Universal Ent. v. Aruze Gaming Am. - Complaint (Sans Exhibits)

Case 2:19-cv-01657 Document 1 Filed 09/20/19 Page 1 of 52
1 Jay J. Schuttert, Esq.

Nevada Bar No. 8656
2 David W. Gutke, Esq.
3 Nevada Bar No. 9820
EVANS FEARS & SCHUTTERT LLP
4 2300 West Sahara Avenue, Suite 950
Las Vegas, NV 89101
5 Telephone (702) 805-0290
Facsimile (702) 805-0291
6
Email: [email protected]
7 Email: [email protected]
8
Attorneys for Plaintiff UNIVERSAL
9 ENTERTAINMENT CORPORATION
10
11
12
13
UNITED STATES DISTRICT COURT
14
DISTRICT OF NEVADA
15
16 UNIVERSAL ENTERTAINMENT CASE NO.:

CORPORATION, a Japanese corporation,
17 COMPLAINT
Plaintiff,
18 DEMAND FOR JURY TRIAL
vs.
19
ARUZE GAMING AMERICA, INC., a Nevada
20 corporation, KAZUO OKADA, an individual
21 Defendants.
22
COMPLAINT
23
Universal Entertainment Corporation, a Japanese corporation, by and through its attorneys,
24
for its Complaint against Aruze Gaming America, Inc., a Nevada corporation (collectively,
25
“Defendant”), hereby alleges as follows:
26
27
28
1
1 PARTIES, JURISDICTION, AND VENUE

2 1. Plaintiff Universal Entertainment Corporation (“UEC” or “Plaintiff”)) is a
3 corporation organized under the laws of Japan with its headquarters and principal place of business
4 located in Tokyo, Japan. UEC is a publicly traded Japanese gaming and entertainment company that
5 is traded on the Tokyo Stock Exchange JASDAQ (standard). For purposes of this litigation, UEC
6 specifically includes all the former operating corporate names and corporate structures of the
7 Plaintiff.
8 2. Defendant Aruze Gaming America, Inc. (“AGA”) is a Nevada corporation, with its
9 principal place of business located at 955 Grier Dr. #A, Las Vegas, Nevada 89119. Upon
10 information and belief, Okada is the sole shareholder of AGA, as well a director of AGA.
11 3. Defendant Kazuo Okada (hereinafter “Okada”) is the founder of UEC and served
12 most recently as the Chairman of the Board of UEC until his removal in June of 2017 and resides in
13 Japan but regularly transacts business in the State of Nevada.
14 4. Defendant Aruze Gaming America, Inc. (“AGA”) is a Nevada corporation, with its
15 principal place of business located at 955 Grier Dr. #A, Las Vegas, Nevada 89199. AGA
16 manufactures, distributes, offers for sale and sells slot machines and other gaming devices. Upon
17 information and belief, Okada is the sole shareholder of AGA, as well as a director of AGA.
18 5. Okada, upon information and believe, continuously and systematically transacts
19 business in the State of Nevada by directing AGA employees in the State of Nevada in their
20 activities involving the design, manufacture and/or sale of infringing game machines (as described
21 below) and is personally licensed by the Nevada Gaming Commission.
22 6. Upon information and belief, Okada also directed AGA employees in the State of
23 Nevada in their activities that resulted in the infringement by AGA of UEC’s patents as
24 described herein.
25 7. This action arises under the patent laws of the United States, Title 35 of the United
26 States Code, 35 U.S.C. §§ 1 et seq. Accordingly, this Court has subject matter jurisdiction over this
27 action under 28 U.S.C. §§ 1331 and 1338(a).
28
2
1 8. This Court also has subject matter jurisdiction under 28 U.S.C. § 1332(a)(2), as this
2 action is between a corporate citizen of a foreign state and a corporate citizen of the State of Nevada
3 and the amount in controversy exceeds $75,000, exclusive of interest and costs.
4 9. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2) or (3). Venue is
5 also proper in this District pursuant to 28 U.S.C. § 1400(b) because AGA is incorporated in
6 Nevada, has its headquarters and established place of business in Nevada, has committed acts of
7 infringement in Nevada, and is subject to both general and specific personal jurisdiction in Nevada.
8
9 THE ASSERTED UEC PATENTS
10 10. UEC is a pioneer in the gaming industry, and in particular, UEC is a pioneer in the
11 design of innovative and unique slot machine type games.
12 11. UEC develops high-quality products and services for the gaming industry, including
13 developing new and exciting gaming devices and describes its mission as providing sound
14 entertainment that transcends the likes of age, gender and national borders for people all over the
15 world. As a result of these innovative efforts, UEC has been awarded over five-hundred patents
16 worldwide (hereinafter “UEC’s Patent Rights”).
17 12. UEC asserts the following two design patents: U.S. Patent No. D573,200 (“the ’200
18 patent), and U.S. Patent No. D573,201 (“the ’201 patent”).
19 13. UEC also asserts the following seven utility patents: U.S. Patent No. 8,083,582
20 (“the ’582 patent”), U.S. Patent No. 8,235,790 (“the ’790 patent”), U.S. Patent No. 8,480,479 (“the
21 ’479 patent”), U.S. Patent No. 8,523,656 (“the ’656 patent”), U.S. Patent No. 8,684,816 (“the ’816
22 patent”), U.S. Reissue Patent No. 46,767 (“the ’767 patent”) and U.S. Reissue Patent No. 46,808
23 (“the ’808 patent”).
24 14. Collectively, the ’200, ’201, ’582, ’790, ’479, ’656, ’816, ’767, and ’808 patents will
25 be referred to herein as the “Asserted Patents.” The Asserted Patents generally relate to slot
26 machine type gaming devices and specific aspects of their construction, operation, and/or
27 ornamental features.
28
3
1 15. Each of the Asserted Patents has been duly and legally issued, is valid and
2 enforceable and has been assigned to UEC.
3 The ’200 Patent:

4 16. UEC owns all right, title and interest to the ’200 patent, entitled “Slot Machine.” The
5 ’200 patent issued on July 15, 2008 with Koichiro Hashimoto and Yoshihide Endo, employees of
6 UEC at the time of the invention of the subject matter of the ’200 patent, being the named inventors
7 of the ’200 patent. The ’200 patent issued from U.S. Application No. 29/287,201, filed on July 9,
8 2007, and ultimately claims priority to Japanese Application No. 2007-010989, filed on April 24,
9 2007. A true and correct copy of the ’200 patent is attached hereto as Exhibit 1.
10 17. A certified copy of the prosecution history of the ’200 patent is attached hereto as
11 Exhibit 2.
12 18. Generally, the ’200 patent is directed to and claims an ornamental design for a slot
13 machine, as shown and described. Figures 8 and 9 below illustrate example views of the claimed
14 design.
15 1.
16
17
18
19
20
21
22
23
24
25 Figure 8 Figure 9
27 19. UEC owns all right, title and interest to the ’201 patent, entitled “Slot Machine.” The
28 ’201 patent issued on July 15, 2008 with Koichiro Hashimoto and Yoshihide Endo, employees of
4
1 UEC at the time of the invention of the subject matter of the ’201 patent, being the named inventors
2 of the ’201 patent. The ’201 patent issued from U.S. Application No. 29/287,202, filed on July 9,
3 2007, and ultimately claims priority to Japanese Application No. 2007-010990, filed on April 24,
6 Exhibit 4.
7 21. Generally, the ’201 patent is directed to and claims an ornamental design for a slot
8 machine, as shown and described. Figure 9 below illustrates an example view of the claimed
9 design.
10
11
12
13
14
15
16
17
18
19
20
21
22 Figure 9
23
25 22. UEC owns all right, title and interest in the ’582 patent, entitled “Gaming Machine.”
26 The ’582 patent duly and lawfully issued on December 27, 2011, with Yoichi Kato, an employee of
27 UEC at the time of the invention of the subject matter of the ’582 patent, being the named inventor
28 of the ’582 patent. The ’582 patent issued from Application No. 12/252,956, filed on October 16,
5
1 2008, and ultimately claims priority to Japanese Application No. 2007-272859, filed on October 19,
4 Exhibit 6.
5 24. Generally, the ’582 patent is directed to a gaming machine that includes a processor
6 and a display upon which symbols are variably displayed (spinning reels for example) and then
7 stopped to statically display a combination of symbols. Initially, the processor executes a base game
8 that triggers a process for awarding a prize to the player when the displayed combination of
9 symbols corresponds to one of a number of special symbol combinations of the game. Based on the
10 particular corresponding special symbol combination, the processor determines a number (how
11 many) of choice images (player-selectable images) to be displayed to the player on the display.
12 Each of the choice images is associated with a free game condition that includes (a) a number of
13 free games and (b) payout rates in those free games. The processor displays the choice images,
14 accepts a player’s selection amongst the choice images and executes the free game according to the
15 conditions of the selected choice image. The free game condition is set such that the payout rate in
16 the free game is set lower as the number of free games is larger, and the payout rate in the free
17 game is set higher as the number of free games is smaller. In this way, no matter which game
18 condition is selected by the player via the choice images, the expectation value in the free game
19 substantially becomes constant.
20 25. As described in the ’582 patent, “[c]onventionally, there has been a known gaming
21 machine that is provided with a symbol display portion including a plurality of symbol display
22 areas. The gaming machine executes a bonus game in a case where predetermined conditions are
23 satisfied (for example, the gaming machine disclosed in U.S. Pat. No. 6,517,433).” ’582 patent,
24 1:21-26. Additionally, “the conventional gaming machine described above always awards the same
25 special prize in a case where predetermined conditions are satisfied . . . [providing] a bonus game at
26 the time point that a specific symbol combination appears on the effective pay line. In addition, the
27 contents of the provided bonus game are always the same as long as the conditions are satisfied.”
28 ’582 patent, 1:38-46. Further, these conventional games “may be configured to provide a bonus
6
1 game if one of plural styles of conditions is satisfied. In this case, the conditions for providing the
2 bonus game are plural, and therefore, the probability of achieving each condition becomes
3 different.” ’582 patent, 1:47-55.

