IGT v. Aristocrat - Complaint

Case 2:15-cv-00473-RFB-GWF Document 1 Filed 03/16/15 Page 1 of 15
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JEFF SILVESTRI, ESQ.

Nevada Bar No. 5779
McDONALD CARANO WILSON LLP
2300 W. Sahara Avenue, Suite 1200
Las Vegas, NV 89102
Telephone: 702.873.4100
Facsimile: 702.873.9966
E-mail: jsilvestri@mcdonaldcarano.com
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2300 WEST SAHARA AVENUE SUITE 1200 LAS VEGAS, NEVADA

PHONE (702)873-4100 FAX (702) 873-9966
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ADAM K. MORTARA, ESQ. (pro hac vice to be submitted)

BRIAN C. SWANSON, ESQ. (pro hac vice to be submitted)
BARTLIT BECK HERMAN
PALENCHAR & SCOTT LLP
54 West Hubbard Street, Suite 300
Chicago, IL 60654
Telephone: 312.494.4400
E-mail: adam.mortara@bartlit-beck.com
brian.swanson@bartlit-beck.com
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DANIEL C. TAYLOR, ESQ. (pro hac vice to be submitted)

BARTLIT BECK HERMAN
1899 Wynkoop Street, 8th Floor
Denver, CO 80202
Telephone: 303.592.3100
E-mail: daniel.taylor@bartlit-beck.com
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Attorneys for Plaintiff IGT
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IN THE UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF NEVADA
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CASE NO. 2:15-cv-00473
IGT,
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Plaintiff,
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COMPLAINT FOR PATENT

INFRINGEMENT
v.
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ARISTOCRAT TECHNOLOGIES, INC.,
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Jury Trial Demanded
Defendant.
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Plaintiff IGT brings this complaint for patent infringement and declaratory judgment against
Defendant Aristocrat Technologies, Inc. (Aristocrat) and alleges as follows:
NATURE OF THE ACTION
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1.
This is an action for patent infringement arising under the patent laws of the United
States, including 35 U.S.C. 271 and 281-285.
2.
This lawsuit pertains to Aristocrats infringement of U.S. Patent Nos. 7,131,908;
7,513,827; 6,394,902; 7,384,334; 8,753,189; D503,951; 6,375,570; 6,702,675; 7,303,469; and
6,932,701.
3.
IGT also seeks a declaratory judgment pursuant to 28 U.S.C. 2201 that the doctrine
of assignor estoppel bars Aristocrat from challenging the validity of U.S. Patent Nos. 6,375,570;
6,702,675; 7,303,469; and 6,932,701.

PHONE (702)873-4100 FAX (702) 873-9966
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PARTIES
4.
Plaintiff IGT is a corporation organized and existing under the laws of the State of
Nevada, with a principal place of business located at 6355 South Buffalo Drive, Las Vegas, Nevada
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89113. IGT is a world leader in gaming entertainment and a leading supplier of casino and lottery
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gaming machines commonly known as slot machines.
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5.
Defendant Aristocrat Technologies, Inc. is a corporation organized and existing under
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the laws of the State of Nevada, with a principal place of business located at 7230 Amigo Street, Las
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Vegas, Nevada 89119. Aristocrat sells, leases, and/or operates gaming machines in the casino and
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lottery markets. Aristocrat is a subsidiary of Aristocrat Leisure Limited, an Australian corporation.
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JURISDICTION AND VENUE

6.
This action arises under the Patent Laws of the United States, 35 U.S.C. 101 et seq.,
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including 35 U.S.C. 271. This Court has subject matter jurisdiction over this matter pursuant to 28
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U.S.C. 1331, 1338(a).
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7.
This Court has personal jurisdiction over Aristocrat. Aristocrat is incorporated in
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Nevada and maintains substantial, continuous and systematic contacts in Nevada. Aristocrat has
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thus purposefully availed itself of the benefits and protections of Nevadas laws such that it should
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reasonably anticipate being haled into court here. Aristocrat regularly transacts business within
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Nevada including the sale, lease, and/or operation of gaming machines in Nevada.
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8.
Venue is proper in the District of Nevada pursuant to 28 U.S.C. 1391, 1400(b).
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FACTUAL BACKGROUND
The Patents at Issue

