Capcom U.S.A. Inc. v. Data East Corp.

Capcom U.S.A. Inc. v. Data East Corp.
Court	United States District Court for the Northern District of California
Decided	March 16, 1994 (1994-03-16)
Citation(s)	1994 WL 1751482 (N.D. Cal. Mar. 16, 1994)
Court membership
Judge sitting	William H. Orrick Jr.

Capcom U.S.A. Inc. v. Data East Corp., 1994 WL 1751482 (N.D. Cal, 1994) was a 1994 legal case related to the copyright of video games, where Capcom alleged that Data East's game Fighter's History infringed the copyright of Capcom's game Street Fighter II. It was revealed that the design documents for Fighter's History contained several references to Street Fighter II, leading Capcom to sue Data East for damages, as well as a preliminary injunction to stop the distribution of the infringing game. In spite of the intentional similarities between the two games, the court concluded that Data East did not infringe upon Capcom's copyright, as most of these similarities were not protected under copyright. Judge William H. Orrick Jr. applied a legal principle known as the merger doctrine, where courts will not grant copyright protection where it would effectively give someone a monopoly over an idea.

Although early cases such as Atari v. Philips ruled against a game for infringing on the copyright of Pac-Man, they also noted that any standard elements of a game could not be protected by copyright. Courts would later expand on this principle, establishing that copyright did not protect generic concepts, functional rules, and scènes à faire. This included an earlier legal dispute, where Data East lost their case against an alleged video game clone of their game Karate Champ because none of the similarities were protected under copyright. Now years later, Data East found themselves on the other side of a similar dispute, and the court determined that the contents of Fighter's History were legally permissible. This trend of a more permissive approach to copyright continued until 2012, when rulings such as Tetris Holding, LLC v. Xio Interactive, Inc. and Spry Fox, LLC v. Lolapps, Inc. ruled that more specific forms of copying are unlawful.