Hi all,
unfortunately it seems like Reallusion Marketing and Support-Team does not answer our email from the 20. January 2022.

I am working on a Unreal Engine game project and I am currently doing a product evaluation for a character creation pipeline.
One of the products we are testing is the Reallusion Character Creator 3. The problem we are currently facing is not a technical problem but a problem with the EULA.

Creating a game costs a lot of resources and we do not want to choose the wrong product only to later find out that we are breaching the EULA with our mechanics. 
The problem we are facing is that the Reallusion EULA is not really clear to our understanding and also bears many risks to our project.

1. Regarding this part of the EULA

• The unique topology of characters generated by Character Creator is Reallusion’s property. You may not do the following applications unless getting explicit permission from Reallusion:
• Repurpose them into any other 3D formats, distribute them, or sell them in any third party marketplaces or applications.
• Use the characters or their morph assets to build up another character generation system in games or interactive services.

We are planning to create a character creation system in our game where the player can customize his own character before starting the game.
The player should be able to choose between different body types, skin tone, eye color, different head presets and hair.
We are not planning to use morph targets as it seems like there is no way to export them from character creator 3.
(As wished by the community since Jan. 2019 and still with no feedback from Reallusion: https://www.reallusion.com/FeedBackTracker/Issue/Exporting-morphs-to-game-engines-like-unreal-or-unity)

An example character creator we are planning could be the game XCOM 2: https://www.youtube.com/watch?v=cQh1ScJ7c1E

We want to achieve this by importing the different body parts and heads from character creator to Unreal Engine and then create an modular character based on the player choices as described here:
https://docs.unrealengine.com/4.27/en-US/AnimatingObjects/SkeletalMeshAnimation/WorkingwithModularCharacters/

We are also planning to create randomly generated Non Player Characters by randomly choosing a body type and a head.

Now from my understanding of the EULA it is not clearly defined what a "character generation system" is.
Is the system we are planning one? Or is the system we are planning a character customization/creation system?

I guess Reallusion wants to make sure that nobody creates a competitive product with their meshes and morphs. But then  I do not understand why the EULA would state "in games".

I would really appreciate it if there would be an official clarification about this part of the EULA as there were multiple people asking this question in the past and not getting an clear answer to this:

No answer here: https://forum.reallusion.com/439859/In-game-Character-Creation-EULA-Question

Anwser telling that as long Reallusion Content can't be extracted it is no problem. But in the EULA it does not state anything like that therefore legally this is kind of worthless.
https://forum.reallusion.com/399548/Character-Generation-System-in-games-not-allowed

Also a question about an In-Game Character Creator with no clear answer:
https://forum.reallusion.com/409945/I-can%E2%80%98t-use-the-characters-or-their-morph-assets-to-build-up-another-character-generation-system-in-games-or-interactive-services



2. The next problem we are currently facing with the EULA is the mass distribution license.
We understand that before releasing our finished game we need to get one by contacting the Reallusion marketing team and sending them information about our game.
This seems like a incredible big business risk for us as.

• The EULA does not say  which reasons lead to a refusal of the mass distribution license.
• The EULA does not say if the mass distribution license can be cancelled after it is granted.
• The EULA does not clarify what information the marketing team needs in order to grant the license. Do we only get the license after development started? Do we get the license when we only write a short sentence about our planned product? We do not want to deep dive into the development only to later find out that we are not eligible for the mass distribution license.