PHONE (702)873-4100 FAX (702) 873-9966
Plaintiff IGT is the owner, by assignment, of all rights, title and interest in U.S. Patent
No. 7,131,908 (the 908 Patent). The 908 Patent issued on November 7, 2006. A true and correct
copy of that patent is attached as Exhibit A.
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No. 7,513,827 (the 827 Patent). The 827 Patent issued on April 7, 2009. A true and correct
copy of that patent is attached as Exhibit B.
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No. 6,394,902 (the 902 Patent). The 902 Patent issued on May 28, 2002. A true and correct
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copy of that patent is attached as Exhibit C.
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12.
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No. 7,384,334 (the 334 Patent). The 334 Patent issued on June 10, 2008. A true and correct
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copy of that patent is attached as Exhibit D.
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13.
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No. 8,753,189 (the 189 Patent). The 189 Patent issued on June 17, 2014. A true and correct
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copy of that patent is attached as Exhibit E.
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14.
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No. D503,951 (the 951 Patent). The 951 Patent issued on April 12, 2005. A true and correct
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copy of that patent is attached as Exhibit F.
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15.
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No. 6,375,570 (the 570 Patent). The 570 Patent issued on April 23, 2002. A true and correct
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copy of that patent is attached as Exhibit G.
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16.
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No. 6,702,675 (the 675 Patent). The 675 Patent issued on March 9, 2004. A true and correct
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copy of that patent is attached as Exhibit H.
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17.
No. 7,303,469 (the 469 Patent). The 469 Patent issued on December 4, 2007. A true and correct
copy of that patent is attached as Exhibit I.
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No. 6,932,701 (the 701 Patent). The 701 Patent issued on August 23, 2005. A true and correct
copy of that patent is attached as Exhibit J.

PHONE (702)873-4100 FAX (702) 873-9966
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Joe Kaminkow and IGT

19.
Joe Kaminkow is a named inventor on the 570 Patent, the 675 Patent, the 469
Patent, and the 701 Patent. Kaminkow is a designer of slot machines.

20.
Kaminkow worked at IGT from 1999 to 2012. As IGTs Vice President of Game
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Design, Kaminkow led the development of several successful slot machines for IGT including SEX
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AND THE CITY, STAR WARS, and GHOSTBUSTERS.
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In the course of performing his duties at IGT, Kaminkow obtained patents on several
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important innovations in the field of electronic gaming machines. Among these patents are the 570
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Patent, the 675 Patent, the 469 Patent, and the 701 Patent. Kaminkow assigned all rights, title,
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and interest in these patents to IGT in exchange for valuable consideration, including salary,
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bonuses, and other employment benefits.
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22.
Kaminkow resigned from IGT in January 2012.
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Joe Kaminkow and Aristocrat

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Upon information and belief, Aristocrat called Kaminkow the same night he resigned
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from IGT to discuss the possibility of employing him. Upon information and belief, Kaminkow had
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lunch with Aristocrat CEO Jamie Odell the next week. See Howard Stutz, Nevadan at Work:
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Veteran Game Designer is Always Creating, Las Vegas Review-Journal (Nov. 2, 2013), available at
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http://www.reviewjournal.com/business/casinos-gaming/nevadan-work-veteran-game-designer-
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always-creating.
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24.
Kaminkow joined Aristocrat in early 2013 immediately after the one-year non-
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compete clause in his employment agreement with IGT expired. Kaminkow currently serves as
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Aristocrats Senior Vice President of Game Development. See News Release, Legendary Game
Developer Joins Aristocrat, Market Wired (Feb. 26, 2013), available at
http://www.marketwired.com/press-release/legendary-game-developer-joins-aristocrat-asx-all-
1761483.htm.

