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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ELOT, INC.

, ) ELOTTERY, INC., and ) ELOTTERY COLLATERAL AGENT, LLC, ) ) Plaintiffs, ) v. ) ) GTECH CORPORATION, ) SCIENTIFIC GAMES CORPORATION, ) SCIENTIFIC GAMES ) INTERNATIONAL, INC., and ) NORTHSTAR LOTTERY GROUP, LLC, ) ) Defendants. )

Case No. DEMAND FOR JURY TRIAL

COMPLAINT FOR PATENT INFRINGEMENT Plaintiffs eLot, Inc., eLottery, Inc., and eLottery Collateral Agent, LLC (collectively, Plaintiffs) file this complaint against defendants GTECH Corporation, Scientific Games Corporation, Scientific Games International, Inc., and Northstar Lottery Group, LLC (collectively, Defendants) and allege as follows: NATURE OF THE ACTION 1. This is an action for patent infringement arising under the Patent Laws of the

United States, 35 U.S.C. 1 et seq. PARTIES 2. Plaintiff eLot, Inc. (eLot) is a Virginia corporation having its principal place of

business at 46 Southfield Avenue, 3 Stamford Landing, Suite 370, Stamford, Connecticut 06902. 3. Plaintiff eLottery, Inc. (eLottery) is a Delaware corporation having its principal

place of business at 46 Southfield Avenue, Suite 310, Stamford, Connecticut 06902. eLottery is a subsidiary of eLot.

4.

Plaintiff eLottery Collateral Agent, LLC (eLottery Collateral) is a Delaware

corporation having its principal place of business at The Nelson Law Firm, LLC, White Plains Plaza, One North Broadway, White Plains, New York, 10601. 5. Upon information and belief, defendant GTECH Corporation (GTECH) is a

Delaware corporation with its principal place of business at 10 Memorial Boulevard, Providence, Rhode Island 02903. 6. Upon information and belief, defendant Scientific Games Corporation (Scientific

Games) is a Delaware corporation with its principal place of business at 750 Lexington Ave., Suite 2500, New York, New York 10022. 7. Upon information and belief, defendant Scientific Games International, Inc.

(SGI), a wholly-owned subsidiary of Scientific Games, is a Delaware corporation with its principal place of business at 1500 Bluegrass Lakes Parkway, Alpharetta, Georgia 30004. 8. Upon information and belief, defendant Northstar Lottery Group, LLC

(Northstar) is an Illinois corporation with its principal place of business at 180 North LaSalle Street, Suite 1810, Chicago, Illinois 60601. Upon information and belief, Northstar is an

integrated consortium comprised of GTECH, Scientific Games, and SGI.

JURISDICTION AND VENUE 9. This Court has jurisdiction over the subject matter of this action pursuant to 28

U.S.C. 1331 and 1338(a), in that this action arises under the Patent Laws of the United States, 35 U.S.C. 1 et seq. 10. Venue is proper in this District pursuant to 28 U.S.C. 1391 (b)-(c) and 1400(b)

in that Defendants have committed acts in this District giving rise to this action, have and

continue to conduct business in this District, have committed acts of infringement in this District, and continue to commit acts of infringement in this District. 11. Upon information and belief, venue in this District is proper because Northstar is

organized and governed by the laws of Illinois and subject to taxation in Illinois. 12. Upon information and belief, venue in this District is proper because Northstar

entered into a private management agreement with the Illinois State Department of Revenue, dated January 18, 2011, to operate the online sales of tickets for the Illinois Lottery. 13. Upon information and belief, Defendants are subject to this Courts specific

and/or general personal jurisdiction due at least to their substantial business in this forum, including: (i) a portion of the infringements alleged herein, including the performance of activity in connection with the online sale of lottery tickets, which infringes the Patents-in-Suit; and (ii) regularly doing or soliciting business, engaging in other persistent courses of conduct, and/or deriving substantial revenue from services provided to individuals in Illinois and in this District. PATENTS-IN-SUIT 14. On August 21, 2001, United States Patent No. 6,277,026 (the 026 Patent),

entitled System and Method for Facilitating the Purchase and Sale of Lottery Tickets Online, was duly and lawfully issued by the United States Patent and Trademark Office. A true and correct copy of the 026 Patent is attached hereto as Exhibit A. 15. eLot and eLottery Collateral are the assignees and the owners of the right, title,

