on other Nintendo cartridge-based systems that had found ways to bypass the hardware lockout chips and sell without paying any royalties to Nintendo, such as by Atari in its subsidiary company Tengen. This licensing approach was similarly used by most other cartridge-based console manufacturers using lockout chip technology. With optical media, where the console manufacturer may not have direct control on the production of the media, the developer or publisher typically must establish a licensing agreement to gain access to the console's proprietary storage format for the media as well as to use the console and manufacturer's logos and branding for the game's packaging, paid back through royalties on sales. In the transition to digital distribution, where now the console manufacturer runs digital storefronts for games, license fees apply to registering a game for distribution on the storefront - again gaining access to the console's branding and logo - with the manufacturer taking its cut of each sale as its royalty. In both cases, this still gives console manufacturers the ability to review and reject games it believes unsuitable for the system and deny licensing rights. With the rise of indie game development, the major console manufacturers have all developed entry level routes for these smaller developers to be able to publish onto consoles at far lower costs and reduced royalty rates. Programs like Microsoft's ID@Xbox give developers most of the needed tools for free after validating the small development size and needs of the team. Similar licensing concepts apply for third-party accessory manufacturers. Emulation and backward compatibility Consoles, like most consumer electronic devices, have limited lifespans. There is great interest in preservation of older console hardware for archival and historical purposes, as games from older consoles, as well as arcade and personal computers, remain of interest. Computer programmers and hackers have developed emulators that can be run on personal computers or other consoles that simulate the hardware of older consoles that allow games from that console to be run. The development of software emulators of console hardware is established to be legal, but there are unanswered legal questions surrounding copyrights, including acquiring a console's firmware and copies of a game's ROM image, which laws such as the United States' Digital Millennium Copyright Act make illegal save for certain archival purposes. Even though emulation itself is legal, Nintendo is recognized to be highly protective of any attempts to emulate its