PHONE (702)873-4100 FAX (702) 873-9966
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Upon information and belief, Kaminkow has been heavily involved in the
development and design of slot machines Aristocrat has released since Kaminkow joined the
company in 2013. The first sentence of a March 2014 article in the publication Casino Enterprise
Management confirms the centrality of Kaminkows role: Walk into Aristocrat Technologies game
development lair, and its clear this is Joe Kaminkows territory. Marian Green, Joe Kaminkow
Cultivates Slot Game Creativity, Casino Enterprise Management (Mar. 3, 2014), available at
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http://www.casinoenterprisemanagement.com/articles/march-2014/joe-kaminkow-cultivates-slot-
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game-creativity.
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Upon information and belief, Aristocrat debuted several of the slot machines
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Kaminkow designed at the Global Gaming Expo (popularly known as G2E) in Las Vegas in
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September 2013. One such slot machine is the BATMAN CLASSIC TV SERIES game. Aristocrat
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CEO Jamie Odell told Global Gaming Business Magazine that the BATMAN game is Joes great
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product and that Aristocrat wouldnt normally have made that sort of game without Kaminkow.
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Q&A with Jamie Odell, Global Gaming Business Magazine (Sept. 25, 2014), available at
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http://ggbmagazine.com/issue/vol-13-no-10-october-2014/article/q-a-with-jamie-odell. Aristocrats
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Vice President of Marketing told the video publication This Week in Gaming that Kaminkow
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designed the BATMAN game. Batman 1966 Slot Machine from Aristocrat Technologies, This
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Week in Gambling (Aug. 13, 2014), available at https://www.youtube.com/watch?v=4iL0UOSp15A
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Aristocrats Vice President of Gaming Operations described the BATMAN game as a coming-out
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party for Joe Kaminkow. Frank Legato, Aristocrat Technologies: Aiming High, Global Gaming
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Business Magazine (Aug. 27, 2013), available at http://ggbmagazine.com/issue/vol-12-no-9-
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september-2013/article/aristocrat-technologies-aiming-high. In a promotional video Aristocrats
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Vice President of Gaming Operations called the BATMAN game the beginning of a new era for
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Aristocrat and said it was very special having Kaminkow bring his skills to Aristocrat, and in
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particular to [the BATMAN game]. Video, Behind-the-Scenes Look at Batman Classic TV Series
Slot Machine (Apr. 9, 2014), available at http://www.vegasnews.com/113305/ aristocrat-releases-
batman-classic-tv-series-slot-machine-and-behind-the-scenes-video.html. In the same video
Kaminkow himself discusses the bonus wheels on the BATMAN game and refers to himself as the
king of wheels having made more wheel games probably than anybody. Id.

