sell products bearing the Kardashian trademarks, asserting, among other things, that "the Kardashians' termination of the license agreement was invalid because the Kardashians breached the license agreement first . . . ."
The district court found for the Kardashians, holding, unremarkably, that a licensee has but two options when faced with a breach of the license agreement by the licensor: "First, the licensee can consider the contract terminated and stop performance. Second, the licensee can instead continue making royalty payments under the license agreement, continue using the trademarks, and then sue for damages. Regardless, the licensee cannot both stop paying royalties but nevertheless continue using the trademark."
Although the options presented to a licensee by the district court decision are seemingly reasonable, they can present real risk to the licensee. For example, if the licensee had made significant investments and engaged a large staff to support the licensed business, terminating the agreement and closing down the licensed business not only will put any number of people out of work without advance notice, but also may result in defaults under the licensee's banking arrangements and the loss of its entire business, thus giving rise to consequential damages potentially far in excess of any award for actual damages to which the licensee may be found to be entitled. Under the district court decision, the licensee's option in these circumstances would be to continue the licensed business and bring an action against the licensor for damages, with the attendant relationship issues potentially adversely affecting performance, while continuing to make royalty payments with no guaranty that the licensee's damages can be recouped, even after years of expensive litigation.
There is another quite unremarkable statement in the decision, which, although not in any way undercutting the ruling, may give some guidance as to how a licensee may attempt to protect itself in circumstances like those that the Kardashian licensee alleged it was facing. The court wrote, "like all contracts, trademark license agreements are governed by general principals of contract law."
Among the most wonderful aspects of our contract laws is that the parties can, in effect and with few limitations, create their own law as to their rights and obligations under almost any circumstances. Accordingly, a licensee familiar with the Kardashian case might look to create a contractual structure whereby it would not have to pay royalties in the event of a significant breach by the licensor or, more realistically, a contractual structure by which it would not have to chase the licensor, at great expense, to recoup royalty payments in order to continue to exploit a generally valuable license agreement.
It is not uncommon to see license agreements in which the licensor has included a right for the licensor to set off amounts due and owing to it by a licensee against any outstanding payment obligations it may have to the licensee. However, even if a licensor would be willing to make this provision bilateral, these provisions are objectively problematic because they cannot be reliably drafted to prevent with certainty a party from merely alleging that the other owes it money in order to trigger the clause (unless, of course, a claimant party is required first to obtain a final judgment as to the amount allegedly owed, which brings us back to the problems with option number two). A better and more objective protection would be to allow the licensee to put its payments of royalties into escrow, with an obligation to take some formal legal action in accordance with the license agreement's arbitration or litigation provisions before, or reasonably soon after, it notifies the licensor that the escrow account has been established. Assuming that the licensee establishes in the proceeding that it is entitled to damages, the escrow fund, even if less than the damage award, will be available to be applied toward the satisfaction of the judgment. It also is possible that establishing an escrow account and making payments into the escrow account will help relieve at least some of the tensions arising from awkward efforts to work together while the parties are adversaries in court or in an arbitration and perhaps even salvage the relationship after the legal action has ended.
Credit: Jonathan R. Tillem
A Big Cheer for Cheerleader UniformsPosted: March 22, 2017 Filed under: Cases, Intellectual Property, Licensing, Textiles | Tags: cheerleading, cheerleading uniforms, copyright, copyright protection, lawsuits, Ruth Bader Ginsberg, Sixth Circuit, Star Athletica, Supreme Court, U.S. Court of Appeals for the Sixth Circuit, U.S. Supreme Court, Varsity Brands Comments Off on A Big Cheer for Cheerleader Uniforms
The Supreme Court decision in Star Athletica L. L. C. v. Varsity Brands, Inc., No. 15-866 was announced today and the fashion industry can breathe a huge sigh of relief. In fact, the industry, especially accessory businesses, would be justified in popping open the Champagne. Not only did the Court uphold the Sixth Circuit's judgment that the designs of the cheerleading uniforms were separable, it greatly simplified and expanded the two- and three-dimensional features of useful articles that can qualify for copyright protection.
