Yes, like Sonic; S1 to 39K resistor to anode of diode, R to 120K resistor to anode of another diode, both diodes' cathodes to base of transistor.

It actually looks like N81. This die doesn't have the 2nd die ID, just the one under the top metal text KMS 73B: www.seanriddle.com/batmantasid.jpg

Since I dumped this one electronically from a 2nd game, I haven't removed the top metal layer yet.