PHONE (702)873-4100 FAX (702) 873-9966
27.
Upon information and belief, Kaminkow owns a vintage Batmobile like the one used
in the 1960s television series on which the BATMAN slot machine is based. Aristocrat displayed
Kaminkows Batmobile alongside the BATMAN game at G2E 2013. Howard Stutz, Nevadan at
Work: Veteran Game Designer is Always Creating, Las Vegas Review-Journal (Nov. 2, 2013),
available at http://www.reviewjournal.com/business/casinos-gaming/nevadan-work-veteran-game-
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designer-always-creating; Video, Frank Fantini Signs Off from G2E 2013 in Joe Kaminkows
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Batmobile (Sept. 26, 2013), available at https://www.youtube.com/watch?v=-3I1KuWFC1M.
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28.
Aristocrat has released several other slot machines in addition to the BATMAN
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CLASSIC TV SERIES game since Kaminkow joined the company. These slot machines include
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SUPERMAN THE MOVIE, TARZAN OF THE APES, THE ROLLING STONES, THE
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WALKING DEAD, and FLASHDANCE. Upon information and belief, Kaminkow has had
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significant involvement in the design and development of these games. See Howard Stutz, Nevadan
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at Work: Veteran Game Designer is Always Creating, Las Vegas Review-Journal (Nov. 2, 2013),
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available at http://www.reviewjournal.com/business/casinos-gaming/nevadan-work-veteran-game-
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designer-always-creating (Aristocrat unveiled five games designed by [Kaminkows] team
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Flashdance, Tarzan, The Rolling Stones, Superman, and Batman.); Frank Legato,
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Aristocrat Technologies: Aiming High, Global Gaming Business Magazine (Aug. 27, 2013),
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available at http://ggbmagazine.com/issue/vol-12-no-9-september-2013/article/aristocrat-
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technologies-aiming-high (quoting Aristocrats Vice President of Gaming Operations as saying that
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Aristocrat already had [Flashdance] in development before we brought Joe Kaminkow in . . . but
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after he was done with it, it was a night-and-day change).
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COUNT I
(INFRINGEMENT OF U.S. PATENT NO. 7,131,908)
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PHONE (702)873-4100 FAX (702) 873-9966
IGT repeats and realleges each of the assertions set forth in Paragraphs 1 through 28
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Upon information and belief, Aristocrats manufacture, use, offer to sell, and sale of
above.
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at least the following gaming machines infringes at least one claim of the 908 Patent: BATMAN
CLASSIC TV SERIES, THE WALKING DEAD, THE ROLLING STONES, TARZAN OF THE
APES, SUPERMAN THE MOVIE, and FLASHDANCE.
31.
IGT is entitled to recover from Aristocrat the damages sustained by IGT as a result of
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Aristocrats wrongful acts in an amount subject to proof at trial, including lost profits and an amount
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not less than a reasonable royalty, together with interest and costs as fixed by this Court under 35
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U.S.C. 284.
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32.
The infringement by Aristocrat of the 908 Patent will continue to cause IGT
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irreparable injury and damage for which there is no adequate remedy at law unless and until
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Aristocrat is enjoined from infringing said patent.
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COUNT II
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33.
34.
above.
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CLASSIC TV SERIES, THE WALKING DEAD, SUPERMAN THE MOVIE, and FLASHDANCE.
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35.
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U.S.C. 284.
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36.
COUNT III
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37.
38.
above.
CLASSIC TV SERIES.
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39.
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U.S.C. 284.
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40.
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COUNT IV
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42.
above.
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CLASSIC TV SERIES and TARZAN OF THE APES.
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U.S.C. 284.
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COUNT V
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46.
above.
CLASSIC TV SERIES, SUPERMAN THE MOVIE, and TARZAN OF THE APES.
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47.
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U.S.C. 284.
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48.
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COUNT VI
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(INFRINGEMENT OF U.S. PATENT NO. D503,951)
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49.
50.
above.
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CLASSIC TV SERIES and SUPERMAN THE MOVIE.
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51.
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Aristocrats wrongful acts in an amount subject to proof at trial, including Aristocrats profits,
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together with interest and costs as fixed by this Court under 35 U.S.C. 289.
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52.
COUNT VII
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53.
54.
above.
CLASSIC TV SERIES and THE ROLLING STONES.
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55.
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U.S.C. 284.
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56.
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COUNT VIII
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(DECLARATORY JUDGMENT OF ASSIGNOR ESTOPPEL ON THE 570 PATENT)
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57.
58.
Joe Kaminkow is a named inventor on the 570 Patent. His name was added to the
above.
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list of inventors by a Certificate of Correction issued on July 8, 2003. Kaminkow assigned all of his
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rights, title, and interest in the 570 Patent to IGT in exchange for valuable consideration.
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59.
Having received valuable consideration for his assignment of the 570 Patent,
Kaminkow is estopped from challenging the patents validity.
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60.
the company is in privity with Kaminkow. Upon information and belief, Kaminkow had extensive
involvement in the design and development of games that infringe the 570 Patent.

PHONE (702)873-4100 FAX (702) 873-9966
Aristocrat is also estopped from challenging the validity of the 570 Patent because
61.
IGT will suffer immediate and real harm if Aristocrat is permitted to challenge the
validity of the 570 Patent. This action therefore represents a live case or controversy and warrants
issuance of a declaration of the parties rights.
COUNT IX
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62.
63.
above.
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CLASSIC TV SERIES, SUPERMAN THE MOVIE, THE WALKING DEAD, THE ROLLING
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STONES, TARZAN OF THE APES, and FLASHDANCE.
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64.
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U.S.C. 284.
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65.
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COUNT X
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66.
67.
Joe Kaminkow is a named inventor on the 675 Patent. Kaminkow assigned all of his
above.
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1
2
68.
69.

