May It Please the Mozzers,
A Jury awarded 4.8 million USD to NetQuote after finding that its competitor, MostChoice, submitted more than 3,500 false applications for insurance quotes to the NetQuote website.
The jury was so disgusted with MostChoice that it actually awarded double the punitive damages that NetQuote asked for in the lawsuit. Getting punitive damages is unusual; getting double what you asked for is extremely rare. After reviewing the allegations in the case, I'm not surprised that the jury wanted to teach MostChoice a lesson.
Both companies operate websites where consumers submit applications for competitive quotes on insurance. Each company then resells the lead information to insurance brokers, who then contact the individuals with an insurance quote. Obviously, the challenge for lead generators is to produce accurate, genuinely interested leads.
NetQuote filed suit in 2006 after receiving complaints from insurers that it was forwarding bogus leads. After investigating, NetQuote's attorneys discovered that MostChoice had hired a man named Brandon Byrd to submit false applications to NetQuote's website.
Allegedly, Byrd worked 20-30 hours a week over nine months submitting at least 3,500 false applications, thus polluting NetQuote's lead database. Some insurance agents and brokers ended their relationship with NetQuote citing bad leads. As if this trickery wasn't enough, MostChoice also advertised on its site (and apparently still does) "Better than Netquote Leads." Ouch.
MostChoice had some creative defenses in this history of the case. It claimed at one point that it shouldn't be held liable for damages resulting from false leads because NetQuote often receives bad leads without MostChoice's help. It also claimed that it couldn't be held liable because it didn't know that NetQuote would actually act on the fake leads MostChoice was feeding NetQuote. MostChoice also argued at one point that it did NetQuote a favor; if MostChoice had never submitted all those false leads, NetQuote would never have developed its super awesome lead filtering system! Not too surprisingly, the Court rejected these argument and others.
MostChoice also had the audacity to countersue NetQuote for "click fraud." Allegedly, NetQuote's employees sometimes clicked on MostChoice ads for which MostChoice paid per click, without any intention of using MostChoice's service. NetQuote employees apparently did this 25 times from October 2004 through August 2005, and 27 times from January 2007 through September 2007. (Srsly?) The court dismissed the counter claim earlier in the case because there was no evidence that NetQuote engaged in any misrepresentation. They clicked on MostChoice's ads to see what services it was offering as part of their practice of checking out what the competition was doing on Google, Yahoo! and other search engines. NetQuote's employees never completed an application for insurance nor were they "prompted by some illicit purpose."
In addition to the Jury deciding that MostChoice should pay 1.6 million in actual damages and 3.2 million in punitive damages, the jury also decided that Byrd should pay $10,000.1 NetQuote only asked for $1 for damages against Byrd, but apparently the jury wasn't impressed with his conduct either.
Although the jury issued its verdict, it is still possible for the judge to reduce the award if MostChoice succeeds in convincing the judge that the jury responded solely out of emotion and contrary to law. I wouldn't hold my breath.
Best Regards,
Sarah
If you want to read more:
Case filings on Justia.com
Rebecca Tushnet covers all the legal angles on the Summary Judgment with aplomb.
The Denver Post also gives you the nitty gritty.
Insure.com also covers the jury award.
1. Under threat of legal action by Mr. Levy, I have changed to the language in this article to clarify that when a jury awards a verdict, the defendant is not required to pay until the judge enters the judgment. As indicated, judges don't always turn the jury verdict into a judgment. The lawyers can make arguments to the judge as to why a jury award should or should not be entered as a judgment. Mr. Levy informs me that there are many developments in the case since I wrote this article. I encourage readers to review his comments below.
it did NetQuote a favor; If MostChoice had never submitted all those false leads, NetQuote would never have developed its super lead filtering system
I wonder how many times Matt Cutts has heard this line from Creative SEO's:
"Seriously Matt, If we never tested the limits, how would you have such relevant SERP's"
I'm actually surprised this is the first I'm hearing of such a practice being identified and sent to court.
There are thousands of lead generation companies, as well as sm/med businesses (car dealers and real estate agents come to mind) who walk a very thin line by "working" Internet leads.
If your business is generating the leads (as is the case here), you live and die by the quality of the lead. A competitor can deliver fake leads to you and ruin your company at any time if it wants to.