4 26. However, as described by the ’582 patent, the conventional game that offers bonus
5 games creates problems. Specifically, “the conventional gaming machine still provides the same
6 bonus to the player. Accordingly, the conventional gaming machine may damage [] the player’s
7 feeling of expectancy for the bonus game, thus leading to lowering in interest.” ’582 patent, 1:56-
8 60. Lowered interest results in boredom and causes players to move on from the game to some
9 other game or other form of entertainment. Additionally, “the same bonus game is also provided to
10 another player who satisfies a condition whose achieving probability is high. As a result, the
11 gaming machine may cause the former player who satisfies the condition whose achieving
12 condition is low to have a feeling of inequity.” ’582 patent, 1:60-64. Likewise, a feeling of
13 inequity causes a player to move on from the game to some other game or other form of
14 entertainment.
15 27. Accordingly, in an attempt to combat the problems of lowered interest and inequity
16 created by the conventional games at the time of filing, the inventive games of the ’582 patent have
17 “been designed considering the above problems, and the present invention relates to a gaming
18 machine that may execute a bonus game in a case where a result of a base game corresponds to one
19 of plural types of conditions” but “without damaging to a feeling of expectancy of a player.” ’582
20 patent, 1:65-2:5. To accomplish this goal, the inventive game machines of the ’582 patent provide
21 the player with the ability to select the conditions of the bonus game for himself.” ’582 patent,
22 2:34-43. In addition, “the gaming machine executes a bonus game under a designed condition
23 based on the player’s selection. Accordingly, the gaming machine does not damage [the] player’s
24 feeling of expectancy for the bonus game. Moreover, the gaming machine may raise interest in the
25 bonus game” itself. ’582 patent, 2:46-50. Additionally, “the gaming machine may diversify the
26 conditions of the bonus game selectable by a player. As a result, the gaming machine may provide
27 the player with bonus games under a diversity of conditions. Thus, the gaming machine may
28 prevent the bonus game from being monotonous.” ’582 patent, 3:19-24.
7
1
3 28. UEC owns all right, title and interest in the ’790 patent entitled “Slot Machine.” The
4 ’790 patent duly and lawfully issued on August 7, 2012, with Kazumasa Yoshizawa, an employee
5 of UEC at the time of the invention of the subject matter of the ’790 patent, being the named
6 inventor of the ’790 patent. The ’790 patent issued from Application No. 12/137,025, filed on June
7 11, 2008, and ultimately claims priority to Provisional Application No. 61/034,626, filed on March
8 7, 2008. A true and correct copy of the ’790 patent is attached hereto as Exhibit 7.
10 Exhibit 8.
11 30. Generally, the ’790 patent is directed to a slot machine including a display, a
12 memory, and a processor. The processor is programmed to execute a basic game and rearrange the
13 symbols during the basic game. The processor is programmed to cumulatively store in the memory,
14 data concerning the number of predetermined symbols rearranged during the basic game. Also, the
15 processor is programmed to determine the number of times to execute a free game based upon the
16 result of an executed sub game in which the number of times to execute the sub game equals the
17 number of the predetermined symbols rearranged on the display. The processor is configured to
18 execute the free game based on the number of times determined during the sub game.
19 31. As described in the ’790 patent, “many of the conventional slot machines have been
20 known which conduct two types of games, i.e., a basic game and a free game. The basic game is
21 executed upon consumption of gaming values (such as coins or credits) correspond to the amount of
22 bet. On the other hand, the free game is executed without consuming gaming values corresponding
23 to the amount of bet.” ’790 patent, 1:33-39. In these conventional games, “it has been a common
24 routine to raise the player’s feeling of expectation for the free game by changing arrangement of
25 symbols during the free game differently from that during the basic game . . . . [H]owever,
26 irrespective of whichever of the basic game and the free game is in progress, the symbols of
27 different types have been randomly arranged in combination and sequential order. These slot
28 machines determine the content of the prize to be awarded, based on a combination of multiple
8
1 symbols that have been arranged in a display device. Therefore, players are allowed to have the
2 feeling of expectation only for random payout based on a combination of plural types of symbols
3 that have been randomly arranged in the display device. Accordingly, a need exists for the advent
4 of a slot machine which can offer new entertainability.” ’790 patent, 1:47-2:4. In other words, the
5 player of the “conventional” game can lose interest because expectations only result from the
6 random arrangement of symbols.
7 32. To solve this problem of lowered interest in the conventional games at the time of
8 filing, the inventive game machines of the ’790 patent provided for “a slot machine . . . [that]
9 determines the number of times in executing the free game by summing numbers of times in
10 executing the free game that are determined in the sub games, respectively.” ’790 patent, 3:33-38.
11 Specifically, “the free game is executed by a total number of times which is obtained by
12 cumulatively summing the number of times in executing the free game, which is determined in each
13 sub game, to the predetermined number of times. For example, in a case where two is determined
14 in the first sub game, as the number of times in executing the free game; one is determined in the
15 second sub game, as the number of times in executing the free game; and six is the determined as
16 the predetermined number of times, the free game is executed by nine times. Therefore, the number
17 of times is cumulatively summed to the predetermined number of times in executing the free game,
18 by repeating the sub game, thereby increasing the number of times in executing the free game.
19 Thus, the slot machine [of the invention] allows players to raise expectations for the number of
20 times in executing the next free game as more sub games are executed, thereby enhancing
21 entertainability.” ’790 patent, 3:42-57.
22
24 33. UEC owns all right, title and interest in the ’479 patent, entitled “Gaming Machine
25 Capable with Free Game Play.” The ’479 patent duly and lawfully issued on July 9, 2013, with
26 Sakiko Kojima, an employee of UEC at the time of the invention of the subject matter of the ’479
27 patent, being the named inventor of the ’479 patent. The ’479 patent issued from U.S. Application
28
9
1 No. 12/905,730, filed on October 15, 2010. A true and correct copy of the ’479 patent is attached
2 hereto as Exhibit 9.
4 Exhibit 10.
5 35. Generally, the ’479 patent is directed to a gaming machine including a display, a
6 game control device, an input device, a point provision device, and a benefit provision device. The
7 control device is operable to provide a payout corresponding to a combination of symbols displayed
8 on the screen. The point provision device provides a point corresponding to any of a plurality of
9 benefits based on a result of a lottery conducted at every time of operation of the input device. The
10 benefit provision device provides a benefit for reaching a predetermined number of points.
11 36. As described in the ’479 patent, conventional slot machine games at the time of
12 filing would shift to a bonus game or free game “when a combination of symbols displayed
13 statically as each reel is stopped matches a predetermined combination, a payout corresponding to
14 the predetermined combination is paid out to a game player. At this time, if a symbol for a bonus
15 trigger is displayed statically, the game can shift to another game mode, so-called a bonus game or
16 free game . . . which is advantageous to the game player.” ’479 patent, 1:21-31.
17 37. The inventive games of the ’479 patent improved upon this bonus or free game
18 mechanism by (among other things) making the bonus or free game stage more interactive and
19 interesting for the player: “In the present invention, in consideration of the aforementioned view, a
20 gaming machine is provided in which a new type of player participating free game can be played
21 since a point is added at every time of the game player’s operation based on a lottery on the gaming
22 machine side until the accumulated points reach the necessary number of points for awarding the
23 benefit.” ’479 patent, 1:47-53.
24 38. Claim 1 of the ’479 patent includes non-conventional hardware limitations in a slot
25 machine such as a “contact input device,” which is also referred to in the ’479 patent as “Touch
26 panel 11.” See, e.g., ’479 patent, Fig. 1; Fig. 6; 4:16-19 (“A touch panel 11 (refer to FIG. 1) is
27 provided on the front face of the lower image display panel 6, and a game player can operate the
28 touch panel 11 (refer to FIG. 1) to input various kinds of instructions.”); 48:47-51 (“a contact input
10
1 device (e.g., touch panel 11) which is provided on the display screen of the device to constitute a
2 contact operation part operative by contact to the operation button displayed on the display
3 screen”).
6 and Gaming Method Thereof.” The ’656 patent duly and lawfully issued on September 3, 2013,
7 with Hiroki Saito, an employee of UEC at the time of the invention of the subject matter of the ’656
8 patent, being the named inventor of the ’656 patent. The ’656 patent issued from U.S. Application
9 No. 13/220,672, filed on August 29, 2011, which is a continuation of U.S. Application No.
10 12/133,081 (now, U.S. Patent No. 8,029,354), and ultimately claims priority to Japanese
11 Application No. 2007-166962, filed on June 25, 2007. A true and correct copy of the ’656 patent is
12 attached hereto as Exhibit 11.
14 Exhibit 12.
15 41. Generally, the ’656 patent is directed to a gaming machine including a display
16 having a plurality of symbols within a matrix having N rows and M columns, and a processor which
17 controls the display. At least N number of predetermined symbols are consecutively arranged on
18 each of the first reels, so that the predetermined symbols are able to be displayed across N rows in a
19 column direction. The processor determines whether N number of all symbols displayed on a
20 column is the predetermined symbols. The processor, in the next game, holds the column on which
21 N number of the predetermined symbols are displayed. The processor changes the first reels to
22 second reels that include more of the predetermined symbols than the first reels.
23 42. As described in the ’656 patent, “some conventional gaming machines have a
24 primary game and a secondary game. If a predetermined condition is met, the secondary game
25 which is beneficial for the player is executed. Also, reels to be used are different in the primary
26 game and the secondary game. In the conventional gaming machines, the beneficial reel for the
27 player is used in the free game. However, a particular process is not executed even though wild
28 symbols fill on some reel, and next game is star[t]ed.” ’656 patent, 1:17-36.
11
1 43. Also, in the conventional gaming machines, alignment of the wild symbols on the
2 reel is not considered . . . . [S]ince there is little possibility that only the wild symbols are displayed
3 all of the reels on display, the player’s interest for the free game may be decreased.” ’656 patent,
4 1:17-36.
6 44. UEC owns all right, title and interest to the ’816 patent, entitled “Slot Machine
7 Displaying Rendered Effects Based on Proportion of Payout Amount to Bet Amount.” The ’816
8 patent issued on April 1, 2014, with Arata Ajiro, an employee of UEC at the time of the invention
9 of the subject matter of the ’816 patent, being the named inventor of the ’816 patent. The ’816
10 patent issued from U.S. Application No. 12/210,447, filed on September 15, 2008, and ultimately
11 claims priority to Japanese Application No. 2007-244620, filed on September 21, 2007. A true and
12 correct copy of the ’816 patent is attached hereto as Exhibit 13.
14 Exhibit 14.
15 46. Generally, the ’816 patent is directed to a slot machine including a display device, a
16 plurality of reels, a bet unit for accepting a bet placed on a game by a player, a plurality of motors
17 for rotationally driving and stopping the reels, a memory for storing the bet accepted by the bet unit,
18 and a controller. The controller is configured to (a) execute a first lottery in response to the bet
19 accepted by the bet unit. The controller is configured to (b) send a signal indicating an instruction
20 for rotationally driving the reels. Additionally, the controller is configured to (c) determine an
21 amount of credits to be awarded to the player with a result of the first lottery. The controller is also
22 configured to (d) calculate a proportion of the amount of credits to the bet by dividing the credits to
23 be awarded by the bet. The controller is configured to (e) cause the display device to display an
24 image that provides a graphical indication of the proportion calculated in (d), wherein the image is
25 selected from a plurality of images based on a result of a second lottery. A probability applied to
26 the second lottery differs according to the proportion calculated in (d). The controller is configured
27 to (f) send a signal indicating an instruction to stop each of the motors with the result of the first
28
12
1 lottery. The controller is configured to (g) when the reels come to a stop, award the amount of
2 credits determined in (c) to the player.
3 47. As described in the ’816 patent, a problem arose with conventional slot machine
4 games (even those with video effects), “[s]ince the same effects are provided regardless of bet
5 amounts, [and] the player may have difficulty anticipating an amount to be gained, distinguishing
6 between 1 bet and 50 bets for an occurrence of an award of 100 credit.” ’816 patent, 1:34-37. To
7 improve upon conventional slot machine games by solving this problem, the inventive slot
8 machines of the ’816 patent, in one aspect, “select[] an image out of the plurality of images
9 according to the result of the lottery in addition to the proportion of the amount of credits to be
10 awarded to the amount of bet. Since the slot machine determines the rendered effects according to
11 not only the proportion but also the result of the lottery, it is possible to augment the variation of the
12 rendered effects. This augmented variation does not allow the player to fully grasp his/her coming
13 gains. In this way, the player has another fun of predicting his/her gains.” ’816 patent, 2:26-35. In
14 other words, the ’816 patent attempts to avoid less interesting and “monotonous display” game play
15 of the conventional games by providing the player with some information that highlights the gains
16 that will be made, but preventing the player from fully understanding of those gains until they are
17 awarded.
20 Allowing Selection of Stopping Order of Reels for Sustaining Player’s Anticipation, and Control
21 Method Thereof.” The ’767 patent duly and lawfully issued on March 27, 2018, with Nakayasu
22 Tsukahara, an employee of UEC at the time of the invention of the subject matter of the ’767
23 patent, being the named inventor of the ’767 patent. The ’767 patent issued from Application No.
24 14/516,999, filed on October 17, 2014, and ultimately claims priority to Provisional Application
