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

Williams Electronics (plaintiff) made the video game DEFENDER and copyrighted three things: its program (stored on ROM chips), its attract-mode display (shown when idle), and its play-mode audiovisual effects. Artic International (defendant) sold a nearly identical game, DEFENSE COMMAND, whose attract-mode and play-mode features closely copied DEFENDER's. Williams sued for infringement of the attract-mode and play-mode copyrights; the district court found for Williams, and Artic appealed, arguing the audiovisual works were not fixed as the Copyright Act requires.

Whether the audiovisual displays of a video game stored on ROM satisfy the Copyright Act's fixation requirement even though the displays change in response to player interaction.