The opinion holds that the design of a useful article is eligible for copyright protection if the feature can be perceived as a copyrightable two or three-dimensional pictorial, graphic or sculptural design separate from the useful article, on its own or in some other tangible medium, if it can be "imagined" separately from the useful article. Physical separability is not required. The analysis of separability under the statute is a purely conceptual undertaking. Conceptual separability does not require that the remaining part of the useful article, apart from the two and three dimensional design, be either fully functional or even equally useful. The focus of the separability analysis under the copyright statute is on the extracted two- and three-dimensional design and, according to the Court, one need not "imagine a fully functioning useful article without the artistic features." Nor does it matter, the Court holds, that the artistic feature plays a role in the function of the useful article.
All of the other glosses on conceptual separability that the various appeals courts had previously articulated are swept away. It does not matter that the artistic feature of the design would be marketable separately, so long as it can be imagined as existing. It doesn't matter that it was conceived originally for the useful purpose to which it was put.
Left for another day is whether the specific designs at issue are copyrightable. That will be the task of the trial court on remand. However, Justice Ginsberg notes in a footnote that the requisite creativity for copyright is extremely low.
Credit: Helene M. Freeman
Here's a previous post that may be of interest…
Matryoshka MarketingPosted: March 8, 2016 Filed under: Accessories, Intellectual Property, Licensing | Tags: accessories, branding, brands, Breitling SA, Matryoshka dolls, Swatch Group, watches Comments Off on Matryoshka Marketing
We have all seen Russian matryoshka (nesting) dolls: open one and out comes another, and open that and you get another, and so on. When a fashion brand incorporates components from another brand into its finished product, it is rather the same thing, with a difference: although the brand covering the finished product is the brand that in all likelihood is the primary branding driver of consumer demand and the primary branding influence for consumer purchasing, that brand will not exist in isolation. It will be helped or hurt by the quality, function and aesthetic appeal of the brands of the constituent parts.
Perhaps the easiest place to see that at work is watchmaking. There are many more well-known watch brands than there are watch movement makers. Although most watch brands design and make their own cases, they often rely on others to make the most important thing in the package: the actual movement. If the movement is not working properly—if the watch is not keeping time—good luck trying to convince the consumer that all he or she really wanted was a well-designed bracelet with a watch-face for decoration. Typically, the maker of the movement is not even mentioned in advertising, on the product or in the accompanying instructions. Clothing, however, is a bit different since there are some key fabric vendors whose brands are considered important enough to drive sales, which is why garment makers are willing, if not eager, to place the Gor-Tex and Loro Piana trademarks on clothes made with fabrics bearing those brands.
All well and good, but a couple of key points should be considered:
First, no matter how you, the manufacturer, market the finished piece, you are helping build good will (and therefore value) in the brand of your supplier. Your vendor is the legal owner of that goodwill, not you. Your advertising will promote and otherwise benefit the vendor, which at times might also participate directly by adding its trademarks to the ads. All of that should be considered when entering into the agreement by which the vendor's trademarks will appear on your fashion products. In addition, your vendor will likely require an agreement permitting it to exercise quality control over the use of its marks—which is again what the law expects—so be prepared to have the vendor involved in production in a way you might not typically expect from a supplier of components not displaying B2C branding.
The other key point to consider is that, even if the consumer is aware of the vendor's brand and the vendor's contribution to your finished product, the consumer will most likely hold your brand accountable for the performance of your product. Going back to the watchmaking example: ETA SA Manufacture Horlogère Suisse (a subsidiary of Swatch Group Ltd.) makes movements that go into a number of watch models made by Breitling SA, which is an unrelated, privately held Swiss company. Even a consumer who is fully aware of that fact is not going to say, "Hey, my Swatch stopped working!" in the (highly unlikely) event that his Breitling should cease to function—even though, in a purely mechanical sense, that is exactly what happened.
Just a few things to keep in mind when entering into supply contracts with important vendors.
