of how Atari VCS game cartridges were programmed to create their own games for the system, founding Activision in 1979 to sell these. Atari took legal action to try to block sale of these games, but the companies ultimately settled, with Activision agreeing to pay a portion of their sales as a license fee to Atari for developing for the console. This established the use of licensing fees as a model for third-party development that persists into the present. The licensing fee approach was further enforced by Nintendo when it decided to allow other third-party developers to make games for the Famicom console, setting a 30% licensing fee that covered game cartridge manufacturing costs and development fees. The 30% licensing fee for third-party developers has also persisted to the present, being a de facto rate used for most digital storefronts for third-party developers to offer their games on the platform. In recent years, larger publishers have acquired several third-party developers. While these development teams are now technically "in-house", they often continue to operate in an autonomous manner (with their own culture and work practices). For example, Activision acquired Raven (1997); Neversoft (1999), which merged with Infinity Ward in 2014; Z-Axis (2001); Treyarch (2001); Luxoflux (2002); Shaba (2002); Infinity Ward (2003) and Vicarious Visions (2005). All these developers continue operating much as they did before acquisition, the primary differences being exclusivity and financial details. Publishers tend to be more forgiving of their own development teams going over budget (or missing deadlines) than third-party developers. A developer may not be the primary entity creating a piece of software, usually providing an external software tool which helps organize (or use) information for the primary software product. Such tools may be a database, Voice over IP, or add-in interface software; this is also known as middleware. Examples of this include SpeedTree and Havoc. Indie game developers Independents are software developers which are not owned by (or dependent on) a single publisher. Some of these developers self-publish their games, relying on the Internet and word of mouth for publicity. Without the large marketing budgets of mainstream publishers, their products may receive less recognition than those of larger publishers such as Sony, Microsoft or Nintendo. With the advent of digital distribution of inexpensive games on game consoles, it is now possible for indie game developers to forge agreements with console manufacturers for broad distribution of their