The Copyright Act did not consider the specific problems raised by the advancement in electronic games. Games are not subject to protection under Copyright Act. Experts are of the opinion that the concept of a game concept is a business idea and therefore cannot be copyrighted. A game is also considered as a useful article. However, courts have held that a miniature hockey game is copyrightable. Pictorial, graphic, and sculptural works included in the game are works of artistic craftsmanship, and the game sounds are of an actual hockey game, but extensively edited to suit the game. These factors qualify the hockey game to be protected as a “compilation” under Copyright Act of 1976.
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