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Williams Electronics, Inc. v. Artic International, Inc.

United States Court of Appeals for the Third Circuit
685 F.2d 870 (1982)


Williams Electronics, Inc. (Williams) (plaintiff) manufactured a video game named DEFENDER for use in coin-operated video-game consoles. Williams registered three aspects of DEFENDER for copyright protection: (1) the computer program, which was stored in read-only memory (ROM) computer chips; (2) the game’s attract-mode feature, which displayed on the console screen when the game was not in use; and (3) the game’s play-mode audiovisual effects, including how a player interacted with the game. Artic International, Inc. (Artic) (defendant) sold components for coin-operated video-game consoles, including components containing a computer program stored on ROM computer chips. Artic manufactured and sold a computer program, called DEFENSE COMMAND, with attract-mode and play-mode features that were virtually identical to those in DEFENDER. Williams brought suit against Artic, alleging that DEFENSE COMAND infringed upon Williams’ attract-mode and play-mode copyrights. The district court found for Williams. Artic appealed, arguing that that the statutory requirement of fixation was not met for those copyrights.

Rule of Law


Holding and Reasoning (Sloviter, J.)

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