St. John's Law Review

A Practical Look at Virtual Property

By: Allen Chein

In June of 2005, a Chinese court in Shanghai delivered a verdict in a case whose facts might be considered fanciful, if not for the tragic and violent outcome that had come to pass.  Qui Chengwei was a player in a massively multiplayer online role playing game (“MMORPG”) called Legend of Mir II.  In the course of his game playing, Qiu and a friend succeeded in a difficult quest, which rewarded them with a sword—the Dragon Sabre—a virtual weapon only of use by characters in the computer generated game world.  They subsequently lent the weapon to Zhu Caoyuan, who, without permission, sold the Dragon Sabre in an online auction for the equivalent of $870 U.S. Dollars.  Qui ultimately sought out Zhu, the virtual thief; the confrontation culminated with Qui stabbing Zhu to death in a “real world” murder.

This paper explores the concept of property in the arena of MMORPGs generally, and then examines how a United States court would resolve Qui’s property claim had the events actually transpired on our shores.  Would he be able to establish rights to the sword and prevail?  This article submits that he would not, though it is by no means a settled question.  Given the popularity of MMORPGs, it is reasonable to conclude that a dispute involving virtual items is just around the corner.