Court finds NBA 2K20's use of copyrighted tattoos on their player models for Lebron James, Kenyon Martin, and Eric Bledsoe by Solid Oak Sketches to be de minimis fair use
Solid Oak Sketches, LLC v. 2K Games, Inc., No. 16-CV-724-LTS-SDA, 2020 WL 1467394 (S.D.N.Y. Mar. 26, 2020)
Topic: Fair Use, De-Minimis - Tattoos & Video Game Design
Solid Oak Sketches, LLC (“Solid Oak” or “Plaintiff”), brings this action against Defendants 2K Games, Inc., and Take-Two Interactive Software, Inc. (collectively, “Take Two” or “Defendants”), asserting a claim of copyright infringement pursuant to the Copyright Act of 1976, 17 U.S.C. § 101 et seq. (the “Copyright Act”). Following this Court’s granting of Defendants’ motion to dismiss Plaintiff’s claims for statutory damages and attorneys’ fees on August 2, 2016, Plaintiff filed a Second Amended Complaint (“SAC”) on October 24, 2016. (Docket Entry No. 55.) On August 16, 2016, Defendants filed counterclaims for declaratory judgment pursuant to the Copyright Act and the Declaratory Judgment Act, 28 U.S.C. §§ 2201-2202 (“Def. Countercl.”). (Docket Entry No. 47.) The Court denied Plaintiff’s motion to dismiss the counterclaims on May 16, 2017 (docket entry no. 64) and, on March 30, 2018, denied Defendants’ motion for judgment on the pleadings (“March Op.,” docket entry no. 117).
Take-Two is a major developer, publisher, and marketer of interactive entertainment and video games that develops and publishes products through its wholly-owned subsidiaries, 2K and Rockstar Games. (SAC ¶¶ 17-18.) Defendants annually release an updated basketball simulation video game that depicts basketball with realistic renderings of different National Basketball Association (“NBA”) teams, including lifelike depictions of NBA players and their tattoos. (Def. Countercl. ¶¶ 8, 141.) Plaintiff alleges that Defendants have infringed its copyrights by publicly displaying works for which Plaintiff owns copyrights—five tattoos (the “Tattoos”) that are depicted on NBA players Eric Bledsoe, LeBron James, and Kenyon Martin (the “Players”)—in versions 2K14, 2K15, and 2K16 (released in 2013, 2014, and 2015, respectively) of Defendants’ basketball simulation video game. (SAC ¶¶ 9-11.)
Solid Oak holds an exclusive license to each of the Tattoos. (See Declaration in Opposition to Defendants’ Motion and in Support of Cross-Motion (“Haberman Decl.”), Docket Entry No. 149.) However, Solid Oak is not licensed to apply the tattoos to a person’s skin, and Solid Oak does not hold any publicity or trademark rights to the Players’ likenesses. (Def. 56.1 ¶¶ 101-02.) The Players “have given the NBA the right to license [their] likeness to third-parties,” and the NBA has granted such a license to Take-Two. (Def. 56.1 ¶¶ 103-04.) The Players also granted Take-Two permission to use their likenesses. (Declaration of LeBron James (“James Decl.”), Docket Entry No. 134, ¶ 13; Declaration of Kenyon Martin (“Martin Decl.”), Docket Entry No. 135, ¶ 15.)
Child Portrait Tattoo
LeBron James’s “Child Portrait” tattoo was inked by tattooist Justin Wright, and was copied from a baby picture provided by Mr. James. (Def. 56.1 ¶¶ 5-10.) Mr. Wright “knew and intended that when [Mr. James] appeared in public, on television, in commercials, or in other forms of media, he would display the Child Portrait Tattoo.” (Def. 56.1 ¶ 11.) It was Mr. Wright’s intention that the “Child Portrait” Tattoo “become a part of Mr. James’s likeness,” which, according to Mr. Wright, “Mr. James was and is free to use ... as he desire[d], including allowing others to depict it, such as in advertisements and video games.” (Def. 56.1 ¶¶ 11-13.)
