Programmer Robin Antonick coded the first Madden game for the Apple II computer in the late 1980s but stopped working with Electronic Arts after that. Two decades later, in 2011, he filed suit against EA claiming that he was owed royalties on the Sega and Super Nintendo console versions of the game.
Writing for a unanimous panel, Circuit Judge Andrew Hurwitz affirmed the ruling of U.S. District Judge Charles Breyer of the Northern District of California, who tossed out a jury verdict in favor of Antonick because neither the computer code nor images of the gameplay were introduced as evidence.
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