and interest in and to the 026 Patent, including the right to assert all causes arising under said patent and the right to any remedies for infringement of it. 16. On November 27, 2001, United States Patent No. 6,322,446 (the 446 Patent),

entitled System and Method for Operating On-line State Lottery Games, was duly and lawfully

issued by the United States Patent and Trademark Office. A true and correct copy of the 446 Patent is attached hereto as Exhibit B. 17. eLottery and eLottery Collateral are the assignees and the owners of the right,

title, and interest in and to the 446 Patent, including the right to assert all causes arising under said patent and the right to any remedies for infringement of it. 18. On March 22, 2005, United States Patent No. 6,869,358 (the 358 Patent),

entitled System and Method for Operating On-Line Governmental Lottery Games, was duly and lawfully issued by the United States Patent and Trademark Office. A true and correct copy of the 358 Patent is attached hereto as Exhibit C. 19. eLottery and eLottery Collateral are the assignees and the owners of the right,

title, and interest in and to the 358 Patent, including the right to assert all causes arising under said patent and the right to any remedies for infringement of it. 20. On April 26, 2011, United States Patent No. 7,931,529 (the 529 Patent),

entitled System and Method for Operating On-Line Governmental Lottery Games, was duly and lawfully issued by the United States Patent and Trademark Office. A true and correct copy of the 529 Patent is attached hereto as Exhibit D. 21. eLottery and eLottery Collateral are the assignees and the owners of the right,

title, and interest in and to the 529 Patent, including the right to assert all causes arising under said patent and the right to any remedies for infringement of it. 22. On May 24, 2011, United States Patent No. 7,946,913 (the 913 Patent), entitled

System and a Method for Operating On-Line Governmental Lottery Games, was duly and lawfully issued by the United States Patent and Trademark Office. A true and correct copy of the 913 Patent is attached hereto as Exhibit E.

23.

eLottery and eLottery Collateral are the assignees and the owners of the right,

title, and interest in and to the 913 Patent, including the right to assert all causes arising under said patent and the right to any remedies for infringement of it. 24. On June 5, 2012, United States Patent No. 8,192,269 (the 269 Patent), entitled

System and a Method for Operating On-Line Governmental Lottery Games, was duly and lawfully issued by the United States Patent and Trademark Office. A true and correct copy of the 269 Patent is attached hereto as Exhibit F. 25. eLottery and eLottery Collateral are the assignees and the owners of the right,

title, and interest in and to the 269 Patent, including the right to assert all causes arising under said patent and the right to any remedies for infringement of it. 26. On May 7, 2002, United States Patent No. 6,383,078 (the 078 Patent), entitled

On-Line Lottery Game System, was duly and lawfully issued by the United States Patent and Trademark Office. A true and correct copy of the 078 Patent is attached hereto as Exhibit G. 27. eLottery and eLottery Collateral are the assignees and the owners of the right,

title, and interest in and to the 078 Patent, including the right to assert all causes arising under said patent and the right to any remedies for infringement of it. 28. On September 25, 2012, United States Patent No. 8,272,959 (the 959 Patent),

entitled Interactive Computer Gaming System with Audio Response, was duly and lawfully issued by the United States Patent and Trademark Office. A true and correct copy of the 959 Patent is attached hereto as Exhibit H. 29. eLottery and eLottery Collateral are the assignees and the owners of the right,

title, and interest in and to the 959 Patent, including the right to assert all causes arising under said patent and the right to any remedies for infringement of it.

30.

On January 8, 2013, United States Patent No. 8,348,742 (the 742 Patent),

entitled System and Method for Operating Governmental Lottery Games With TelevisionBased User Terminals, was duly and lawfully issued by the United States Patent and Trademark Office. A true and correct copy of the 742 Patent is attached hereto as Exhibit I. 31. eLottery and eLottery Collateral are the assignees and the owners of the right,

title, and interest in and to the 742 Patent, including the right to assert all causes arising under said patent and the right to any remedies for infringement of it. COUNT IPATENT INFRINGEMENT OF THE 026 PATENT BY GTECH 32. forth herein. 33. Upon information and belief, GTECH has infringed the 026 Patent and continues The allegations of paragraphs 131 are incorporated by reference as if fully set

to do so by performing activities within the United States that are covered by one or more of the 026 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT IIPATENT INFRINGEMENT OF THE 026 PATENT BY SCIENTIFIC GAMES 34. forth herein. 35. Upon information and belief, Scientific Games has infringed the 026 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 026 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery.