330 and Flames Tattoo
LeBron James’s “330 and Flames” tattoo was inked by tattooist Deshawn Morris, also known as Shawn Rome (“Mr. Rome”). (Def. 56.1 ¶¶ 14-15.) At Mr. James’s request, Mr. Rome created the tattoo by shading in the outline of, and adding flames to, the number “330,” which had already been inked on Mr. James’s arm. (Def. 56.1 ¶¶ 16-19.) The number “330” represents the area code of Akron, Ohio. (Def. 56.1 ¶ 16.) According to Defendants’ expert, Dr. Nina Jablonski, flames are a common motif used for tattoos. (Def. 56.1 ¶ 20.)
Mr. Rome stated that, “[a]t the time that [he] inked [the ‘330 and Flames’ tattoo] on Mr. James, [he] knew that Mr. James was a professional basketball player with the [NBA],” and that “it was likely that Mr. James was going to appear in public, on television, in commercials, or in other forms of media, like video games.” (Declaration of Deshawn Morris (“Morris Decl.”), Docket Entry No. 132, ¶ 9.) Mr. Rome also stated that, “[w]hen [he] inked [the ‘330 and Flames’ tattoo] on Mr. James according to his requests, [he] knew and intended that [Mr. James] would display [the ‘330 and Flames’ tattoo] whenever he appeared in public,” and that he “intended that [the ‘330 and Flames’ tattoo] become a part of Mr. James’s likeness and part of his image.” (Morris Decl. ¶ 10.)
Script with a Scroll, Clouds and Doves Tattoo
Shawn Rome also inked LeBron James’s “Script with a Scroll, Clouds and Doves” tattoo. (Def. 56.1 ¶ 21.) The “Script” tattoo was copied from a design in Mr. Rome’s sketchbook. (Def. 56.1 ¶ 22.) Solid Oak did not license the drawing used to create the “Script” tattoo. (Def. 56.1 ¶ 23.) According to Dr. Jablonski, birds, such as doves, “have been a popular subject of tattoos since ancient times.” (Def. 56.1 ¶ 24.)
As with the “330 and Flames” tattoo, Mr. Rome “intended that [the ‘Script’ tattoo] become a part of Mr. James’s likeness and part of his image,” knowing that (i) Mr. James was a professional basketball player with the NBA and that (ii) it was “likely that Mr. James was going to appear in public, on television, in commercials, or in other forms of media, like video games.” (Morris Decl. ¶¶ 9-10.)
Wizard Tattoo
Kenyon Martin’s “Wizard” tattoo was inked by Thomas Ray Cornett, and was “copied ... directly from the pre-existing design” that Mr. Martin chose from designs featured on the walls and in books at Mr. Cornett’s parlor. (Def. 56.1 ¶¶ 25, 27-28.) Mr. Cornett did not design the tattoo. (Declaration of Thomas Ray Cornett (“Cornett Decl.”), Docket Entry No. 131, ¶ 13.) The “Wizard” tattoo appears as a grim reaper holding a basketball. (Def. 56.1 ¶ 26.) Both basketballs and “depictions of death or the grim reaper” are common tattoo motifs. (Def. 56.1 ¶¶ 30-31.)
When he inked the “Wizard” tattoo, Mr. Cornett “knew and intended” that the tattoo “would be displayed if Mr. Martin appeared in media, such as on television or in commercials.” (Cornett Decl. ¶ 15.) Mr. Cornett “also intended that the tattoo become a part of Mr. Martin’s likeness and part of his image.” (Id.) Further, Mr. Cornett “knew and intended that the tattoo would need to be included if anyone were to create a rendition of Mr. Martin’s likeness, such as in art or video games.” (Id.)
Basketball with Stars and Script
Mr. Cornett also inked Eric Bledsoe’s “Basketball with Stars and Script” tattoo. (Cornett Decl. ¶ 20.) This tattoo was designed by Mr. Cornett with Mr. Bledsoe’s direction and input. (Id.) When Mr. Cornett inked the “Basketball with Stars and Script” tattoo on Mr. Bledsoe, he “knew and intended that [Mr. Bledsoe] would display the tattoo whenever he appeared in public,” such as “on television or in commercials.” (Id. ¶ 21.) As with Mr. Kenyon’s “Wizard” tattoo, Mr. Cornett “intended that the [‘Basketball with Stars and Script’] tattoo [would] become a part of Mr. Bledsoe’s likeness and part of his image,” and he “knew and intended that the tattoo would need to be included if anyone were to create a rendition of Mr. Bledsoe’s likeness, such as in art or video games.” (Id.)
