Midway Manufacturing Co. v. Artic International, Inc., 704 F.2d 1009 (7th Cir. 1983), was a legal case where the United States Court of Appeals for the Seventh Circuit found that Artic violated Midway´s copyright in their arcade games Pac-Man and Galaxian. The lawsuit was part of a trend of "knock-off" video games in the early 1980s, with courts recognizing that a video game can qualify for protection as a copyrighted audiovisual work.
Both Galaxian and Pac-Man were bestselling games in the early 1980s, with Pac-Man generating over $1 billion in revenues, as well as sequels, merchandising, and a cartoon. The dispute arose when Artic began to distribute an alleged clone of Pac-Man, and a circuit board that could speed-up the gameplay of Galaxian. While Midway registered their copyrights as audiovisual works by submitting video recordings of their games being played, Artic argued that this did not protect the games themselves, as the game´s graphics were not fixed like a conventional video. The district court disagreed, finding that both games were protected as audiovisual works, and enjoined Artic from distributing their infringing hardware. The decision was affirmed by the United States Court of Appeals for the Seventh Circuit.
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