COUNT IIIPATENT INFRINGEMENT OF THE 026 PATENT BY SGI 36. forth herein. 37. Upon information and belief, SGI has infringed the 026 Patent and continues to The allegations of paragraphs 131 are incorporated by reference as if fully set

do so by performing activities within the United States that are covered by one or more of the 026 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT IVPATENT INFRINGEMENT OF THE 026 PATENT BY NORTHSTAR 38. forth herein. 39. Upon information and belief, Northstar has infringed the 026 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 026 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT VPATENT INFRINGEMENT OF THE 446 PATENT BY GTECH 40. forth herein. 41. Upon information and belief, GTECH has had actual knowledge of the 446 The allegations of paragraphs 131 are incorporated by reference as if fully set

Patent since at least August 2005 as a result of negotiations with eLottery in connection with a Technology Cooperation Agreement. 42. Upon information and belief, GTECH has infringed the 446 Patent and continues

to do so by performing activities within the United States that are covered by one or more of the 7

446 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. 43. Upon information and belief, GTECHs infringement of the 446 Patent has been

and continues to be willful, wanton, and deliberate, and carried out with full knowledge and awareness of the Plaintiffs patent rights and without license from Plaintiffs. COUNT VIPATENT INFRINGEMENT OF THE 446 PATENT BY SCIENTIFIC GAMES 44. forth herein. 45. Upon information and belief, Scientific Games has infringed the 446 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 446 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT VIIPATENT INFRINGEMENT OF THE 446 PATENT BY SGI 46. forth herein. 47. Upon information and belief, SGI has infringed the 446 Patent and continues to The allegations of paragraphs 131 are incorporated by reference as if fully set

do so by performing activities within the United States that are covered by one or more of the 446 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT VIIIPATENT INFRINGEMENT OF THE 446 PATENT BY NORTHSTAR 48. forth herein. 8 The allegations of paragraphs 131 are incorporated by reference as if fully set

49.

Upon information and belief, Northstar has infringed the 446 Patent and

continues to do so by performing activities within the United States that are covered by one or more of the 446 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT IXPATENT INFRINGEMENT OF THE 358 PATENT BY GTECH 50. forth herein. 51. Upon information and belief, GTECH has had actual knowledge of the 358 The allegations of paragraphs 131 are incorporated by reference as if fully set

Patent since at least August 2005 as a result of negotiations with eLottery in connection with a Technology Cooperation Agreement. 52. Upon information and belief, GTECH has infringed the 358 Patent and continues

to do so by performing activities within the United States that are covered by one or more of the 358 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. 53. Upon information and belief, GTECHs infringement of the 358 Patent has been

and continues to be willful, wanton, and deliberate, and carried out with full knowledge and awareness of the Plaintiffs patent rights and without license from Plaintiffs. COUNT XPATENT INFRINGEMENT OF THE 358 PATENT BY SCIENTIFIC GAMES 54. forth herein. 55. Upon information and belief, Scientific Games has infringed the 358 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or

more of the 358 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XIPATENT INFRINGEMENT OF THE 358 PATENT BY SGI 56. forth herein. 57. Upon information and belief, SGI has infringed the 358 Patent and continues to The allegations of paragraphs 131 are incorporated by reference as if fully set

do so by performing activities within the United States that are covered by one or more of the 358 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XIIPATENT INFRINGEMENT OF THE 358 PATENT BY NORTHSTAR 58. forth herein. 59. Upon information and belief, Northstar has infringed the 358 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 358 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT XIIIPATENT INFRINGEMENT OF THE 529 PATENT BY GTECH 60. forth herein. 61. Upon information and belief, GTECH has infringed the 529 Patent and continues The allegations of paragraphs 131 are incorporated by reference as if fully set

to do so by performing activities within the United States that are covered by one or more of the

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529 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT XIVPATENT INFRINGEMENT OF THE 529 PATENT BY SCIENTIFIC GAMES 62. forth herein. 63. Upon information and belief, Scientific Games has infringed the 529 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 529 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XVPATENT INFRINGEMENT OF THE 529 PATENT BY SGI 64. forth herein. 65. Upon information and belief, SGI has infringed the 529 Patent and continues to The allegations of paragraphs 131 are incorporated by reference as if fully set

do so by performing activities within the United States that are covered by one or more of the 529 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XVIPATENT INFRINGEMENT OF THE 529 PATENT BY NORTHSTAR 66. forth herein. 67. Upon information and belief, Northstar has infringed the 529 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or

