Decided to go straigh to the source
COA and Hologram
Counterfeit Protection
Don't fall victim to stand-alone COAs. If you receive offers for COAs as stand-alone items, be aware that these offers are highly suspect—and they can put you and your customers at risk. If you fall victim to stand-alone COAs, you will have wasted money and your customers will not have a legal license to run their software.
Protect your customers and your company. Purchase software through a Microsoft authorized OEM distributor, an assured source of genuine Microsoft software.
The Anti-Counterfeiting Act of 2003 (U.S. only), passed on December 24, 2004, makes it a criminal offense to distribute stand-alone COA labels. There is now a significant legal risk for dishonest resellers to illegally deal in stand-alone COAs. The full weight of the law is behind the efforts of Microsoft to make the marketplace safe for your honest partners.
So, according to Microsoft, it is illegal to distribute stand-alone COA labels. I'll trust the law on this one. Thanks everyone - looks like my devil's advocate was wrong. I'm not sure I agree with the law - but it is the law and I will follow it.
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