I agree with everything you said, Nintendo was the 800 pound gorilla in the market place and so they could insure their profitability from the consumer and the 3rd-party developers (charging them three times what it cost to produce the chips and regulating that they could only produce two games a year).
I don't want to use old CIC chips because they varied so much over the lifetime of their manufacturing, plus there is a "ship in the bottle" sort of challenge in making the chip that Atari and all other third-party developers failed to make. The question that remains to be answered is "is it legal". The last thing I want is Nintendo breathing down my next over a small run of art games.
Do you know if the CIC varied from board to board depending on the memory map locations?