The NBA 2K game, which is much shorter in duration than an actual NBA game, has “many components, including graphics, characters, a fictitious plot, gameplay, [and] music.” (Def. 56.1 ¶¶ 70, 72.) These components, which include auditory elements such as “the sound of shoes against the court’s surface; the noise of the crowd, the horns and other audible warnings signaling elapsing shot clocks, ending timeouts, ... television announcers performing play-by-play,” and visual elements such as “the basketball; the hoop, ... the court, ... the players, including multiple individuals on the court and on the sidelines, each of whom wears jerseys with different accessories and other features (such as tattoos); coaches; referees; cheerleaders; spectators; the stadium; and the game clock and scoring system,” are designed to most accurately simulate the look and feel of an actual NBA game. (Def. 56.1 ¶¶ 74, 93; see also Declaration of Jeffrey Thomas in Support of Defendants-Counterclaimants’ Motion for Summary Judgment (“Thomas Decl.”), Docket Entry No. 130, ¶ 2.)
To further the goal of simulating an actual NBA game, Take-Two included the Tattoos in NBA 2K “to accurately depict the physical likenesses of the real-world basketball players as realistically as possible.” (Def. 56.1 ¶ 79.) However, for a number of reasons, NBA 2K users do not see the Tattoos clearly, if at all, during gameplay. (Def. 56.1 ¶¶ 91-99.) NBA 2K does not depict the Tattoos separately from the Players. (Def. 56.1 ¶ 85.) Therefore, the Tattoos only appear when a user selects Mr. James, Mr. Martin, or Mr. Bledsoe from over 400 available players. (Def. 56.1 ¶¶ 85-86.) The Tattoos comprise only a miniscule proportion of the video game data: only 0.000286% to 0.000431% of the NBA 2K game data is devoted to the Tattoos. (Def. 56.1 ¶¶ 75-78.)
When a Tattooed player is selected, the Tattoos are depicted on a computer or television screen at about 4.4% to 10.96% of the size that they appear in real life “due to the great distance from the camera that the players usually are depicted” and the resulting relatively small size of the player figures. (Def. 56.1 ¶¶ 91-92; Expert Report and Declaration of Ian Bogost, Ph.D. (“Bogost Decl.”), Docket Entry No. 136, ¶¶ 71-77.) The Tattoos appear merely as “visual noise,” “no more noticeable than a simulated player’s nose shape or hairstyle.” (Def. 56.1 ¶¶ 94-95 (internal quotation marks omitted).) The Tattoos “are subordinated to the display of the court and the players in competition.” (Def. 56.1 ¶ 96 (internal quotation marks omitted).) The Tattoos also cannot be observed clearly because they are often “blocked from view by other players,” are “obstruct[ed] by other game elements,” “often appear out-of-focus,” and “players on whom the Tattoos appear move quickly in the game.” (Def. 56.1 ¶ 97 (internal quotation marks omitted).)
Defendants provided video clips showing how each of the Players appears during NBA 2K gameplay. (Thomas Decl., Exs. B, C, and D.) At no point during the video clips are the Tattoos discernible to the viewer. These videos demonstrate that the Players’ tattoos, including the Tattoos at issue, appear entirely out-of-focus. The Tattoos are further obscured by the Players’ quick and erratic movements up and down the basketball court. (Thomas Decl., Exs. B, C, and D.)
The Tattoos did not play a significant role in marketing NBA 2K. The NBA 2K game covers do not depict the Players or their tattoos, and the advertising materials neither depicted nor discussed the Tattoos. (See Def. Countercl. ¶¶ 161-67; Plaintiff’s Answer to Defendants’ Counterclaims (“Pl. Ans.”), Docket Entry No. 65, ¶¶ 161-67.) According to Defendants’ expert, Dr. Jay, while “consumers buy NBA 2K video games for numerous reasons ... consumers do not buy NBA 2K video games for the tattoos on LeBron James, Eric Bledsoe or Kenyon Martin.” (Def. 56.1 ¶ 90.)
Defendants’ motion for summary judgment is granted in its entirety and Plaintiff’s cross motion to exclude Defendants’ expert testimony is denied.
