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What do you secretly judge people for?
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Yes, my labor, which resulted in passive income. Nobody is saying that passive income is a magical thing which you just acquire without effort. You invest the effort, and then you sit back and reap the rewards.
By your definition game development (in the old style) is also passive income... so is art... so is building a house or a car or pretty much any form of manufacturing.
These activities all involve building something with no promise of selling it - then trying to find a buyer... in each case you, the producer, are investing up front in a venture which may or may not succeed and then hoping someone will pay you for it.
Homebuilding would be active income, since you can only sell each house once. Game development would be a good example for someone like the Minecraft creator. He invested a bunch of time creating this cool game, and then he sat back and got rich. It's passive at that point (assuming no maintenance, bug fixes, etc.), since he continues to gain sales, despite only doing the work once. The digital realm is full of opportunities for passive income, or at least it used to be. Corporations have essentially shoved individual creators out of the market.