If your business is responding to leads and getting results, you likely have a strict process to follow on a daily basis knowing you'll have X amount of leads to deal with. A competitor can easily swamp you with fake leads and clog up that process to the point that you simply cannot do business efficiently anymore.
For the sake of Internet commerce I do hope this case sets a precedent and locks down the lead generation business a little tighter... though, given the "do-whatever-it-takes" attitude of businesses like car dealers, realtors, and other salespeople, I guarantee we'll start seeing more cases like this pop up.
Mitch,
I too wish there was some sort of guidance as to what you can do and what you can't. You see, we never hid what we did because there was no reason to believe that how we did it or why we did it made it wrong. This is also why we admitted to it. There is actually no specific law that makes what we did wrong. Competitors are specifically allowed to do what might be considered tortious by non-competitors. Netquote's CEO even testified that he new this as well and that he had instructed a Netquote employee to make submissions into our system. In fact, numerous Netquote employees did make submissions. However, we caught them and filtered them out.
Had we dumped 3500 leads on them in one day, it MIGHT have caused a problem (I'll explain more on this below.) However, 3500 slowly over 9 months could not cause a problem when the total of all of their leads over that 9 month period is 3.6 million. This is why Netquote had to make up a wild story and hire an expert witness to try to prove how it was mathematically possible, which failed. His testimony was struck by the court as unscientific and unreliable.
In the end they relied upon emotion. They talked at length about "crying employees" dreading coming to work and facing "screaming agents," the company "grinding to a halt," their great fear of going out of business and the panick causing people to "run up and down the stairs" yelling "the bad leads are coming the bads leads are coming." My personal favorite was refering to their agents as being like "fourth graders being beat up at school" by our .098% of the leads. Meanwhile, they had hockey stick growth and were actually throwing office parties celebrating their success. The ex-employees we encountered at the 12th hour of this trial told us the truth, but it was too late to get them on the witness list to testify. If there is one thing I learned from sitting through 2 weeks of trial is that trials are as much or more about legal gamesmanship as truth and justice.
To answer your question specifically, Bad leads are easy to filter out by IP address(that one is a wringer) and other methods. We only sent these leads from 2 IP addresses. All lead generators have filters that capture and send suspect leads to manual review. Without this, no one in our industry could operate. However, internal documents (emails) from Netquote showed that they made the consious decision to put an "on/off" switch in their filtering system. I believe they deliberately turned the filters off. They were scaling up their incentivized lead programs with Mypoints.com and Publishersclearinghouse.com and, from what I can glean from the information I have, there were so many bad leads from those programs they chose not to review any at all. They did testified they had to make 15 email templates to send to consumers to tell them if they wanted their points and prizes they had to complete a lead form. That gives you an idea of how widespread the problem was with the incentivized leads.
I believe that when the heat came down from their agents, and when we wouldnt sell our company to them or sell our leads to them, they decided to make us the patsy. I believe their ex-CEO was just looking to CYA and take revenge for us not caving to his obviously one-sided offer to purchase all of our leads. If you look at Netqotes's profile on quantcast, their traffic has plummeted lately. I believe they have dropped some of these programs maybe they are taking actions to correct these incentivized lead problems now.
Another point you should know is that they knew about or submissions for weeks, maybe months, before even bothering to talk to us about it. They were trying to buy our leads, every one of them, to resell to their agents and had made a previous offer to bid on the purchase of MostChoice. It was only after those negotiations fell through that they served our employee and then added MostChoice to the suit. Before this, they had sued "John Doe." They receive 13,000 leads a day and on average they only got about 13 or so leads a day from us, compared to the thousands of bad leads they were getting from the incentivized lead programs and their affiliate program. I feel they obviously knew it wasn't hurting them. When asked in court why they didn't just give us a phone call and ask us to stop, their President (Who is now the CEO) and their CEO (who is now the chairman of the board, who I believe is now living in Los Angeles, not Denver) testified that they thought their attorneys had spoken to us. Attorney client privilege stopped us from asking exactly why. Again, legal gamesmanship. There are many things that the Jury was never allowed to hear that were critical to proving our case.
Unfortunately, they also hid many important details from us that we needed to know much earlier. They had asked, and received from a lower court, the right to an AEO (attorney's eyes only) provision that kept me from seeing 95% of the 10,000 pages of documents they produced until one month before trial which was after the time period to add witnesses had expired, at least as a practical matter.