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more of the 529 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT XVIIPATENT INFRINGEMENT OF THE 913 PATENT BY GTECH 68. forth herein. 69. Upon information and belief, GTECH has infringed the 913 Patent and continues The allegations of paragraphs 131 are incorporated by reference as if fully set

to do so by performing activities within the United States that are covered by one or more of the 913 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT XVIIIPATENT INFRINGEMENT OF THE 913 PATENT BY SCIENTIFIC GAMES 70. forth herein. 71. Upon information and belief, Scientific Games has infringed the 913 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 913 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XIXPATENT INFRINGEMENT OF THE 913 PATENT BY SGI 72. forth herein. 73. Upon information and belief, SGI has infringed the 913 Patent and continues to The allegations of paragraphs 131 are incorporated by reference as if fully set

do so by performing activities within the United States that are covered by one or more of the

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913 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XXPATENT INFRINGEMENT OF THE 913 PATENT BY NORTHSTAR 74. forth herein. 75. Upon information and belief, Northstar has infringed the 913 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 913 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT XXIPATENT INFRINGEMENT OF THE 269 PATENT BY GTECH 76. forth herein. 77. Upon information and belief, GTECH has infringed the 269 Patent and continues The allegations of paragraphs 131 are incorporated by reference as if fully set

to do so by performing activities within the United States that are covered by one or more of the 269 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT XXIIPATENT INFRINGEMENT OF THE 269 PATENT BY SCIENTIFIC GAMES 78. forth herein. 79. Upon information and belief, Scientific Games has infringed the 269 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or

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more of the 269 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XXIIIPATENT INFRINGEMENT OF THE 269 PATENT BY SGI 80. forth herein. 81. Upon information and belief, SGI has infringed the 269 Patent and continues to The allegations of paragraphs 131 are incorporated by reference as if fully set

do so by performing activities within the United States that are covered by one or more of the 269 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XXIVPATENT INFRINGEMENT OF THE 269 PATENT BY NORTHSTAR 82. forth herein. 83. Upon information and belief, Northstar has infringed the 269 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 269 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT XXVPATENT INFRINGEMENT OF THE 078 PATENT BY GTECH 84. forth herein. 85. Upon information and belief, GTECH has had actual knowledge of the 078 The allegations of paragraphs 131 are incorporated by reference as if fully set

Patent since at least August 2005 as a result of negotiations with eLottery in connection with a Technology Cooperation Agreement. 14

86.

Upon information and belief, GTECH has infringed the 078 Patent and continues

to do so by performing activities within the United States that are covered by one or more of the 078 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. 87. Upon information and belief, GTECHs infringement of the 078 Patent has been

and continues to be willful, wanton, and deliberate, and carried out with full knowledge and awareness of the Plaintiffs patent rights and without license from Plaintiffs. COUNT XXVIPATENT INFRINGEMENT OF THE 078 PATENT BY SCIENTIFIC GAMES 88. forth herein. 89. Upon information and belief, Scientific Games has infringed the 078 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 078 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XXVIIPATENT INFRINGEMENT OF THE 078 PATENT BY SGI 90. forth herein. 91. Upon information and belief, SGI has infringed the 078 Patent and continues to The allegations of paragraphs 131 are incorporated by reference as if fully set

do so by performing activities within the United States that are covered by one or more of the 078 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery.

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COUNT XXVIIIPATENT INFRINGEMENT OF THE 078 PATENT BY NORTHSTAR 92. forth herein. 93. Upon information and belief, Northstar has infringed the 078 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 078 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery.

COUNT XXIXPATENT INFRINGEMENT OF THE 959 PATENT BY GTECH 94. forth herein. 95. Upon information and belief, GTECH has infringed the 959 Patent and continues The allegations of paragraphs 131 are incorporated by reference as if fully set

to do so by performing activities within the United States that are covered by one or more of the 959 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery. COUNT XXXPATENT INFRINGEMENT OF THE 959 PATENT BY SCIENTIFIC GAMES 96. forth herein. 97. Upon information and belief, Scientific Games has infringed the 959 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 959 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery.

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COUNT XXXIPATENT INFRINGEMENT OF THE 959 PATENT BY SGI 98. forth herein. 99. Upon information and belief, SGI has infringed the 959 Patent and continues to The allegations of paragraphs 131 are incorporated by reference as if fully set

do so by performing activities within the United States that are covered by one or more of the 959 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XXXIIPATENT INFRINGEMENT OF THE 959 PATENT BY NORTHSTAR 100. forth herein. 101. Upon information and belief, Northstar has infringed the 959 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 959 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery.

