Copyright and video games between the games were limited to the plaintiff's ideas. According to the court the similarities, "were inevitable given the requirements of the idea of a game involving a spaceship combating space rocks and given the technical demands of the medium of a video game." In Atari v. North American Philips Consumer Electronics Corp. (1982) the 7th Circuit wrote that "no plagiarist can excuse the wrong by showing how much of his work he did not pirate." This was said in the context of the fact that, "while a game is not protectable by copyright as such, this kind of work
Nolan Bushnell take any body of knowledge from English language arts to foreign language, geography, multiplication table or chemistry tables, to parts of the human body and gamify the experience. BrainRush calls their underlying technology "Adaptive Practice." They have also developed an open-authoring system allowing users to quickly create games in different topic areas. Between 2010 and 2012, BrainRush ran a test in Spanish language vocabulary learning with over 2200 teachers and 80,000 students across the country and got an increase in learning speed of between 8–10 times traditional learning. BrainRush rolled out the full platform in the Fall of 2013. Bushnell