25 No. 61/076,325, filed on June 27, 2008, and Provisional Application No. 61/055,329, filed on May
26 22, 2008. A true and correct copy of the ’767 patent is attached hereto as Exhibit 15.
27 49. A certified copy of the prosecution history of the ’767 patent is attached as Exhibit
28 16.
13
1 50. Generally, the ’767 patent is directed to a gaming machine having a display, a
2 memory, an input device, and a CPU. The CPU is programmed to randomly determine a symbol to
3 be statically displayed in each of a plurality of symbol display regions and determine whether the
4 displayed combination of symbols along a pay line corresponds to a winning combination. When it
5 is determined that the to-be-displayed combination of symbols will not constitute a winning
6 combination, the CPU is programmed to first display symbols that could correspond to a winning
7 combination to heighten a player’s excitement, but then subsequently display the rest of the
8 symbols that do not correspond to a winning combination. On the other hand, when it is determined
9 that the combination of symbols to be displayed will constitute a winning combination, the CPU is
10 programmed to randomly display the symbols corresponding to the winning combination.
11 51. As described in the ’767 patent, conventional slot machine games “[a]fter a
12 predetermined period of time, the variable display on the display unit or the rotation of the reels is
13 stopped, and it is determined whether the static symbols form a winning combination or not. In this
14 case, the symbol groups are statically displayed in a predetermined order. . . . [F]or example, the
15 left-most symbol group is first statically displayed. In this case, if a symbol not included in any
16 winning combination is displayed first, the player may be disappointed to know that he missed an
17 award, and may not be interested in other symbols. Then, the player may be bored and
18 uncomfortable until all the symbol groups are statically displayed. Since a lot of games are usually
19 executed repeatedly in a slot game, such a disappointment may gradually discourage and deter the
20 players.” ’767 patent, 1:49-65.
21 52. To solve this problem created by conventional slot machines at the time of filing, the
22 inventive slot machine games of the ’767 patent provide for a “gaming machine that can control an
23 order in which symbols are statically displayed in symbol display regions in response to a
24 predetermined condition, and a control method thereof.” ’767 patent, 1:66-2:4. Specifically, if the
25 player is going to win, the slot machine game statically displays the reels in a random order.
26 However, if the player is going to lose, the slot machine game will statically display those symbols
27 that could correspond to a winning combination first, while statically displaying symbols that
28 would result in a loss later. See, e.g., ’767 patent, claim 1. “According to the aspect of the present
14
1 invention, even in a case where the combination of symbols to be statically displayed along the
2 activated pay line is not a combination qualified for an award, the symbol display region displaying
3 the symbol not constituting a combination qualified for an award can be statically displayed delayed
4 from the symbol display region displaying the symbol constituting the combination. In addition, in
5 a case where the combination of symbols to be statically displayed along the activated pay line
6 corresponds to a combination qualified for an award, the stopping order of the plurality of symbols
7 display regions is randomly changed.” ’767 patent, 6:27-38. In other words, the inventive games
8 of the ’767 patent subvert the expectations of the player by controlling the stopping order of the
9 symbols. If a player is to win, the symbols are stopped in a random order. If a player is to lose, the
10 symbols are stopped such that the symbol that shows a loss occurred is delayed. In this way, the
11 player’s anticipation in the outcome is extended.
12
15 Allowing Selection of Stopping Order of Reels for Sustaining Player’s Anticipation, and Control
16 Method Thereof.” The ’808 patent duly and lawfully issued on April 24, 2018, with Nakayasu
17 Tsukahara, an employee of UEC at the time of the invention of the subject matter of the ’808
18 patent, being the named inventor of the ’808 patent. The ’808 patent issued from Application No.
19 14/573,477, filed on December 17, 2014, and ultimately claims priority to Provisional Application
20 No. 61/076,325, filed on June 27, 2008, and Provisional Application No. 61/055,329, filed on May
21 22, 2008. A true and correct copy of the ’808 patent is attached hereto as Exhibit 17. The ’808
22 patent is related to the ’767 patent.
23 54. A certified copy of the prosecution of the ’808 patent is attached hereto as Exhibit
24 18.
25 55. Generally, the ’808 patent is directed to a slot machine having a CPU and a display.
26 For a particular spin, prior to displaying the static (stopped) result of all of the reels, the CPU
27 determines whether the combination of the symbols to be statically displayed when the reels are
28 stopped is going to be a winning combination. If it is not going to be a winning combination, the
15
1 CPU determines, for each reel, whether the symbol to be displayed on that reel when stopped
2 matches the symbol of an “analogous” winning combination. In this context, an “analogous”
3 winning combination is a winning combination of the game that has the greatest number of symbols
4 in common with the combination of symbols to be displayed. The CPU then delays stopping each
5 real that does not have a matching symbol to the analogous winning combination until after the
6 reels having matching symbols to the analogous winning combination have been stopped and are
7 displaying their symbol. Alternatively, if the stopped combination of symbols is going to be a
8 winning combination of the game, the CPU automatically randomly displays the symbols. In this
9 manner, by statically displaying those symbols that match a winning combination first, the game
10 raises a player’s anticipation for winning as the CPU is programmed to perform a payout when a
11 winning combination is displayed.
12 56. As described in the ’808 patent, conventional slot machine games “[a]fter a
13 predetermined period of time, the variable display on the display unit or the rotation of the reels is
14 stopped, and it is determined whether the static symbols form a winning combination or not. In this
15 case, the symbol groups are statically displayed in a predetermined order. . . . [F]or example, the
16 left-most symbol group is first statically displayed. In this case, if a symbol not included in any
17 winning combination is displayed first, the player may be disappointed to know that he missed an
18 award, and may not be interested in other symbols. Then, the player may be bored and
19 uncomfortable until all the symbol groups are statically displayed. Since a lot of games are usually
20 executed repeatedly in a slot game, such a disappointment may gradually discourage and deter the
21 players.” ’808 patent, 1:62-2:12.
22 57. To solve this problem in the conventional slot machine games at the time of filing,
23 the inventive slot machine games of the ’808 patent provide for a “gaming machine that can control
24 an order in which symbols are statically displayed in symbol display regions in response to a
25 predetermined condition, and a control method thereof.” ’808 patent, 2:13-16. Specifically, if the
26 player is going to win, the slot machine game statically displays the reels in a random order.
27 However, if the player is going to lose, the slot machine game will statically display those symbols
28 that could correspond to a winning combination first, while statically displaying symbols that
16
1 would result in a loss later. See, e.g., ’808 patent, claim 14. “According to the aspect of the present
2 invention, even in a case where the combination of symbols to be statically displayed along the
3 activated pay line is not a combination qualified for an award, the symbol display region displaying
4 the symbol not constituting a combination qualified for an award can be statically displayed delayed
5 from the symbol display region displaying the symbol constituting the combination. In addition, in
6 a case where the combination of symbols to be statically displayed along the activated pay line
7 corresponds to a combination qualified for an award, the stopping order of the plurality of symbols
8 display regions is randomly changed.” ’808 patent, 6:41-53. In other words, the inventive games
9 of the ’808 patent subvert the expectations of the player by controlling the stopping order of the
10 symbols. If a player is to win, the symbols are stopped in a random order. If a player is to lose, the
11 symbols are stopped such that the symbol that shows a loss occurred is delayed. In this way, the
12 player’s anticipation in the outcome is extended.
13
14 PATENT MARKING
15 58. Throughout the relevant time-period, UEC complied with the marking provisions of
16 35 U.S.C. § 287(a) with respect to each of the Asserted Patents.
17
18 AGA AND ITS UNAUTHORIZED USE OF UEC’S ASSERTED PATENTS
19 59. By 2005, AGA manufactured gaming devices for sale outside of Japan and was
20 entirely owned by UEC and operated as a consolidated subsidiary of UEC.
21 60. In August 2008, Okada acquired shares of AGA from UEC and UEC issued
22 additional shares of AGA to Okada.
23 61. In December 2008, a decision was made to transfer the remaining stock of AGA
24 owned by UEC to Okada. After this decision, both UEC and AGA employees began preparing for
25 this change.
26 62. The transfer of the remaining UEC owned shares of AGA began in 2009. As a
27 result, as of January 2009, while AGA was still operating as a subsidiary of UEC, UEC only held
28 49.95% of AGA’s stock and the remaining 50.05% was held by Okada.
17
1 63. The transfer of UEC’s remaining shares in AGA was completed and AGA ceased to
2 operate as a UEC subsidiary in 2009.
3 64. Upon information and belief, Okada has presided over AGA and made all of its
4 important business decisions since AGA’s separation from UEC.
5 65. At no time during the last six years was AGA authorized to practice any of the
6 Asserted Patents by any appropriately authorized officer, director, manager or other UEC
7 employee.
8
9 AGA’S ACCUSED PRODUCT DESIGNS
10 66. AGA manufactures, sells and offers for sale various slot machine games, which are
11 contained within housings of various designs styles. AGA’s products are advertised and offered for
12 sale at AGA’s website at: https://aruzegaming.com.
13 67. As detailed below, the asserted ’200 and ’201 design patents are asserted against the
14 five accused housing designs, regardless of what specific slot games are sold within.
15 68. The product designs manufactured, sold and offered for sale by AGA and accused of
16 infringement herein, include, but are not necessarily limited to the following:
17 Innovator:
18 69. AGA offers for sale as one of its product designs the “Innovator” (hereinafter
19 “INNOVATOR”). AGA’s INNOVATOR is described and offered for sale, for example, at AGA’s
20 website: https://aruzegaming.com/innovator/. A representative image of the INNOVATOR is
21 reproduced below:
22
23
24
25
26
27
28
18
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Innovator Deluxe:
16
70. AGA offers for sale as one of its product designs the “Innovator Deluxe”
17
(hereinafter “INNOVATOR DELUXE”). AGA’s INNOVATOR DELUXE is described and
18
offered for sale, for example, at AGA’s website: https://aruzegaming.com/innovator-deluxe/. A
19
representative image of the INNOVATOR DELUXE is reproduced below:
20
21
22
23
24
25
26
27
28
19
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24 G-ENEX:
25 71. AGA offers for sale as one of its product designs the “G-ENEX” (hereinafter “G-
26 ENEX”). AGA’s G-ENEX is described and offered for sale, for example, at AGA’s website:
27 https://aruzegaming.com/g-series/. A representative image of the G-ENEX design is reproduced
28 below:
20
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24 G-Series Deluxe:
25 72. AGA offers for sale as one of its product designs the “G-Series Deluxe” (hereinafter
26 “G-SERIES DELUXE”). AGA’s G-SERIES DELUXE is described and offered for sale, for
27 example, at AGA’s website: https://aruzegaming.com/g-deluxe/. A representative image of the G-
28 SERIES DELUXE is reproduced below:
21
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24 G-Link:
25 73. AGA offers for sale as one of its product designs the “G-Link” (hereinafter “G-
26 LINK”). AGA’s G-LINK is described and offered for sale, for example, at AGA’s website:
27 https://aruzegaming.com/g-link/. A representative image of the G-LINK is reproduced below:
28
22
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18 AGA’S ACCUSED SLOT MACHINE GAME PRODUCTS
19 74. AGA manufactures, sells and offers for sale various slot machine game products,
20 which are contained within various styles of product designs. AGA’s products are advertised and
21 offered for sale at AGA’s website at: https://aruzegaming.com.
22 75. Often, on its website, AGA groups individual slot machines together. For purposes
23 of this Complaint, UEC follows the groupings established by AGA on its website. Where AGA
24 groups slot machine games together on its website, UEC will refer to that group as a “family” of
25 games. Not every slot machine game accused of infringement herein is a member of a family.
26 Twelve individual slot machine games and eighteen families of slot machine games are accused of
27 infringement herein. Additionally, the AGA slot machines accused of infringement can be
28
23
1 manufactured, sold and/or offered for sale by AGA in more than one style of design according to
2 AGA’s website.
3 76. The AGA slot machines detailed below are accused of infringing one or more of
4 UEC’s Asserted Patents – the ’582, ’790, ’479, ’816, ’767 and ’808 patents.
5 77. The slot machine games manufactured, sold and offered for sale and accused of
6 infringement herein, include, but are not necessarily limited to the following:
7 100Lines Stack Feature Family:
8 78. AGA offers for sale as one of its products the “100Lines Stack Feature” family of
9 slot machine games (hereinafter “100LINES STACK FEATURE FAMILY”). AGA’s 100LINES
10 STACK FEATURE FAMILY of slot machine games includes at least the games “100LINES
11 STACK FEATURE PANDA” and “100LINES STACK FEATURE ROSE.” AGA’s 100LINES
12 STACK FEATURE FAMILY of slot machine games are described and offered for sale at AGA’s
13 website at https://aruzegaming.com/g-series/100lines-stack-feature/ and https://aruzegaming.com/g-
14 series/100lines-stack-feature-rose, and videos depicting aspects of their operation can be found at
15 the same websites.
16 500G Family:
17 79. AGA offers for sale as one of its products the “500G” family of slot machine games
18 (hereinafter “500G FAMILY”). AGA’s 500G FAMILY of slot machine games includes at least the
19 games “CAPTAIN’S TREASURE 500G” and “WOLF 500G.” AGA’s 500G FAMILY of slot
20 machine games are described and offered for sale at, for example, AGA’s website at
21 https://aruzegaming.com/g-series/captains-treasure-500g/ and https://aruzegaming.com/g-
22 series/wolf-500g/, and videos depicting aspects of their operation can be found at the same
23 websites.
24 Alibaba:
25 80. AGA offers for sale as one of its products the “Alibaba” slot machine game
26 (hereinafter “ALIBABA”). AGA’s ALIBABA slot machine game is described and offered for sale
27 at, for example, AGA’s website at https://aruzegaming.com/innovator-deluxe/alibaba/, and a video
28 depicting aspects of its operation can be found at the same website.
24
1 Ancient Wheel Family:

