I think as soon as you say "the game relies on an online service" it's exempt from the provisions of this initiative. Of course anything can be pretended to be

I think as soon as you say "the game relies on an online service" it's exempt from the provisions of this initiative. Of course anything can be pretended to be an online service (that's the whole point of SaaS) but all the initiative concretely says is "phoning home for no reason is not a service".