After losing a case for $175, I am now armored with knowledge and insight into what PayPal actually cares about. Yes, I LOST the case. After spending hours on the phone with PayPal representatives and claims specialists, here is some knowledge for those who don't know. 1. Sending as gift is NOT a "better" method. The buyer may charge back on ANY type of transaction. In my case, the buyer claimed it was an "Unauthorized" transaction. Meaning, someone supposedly hacked his account. And yes, this transaction was done via 'gift'. 2. Notes DO NOT matter as much as you think they do. In the words of the PayPal specialist, "Notes essentially don't matter at all, especially in the case of a virtual item." Reason being, if a person claims this transaction was unauthorized (hacked), the hacker could have been the one to type in the notes. So even if they write "will not charge-back", that is irrelevant to PayPal in the case of an unauthorized transaction. 3. Charge-backs can only happen within 45-60 days of a transaction. This is why people like myself require all buyers to have SourceOP Rep exceeding 45 days. I personally say 2+ months, but you get the point. 4. Virtual Items are NOT protected under buyer protection. Mostly because there is no tracking number. Although PayPal doesn't cover virtual items very well, they still try and investigate a disputed transaction. 5. Sending as purchased goods is a preferred method. Although there is 4% fee the seller pays, it is the preferred method over "gift". If PayPal finds out you are selling/buying items using the gift method, they will most likely remove your option to send or receive money as a gift. The representative was very stern on this, and informed me that they will take action if people are bypassing the 'purchased goods' option for the 'gift' option, just to avoid the 4% fee. Although many people on here have claimed to use the gift option for months, it's just a 'rather safe than sorry' thing. Also, in the case of disputes, using the 'purchased goods' option helps your case more than it would if you use 'gift'. Although it might not be a significant help, it's still a step in the right direction. As a rule, to avoid all this non-sense, just make sure you do ALL your research on a buyer before selling. SourceOP Rep (45-60 day rule), Outpost (banned status), SteamRep (good/bad standing), etc... Although PayPal doesn't really care for what displays in the notes, I usually make the buyer put one for my own reference. I'm not sure if STEAM would dupe your items if you get scammed, but notes in your PayPal may also be useful for that as well (if you don't win the case). For every buyer, I make the them write a note that goes something like this: "Paid for virtual items, already received - 3 buds - STEAM_0:1:12345678" I figured their Steam ID is better than their name, since the name can just be changed easily. Anyways, thanks for your time and I hope this will be of use to someone! Happy trading!