2 81. AGA offers for sale as one of its products the “Ancient Wheel” family of slot
3 machine games (hereinafter “ANCIENT WHEEL FAMILY”). AGA’s ANCIENT WHEEL

4 FAMILY of slot machine games includes at least the games “ANCIENT WHEEL BIG 5” and
5 “ANCIENT WHEEL PANDA.” AGA’s ANCIENT WHEEL FAMILY of slot machine games are
6 described and offered for sale at, for example, AGA’s website at https://aruzegaming.com/cube-x-
7 vertical/ancient-wheel-big-5/ and https://aruzegaming.com/cube-x-vertical/ancient-wheel-panda/,
8 and videos depicting aspects of their operation can be found at the same websites.
9 Coat of Arms Griffin:
10 82. AGA offers for sale as one of its products the “Coat of Arms Griffin” slot machine
11 game (hereinafter “COAT OF ARMS GRIFFIN”). AGA’s COAT OF ARMS GRIFFIN slot
12 machine game is described and offered for sale at, for example, AGA’s website at
13 https://aruzegaming.com/cube-x-video/coat-of-arms-griffin/, and a video depicting aspects of its
14 operation can be found at the same website.
15 Cyber Seven:
16 83. AGA offers for sale as one of its products the “Cyber Seven” slot machine game
17 (hereinafter “CYBER SEVEN”). AGA’s CYBER SEVEN slot machine game is described and
18 offered for sale at, for example, AGA’s website at https://aruzegaming.com/innovator/cyber-seven/,
19 and a video depicting aspects of its operation can be found at the same website.
20 Extreme Family:
21 84. AGA offers for sale as one of its products the “Extreme” family of slot machine
22 games (hereinafter “EXTREME FAMILY”). AGA’s EXTREME FAMILY of slot machine games
23 includes at least the games “EXTREME DRAGON,” “EXTREME KYLIN,” “EXTREME
24 PHOENIX,” and “EXTREME TORTOISE.” Each game of the EXTREME FAMILY of slot
25 machine games has a Cube-X and a G-Series version. AGA’s EXTREME FAMILY games are
26 described and offered for sale at, for example, AGA’s website at,
27 https://aruzegaming.com/cube-x-video/extreme-dragon/,
28 https://aruzegaming.com/g-series/extreme-dragon/,
25
1 https://aruzegaming.com/cube-x-video/extreme-kylin-cube-x/,
2 https://aruzegaming.com/g-series/extreme-kylin,
3 https://aruzegaming.com/cube-x-video/extreme-phoenix-cube-x/,
4 https://aruzegaming.com/g-series/extreme-phoenix/,
5 https://aruzegaming.com/cube-x-video/extremetortoise/, and
6 https://aruzegaming.com/g-series/extreme-tortoise/, and videos depicting aspects of their
7 operation can be found at the same websites.
8 Feature Rush Family:
9 85. AGA offers for sale as one of its products the “Feature Rush” family of slot machine
10 games (hereinafter “FEATURE RUSH FAMILY”). AGA’s FEATURE RUSH FAMILY of slot
11 machine games includes at least the games “FEATURE RUSH ANUBIS” and “FEATURE RUSH
12 HORUS.” AGA’s FEATURE RUSH FAMILY of slot machine games are described and offered for
13 sale at, for example, AGA’s website at https://aruzegaming.com/cube-x-video/feature-rush-anubis/
14 and https://aruzegaming.com/cube-x-video/feature-rush-horus/, and videos depicting aspects of
15 their operation can be found at the same websites.
16 Fu Lu Shou:
17 86. AGA offers for sale as one of its products the “Fu Lu Shou” slot machine game
18 (hereinafter “FU LU SHOU”). AGA’s FU LU SHOU slot machine game is described and offered
19 for sale at, for example, AGA’s website at https://aruzegaming.com/innovator/fu-lu-shou/, and a
20 video depicting aspects of its operation can be found at the same website.
21 God Family:
22 87. AGA offers for sale as one of its products the “God” family of slot machine games
23 (hereinafter “GOD FAMILY”). AGA’s GOD FAMILY of slot machine games includes at least the
24 games “GOD OF ATLANTIS” and “GOD OF THE HEAVENS.” AGA’s GOD FAMILY of slot
25 machine games are described and offered for sale at, for example, AGA’s website
26 https://aruzegaming.com/cube-x-video/god-of-atlantis/ and https://aruzegaming.com/cube-x-
27 video/god-of-the-heavens/, and videos depicting aspects of their operation can be found at the same
28 websites.
26
1 Goddesses Family:
2 88. AGA offered for sale as one of its products the “Goddesses” family of slot machine
3 games (hereinafter “GODDESSES FAMILY”). AGA’s GODDESSES FAMILY of slot machine