Plaintiff’s Second Amended Complaint is dismissed in its entirety. Defendants are granted summary judgment on their First and Second Counterclaims, and the Court hereby declares that Defendants’ use of the Tattoos in the challenged versions of their video game is de minimis and fair use and therefore does not infringe Plaintiff’s copyrights.
https://business.cch.com/ipld/SolidOakSketches2KGames20200326.pdf
Topic: Fair Use, De-Minimis - Tattoos & Video Game Design
Solid Oak Sketches, LLC (“Solid Oak” or “Plaintiff”), brings this action against Defendants 2K Games, Inc., and Take-Two Interactive Software, Inc. (collectively, “Take Two” or “Defendants”), asserting a claim of copyright infringement pursuant to the Copyright Act of 1976, 17 U.S.C. § 101 et seq. (the “Copyright Act”). Following this Court’s granting of Defendants’ motion to dismiss Plaintiff’s claims for statutory damages and attorneys’ fees on August 2, 2016, Plaintiff filed a Second Amended Complaint (“SAC”) on October 24, 2016. (Docket Entry No. 55.) On August 16, 2016, Defendants filed counterclaims for declaratory judgment pursuant to the Copyright Act and the Declaratory Judgment Act, 28 U.S.C. §§ 2201-2202 (“Def. Countercl.”). (Docket Entry No. 47.) The Court denied Plaintiff’s motion to dismiss the counterclaims on May 16, 2017 (docket entry no. 64) and, on March 30, 2018, denied Defendants’ motion for judgment on the pleadings (“March Op.,” docket entry no. 117).
Take-Two is a major developer, publisher, and marketer of interactive entertainment and video games that develops and publishes products through its wholly-owned subsidiaries, 2K and Rockstar Games. (SAC ¶¶ 17-18.) Defendants annually release an updated basketball simulation video game that depicts basketball with realistic renderings of different National Basketball Association (“NBA”) teams, including lifelike depictions of NBA players and their tattoos. (Def. Countercl. ¶¶ 8, 141.) Plaintiff alleges that Defendants have infringed its copyrights by publicly displaying works for which Plaintiff owns copyrights—five tattoos (the “Tattoos”) that are depicted on NBA players Eric Bledsoe, LeBron James, and Kenyon Martin (the “Players”)—in versions 2K14, 2K15, and 2K16 (released in 2013, 2014, and 2015, respectively) of Defendants’ basketball simulation video game. (SAC ¶¶ 9-11.)
Solid Oak holds an exclusive license to each of the Tattoos. (See Declaration in Opposition to Defendants’ Motion and in Support of Cross-Motion (“Haberman Decl.”), Docket Entry No. 149.) However, Solid Oak is not licensed to apply the tattoos to a person’s skin, and Solid Oak does not hold any publicity or trademark rights to the Players’ likenesses. (Def. 56.1 ¶¶ 101-02.) The Players “have given the NBA the right to license [their] likeness to third-parties,” and the NBA has granted such a license to Take-Two. (Def. 56.1 ¶¶ 103-04.) The Players also granted Take-Two permission to use their likenesses. (Declaration of LeBron James (“James Decl.”), Docket Entry No. 134, ¶ 13; Declaration of Kenyon Martin (“Martin Decl.”), Docket Entry No. 135, ¶ 15.)
Child Portrait Tattoo
LeBron James’s “Child Portrait” tattoo was inked by tattooist Justin Wright, and was copied from a baby picture provided by Mr. James. (Def. 56.1 ¶¶ 5-10.) Mr. Wright “knew and intended that when [Mr. James] appeared in public, on television, in commercials, or in other forms of media, he would display the Child Portrait Tattoo.” (Def. 56.1 ¶ 11.) It was Mr. Wright’s intention that the “Child Portrait” Tattoo “become a part of Mr. James’s likeness,” which, according to Mr. Wright, “Mr. James was and is free to use ... as he desire[d], including allowing others to depict it, such as in advertisements and video games.” (Def. 56.1 ¶¶ 11-13.)
330 and Flames Tattoo
LeBron James’s “330 and Flames” tattoo was inked by tattooist Deshawn Morris, also known as Shawn Rome (“Mr. Rome”). (Def. 56.1 ¶¶ 14-15.) At Mr. James’s request, Mr. Rome created the tattoo by shading in the outline of, and adding flames to, the number “330,” which had already been inked on Mr. James’s arm. (Def. 56.1 ¶¶ 16-19.) The number “330” represents the area code of Akron, Ohio. (Def. 56.1 ¶ 16.) According to Defendants’ expert, Dr. Nina Jablonski, flames are a common motif used for tattoos. (Def. 56.1 ¶ 20.)
