The Sega Mega Drive's sole means of unlicensed games protection, TMSS, failed to hold in the American courts, and for whatever reason Sega didn't try to enforce it elsewhere. Consequently, a number of unlicensed Mega Drive games appeared over the years, primarily in the Chinese market (though some publishers brought some of the Chinese homebrew overseas and though Accolade continued to make some of its later releases unlicensed). In more recent times, several groups of developers have banded together and an active development community exists today.
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