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No. 2421
[Edit]
I think there are a few factors at play here. One is the growing size of Shanghai Alice or Mediascape or whatever, I'm not sure how this works and it probably actually plays into it because it seems that Mediascape might have the license to it or at least it does on steam, anyway, they have gone form an indie dev of one guy to a company on Steam that also has been licensing Touhou Fan games like Touhou Genso Wanderer and has games out on PlayStation and the Switch. I don't know how many people work there now but unlike one guy making indie games, now there are going to be company Lawers and such involved as well.
Secondly, Mediascape or whoever seems like it probably would be quite aggressive legal wise simply due to all the work it would have to do. While making a fan game is legal if it doesn't make any money, if people are making games based on another persons IP for money, that is illegal and Touhou is swamped with that kind of thing, there is a pirate site that I check to see what new games come out and if any are good at least once a month it seems that a new game has been released that is ripping off Touhou's IP, and these games are mostly pirated from Steam, so they are getting through whatever copyright policy Steam has as well. Anyway, due to how active these lawyers are going to be, it makes sense that there would be spill over unto other realms such as piracy.
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