4 games includes at least the games “GODDESSES HERA,” “GODDESSES ATHENA” and
5 “GODDESSES APHRODITE.” The GODDESSES FAMILY of slot machine games were
6 described and offered for sale at, for example, AGA’s website https://www.aruzegaming.com/, and
7 a video depicting aspects of the operation of the GODDESS HERA game, for example, can still be
8 found at https://vimeo.com/131484100/ on the Aruze Gaming Group channel.
9 Golden Family:
10 89. AGA offers for sale as one of its products the “Golden” family of slot machine
11 games (hereinafter “GOLDEN FAMILY”). AGA’s GOLDEN FAMILY of slot machine games
12 includes at least the games “GOLDEN CLUB,” “GOLDEN DIAMOND,” “GOLDEN HEART,”
13 and “GOLDEN SPADE.” Each game of the GOLDEN FAMILY of slot machine games has a
14 Cube-X and a G-Series version. AGA’s GOLDEN FAMILY games are described and offered for
15 sale at, for example, AGA’s website at
16 https://aruzegaming.com/cube-x-video/golden-club-apx/,
17 https://aruzegaming.com/g-series/golden-club-ap7/,
18 https://aruzegaming.com/cube-x-video/golden-diamond/,
19 https://aruzegaming.com/g-series/golden-diamond-ap7/,
20 https://aruzegaming.com/cube-x-video/golden-heart/,
21 https://aruzegaming.com/g-series/golden-heart/,
22 https://aruzegaming.com/cube-x-video/golden-spade-apx/, and
23 https://aruzegaming.com/g-series/golden-spade-ap7/, and videos depicting aspects of their
25 Jin II Family:
26 90. AGA offers for sale as one of its products the “Jin II” family of slot machine games
27 (hereinafter “JIN II FAMILY”). AGA’s JIN II FAMILY of slot machine games includes at least the
28 games “FU JIN II” and “RAI JIN II.” AGA’s JIN II FAMILY of slot machine games are described
27
1 and offered for sale at, for example, AGA’s website at https://aruzegaming.com/cube-x-video/fu-
2 jin-ii/ and https://aruzegaming.com/cube-x-video/rai-jin-ii/, and videos depicting aspects of their

