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Midway Manufacturing Co. v. Artic International, Inc.
United States District Court for the Northern District of Illinois
547 F. Supp. 999 (1982)
Midway Manufacturing Co. (Midway) (plaintiff) owned the copyrights of two video games, Pac-Man and Galaxian. The games had a play mode in which players controlled the game and an attract mode that simulated the play mode repeatedly until a player initiated play mode. The audiovisual displays of the games were stored on computer chips. Artic International, Inc. (Artic) (defendant) sold a speedup kit to modify the images’ movements in the Galaxian game as well as a circuit board that replicated the Pac-Man game. Midway sued Artic for copyright infringement and requested a preliminary injunction. Artic argued that Midway’s copyrights were invalid because the games’ computer chips created the audiovisual displays using numbers and symbols, as the chips did not contain enough memory to store the actual audiovisual displays. Therefore, Artic argued, the computers repeatedly created new pictures that were not fixed and thus were not capable of copyright protection.
Rule of Law
Holding and Reasoning (Decker, J.)
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