It was just blind luck that an ex-employee of Netquote moved to Atlanta and about 3 weeks before the trial she interviewed for a job at MostChoice. She had been with Netquote for years and had an opportunity to work there under both the original management and the new management. She had "blown the whistle" on a lot of these incentivized marketing and affiliate program problems that occurred after the change in management. She knew the problems well because she spoke to the agents every day. She was a key customer service person. They fired her, 3 weeks after giving her a good review. They fired almost everyone in her department that had been hired by the old management.
After speaking to her, we filed a motion to add her as a witness. Netquote filed an objection pointing out that the time period had expired to add witnesses and claimed she had been effectively identified because her name was somewhere in the 10,000 pages of documents that I wasn't allowed to see before I could add her as a witness. Again, legal gamesmanship. They also threatened to sue her and we believe took other actions to intimidate her and numerous other employees that had been fired, all of which pre-dated the new management. Their objection was successful. However, she still sat behind me every day in court and helped as best she could. We are very thankful for this. It was very brave of her.
I'm still waiting for Sarah to publish what I sent her. Maybe it got caught in her spam filter? The word "Netquote" has a tendency to do that. By the way, I believe Netquote owns Azoogle Ads. :-)
I would like to see more on this case as well.
Have you PM'd her?
I have now.
"Better than the NetQuote leads" - that made my day. Funny if you were really evil you would hire bunch of East European/Indian IT people using anonymous IPs. No way to prove, no way to prosecute and no witnesses. I hope the judgement sticks.
I think the jury did an excellent thing here, sending a real message to companies who engage in this type of behavior. If you know what happened in this case, you're gonna think long and hard before you try to pull some other BS like this.
yeah great stuff. We all have these idiot rip off merchants in various niches so hopefully this will put a bit of fear into them. Lets hope it is a continued pattern to oust all fraudulent claims and activities.
Interesting article and even better outcome. While I really don't want to see regulation of the net, if we don't see a general cleanup of the hucksters and out-right scammers that take advantage of businesses, or even the e-Bay phishers (my Mother got taken, called me 1 day after the fact, was I steamed), then our business arena is going to take longer to be accepted as the business model that print and TV/Radio have.
Glad to see a jury at least understood the horrible business practice of MostChoice, and understood even further the loss that NetQuote endured. I think the shops that scam should really be shuttered (sorry if folks loss a job, but do we really want people being taught this crap) and a close watch kept on the CEO's CMO's, etc., to make sure they don't put a new tent up somewhere else.
Haha great post, great story. Nice to see the legal system works
Thanks for providing an interesting read. Fake quote requests should definitely not be permitted and judges should definitely set an example with any company that is profiting off this practice.My recommendation? I think there should be a bit less opinion and more cross-referenced facts in this piece. I can tell from the post that you found this case rightfully shocking, but as Mr. Levy pointed out in his comments, the situation appears to be more complex than your piece outlines.That said, I'm again glad you posted about it. It is important that Moz readers have the opportunity to better understand what is happening in the wilds of the Internet and this is a great example of horribly handled lead generation.Essentially, to clarify, I think you did a good job of warning everyone about the practice of creating fake leads and the consequences. If any of your readers are involved in something similar, I'm sure this warning will make them rethink it.
Such is life. I'm surprised that they didn't think they would get caught. However, I do feel slightly sad for Byrd, even moreso if he was just doing his job with no actual knowledge of what he was doing or the damages it could cause. I'm not exempting him in any manner, but I do feel kind of bad for him.
I testified at court that the whole thing was my idea and Brandon had no idea what the purpose of this was even for. I asked Netquote to let him out of the suit, they wouldn't. They even tried to have him arrested, even after they knew he was just an employee. They sued his ex-girlfriend and she has testified in an unrelated deposition that they wouldn't let her out of the suit unless she pressed criminal charges against him. Fortunately, the charges were thrown out of court, but it was a big hassle and really scared Brandon. Mean. Mean. Mean.
Karma in full effect..
Haha great post, great story. Nice to see the legal system works
The more we can have the internet subject to reasonable rules that are actually enforced, the better for all of us. Left alone, the internet is a "cesspool of misinformation, [copyright theft and pornography]."
hmmm, i know some that like the pornography :-/
Reading that story just made my day. There are so many unethical people out there on the net making it harder for the rest of us. It is nice to see someone get burnt for it.
one mans porn is another mans treasure..