4 Jungle Cash Ultra Stack Family:
5 91. AGA offers for sale as one of its products the “Jungle Cash Ultra Stack” family of
6 slot machine games (hereinafter “JUNGLE CASH ULTRA STACK FAMILY”). AGA’s JUNGLE
7 CASH ULTRA STACK FAMILY of slot machine games includes at least the games “JUNGLE
8 CASH ULTRA STACK BEAUTY IN THE WILD,” “JUNGLE CASH ULTRA STACK BIG 5,”
9 “JUNGLE CASH ULTRA STACK FEATURE BUTTERFLY,” and “JUNGLE CASH ULTRA
10 STACK FEATURE PANDA.” AGA’s JUNGLE CASH ULTRA STACK FAMILY of slot
11 machine games are described and offered for sale at, for example, AGA’s website at
12 https://aruzegaming.com/cube-x-video/jungle-cash-ultra-stack-beauty-wild/,
13 https://aruzegaming.com/cube-x-video/jungle-cash-ultra-stack-big-5/,
14 https://aruzegaming.com/cube-x-video/jungle-cash-ultra-stack-feature-butterfly/, and
15 https://aruzegaming.com/cube-x-video/jungle-cash-ultra-stack-feature-panda/, and videos
16 depicting aspects of their operation can be found at the same websites.
17 Master of Wealth:
18 92. AGA offers for sale as one of its products the “Master of Wealth” slot machine game
19 (hereinafter “MASTER OF WEALTH”). AGA’s MASTER OF WEALTH is described and offered
20 for sale at, for example, AGA’s website at https://aruzegaming.com/g-series/master-of-wealth/, and
21 a video depicting aspects of its operation can be found at the same website.
22 Moonlight Owl:
23 93. AGA offers for sale as one of its products the “Moonlight Owl” slot machine game
24 (hereinafter “MOONLIGHT OWL”). AGA’s MOONLIGHT OWL slot machine game is described
25 and offered for sale at, for example, AGA’s website at https://aruzegaming.com/g-series/moonlight-
26 owl/, and a video depicting aspects of its operation can be found at the same website.
27
28
28
1 Platinum Jackpot:
2 94. AGA offers for sale as one of its products the “Platinum Jackpot” slot machine game
3 (hereinafter “PLATINUM JACKPOT”). AGA’s PLATINUM JACKPOT slot machine game is

4 described and offered for sale at, for example, AGA’s website at
5 https://aruzegaming.com/innovator-deluxe/platinum-jackpot/, and a video depicting aspects of its
7 Rainbow Cash Ultra Stack Feature Family:
8 95. AGA offers for sale as one of its products the “Rainbow Cash Ultra Stack Feature”
9 family of slot machine games (hereinafter “RAINBOW CASH ULTRA STACK FEATURE
10 FAMILY”). AGA’s RAINBOW CASH ULTRA STACK FEATURE FAMILY of slot machine
11 games includes at least the games “RAINBOW CASH ULTRA STACK FEATURE BLOSSOM,”
12 “RAINBOW CASH ULTRA STACK FEATURE BUTTERFLY,” “RAINBOW CASH ULTRA
13 STACK FEATURE ROSE,” and “RAINBOW CASH ULTRA STACK FEATURE SPRING.”
14 AGA’s RAINBOW CASH ULTRA STACK FEATURE FAMILY of slot machines games are
15 described and offered for sale at, for example, AGA’s website at
16 https://aruzegaming.com/cube-x-video/rainbow-cash-ultra-stack-feature-blossom/,
17 https://aruzegaming.com/cube-x-video/rainbow-cash-ultra-stack-feature-butterfly/,
18 https://aruzegaming.com/cube-x-video/rainbow-cash-ultra-stack-feature-rose/, and
19 https://aruzegaming.com/cube-x-video/rainbow-cash-ultra-stack-feature-spring/, and videos
20 depicting aspects of their operation can be found at the same websites.
21 Rapid Shot Family:
22 96. AGA offers for sale as one of its products the “Rapid Shot” family of slot machine
23 games (hereinafter “RAPID SHOT FAMILY”). AGA’s RAPID SHOT FAMILY of slot machine
24 games includes at least the games “RAPID SHOT DIAMOND,” “RAPID SHOT RUBY,” and
25 “RAPID SHOT SAPPHIRE.” The RAPID SHOT FAMILY of slot machine games are described
26 and offered for sale at, for example, AGA’s website at https://aruzegaming.com/innovator/rapid-
27 shot/, and a video depicting aspects of their operation can be found at the website.
28
29
1 Shen Long Fever:

2 97. AGA offers for sale as one of its products the “Shen Long Fever” slot machine game
3 (hereinafter “SHEN LONG FEVER”). AGA’s SHEN LONG FEVER slot machine game is
4 described and offered for sale at, for example, AGA’s website at https://aruzegaming.com/g-
5 deluxe/shen-long-fever/, and a video depicting aspects of its operation can be found at the same
6 website.
7 Sinbad:
8 98. AGA offers for sale as one of its products the “Sinbad” slot machine game
9 (hereinafter “SINBAD”). AGA’s SINBAD slot machine game is described and offered for sale at,
10 for example, AGA’s website at https://aruzegaming.com/g-link/sinbad/, and a video depicting
11 aspects of its operation can be found at the same website.
12 Spirit Family:
13 99. AGA offers for sale as one of its products the “Spirit” family of slot machine games
14 (hereinafter “SPIRIT FAMILY”). AGA’s SPIRIT FAMILY of slot machine games includes at least
15 the games “AZTEC SPIRIT,” “DANCING DRAGON SPIRIT,” and “PANDA SPIRIT.” AGA’s
16 SPIRIT FAMILY of slot machine games are described and offered for sale at, for example, AGA’s
17 website at
18 https://aruzegaming.com/innovator/aztec-spirit/,
19 https://aruzegaming.com/cube-x-innovator/dancing-dragon-spirit/, and
20 https://aruzegaming.com/innovator/panda-spirit/, and videos depicting aspects of their
22 Stackin’ Wealth:
23 100. AGA offers for sale as one of its products the “Stackin’ Wealth” slot machine game
24 (hereinafter “STACKIN’ WEALTH”). AGA’s STACKIN’ WEALTH slot machine game is
25 described and offered for sale at, for example, AGA’s website at https://aruzegaming.com/g-
26 series/stackin-wealth/, and a video depicting aspects of its operation can be found at the same
27 website.
28
30
1 Streaking Family:
2 101. AGA offers for sale as one of its products the “Streaking” family of slot machine
3 games (hereinafter “STREAKING FAMILY”). AGA’s STREAKING FAMILY of slot machine

