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The Entertainment Software Association (ESA) has asked the U.S. Trade Representative (USTR) to identify the pseudonymous voices38 operation as a notorious online market in its 2026 review. That is an industry recommendation—not a government designation. As of TorrentFreak’s October 12, 2026 report, USTR had not decided which recommendations would appear on its final list.
What ESA says voices38 does
In comments submitted to USTR on October 7, 2026, ESA describes voices38 as a persistent crack-development and release operation specializing in Denuvo Anti-Tamper. ESA says Reddit’s r/CrackWatch index attributes approximately two dozen cracked or bypassed games to the operation. It also says at least nine of its member companies use Denuvo Anti-Tamper for PC games. These are claims in ESA’s advocacy submission, not findings by USTR or a court. TorrentFreak reported on the request, and the ESA submission to USTR contains the association’s claims.
Why ESA argues a crack operation can qualify as a market
ESA’s case rests on the role it says voices38 plays in the piracy supply chain. A crack can make a game usable without authorization; other services and communities—including repackers, torrent indexes, cyberlockers, peer-to-peer networks, direct-download services, and forums—can then distribute copies. ESA argues that a market can enable substantial piracy without looking like a storefront with multiple sellers or hosting complete game files itself.
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As ESA puts it, “Each crack therefore unlocks an entire downstream market for an unauthorized copy of that title. For a title that no other actor has made usable, but for Voices38’s crack there would be no functioning pirated copy for those markets to offer.” The statement expresses ESA’s policy argument; it does not establish that USTR has accepted it.
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What designation could mean—and what it would not mean
ESA says a designation would focus attention on identifying the operator, preserving evidence, disrupting distribution accounts and donation channels, and coordinating action across forums, repositories, hosting services, peer-to-peer infrastructure, and other intermediaries. That describes the action ESA wants USTR’s listing to encourage. The request itself does not show that any of those steps have been taken, and USTR’s review is not a court ruling.
Keep the other figures in ESA’s filing separate
ESA’s submission also discusses FitGirl, a separate nomination. Its estimates of 15,484,145 users detected in peer-to-peer swarms between March and August 2026 and $1,083,735,308.55 in estimated lost value concern FitGirl, not voices38. ESA says it calculated the estimated value by applying a $69.99 MSRP to each detected user; that is an advocacy estimate, not independently verified actual losses. ESA also reports that zero links were removed after its notices to FitGirl between August 2025 and August 2026. Those claims should not be read as measurements of voices38 activity or its alleged impact.
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What happens next
USTR considers submissions from rightsholders and other stakeholders during its notorious markets review. ESA’s comments include recommendations beyond voices38, such as handheld devices allegedly offered with unauthorized game libraries, repackers, torrent and coordination sites, digital-goods marketplaces, and cheat sellers. Those are separate requests. USTR—not ESA—decides what is included in the final 2026 list.
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