Although Acme Oil Company has been destroyed by James Pond, his arch enemy Dr. Maybe survived and has retreated to the North Pole where he has taken over Santa's workshop.

James Pond is recruited to infiltrate Santa's grotto, free the captive penguins, retrieve the stolen toys for the children of the world, and defeat Dr. Maybe once and for all.

This time, however, due to the greater risks involved in this mission, James Pond is given a robotic suit and the code name "RoboCod" (a play on RoboCop).

This suit gives Pond superhuman strength and agility as well as enabling him to stretch his midsection almost indefinitely and reach otherwise impossibly high areas.

[5] The 1991 EA release in the U.S. and Euro market featured the penguin in a Christmas scene in box art by illustrator Marc Ericksen.

According to a 1994 article in the UK edition of PC Gamer, Penguin outsold arch-rival KitKat for the first time in the product's history soon after the release of the game.

[7] Electronic Gaming Monthly gave the SNES version a 5 out of 10, commenting that "James's ability to make himself tall is quite interesting, but that is really the only special thing about him.

Though they praised the soundtrack, they remarked that the garishly colorful graphics tend to cause eye strain, the gameplay is mildly fun but unexciting, and that aside from the "extremely pixelated" full motion video intro, it is identical to the version on the less powerful Sega Genesis.