4 games includes at least the games “STREAKING BEAST TIGER” and “STREAKING
5 DRAGON.” AGA’s STREAKING FAMILY of slot machine games includes Cube-X and G-Series
6 versions. AGA’s STREAKING FAMILY of slot machine games are described and offered for sale
7 at, for example, AGA’s website at
8 https://aruzegaming.com/cube-x-video/streaking-beast-tiger-apx/,
9 https://aruzegaming.com/g-series/streaking-beast-tiger/,
10 https://aruzegaming.com/cube-x-video/streaking-dragon-apx/, and
11 https://aruzegaming.com/g-series/streaking-dragon/, and videos depicting aspects of their
13 Tower Stack Family:
14 102. AGA offers for sale as one of its products the “Tower Stack” family of slot machine
15 games (hereinafter “TOWER STACK FAMILY”). AGA’s “TOWER STACK FEATURE PANDA
16 (CUBE-X VERTICAL),” “TOWER STACK FEATURE PANDA (CUBE-X VERTICAL 80),”
17 “TOWER STACK FEATURE ROSE (CUBE-X VERTICAL),” and “TOWER STACK FEATURE
18 ROSE (CUBE-X VERTICAL 80)” are described and offered for sale at, for example, AGA’s
19 website at
20 https://aruzegaming.com/cube-x-vertical/tower-stack-feature-panda/,
21 https://aruzegaming.com/cube-x-vertical-80/tower-stack-feature-panda/,
22 https://aruzegaming.com/cube-x-vertical/tower-stack-feature-rose/, and
23 https://aruzegaming.com/cube-x-vertical-80/tower-stack-feature-rose/, and videos depicting
24 aspects of their operation can be found at the same websites.
25 Ultimate Diamond:
26 103. AGA offers for sale as one of its products the “Ultimate Diamond” slot machine
27 game (hereinafter “ULTIMATE DIAMOND”). AGA’s ULTIMATE DIAMOND slot machine
28 game is described and offered for sale at, for example, AGA’s website at
31
1 https://aruzegaming.com/innovator-deluxe/ultimate-diamond/, and a video depicting aspects of its

3 Ultimate Eruption:
4 104. AGA offers for sale as one of its products the “Ultimate Eruption” slot machine
5 game (hereinafter “ULTIMATE ERUPTION”). AGA’s ULTIMATE ERUPTION is described and
6 offered for sale at, for example, AGA’s website at https://aruzegaming.com/cube-x-vertical-
7 80/ultimate-eruption/, and a video depicting aspects of its operation can be found at the same
8 website.
9 Ultra Slide Ryuko:
10 105. AGA offers for sale as one of its products the “Ultra Slide Ryuko” slot machine
11 game (hereinafter “ULTRA SLIDE RYUKO”). AGA’s ULTRA SLIDE RYUKO slot machine
12 game is described and offered for sale at, for example, AGA’s website at
13 https://aruzegaming.com/g-series/ultra-slide-ryuko/, and a video depicting aspects of its operation
14 can be found at the website.
15 Ultra Stack Feature Family:
16 106. AGA offers for sale as one of its products the “Ultra Stack Feature” family of slot
17 machine games (hereinafter “ULTRA STACK FEATURE FAMILY”). AGA’s ULTRA STACK
18 FEATURE FAMILY of slot machine games includes at least the games “ULTRA STACK
19 FEATURE AFRICA (CUBE-X),” “ULTRA STACK FEATURE AFRICA (G-SERIES),” “ULTRA
20 STACK FEATURE BUTTERFLY (G-SERIES),” “ULTRA STACK FEATURE PANDA (CUBE-
21 X),” “ULTRA STACK FEATURE PANDA (G-SERIES),” “ULTRA STACK FEATURE ROSE
22 (CUBE-X),” “ULTRA STACK FEATURE ROSE (G-SERIES),” and “ULTRA STACK
23 FEATURE TIKI (G-SERIES).” The ULTRA STACK FEATURE FAMILY of slot machine games
24 are described and offered for sale at, for example, AGA’s website at
25 https://aruzegaming.com/cube-x-video/ultra-stack-feature-africa-cube-x/,
26 https://aruzegaming.com/g-series/ultra-stack-feature-africa/,
27 https://aruzegaming.com/g-series/ultra-stack-feature-butterfly/,
28 https://aruzegaming.com/cube-x-video/ultra-stack-feature-panda/,
32
1 https://aruzegaming.com/g-series/ultra-stack-feature/,
2 https://aruzegaming.com/cube-x-video/ultra-stack-feature-rose-cube-x/,
3 https://aruzegaming.com/g-series/ultra-stack-feature-rose/, and
4 https://aruzegaming.com/g-series/ultra-stack-feature-tiki/, and videos depicting aspects of
5 their respective operations can be found at the same websites.
6 Ultra Stack Poseidon Family:
7 107. AGA offers for sale as one of its products the “Ultra Stack Poseidon” family of slot
8 machine games (hereinafter “ULTRA STACK POSEIDON FAMILY”). AGA’s ULTRA STACK
9 POSEIDON FAMILY of slot machine games includes at least the games “ULTRA STACK
10 POSEIDON (CUBE-X VIDEO)” and “ULTRA STACK POSEIDON (G-SERIES).” The ULTRA
11 STACK POSEIDON FAMILY of slot machine games are described and offered for sale at, for
12 example, AGA’s website at https://aruzegaming.com/g-series/ultra-stack-poseidon/ and
13 https://aruzegaming.com/cube-x-video/ultra-stack-poseidon/, and videos depicting aspects of their
15 Vegas Cash Family:
16 108. AGA offers for sale as one of its products the “Vegas Cash” family of slot machine
17 games (hereinafter “VEGAS CASH FAMILY”). AGA’s VEGAS CASH FAMILY of slot machine
18 games includes at least the games “VEGAS CASH COCKTAIL GIRL” and “VEGAS CASH
19 SHOWGIRL.” The VEGAS CASH FAMILY of slot machine games are described and offered for
20 sale at, for example, AGA’s website at https://aruzegaming.com/g-series/vegas-cash-cocktail-girl/
21 and https://aruzegaming.com/g-series/vegas-cash-showgirl, and videos depicting aspects of their
22 respective operations can be found at the same websites.
23 109. Collectively, the INNOVATOR design, INNOVATOR DELUXE design, G-ENEX
24 design, G-SERIES DELUXE design, and G-LINK design products as well as at least the 100LINES
25 STACK FAMILY, 100LINES STACK FEATURE FAMILY, 4 CHINESE BEASTS, 500G
26 FAMILY, ALADDIN AND THE LAMP, ALIBABA, ANCIENT WHEEL FAMILY,
27 CANNONBALL FAMILY, COAT OF ARMS GRIFFIN, CYBER SEVEN, EXTREME FAMILY,
28 FEATURE RUSH FAMILY, FISHING FAMILY, FU LU SHOU, GOD FAMILY, GODDESSES
33
1 FAMILY, THE GOLD, GOLDEN FAMILY, GOLDEN FRONTIER, HAPPY FESTIVAL

2 FAMILY, IMPERIAL PHOENIX, JIN II FAMILY, JUNGLE CASH ULTRA STACK FAMILY,
3 MASTER OF WEALTH, MOONLIGHT OWL, PLATINUM JACKPOT, RAINBOW CASH

