Tengen Inc. was an American video game publisher and developer that was created by the arcade game manufacturer Atari Games for publishing computer and console games. It had a Japanese subsidiary named . History By 1984, Atari, Inc. had been split into two distinct companies. Atari Corporation was responsible for computer and console games and hardware and owned the rights to the Atari brand for these domains. Atari Games was formed from Atari, Inc.'s arcade division, and were able to use the Atari name on arcade releases but not on console or computer games. When Atari Games wanted to enter the console game market, it needed to create a new label that did not use the Atari name. The new subsidiary was dubbed Tengen, which in the Japanese nomenclature of the board game Go refers to the central point of the board (the word "Atari" comes from the same game). At the time, Nintendo restricted their licensees to releasing only five games per year, mandated that Nintendo handle cartridge manufacturing, and required their games to be NES-exclusive for two years. Atari Games tried to negotiate for a less restrictive license to produce games for the Nintendo Entertainment System; Nintendo refused, so in December 1987, Atari Games agreed to Nintendo's standard licensing terms. Tengen was incorporated on December 21 of that year. In 1988, Tengen released its first and only three games licensed by Nintendo: R.B.I. Baseball, Pac-Man, and Gauntlet. Meanwhile, Tengen secretly worked to bypass Nintendo's lock-out chip called 10NES that gave it control over which games were published for the NES. They started development on a chip they called Rabbit. While numerous manufacturers managed to override this chip by zapping it with a voltage spike, Tengen engineers feared this could potentially damage NES consoles and expose them to unnecessary liability. The other problem was that Nintendo made frequent modifications to the NES to prevent this technique from working. Instead, Tengen chose to reverse engineer the chip and decipher the code required to unlock it. However, the engineers were unable to do so, and the launch date for its first batch of games was rapidly approaching. With time running short, Tengen turned to the United States Copyright Office. Its lawyers contacted the government office to request a copy of the Nintendo lock-out program, claiming that the company needed it for potential litigation against Nintendo. Once obtained, it used the program