## Facts

- Sanders Associates, Inc. (Sanders) owned U.S. Patent Re. 28,507 (the ’507 patent), which described a television game apparatus that displayed a moving “hit” symbol (a lighted dot) and player-controlled “hitting” symbols that could intercept the hit symbol.
- The ’507 patent described that when the hit symbol and a hitting symbol coincided at the same position on the screen, circuitry would cause a change in the hit symbol’s direction of motion (a collision/deflection effect typical of ball-and-paddle games).
- The patent disclosure described producing the game signals using analog circuitry associated with a television receiver.
- Magnavox Co. was the exclusive licensee of the ’507 patent and commercialized home television ball-and-paddle style games in which players controlled edge-of-screen symbols to intercept and reverse a ball symbol’s travel path.
- Later, the home video game market moved toward microprocessor-based consoles that read interchangeable game cartridges, allowing multiple games to be played on a single console connected to a television.
- Mattel, Inc. manufactured a microprocessor-based home console (the “Master Component”) and a set of sports game cartridges; collectively, this product line was known as the Mattel Intellivision.
- Intellivision sports games displayed player-controlled symbols (such as racquets) on opposite sides of the screen that could be moved to intercept a moving ball icon, affecting the ball’s path during play.
- Unlike the patent’s analog examples, Intellivision used processors and digital circuitry to generate images and gameplay behavior; however, the functions performed by Intellivision’s circuitry corresponded to those described in the ’507 patent.
- Mattel argued that earlier technologies (including military targeting/tracking work and computer display systems) anticipated the ’507 patent or made it obvious, and also argued that Intellivision’s digital implementation avoided infringement.
- Magnavox sued Mattel for infringement of the ’507 patent based on Intellivision’s console-and-cartridge operation on a television.

## Issues

1. Whether the asserted ’507 patent claims were invalid as anticipated or obvious in view of the cited prior art (including earlier targeting and computer display systems).
2. Whether Mattel’s Intellivision infringed the ’507 patent even though Intellivision used microprocessors and digital circuitry rather than the analog circuitry described in the patent.
3. Whether differences in implementation (digital processing and cartridge-based programming) avoided infringement where the accused products produced the same on-screen hit/hitting symbol interaction and collision-based change in motion.

## Decision

- The court upheld the validity of the asserted claims of the ’507 patent, rejecting Mattel’s anticipation and obviousness defenses.
- The court found that Mattel’s Intellivision infringed the ’507 patent, notwithstanding Intellivision’s use of digital circuitry and microprocessor-based design.
- The court treated the accused product as the television game apparatus as used to play the cartridge games on a television, and concluded that this operation satisfied the claimed elements.

## Legal Principles

- A patent claim directed to a functional television game combination is not limited to the specific circuitry examples in the specification when the accused device performs the claimed display and interaction functions.
- Anticipation requires a single prior-art reference to disclose each claim element; prior systems sharing only individual features (such as screen displays or tracking) do not anticipate absent the full claimed arrangement.
- Obviousness is not established by pointing to separate prior-art features unless the prior art supports combining them to yield the claimed television game interaction (hit symbol, player-controlled hitting symbols, coincidence detection, and resulting change in hit symbol motion).
- Use of a different technological implementation (analog circuitry versus microprocessor-based digital circuitry) does not by itself avoid infringement where the accused circuitry performs functions corresponding to the claimed elements and produces the same interactive on-screen result.
- For apparatus-style video game claims, infringement may be assessed based on the accused console operating with its game cartridges in ordinary use, when that combined operation performs the claimed gameplay functions.

## Conclusion

In *Magnavox Co. v. Mattel, Inc.*, the court held the Sanders ’507 television game patent valid and ruled that Mattel’s Intellivision infringed because its console and cartridge games implemented the patented hit/hitting symbol interaction and collision-driven change in the moving symbol’s path, even though Intellivision generated the gameplay using microprocessors and digital circuitry rather than the analog circuitry described in the patent.


Magnavox Co. v. Mattel, Inc., 216 U.S.P.Q. 28 (1982)