Credit: Alan Behr
Designers Defending Their NamesPosted: September 22, 2015 Filed under: Business Law, Intellectual Property, Licensing, Menswear, Transactions, Womenswear | Tags: brands, Catherine Malandrino, designers, Elie Tahari, Halston, Jacqueline Kennedy, Joseph Abboud, Karl Lagerfeld, Men's Warehouse, Ralph Lauren, Roy Halston Frowick, trademarks Comments Off on Designers Defending Their Names
If you are interested enough in fashion to be visiting this page, I cannot tell you anything new about Roy Halston Frowick, better known as Halston. He was unique in many ways, starting with the fact that he launched his career with a single piece: the pillbox hat that Jacqueline Kennedy wore to John F. Kennedy's inauguration as president, in 1961. (The fact that Mrs. Kennedy was also wore a Halston pillbox while sitting in the car next to the president as he was assassinated, in Dallas, led to the style going out of fashion in the blink of an eye.) By 1983, Halston's company, Halston Limited, was owned by Norton Simon, Inc. Unless Halston had agreed to all that at some point, the likely explanation was that there had been no form of what lawyers call a non-assignment clause in place in the relationship that Halston, the man, had set up with the owners of Halston, the brand. In any event, within about one year, Halston was no longer designing for Halston Limited. He died in 1990, a man without his own name in design. Once that disassociation occurred, Halston, the brand, which still exists, has a life of its own, and it has since changed hands seven times more.
Catherine Malandrino recently filed a lawsuit against Elie Tahari and others, claiming she was wrongfully deprived of rights under a deal by which she sold her brand (and, for all intents and purposes, her professional name) to a company controlled in part by Tahari, which employed her as its creative director. Malandrino had only minority representation on her new employer's management committee. She alleges that her co-venturers and others routed around her in subsequent dealings, damaging the brand and failing to compensate her as agreed. Although the complaint is passionately composed, it does not directly address what appears to be the underlying issue: Malandrino and her representatives did not provide, in the agreements she signed, the kind of contractual protections that could have reduced or eliminated many of the alleged wrongs and that would have given her final say as to what was and was not a Catherine Malandrino creation.
On a happier note there is the long, circular tale of Joseph Abboud. His eponymous menswear line debuted in 1987. His name was registered as part of trademarks that he licensed to a joint venture in which he took an interest through a corporation he owned. He then sold off his equity interest and worked as a consultant to the company that now exclusively owned his name in the fashion business—until creative differences caused an abrupt. Abboud tried to start a new brand called "jaz," making it known in the trade that he was the designer. In the lawsuit filed by the company that owned the Joseph Abboud trademarks, the court ruled, "Abboud is permanently enjoined and restricted from using her personal name to sell, market, or otherwise promote, goods, products, and services to the consuming public." In all, a humiliating result for one of my favorite menswear designers. Several sales of branding rights and changes in price point later, man and brand were effectively reunited; in 2014, Abboud became chief creative director at Men's Wearhouse, which is the current owner of the Joseph Abboud brand and trademarks.
And we must not forget that there are many success stories. Karl Lagerfeld is still a walking brand, regardless of whatever house for which he has already has served or may yet serve as designer. Ralph Lauren's name is owned by his company, which is public and so owned by many shareholders—but he has set up everything quite nicely and is surely not losing sleep worrying about whether he will still be designing under his own name.
The message: every good designer is either a good business person or should work in close company with someone else who is just that—and every good business person watching over a designer's name should have a lawyer nearby who knows what to do to keep the designer and his name permanently in each other's company.
Next: we will show a bit of how that works.
Credit: Alan Behr
See previously published related posts:
Patent Falls In Spiderman's Web: Are You Paying Royalties Unnecessarily?Posted: July 7, 2015 Filed under: Business Law, Cases, Federal & State Laws, Intellectual Property, Licensing | Tags: contracts, copyrights, court cases, fashion, Kimble v. Marvel, license, licensees, licensors, litigation, Marvel Entertainment, patents, Spiderman, Steven Kimble, U.S. Supreme Court Comments Off on Patent Falls In Spiderman's Web: Are You Paying Royalties Unnecessarily?
While the Supreme Court's recent healthcare and marriage equality rulings garnered a lot of attention, there was another decision at the end of the Court's term that may be more meaningful to the business of fashion – Kimble v. Marvel Entertainment, the Spiderman patent litigation. Steven Kimble secured a patent for a Spiderman toy that shot the character's "webs" from a hand. Marvel, owner of the character, purchased the patent to resolve a claim of patent infringement, promising to pay royalties on sales of the toy.
The popularity of the toy outlived the twenty-year patent term. Under a fifty-year-old Supreme Court decision, the obligation to pay royalties under a contract ends when the patent term expires, even if the agreement contains no termination date. Court decisions have applied the same rule to copyright licenses and assignments.