Honestly, I shouldn't be laughing after reading this. Gezzz, what scum-bags.
I think this practice is a lot more common than we think. Four years ago I used MostChoice.com when I was a financial advisor for a firm here in Colorado Springs. I would talk to a lot of my "leads" and they would say that they never filled a form out. One guy passed away 2 months earlier.
I contacted Most Choice and found them to be very unfriendly. I see now the company lacks integrity (not really surprised, sadly) and will warm my co-workers against them.
The business week "click fraud" article is from 2006. No relation to this verdict, outside of the irony.
Wow, on MostChoice's site as well, they're proud of the fact that their click fraud story made it to the cover of Business Week. That doesn't look so good sitting up there now.
I'm not sure if that Byrd fellow should have to pay 10,000. I'm sure he was far from the mastermind in this situation.
Regardless of whether he was the mastermind, he should clearly have known what he was doing was unethical. Some penalty would be deserved in my opinion.
He still did it, i find completely and totally impossible to believe he didn't know what he was doing was unethical. I'm surprised he didn't get slapped for more. But it does make more sense to go after the deep pockets.
Jac: Actually, the fact that they did post it on their website is certainly not because they are "proud" of it. Most of these court rulings make it mandatory for the defendant (if guilty) to post the story or the ruling on their website. My guess is that it's probably what happened in this case. Unless they are just idiots?
The magazine cover/article actually referred to a previous incidence of click fraud that Most Choice endured. They were the "victims" of that story. You can read it here. I just thought it was hilarious that they were so proud to be whistleblowers of this click fraud when they were up to something equally insidious.
Is saw that too! What the hell, why would you advertise that you got your ass sued for 4.8 million dollars and lost. Guess it goes back to the old saying "there is no such thing as bab publicity because then at least people are talking about you or your brand".
Oh snap! Hahahaha.
Whoa, loving the MoreChoice counter-arguments! Creative guys, that's for sure!
Nice.....you play with fire you’re gonna get burned.If you play fair things will work out at the end. That's the same mentality as black hat SEO. Trick, deceive, and cheat the system to a point that it hurts others and eventually it will hurt you back.
Great stuff as always Sarah.
I agree that this is probably Not an isolated incident but more likely the tip of the iceberg.
However if more of these judgements follow, then maybe some of these jerks will think twice before attempting to hammer their competition by manipulating their data.
In the end, if they had spent as much effort in improving their own service they wouldn't have to worry about their competition.
Maybe these kinds of suits that make companies take responsibility on the net will improve the credibility. It hurts all online when we find out we can't trust online services.
Crease-
Your hitting on some of the key points of this case. However, there is more information that will show there was no malice. I am waiting for Sarah to publish what I sent her so I won't go into everything now. However, you took the time to post something well thought out and I think I should do the same in return.
You should know that we are suing Netquote for false advertising practices, largely relating to their claims of the size and scope of their agent network. At the end of the lead submission the agents the lead went to were sent in a return email. We counted the agents and they didn't have the 20,000 they claimed. We called them and found out many were "ghost" agents. It was revealed in court the real number was only 6700 when we started our investigation, so our suspicions were correct. They still are. Netquote has stopped making this particular statement. This was the purpose of the submissions, agent customer count. Lead quality dilution was mathematically impossible.
We never put 3500 leads into their system at all and never in one month. We put roughly 13/day on average over a 9 month period. This accounted for only .098% of the 3.6 million leads Netquote received during that same time period. This was at the heart of why their expert witness's testimony as to causation was struckby the court. There is no way what we did resulted in lead quality dilution.
Further, there affiliate program, incentivized lead generation programs and lead purchase deals with other lead generators, and the fact that they did not disclose to their agents that they used such marketing methods is another large part of our suit against them. In short, they generate junk leads yet they claim their leads are the same quality as the search engine generated leads that we pay a lot of money to generate. Some of their agents actually testified on our behalf that it was these programs that caused them to leave, not us. None of thir agents testified on behalf of Netquote. They brought no agent witnesses at all and their expert testimony was eliminated as to causation so in the end they had no proof of their claim.