COUNT XXXIIIPATENT INFRINGEMENT OF THE 742 PATENT BY GTECH 102. forth herein. 103. Upon information and belief, GTECH has infringed the 742 Patent and continues The allegations of paragraphs 131 are incorporated by reference as if fully set

to do so by performing activities within the United States that are covered by one or more of the 742 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery.

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COUNT XXXIVPATENT INFRINGEMENT OF THE 742 PATENT BY SCIENTIFIC GAMES 104. forth herein. 105. Upon information and belief, Scientific Games has infringed the 742 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 742 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XXXVPATENT INFRINGEMENT OF THE 742 PATENT BY SGI 106. forth herein. 107. Upon information and belief, SGI has infringed the 742 Patent and continues to The allegations of paragraphs 131 are incorporated by reference as if fully set

do so by performing activities within the United States that are covered by one or more of the 742 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery and the Minnesota State Lottery. COUNT XXXVIPATENT INFRINGEMENT OF THE 742 PATENT BY NORTHSTAR 108. forth herein. 109. Upon information and belief, Northstar has infringed the 742 Patent and The allegations of paragraphs 131 are incorporated by reference as if fully set

continues to do so by performing activities within the United States that are covered by one or more of the 742 Patent claims, including, but not limited to activities in connection with online lottery ticket sales for the Illinois State Lottery.

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PRAYER FOR RELIEF WHEREFORE, Plaintiffs respectfully request that the Court enter judgment in their favor as follows: (a) that Defendants have directly infringed one or more of the claims of the 026

Patent, the 446 Patent, the 358 Patent, the 529 Patent, the 913 Patent, the 269 Patent, the 078 Patent, the 959 Patent, and the 742 Patent; (b) that Defendants, and their respective officers, directors, agents, servants,

affiliates, employees, subsidiaries, parents, licensees assignees, and customers, and all others acting in concert of participation with them, be enjoined, as provided by 35 U.S.C. 283, from further acts of infringement of the 026 Patent, the 446 Patent, the 358 Patent, the 529 Patent, the 913 Patent, the 269 Patent, the 078 Patent, the 959 Patent, and/or the 742 Patent; (c) that Defendants be ordered to compensate Plaintiffs for their infringement of the

026 Patent, the 446 Patent, the 358 Patent, the 529 Patent, the 913 Patent, the 269 Patent, the 078 Patent, the 959 Patent, and/or the 742 Patent; (d) that GTECH be ordered to pay enhanced damages, up to treble damages, as

provided by 35 U.S.C. 284 for the deliberate and willful nature of its infringement of the 446 Patent, the 358 Patent, and the 078 Patent, together with interest thereon in the form of both pre-judgment and post-judgment interest; (e) that the Defendants be ordered to pay a compulsory future royalty with respect to

the 026 Patent, the 446 Patent, the 358 Patent, the 529 Patent, the 913 Patent, the 269 Patent, the 078 Patent, the 959 Patent, and/or the 742 Patent; (f) that this case is exceptional within the meaning of 35 U.S.C. 285;

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(g)

that Defendants be ordered to pay Plaintiffs costs and expenses and their

reasonable attorneys fees under 35 U.S.C. 285; and (h) that Plaintiffs be granted such other relief as the Court deems just and proper. JURY TRIAL DEMANDED Plaintiffs respectfully request a trial by jury on all issues triable to a jury. DATED: April 23, 2013 Respectfully submitted, By: Robert W. Unikel Robert W. Unikel robert.unikel@kayescholer.com Deanna L. Keysor deanna.keysor@kayescholer.com Michelle K. Marek michelle.marek@kayescholer.com KAYE SCHOLER LLP 70 W. Madison St. Suite 4200 Chicago, IL 60602 Telephone: 312.583.2300 Fax: 312.583.2360 James S. Blank James.Blank@kayescholer.com KAYE SCHOLER LLP 425 Park Avenue New York, NY 10022 Telephone: 212.836.7528 Fax: 212.836.8689 Paul I. Margulies Paul.Margulies@kayescholer.com KAYE SCHOLER LLP 901 Fifteenth Street, NW Washington, D.C. 20005 Telephone: 202.682.3561 Fax: 202.414.0342 Attorneys for Plaintiffs eLot, Inc. eLottery, Inc., and eLottery Collateral Agent, LLC

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