The Spiderman case called for the Supreme Court to reconsider the rule and permit the continued collection of royalties as provided in the contract. Although conceding that the fifty-year-old case might have been wrongly decided, as a number of courts and commentators have noted, the Court declined the opportunity to overrule it. Instead, it advised that, if the rule is to be changed, it is up to Congress to do so. Spidey is now free to cast his web without writing any more checks.
The decision is a reminder to licensors that patent and copyright rights do not last forever. In contrast, trademarks last as long as they are used and protected and trade secrets last as long as their secrecy is maintained. Joining a license for patents and copyrights with related trademarks or trade secrets can be a good way to maintain royalties after the patents and copyrights have expired. Licensees, on the other hand, should periodically investigate whether they are paying royalties under patents or copyrights that may have expired.
Credit: Helene M. Freeman
The ConformistPosted: April 28, 2015 Filed under: Business Law, Licensing | Tags: fashion manufacturing, garment manufacturing, licensees, licensing agreements, licensors Comments Off on The Conformist
Have you ever had the experience of going into a fitting room and trying on two of the same item in the same size, perhaps only in different colors, only to find that they fit quite differently—to the point that one might not fit at all although the other did? Production line manufacturing may be efficient, but no one ever claimed it to be an exact science.
No one expects the retailer to guarantee that every item sold under the same SKU will fit exactly like every other item bearing that SKU in the same size. But in fashion licenses, that kind of elasticity in expectations can become the subject of negotiation.
It typically plays out like this: the licensee agrees to provide pre-production samples to the licensor for approval. The licensor either approves or disapproves; if it disapproves, the licensee is often entitled to a second try, adjusting the style to suit the licensor's expectations. Once the styles are approved, the licensee initiates production. More typically in the fashion business, the licensee contacts someone else, often half a world away, and tells him or her to initiate production.
The licensor may demand, in the representations and warranties section of the license (which has been the subject of this series of posts), that the licensee warrant that production models will not deviate from approved samples. If the licensee is careful, that may be qualified by adding in any material way or by breaking the force of terms like will conform by dropping in the forgiving qualifier substantially. But bolts of cloth from different batches can easily have variations, and sometimes the chosen buttons, snaps and other accessories run out and others need to be substituted; the list of potential deviations goes on. In a seasonal business such as fashion, where a handful of weeks can make or break a SKU, a style, a look, a collection or even an entire business, the date on which finished goods are to be sent to retail doors is hardly the time to get into an argument over whether something already bought and delivered does or does not substantially or materially conform to the appearance or other attribute of an approved prototype.
The first rule of warranties applies here as it does to all others: for the licensee, never make a promise that you cannot keep; for the licensor, never ask anyone else to make a promise that you can be reasonably sure he or she will not be able to honor. To avoid surprises, it is useful for the parties to think through, and to talk through, contingencies due to variations in manufacture and to consider adding to the license, as a defined term, exactly what they mean when they say something must conform to what has been approved. Even if something is completely non-conforming, alternatives such as sale into outlets or other lower end channels, or outside the territory, perhaps with labels removed, can sometimes work.
In the end, however, all licenses, like all contracts, rely more on the element of trust (and forgiveness) than lawyers can hope to draft into them. Simply, a well-written contract can get you a favorable result in court, but working with the right people is a good way to help stay out of court.
Here as with most else in licensing, the name of the game is cooperation. The devil, as they say, will always be in the details.
Credit: Alan Behr
See previously published related posts:
- "I'm A Good Neighbor–Most Places"
- "I Own It — I Mean, Really, I Do!"
- "I Hereby Promise That You Are My one and Only-ish"
- "I Promise, Therefore I Am"
- "No Guarantees In Life But Plenty in Contracts"
I Own It — I Mean, Really, I Do!Posted: March 31, 2015 Filed under: Business Law, Intellectual Property, Licensing | Tags: contracts, distribution agreements, license agreements, licensees, licensors, trademarks, warranties Comments Off on I Own It — I Mean, Really, I Do!
In our exploration of the representations and warranties often seen in fashion agreements, we come to one that is at the core of licensing and distribution agreements, and it typically looks like this:
Fashion Company represents and warrants that it owns and maintains trademark registrations in the Territory [the scope of which should be clearly defined] for the licensed marks set forth in Exhibit A to this agreement.