PHONE (702)873-4100 FAX (702) 873-9966
70.
COUNT XI
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71.
72.
above.
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at least the following gaming machines infringes at least one claim of the 469 Patent: SUPERMAN
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THE MOVIE and TARZAN OF THE APES.
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73.
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U.S.C. 284.
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74.
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COUNT XII
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75.
76.
Joe Kaminkow is the named inventor on the 469 Patent. Kaminkow assigned all of
above.
his rights, title, and interest in the 469 Patent to IGT in exchange for valuable consideration.
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1
2
77.
78.

PHONE (702)873-4100 FAX (702) 873-9966
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COUNT XIII
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80.
81.
above.
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CLASSIC TV SERIES and SUPERMAN THE MOVIE.
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82.
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U.S.C. 284.
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83.
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COUNT XIV
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84.
85.
Joe Kaminkow is a named inventor on the 701 Patent. Kaminkow assigned all of his
above.
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1
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PHONE (702)873-4100 FAX (702) 873-9966

87.
86.
88.
REQUESTED RELIEF
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WHEREFORE, IGT respectfully requests the following relief:
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A.
The entry of judgment that Aristocrat has infringed one or more claims of the 908,
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827, 902, 334, 189, 951, 570, 675, 469, and/or 701 Patents literally and/or under the doctrine
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of equivalents;
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B.
The entry of a permanent injunction, pursuant to 35 U.S.C. 283, enjoining
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Aristocrat and its agents, servants, officers, directors, employees, affiliated entities, and all persons
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in active concert or participation with them from continued infringement of the 908, 827, 902,
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334, 189, 951, 570, 675, 469, and/or 701 Patents;
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C.
A declaration that the doctrine of assignor estoppel bars Aristocrat from challenging
the validity of the 570 Patent, the 675 Patent, the 469 Patent, and/or the 701 Patent;
D.
An award to IGT of damages adequate to compensate IGT for Aristocrats acts of
infringement of the 908, 827, 902, 334, 189, 951, 570, 675, 469, and/or 701 Patents;
E.
An award to IGT equal to any profits that Aristocrat gained from its infringement of
the 908, 827, 902, 334, 189, 951, 570, 675, 469, and/or 701 Patents;
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F.
An award of prejudgment and post-judgment interest on all sums awarded;
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G.
A post-verdict and post-judgment account for any infringement of the 908, 827,
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902, 334, 189, 951, 570, 675, 469, and/or 701 Patents not otherwise covered by a damages
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award and the requested injunctive relief; and
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H.
Any such other and further relief as the Court may deem just and proper under the
circumstances.
DEMAND FOR JURY TRIAL
Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, IGT respectfully requests a
trial by jury of any and all issues on which a trial by jury is available under applicable law.
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PHONE (702)873-4100 FAX (702) 873-9966
RESPECTFULLY SUBMITTED this 16th day of March, 2015.

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By: /s/ Jeff Silvestri

JEFF SILVESTRI, ESQ. (#5779)
2300 W. Sahara Avenue, Suite 1200
Las Vegas, NV 89102
Telephone: 702.873.4100
Facsimile: 702.873.9966
E-mail: jsilvestri@mcdonaldcarano.com
ADAM K. MORTARA, ESQ. (pro hac vice to be
submitted)
BRIAN C. SWANSON, ESQ. (pro hac vice to be
submitted)
BARTLIT BECK HERMAN
54 West Hubbard Street, Suite 300
Chicago, IL 60654
Telephone: 312.494.4400
E-mail: adam.mortara@bartlit-beck.com
brian.swanson@bartlit-beck.com
23
DANIEL C. TAYLOR, ESQ. (pro hac vice to be

submitted)
BARTLIT BECK HERMAN
1899 Wynkoop Street, 8th Floor
Denver, CO 80202
Telephone: 303.592.3100
E-mail: daniel.taylor@bartlit-beck.com
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Attorneys for Plaintiff IGT
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Case 2:15-cv-00473-RFB-GWF Document 1 Filed 03/16/15 Page 1 of 15

JEFF SILVESTRI, ESQ.

