Innovention Toys, LLC v. MGA Entertainment, Inc.

Innovention Toys (plaintiff) patented a physical, chess-like strategy board game using refracted laser beams, and sued MGA Entertainment (defendant) for infringement after MGA created a similar game; MGA countersued that Innovention's patent was obvious in light of Laser Chess, a prior electronic computer game using virtual lasers in similar chess-like strategy gameplay. The district court found Laser Chess was not "analogous art" for obviousness purposes because it was an electronic game rather than a physical one like Innovention's, and granted Innovention summary judgment; MGA appealed.