Similar warranties can be made, as applicable, for rights to trade dress (which is an important trademark derivative for those fields, such as fashion, in which designs can be important assets) and in copyright and design patents. Those will be discussed in subsequent posts.
For trademarks, the important thing is to clarify what is actually being licensed. Scheduling the licensed marks, particularly if any involves specific colors, fonts, devices (logos) or other design elements in how they are presented, is very important because the warranty of ownership will apply only to what is specifically listed, and with trademarks, any change or variation in more than a "de minimis" or token amount may be deemed to have created a different mark—one that is not covered by the warranty.
Pitfall: licensees beware. Licensors may change their branding indicia during the term of licenses. If that happens, and the licensed trademarks are listed in the agreement, the new versions may not be covered by the contractual warranty. As an example, the mark FASHION COMPANY registered in the stylized form FASHION COMPANY will likely not be seen as the same stylized mark as FASHION COMPANY when used in the latter form. The license agreement should therefore be drafted to include any new versions of the listed trademarks within the definition of the "licensed marks"—and to require the licensor to give fair notice when any such changes in branding may be forthcoming. Financial issues concerning the costs of the changeover to the licensee can become the subject of additional negotiations.
Although due to the oddly backwards way in which United States trademark law developed (which is a long story in and of itself), it is not necessary to have a federal trademark registration to claim ownership of a mark in the USA. It is therefore common, and indeed usually prudent, for a licensee to insist on a warranty that the licensed marks have been registered for the specific goods covered by the scope of the license. Where things can get tricky is if such registrations have not yet been granted in the USA or in other jurisdictions in the territory covered by the license. The licensor may, in certain instances, be able to warrant ownership of marks that have not been registered (although it cannot so warrant ownership of the registrations themselves), or it may demand that it limit its warranty to those portions of the territory where it has registrations in place and is confident the use of the mark as licensed would go unchallenged. The business and legal risks, and the operational considerations implicit in partially encompassing warranties, should be carefully considered by both parties.
The key takeaway here is that, in the USA, trademark protection tends to be quite specific, exact and exacting. It is therefore prudent for the licensee to do due diligence to comfort itself that the licensor or other trademark owner's warranty of ownership (and registration) is valid and accurate—because once you sign the agreement and start acting under it, you will likely be spending your money to make things happen, and no one likes throwing away money due to promises (that is, warranties) that cannot be honored.
Credit: Alan Behr
See previously published related posts:
- "I Hereby Promise That You Are My one and Only-ish"
- "I Promise, Therefore I Am"
- "No Guarantees In Life But Plenty in Contracts"


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|32 m²
|Property type
|Minimum Stay
|2 nights
Take deep breath in fresh air in the morning , enjoy awesome rice field surrounding villa with serene environment . enjoy NOOK Restaurant with rice field view just in front of villa 2 minute walking . and many famous restaurants surround there like METIS , THE SARDHINE, MIE 88, DEVGAN Restaurants we have 3 bed room ,private pool and tropical garden , sun bath area.
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we have 24 hours security and our villa staff will help you until 15 .00pm. feel free contact me for futher information .im here to hosting you and arrange your wonderfull vacation

subset: commoncrawl


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West Holmes won the battle against Triway to win the Hiland Tennis Invitational by a slim one point 11-10, Coshocton was third with six and the host Hawks finished with three points.
The Knights were led by champions Eric Biltz, who won his title in a rugged battle 3-6, 6-2 and 10-7, and fellow Knight Jason Abraham held off Hiland's Tim Schlabach 6-2, 6-4.
At third singles, it was the Titans' Emily Allison holding off West Holmes' Megan Morrison 7-5, 6-3 as she set the tone for Triway to reel off the next two wins. Chase Jennings and Chase Chargualaf rallied for a 1-6, 6-2, 12-10 win, and Nic Noble and Jake Friday pulled off a 6-3, 7-6 win.


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FOXBOROUGH, Mass. The NFL has fined New England Patriots quarterback Tom Brady $10,000 for kicking Baltimore Ravens defender Ed Reed during Sunday's AFC championship game, CBSSports.com's Mike Freeman has confirmed. The news was originally reported by NFL.com's Ian Rapoport.