Mr. Rome stated that, “[a]t the time that [he] inked [the ‘330 and Flames’ tattoo] on Mr. James, [he] knew that Mr. James was a professional basketball player with the [NBA],” and that “it was likely that Mr. James was going to appear in public, on television, in commercials, or in other forms of media, like video games.” (Declaration of Deshawn Morris (“Morris Decl.”), Docket Entry No. 132, ¶ 9.) Mr. Rome also stated that, “[w]hen [he] inked [the ‘330 and Flames’ tattoo] on Mr. James according to his requests, [he] knew and intended that [Mr. James] would display [the ‘330 and Flames’ tattoo] whenever he appeared in public,” and that he “intended that [the ‘330 and Flames’ tattoo] become a part of Mr. James’s likeness and part of his image.” (Morris Decl. ¶ 10.)
Script with a Scroll, Clouds and Doves Tattoo
Shawn Rome also inked LeBron James’s “Script with a Scroll, Clouds and Doves” tattoo. (Def. 56.1 ¶ 21.) The “Script” tattoo was copied from a design in Mr. Rome’s sketchbook. (Def. 56.1 ¶ 22.) Solid Oak did not license the drawing used to create the “Script” tattoo. (Def. 56.1 ¶ 23.) According to Dr. Jablonski, birds, such as doves, “have been a popular subject of tattoos since ancient times.” (Def. 56.1 ¶ 24.)
As with the “330 and Flames” tattoo, Mr. Rome “intended that [the ‘Script’ tattoo] become a part of Mr. James’s likeness and part of his image,” knowing that (i) Mr. James was a professional basketball player with the NBA and that (ii) it was “likely that Mr. James was going to appear in public, on television, in commercials, or in other forms of media, like video games.” (Morris Decl. ¶¶ 9-10.)
Wizard Tattoo
Kenyon Martin’s “Wizard” tattoo was inked by Thomas Ray Cornett, and was “copied ... directly from the pre-existing design” that Mr. Martin chose from designs featured on the walls and in books at Mr. Cornett’s parlor. (Def. 56.1 ¶¶ 25, 27-28.) Mr. Cornett did not design the tattoo. (Declaration of Thomas Ray Cornett (“Cornett Decl.”), Docket Entry No. 131, ¶ 13.) The “Wizard” tattoo appears as a grim reaper holding a basketball. (Def. 56.1 ¶ 26.) Both basketballs and “depictions of death or the grim reaper” are common tattoo motifs. (Def. 56.1 ¶¶ 30-31.)
When he inked the “Wizard” tattoo, Mr. Cornett “knew and intended” that the tattoo “would be displayed if Mr. Martin appeared in media, such as on television or in commercials.” (Cornett Decl. ¶ 15.) Mr. Cornett “also intended that the tattoo become a part of Mr. Martin’s likeness and part of his image.” (Id.) Further, Mr. Cornett “knew and intended that the tattoo would need to be included if anyone were to create a rendition of Mr. Martin’s likeness, such as in art or video games.” (Id.)
Basketball with Stars and Script
Mr. Cornett also inked Eric Bledsoe’s “Basketball with Stars and Script” tattoo. (Cornett Decl. ¶ 20.) This tattoo was designed by Mr. Cornett with Mr. Bledsoe’s direction and input. (Id.) When Mr. Cornett inked the “Basketball with Stars and Script” tattoo on Mr. Bledsoe, he “knew and intended that [Mr. Bledsoe] would display the tattoo whenever he appeared in public,” such as “on television or in commercials.” (Id. ¶ 21.) As with Mr. Kenyon’s “Wizard” tattoo, Mr. Cornett “intended that the [‘Basketball with Stars and Script’] tattoo [would] become a part of Mr. Bledsoe’s likeness and part of his image,” and he “knew and intended that the tattoo would need to be included if anyone were to create a rendition of Mr. Bledsoe’s likeness, such as in art or video games.” (Id.)
