Japan is also a member of the Berne convention. Video games, and computer code in general, are considered to fall under copyright as they are a "work of authorship" as "a production in which thoughts or emotions are expressed in a creative way and which falls in the literary, scientific, artistic or musical domain."[40] Video games being eligible for copyrights in the same manner as cinematic works were established through three cases related to video game clones from 1982 to 1984, in which Japan's courted ruled, collectively, that the act of storing data into a computer's read-only memory (ROM) constitutes copying and thus unauthorized copies can be violations of copyright, that similarly hardware circuitry can carry software information and is also copyrightable, and that video games can contain artistic expression that is protected by copyright.[40] These cases gave video games stronger protections for copyright than before, as Japan's courts typically put more onus on plaintiffs in copyright infringement cases to demonstrate similarity, and the fair use allowances tended to be more lax.[41]