Their own CEO, now ex-CEO, admitted their affiliate program and incentivized lead programs had become problematic and bad affilaites and incentivized lead sources had to be culled out on a regular basis. We believe that literally millions of bad leads come from these programs which is the real source of Netquotes woes. One agent even testified that he discovered Insure.com was selling Netquote bad leads and sure enough, they have a deal with Netquote. Ironically, Netquote sued us for bad leads yet they regularly pay affiliates, incentivized marketers, and other lead generators for leads that are bad as well.
Maybe if I had sold my company to them for penny's on the dollar as they wanted, or all of my leads for cheap as they wanted, they would not have sued us. Who knows. They bought two other lead companies for cheap, but I wouldn't cave. They buy leads from many other lead generators for cheap, but I wouldn't join the cartel. The road to hell is paved with good intentions.
Explaining all of this to a hometown Denver jury (Netquote is in Denver,) when we were the out-of-town company from Atlanta, just didn't work. We got Home-cooked "well-done" and what we did truly looks bad on the surface, so it was easy for them to do. Just look at all of these posts. No one ever gave us the benefit of the doubt. However, when you take the emotion out of the equation and understand all of the facts it becomes obvious this was just one competitor investigating the other. The evidence of that investigation being used in a lawsuit. Netquote's CEO even testified that there were legitimate reasons for putting leads into another competitors system and he instructed a Netquote employee to put leads into our system as well. I believe they investigate us regularly.
Netquote seized the opportunity to make us the scapegoat of their problems and I believe is trying to force us to settle our suit against them. They are backed by a multi-million dollar venture capital fund and hired one of the country's largest law firms to sue us and our employee, who is a good friend of mine (That was just plain mean.) By comparison, MostChoice is a small company without the financial backing that Netquote has. Standing up to this type of high-dollar legal firepower is difficult, but not impossible. They did a good job putting up their case for the jury. We focused on facts, not emotion. Netquote's case was based in emotion and that was obvious at trial. I am confident that in the end we will get all the facts out in the open, all of the emotion out of the equation, and we will prevail. That is the way our legal system is supposed to operate.
Thank you for taking the time to analyze the situation.
It just goes to prove the old adage: no matter how thinly you slice the baloney, there is always 2 sides.
Well written. Very informative.
Thank you very much.
Mike, seems to me there are two primary issues to be answered for any jury (or peers otherwise, such as SEOmoz) to take a side - assuming what you've said is true.
1. What is considered an acceptable level of "competitive analysis" via false lead generation in your industry? 1% of the competitor's leads? 0.1%? 10%? And what is considered an acceptable time period to conduct such analysis via false lead generation? 9 months? 1 month? 5 years? If neither the plaintiff nor defendant can answer these questions confidently, will they both agree that such competitive analysis is expected and, unless statistically proven otherwise by the victimized party, a non-destructive force on the ability to do business?
2. If your company's false lead generation was conducted for the purposes of competitive analysis, where is the analysis? What did you find? Are there charts, trend reports... any kind of physical proof that the false leads were being implemented from the beginning and throughout the 9-month period as a research tool, and not as sabotage?
As far as percentages go, all lead services have a credit policy. Netquote credited up to 10% of the leads automatically. I guess this was because they knew that they had at least 10% bad leads already. Most of the agents testified the number of bad leads they got from Netquote was around 30%. One testified it was 90%, he never got a single lead from us. Therefore, .098% from us would obviously not be material. We couldn't make a dent. Internal documents (emails) from Netquote showed that when they credited the bad leads the agents did not quit, regardless of who the lead came from. As long as they didn't pay for it, no harm no foul. However, even though they knew the leads were bad, they stopped crediting them at some point when new management came in. Had the old management, who founded the company, been in place I don't think any of this would have happened.
As for charts and reports, we documented everything thoroughly because the intention was to use it as evidence in the false advertising case against Netquote should the result of the investigation show they had less than 20,000 agents (we only found 1600.) Therefore, we have a printout of every email that was sent to us that contained the agent information, etc. That information was also inserted into a database and de-duped. In an ironic twist, Netquote produced an internal document that showed the number of agents that really were buying leads and that proved our point further. They never had 20,000. When they started making the statement they had 4850 and when we started the investigation they only had 6700. There false advertising is much more extensive than that, but it was disproving this statement that was the purpose of the investigation.
Wow, you guys are bashing us pretty good considering no one even asked us for our side of the story! There is a lot more to this story than meets the eye. Things are not always as they appear. I have sent an email to Sarah with some information on this case that needs to be reported if reporting is to be done fairly. I await an update to her blog.