2300 WEST SAHARA AVENUE SUITE 1200 LAS VEGAS, NEVADA

McDONALD CARANO WILSON LLP

ADAM K. MORTARA, ESQ. (pro hac vice to be submitted)

DANIEL C. TAYLOR, ESQ. (pro hac vice to be submitted)

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEVADA

CASE NO. 2:15-cv-00473

COMPLAINT FOR PATENT

Jury Trial Demanded

States, including 35 U.S.C. 271 and 281-285.

Case 2:15-cv-00473-RFB-GWF Document 1 Filed 03/16/15 Page 2 of 15

This lawsuit pertains to Aristocrats infringement of U.S. Patent Nos. 7,131,908;

7,513,827; 6,394,902; 7,384,334; 8,753,189; D503,951; 6,375,570; 6,702,675; 7,303,469; and

6,702,675; 7,303,469; and 6,932,701.

2300 WEST SAHARA AVENUE SUITE 1200 LAS VEGAS, NEVADA

McDONALD CARANO WILSON LLP

gaming machines commonly known as slot machines.

Defendant Aristocrat Technologies, Inc. is a corporation organized and existing under

lottery markets. Aristocrat is a subsidiary of Aristocrat Leisure Limited, an Australian corporation.

JURISDICTION AND VENUE

U.S.C. 1331, 1338(a).

This Court has personal jurisdiction over Aristocrat. Aristocrat is incorporated in

Venue is proper in the District of Nevada pursuant to 28 U.S.C. 1391, 1400(b).

Case 2:15-cv-00473-RFB-GWF Document 1 Filed 03/16/15 Page 3 of 15

The Patents at Issue

2300 WEST SAHARA AVENUE SUITE 1200 LAS VEGAS, NEVADA

copy of that patent is attached as Exhibit A.

McDONALD CARANO WILSON LLP

copy of that patent is attached as Exhibit B.

copy of that patent is attached as Exhibit C.

copy of that patent is attached as Exhibit D.

copy of that patent is attached as Exhibit E.

copy of that patent is attached as Exhibit F.

copy of that patent is attached as Exhibit G.

copy of that patent is attached as Exhibit H.

Case 2:15-cv-00473-RFB-GWF Document 1 Filed 03/16/15 Page 4 of 15

copy of that patent is attached as Exhibit I.

copy of that patent is attached as Exhibit J.

2300 WEST SAHARA AVENUE SUITE 1200 LAS VEGAS, NEVADA

McDONALD CARANO WILSON LLP

Joe Kaminkow and IGT

Patent, and the 701 Patent. Kaminkow is a designer of slot machines.

AND THE CITY, STAR WARS, and GHOSTBUSTERS.

bonuses, and other employment benefits.

Kaminkow resigned from IGT in January 2012.

Joe Kaminkow and Aristocrat

Case 2:15-cv-00473-RFB-GWF Document 1 Filed 03/16/15 Page 5 of 15

Developer Joins Aristocrat, Market Wired (Feb. 26, 2013), available at

2300 WEST SAHARA AVENUE SUITE 1200 LAS VEGAS, NEVADA

McDONALD CARANO WILSON LLP

Week in Gambling (Aug. 13, 2014), available at https://www.youtube.com/watch?v=4iL0UOSp15A

Business Magazine (Aug. 27, 2013), available at http://ggbmagazine.com/issue/vol-12-no-9-

september-2013/article/aristocrat-technologies-aiming-high. In a promotional video Aristocrats

Case 2:15-cv-00473-RFB-GWF Document 1 Filed 03/16/15 Page 6 of 15

Slot Machine (Apr. 9, 2014), available at http://www.vegasnews.com/113305/ aristocrat-releases-

batman-classic-tv-series-slot-machine-and-behind-the-scenes-video.html. In the same video

2300 WEST SAHARA AVENUE SUITE 1200 LAS VEGAS, NEVADA

McDONALD CARANO WILSON LLP

Batmobile (Sept. 26, 2013), available at https://www.youtube.com/watch?v=-3I1KuWFC1M.

designer-always-creating (Aristocrat unveiled five games designed by [Kaminkows] team

technologies-aiming-high (quoting Aristocrats Vice President of Gaming Operations as saying that

after he was done with it, it was a night-and-day change).