On a first-and-goal near the end of the second quarter, Brady was forced out of the pocket to his left. He ran for 3 yards but slid before he could be tackled. In the process, he raised his right leg and kicked Reed in the thigh.
Brady apologized to Reed, according to the Ravens defensive back.
"You know, we talked," Reed told CBS station WJZ-FM in Baltimore. "We talked actually not too long ago, we talked on the phone. He actually reached out to me, texted me. I tried to text him back, but the message exploded after 12 seconds, so I had to call him ... and he's just apologized and what not. But I told him, 'You know, it's good, man.'"
Patriots spokesman Stacey James says he has no information on the fine. A message was left seeking comment from NFL spokesman Michael Signora.
The Ravens won 28-13 to advance to the Super Bowl.


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BJP MP Ramakant Yadav arrested
BJP parliamentarian Ramakant Yadav, who is wanted in a case of murder since August 12, has been arrested on Tuesday.
Zeenews Bureau
Azamgarh: BJP MP from Azamgarh Sadar
constituency Ramakant Yadav was today arrested in the district
in connection with a murder and attempt to murder case lodged
against him.
"BJP MP Ramkant Yadav was arrested from Pathlipur
Bazar area this evening and has been taken to Deedarganj
police station," Deputy Inspector General of Police K K
Tripathi said.
According to reports, the police had managed to get the details of Yadav`s cellphone conversations indicated his location around Talkatora Road in Central Delhi till Sunday evening.
Yadav was named in the murder case after he and his men allegedly clashed with members of Ulema Council in Phoolpur on August 12. While Council members attacked Yadav`s convoy, the MP`s men had opened fire, killing a youth and injuring three others.
Meanwhile, Allahabad HC had rejected Yadav's plea for stay on the arrest in connection with an FIR against him. A division bench, comprising Justices Ravindra Singh and Y C Gupta, had directed him to surrender before the court concerned.


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Guerrilla War
Review by MikeHaggar
"SNK's greatest game of the eighties."
Guerilla War (aka Guevara) was released in 1987 by the SNK company. Guerilla War is my favorite SNK released game of the eighties, it's action packed from beginning to end. The tagline behind Guerilla War is 'Hail the heroes of the Revolution'. After you beat this game, you'll feel like a hero, because this is one tough game.
The idea behind Guerilla War is simple, you are a one man army who's goal is to kill as many enemy soldiers as possible, rescue your fellow men and to keep on marching until you've driven your enemies out of there stronghold. Like I said, it will not be an easy task. Sorry, but even after beating the game, I don't know very much about the actual storyline of the game.
Graphics 8/10
The graphics are very well detailed. That include both background and character art. Since this was released in 1987, don't be expecting Neo Geo powered graphics, but they are very well done.
Sound 6/10
Not a strong point. While the sound effects aren't terrible or anything, they could have been a little more livelier. I like the music in some stages, but other stages' music kind of get on my nerves after awhile.
Control 7/10
The dial controller was a bad idea. You have to move your character in all directions, while soldiers appear from any area of the screen. This leads to a lot of uncontrollable deaths. It would have been much better if SNK had just used an 8 way controller and have the enemies appear in less sneaky areas in my opinion. You do get used to it after awhile though.
Difficulty 10/10
Oh man is this game hard. Don't be surprised to die a hundred times before you reach the halfway point of the game. It has a lot to do with the control in my opinion. I'm sure there are people out there who can do great in this game, but I am not one of them.
Gameplay 9/10
Guerilla War is a war game where you advance your character to the north of the screen, killing as many enemies as possible. It's the pseudo 3D style made famous by Ikari Warriors. The majority of your enemies are lowly soldiers, but at the end of each level, there is a boss character. The boss characters are really cool, but also very tough. Most of the time you are on foot, but sometimes you can take control of a tank. Your characters main weapon is a pistol, but killing red enemies can get you a machine gun or flame thrower. The game is one of the greatest action games I have ever played. Even though it's one of the toughest games of all time, it's so action packed and so fun, I can't stop playing.
You should try and play Guerilla War. I wish I could say it was easy to find, but it's not. Your best bet is an emulator. If anybody knows where I can play on a real Guerilla War machine and lives within two hundred miles of Minnesota, give me an e-mail at firstname.lastname@example.com
Reviewer's Rating: 4.0 - Great
Originally Posted: 12/20/01, Updated 12/20/01
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