The NBA 2K game, which is much shorter in duration than an actual NBA game, has “many components, including graphics, characters, a fictitious plot, gameplay, [and] music.” (Def. 56.1 ¶¶ 70, 72.) These components, which include auditory elements such as “the sound of shoes against the court’s surface; the noise of the crowd, the horns and other audible warnings signaling elapsing shot clocks, ending timeouts, ... television announcers performing play-by-play,” and visual elements such as “the basketball; the hoop, ... the court, ... the players, including multiple individuals on the court and on the sidelines, each of whom wears jerseys with different accessories and other features (such as tattoos); coaches; referees; cheerleaders; spectators; the stadium; and the game clock and scoring system,” are designed to most accurately simulate the look and feel of an actual NBA game. (Def. 56.1 ¶¶ 74, 93; see also Declaration of Jeffrey Thomas in Support of Defendants-Counterclaimants’ Motion for Summary Judgment (“Thomas Decl.”), Docket Entry No. 130, ¶ 2.)
To further the goal of simulating an actual NBA game, Take-Two included the Tattoos in NBA 2K “to accurately depict the physical likenesses of the real-world basketball players as realistically as possible.” (Def. 56.1 ¶ 79.) However, for a number of reasons, NBA 2K users do not see the Tattoos clearly, if at all, during gameplay. (Def. 56.1 ¶¶ 91-99.) NBA 2K does not depict the Tattoos separately from the Players. (Def. 56.1 ¶ 85.) Therefore, the Tattoos only appear when a user selects Mr. James, Mr. Martin, or Mr. Bledsoe from over 400 available players. (Def. 56.1 ¶¶ 85-86.) The Tattoos comprise only a miniscule proportion of the video game data: only 0.000286% to 0.000431% of the NBA 2K game data is devoted to the Tattoos. (Def. 56.1 ¶¶ 75-78.)
When a Tattooed player is selected, the Tattoos are depicted on a computer or television screen at about 4.4% to 10.96% of the size that they appear in real life “due to the great distance from the camera that the players usually are depicted” and the resulting relatively small size of the player figures. (Def. 56.1 ¶¶ 91-92; Expert Report and Declaration of Ian Bogost, Ph.D. (“Bogost Decl.”), Docket Entry No. 136, ¶¶ 71-77.) The Tattoos appear merely as “visual noise,” “no more noticeable than a simulated player’s nose shape or hairstyle.” (Def. 56.1 ¶¶ 94-95 (internal quotation marks omitted).) The Tattoos “are subordinated to the display of the court and the players in competition.” (Def. 56.1 ¶ 96 (internal quotation marks omitted).) The Tattoos also cannot be observed clearly because they are often “blocked from view by other players,” are “obstruct[ed] by other game elements,” “often appear out-of-focus,” and “players on whom the Tattoos appear move quickly in the game.” (Def. 56.1 ¶ 97 (internal quotation marks omitted).)
Defendants provided video clips showing how each of the Players appears during NBA 2K gameplay. (Thomas Decl., Exs. B, C, and D.) At no point during the video clips are the Tattoos discernible to the viewer. These videos demonstrate that the Players’ tattoos, including the Tattoos at issue, appear entirely out-of-focus. The Tattoos are further obscured by the Players’ quick and erratic movements up and down the basketball court. (Thomas Decl., Exs. B, C, and D.)
The Tattoos did not play a significant role in marketing NBA 2K. The NBA 2K game covers do not depict the Players or their tattoos, and the advertising materials neither depicted nor discussed the Tattoos. (See Def. Countercl. ¶¶ 161-67; Plaintiff’s Answer to Defendants’ Counterclaims (“Pl. Ans.”), Docket Entry No. 65, ¶¶ 161-67.) According to Defendants’ expert, Dr. Jay, while “consumers buy NBA 2K video games for numerous reasons ... consumers do not buy NBA 2K video games for the tattoos on LeBron James, Eric Bledsoe or Kenyon Martin.” (Def. 56.1 ¶ 90.)
Defendants’ motion for summary judgment is granted in its entirety and Plaintiff’s cross motion to exclude Defendants’ expert testimony is denied.
Plaintiff’s Second Amended Complaint is dismissed in its entirety. Defendants are granted summary judgment on their First and Second Counterclaims, and the Court hereby declares that Defendants’ use of the Tattoos in the challenged versions of their video game is de minimis and fair use and therefore does not infringe Plaintiff’s copyrights.
Read full case opinion at:
https://business.cch.com/ipld/SolidOakSketches2KGames20200326.pdf
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