The Magnavox Odyssey 2 (released 1978, a year after the Atari VCS) could have 16 sprites onscreen at once. Four of them were "user-defined sprites," meaning the game designer could draw them. 12 had to pull from the pool of 64 preset characters in the BIOS ROM.

The intention seems to have been that you would do the gameplay with the custom sprites, and draw text, the score, etc. with the ROM sprites, but a lot of games relied heavily on the ROM art. It's an interesting design constraint.