“Click fraud” generally refers to the practice of clicking on an Internet advertisement for the sole purpose of forcing the advertiser to pay for the click.  (Id. ¶ 43).   Because advertisers only pay when someone clicks through to their website, artificial clicks can be very costly to advertisers.  (Id.) Click fraud includes the use of illicit practices such as spyware, browser hijacking software, and other “bots” or “non-human traffic.” 3  (Id. ¶¶ 43–44).   Such practices result in lower sales conversion rates for advertisers because the leads are false—they do not come from actual buyers interested in purchasing the advertised products.  (Id. ¶ 26).   Because lower conversion rates lead to lower advertiser bids and thus to decreased revenue, ensuring the quality of its distribution partners and eliminating improper Internet traffic are extremely important for a pay-per-click company such as MIVA.