Hmmm, interesting. So there is information that isn't in the court papers?
Seemed to me that the court papers and both arguments presented both sides of the arguement.
Would you be disposed to share the information with us here as well as sending it to Sarah? I should hope so. :-)
Agreed, the courts have spoken and you have lost BIG TIME, what else could there be that wasn't discussed in the case? I assume an appeal is on the way allowing lawyers to rack up more money (Love you though Sarah).
"...discussed in the case?" Where is this discussion of the case you speak of?
Actually he said "discussed IN the case" meaning in court.
We are not the Jury. However, it seems that most agree with the jury.
What else is there that was not brought to light during the case?or was it just not highlighted in Sarah's summary?
Exactly. "Discussed IN the case?" Meaning have you seen the transcript? Do you know what actually happened in this case? Do you know were this case stands right now? Do you know anything other than what you have read on the internet? You make such definitive statements of fact, mostly based on assumption, but did you ever check the facts first? What about at all? Do you believe everything you read?
If you mean the internet by reading the Actual documents the court makes availbile online and re-distributed on Justia, then yes. :-)
If the court documents aren't the facts, then I don't know what is.
Not trying to be combative here, but based on the court papers, readings, and filings as well as the juries' decisions what other conclusion can we come to?
You said you have special information or undisclosed details or facts that the court didn't see, please share them so we may have the chance to re-evaluate our opinions.
Until then you have admit that based on the facts presented its reasonable to understand the conclusions we've drawn from said facts. :-)
I have traded emails with Sarah and I believe she is going to reprint my email on the site and/or illustrate some of my points. As for Justia, I don't have a subscription but the last date of the documents I see from that link is May 13,2008. This case was tried only a month ago and the jury gave its decision on 10/17/2008. That is a 6 month gap. The Tushnet blog is from July. That is 4 months old. At this time, there is no judgement in this case. There is a difference between a verdict and a judgement. We have not been ordered to pay anything, yet. However, what I have been alluding to is not the lack of a judgement, it is what happened at trial. In short, Netquote lost there expert in the middle of the trial. His testimony was struck by the court after it was determined that he was unreliable and did not use scientific methods meeting the standard for expert testimony. The judge told the jury to disregard the expert's testimony, but two days on the stand had prejudiced their opinion too much. This wasn't the only problem with the case from a legal standpoint, or a factual standpoint, but this is all I will cover for now. Where the case currently stands is that we have filed a motion for judgement as a matter of law and will ask to retry the case if necessary. If both of those fail, then we will appeal. We are very confident we will win this in the end and this battle is far from over.
Obviously, not all of the court papers are online.
I will share all of the information directly, if necessary. However, I'm going to show Sarah some courtesy and allow her to revise some of the statements she made first.
Which court papers aren't online at justia? Seems like its pretty comprehensive in listing papers and arguments that the court judged correctly filed and appropriate.
I still hold that if people read the court papers, documents, and rulings they will come to the same conclusion that Sarah has.
What's the last date you see on those papers in Justia?
Interesting case. I don't want to sound like a bad guy but I think the award is egregious and will likely be trimmed sharply on appeal (like 99% of awards it seems), if an appeal is heard. It seems pretty steep for false representation with knowledge resulting in damage. I'd be curious to see how damage was calculated and proven.
This is kind of a problem with all lead-generating services, in that they're only as useful as the participants' willingness to play by the rules. This sort of situation even has a (tenuous) bearing on certain CPC and affiliate relationships. What's nice though is that the affiliate market has standardized somewhat, and the main publishers usually have multiple forms of redress. Affiliate cases are usually simplified also that they're transaction based (which is much more quantifiable) than leads.
Which leads (har!) me to question, what kind of verification process was done on these so called pre-qualified leads? Is it as simple a matter as, "hey first name, last name, email, okay off you go!" or was there more to it? SIN database lookup? Residency check? DMV check? If NetQuotes has a demonstrably weak verification process it could be more their "fault" than anyone who submits, malicious or not.
That said, it would be hard to not prove malice in this case so the judgement is probably always going to stand. But I wonder if the scope and language of the reward will as well.
EDIT-whoops, meant to reply to root article not Mr Levy. You can ignore my comments Mr Levy.