Up until 2012, U.S. courts were reluctant to find for copyright infringement of clones. Driving case law in the United States was principally through the case "Atari, Inc. v. Amusement World, Inc." (547 F. Supp. 222, 1982). Atari had sued Amusement World claiming that its video game "Meteos" violated their copyright on "Asteroids". The court did find twenty-two similarities between the two games, but ruled against Atari's claims, citing these elements as "scènes à faire" for games about shooting at asteroids. The case established that "look and feel" of a game could not easily be protected. Attorney Stephen C. McArthur, writing for "Gamasutra", said that during this period, courts opted to take a more lax view to balance innovation in the industry and prevent overzealous copyright protection that could have one company claim copyright on an entire genre of games. At best, copyright holders could challenge clones by threatening cease and desist letters, or on other intellectual property rights such as trademarks.