4 ULTRA STACK FEATURE FAMILY, RAPID SHOT FAMILY, RED DICE WILD FAMILY,
5 SHEN LONG FEVER, SINBAD, SPIRIT FAMILY, STACKIN’ MYSTERY CRYSTAL
6 BEAUTY, STACKIN’ WEALTH, STREAKING FAMILY, TOWER STACK FAMILY,
7 ULTIMATE DIAMOND, ULTIMATE ERUPTION, ULTRA SLIDE RYUKO, ULTRA STACK
8 FAMILY, ULTRA STACK FEATURE FAMILY, ULTRA STACK POSEIDON FAMILY,
9 ULTRA STACK SHOW GIRLS, and VEGAS CASH FAMILY slot machine game products as
10 well as other slot machine games exhibiting features similar thereto as described below constitute
11 the “Accused Products” and infringe one or more claims of the Asserted Patents as set forth herein.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
34
1 COUNT ONE
2 (Infringement of the ’200 patent – AGA)
3 110. UEC repeats and re-alleges, as if fully set forth herein, the allegations contained in
4 all the preceding paragraphs ¶¶ 1 – 109.
5 111. Representative images showing application of the claimed design or a colorable
6 imitation thereof to the INNOVATOR, the INNOVATOR DELUXE, the G-ENEX, G-LINK
7 SERIES and the G-SERIES DELUXE designs are provided below:
8
9
10
11
12 INNOVATOR (relevant portion)
13
14
15
16
17 INNOVATOR DELUXE (relevant portion)
18
19
20
21
22 G-ENEX (relevant portion)
23
24
25
26 Fig. 1 of the ’200 patent
27
28
35
1
2
3
4
5 G-SERIES DELUXE (relevant portion)
6
7
8
9
10
11 G-LINK (relevant portion)
12
13
14
15
16
17
18
19 Fig. 1 of the ’200 patent
20 112. AGA has infringed and continues to infringe the claimed design of the ’200 patent
21 by manufacturing, providing, selling, offering to sell, importing and/or distributing without
22 authority, several infringing slot machines or components thereof, as well as other similar design
23 variations, including without limitation the INNOVATOR, the INNOVATOR DELUXE, the G-
24 ENEX, G-ENEX, and the G-LINK designs.
25 113. Moreover, on information and belief, AGA has induced, and is inducing, the
26 infringement of the claim of the ’200 patent. On information and belief, the direct infringement
27 induced by AGA includes at least the unlicensed use by gaming establishments of the
28 INNOVATOR, the INNOVATOR, the G-ENEX, the G-SERIES DELUXE, and the G-LINK
36
1 designs. On information and belief, AGA has the specific intent to encourage or direct the gaming
2 establishments to infringe the ’200 patent by at least using a product to which the design claimed in
3 the ’200 patent is applied or any colorable imitation thereof. AGA induces these users to use the
4 INNOVATOR, the INNOVATOR DELUXE, the G-ENEX, and the G-SERIES DELUXE, and the
5 G-LINK designs knowing that these acts constitute infringement of the ’200 patent and with
6 specific intent to encourage those acts and encourage infringement.
7
8 COUNT TWO
12 115. Representative images showing application of the claimed design or a colorable
13 imitation thereof to the INNOVATOR and the G-ENEX designs are provided below:
14
15
16
17
18
19
20
21
22
23 INNOVATOR Fig. 1 of the ’201 patent G-ENEX
24 116. AGA has infringed and continues to infringe the claimed design of the ’201 patent
25 by manufacturing, providing, selling, offering to sell, importing and/or distributing without
26 authority, several infringing slot machines or components thereof, as well as other similar design
27 variations, including without limitation the INNOVATOR and the G-ENEX designs.
28
37
2 infringement of the claim of the ’201 patent. On information and belief, the direct infringement
3 induced by AGA includes at least the unlicensed use by gaming establishments of the
4 INNOVATOR and the G-ENEX designs. On information and belief, AGA has the specific intent to
5 encourage or direct the gaming establishments to infringe the ’201 patent by at least using a product
6 to which the design claimed in the ’200 patent is applied or any colorable imitation thereof. AGA
7 induces these users to use the INNOVATOR and the G-ENEX designs knowing that these acts
8 constitute infringement of the ’201 patent and with specific intent to encourage those acts and
9 encourage infringement.
10
11 COUNT THREE
15 119. On information and belief, AGA has infringed and continues to infringe, either
16 literally or under the doctrine of equivalents, at least claim 1 of the ’582 patent by manufacturing,
17 providing, selling, offering to sell, importing and/or distributing without authority, the infringing
18 slot machines, including without limitation the COAT OF ARMS GRIFFIN (Exhibit 19),
19 FEATURE RUSH ANUBIS (Exhibit 20), FU LU SHOU (Exhibit 21), JUNGLE CASH ULTRA
20 STACK BEAUTY IN THE WILD (Exhibit 22), STACKIN’ WEALTH (Exhibit 23), STREAKING
21 DRAGON (CUBE-X) and STREAKING DRAGON (G-SERIES) (collectively, Exhibit 24), and
22 ULTRA STACK POSEIDON FAMILY (Exhibit 25) slot machine games, as described in the claim
23 charts attached hereto as Exhibits 19-25 as well as slot machine games exhibiting similar features,
24 including at least FEATURE STREAK DRAGON and WHEELS GO ROUND BULL.
26 infringement of the claims of the ’582 patent (for example, claim 1). On information and belief, the
27 direct infringement induced by AGA includes at least the unlicensed operation by gaming
28 establishments, and their customers, of the COAT OF ARMS GRIFFIN, FEATURE RUSH
38
1 ANUBIS, FU LU SHOU, JUNGLE CASH ULTRA STACK BEAUTY IN THE WILD,

2 STACKIN’ WEALTH, STREAKING DRAGON (CUBE-X) and STREAKING DRAGON (G-
3 SERIES), and ULTRA STACK POSEIDON FAMILY and slot machine games exhibiting similar
4 features. On information and belief, AGA has the specific intent to encourage or direct the end
5 users to infringe the ’582 patent by practicing all the limitations of at least one claim of the ’582
6 patent. AGA induces these users to operate the COAT OF ARMS GRIFFIN, FEATURE RUSH
7 ANUBIS, FU LU SHOU, JUNGLE CASH ULTRA STACK BEAUTY IN THE WILD,
8 STACKIN’ WEALTH, STREAKING DRAGON (CUBE-X) and STREAKING DRAGON (G-
9 SERIES), ULTRA STACK POSEIDON FAMILY and slot machine games exhibiting similar
10 features knowing that these acts constitute infringement of the ’582 patent and with specific intent
11 to encourage those acts and encourage infringement.
12 121. Further, on information and belief, AGA has contributed to, and is contributing to,
13 the infringement of the claims of the ’582 patent (for example, claim 1). On information and belief,
14 the direct infringement contributed to by AGA includes at least the unlicensed operation by gaming
15 establishments, and their customers, of the FU LU SHOU slot machine game. On information and
16 belief, AGA with knowledge and without authorization provides the FU LU SHOU slot machine
17 game as a unit and/or as one or more components including replacement parts or to be assembled.
18 The FU LU SHOU slot machine game is a dedicated slot machine game, with one or more
19 components being specifically adapted, shaped and/or fitted, including at least the reel wheels, for
20 such slot machine games, which infringe claims of the ’582 patent. These non-interchangeable,
21 discrete, specially designed and engineered components, including at least the reel wheels,
22 constitute a material part of the claimed invention, with AGA knowing that at least the reel wheels
23 are made and/or especially adapted for use in an infringement of the patent. Accordingly, the one or
24 more non-interchangeable, discrete, specially designed and engineered components, including at
25 least the reel wheels, are not staple articles of commerce, commodities or commonly available items
26 and have no substantial non-infringing uses other than as a component of the infringing FU LU
27 SHOU, and AGA has provided these non-interchangeable, discrete, specially designed and
28 engineered components, including at least the reel wheels with this knowledge.
39
1 COUNT FOUR
8 slot machines, including without limitation the 100LINES STACK FEATURE FAMILY (Exhibit
9 26), 500G FAMILY (Exhibit 27), ANCIENT WHEEL BIG 5 and ANCIENT WHEEL PANDA
10 (collectively, Exhibit 28), GOD FAMILY (Exhibit 29), JIN II FAMILY (Exhibit 30), JUNGLE
11 CASH ULTRA STACK BIG 5, JUNGLE CASH ULTRA STACK FEATURE BUTTERFLY, and
12 JUNGLE CASH ULTRA STACK FEATURE PANDA (collectively, Exhibit 31), MOONLIGHT
13 OWL (Exhibit 32), RAINBOW CASH ULTRA STACK FEATURE FAMILY (Exhibit 33),
14 SPIRIT FAMILY (Exhibit 34), TOWER STACK FEATURE PANDA (CUBE-X VERTICAL),
15 TOWER STACK FEATURE PANDA (CUBE-X VERTICAL 80), TOWER STACK FEATURE
16 ROSE (CUBE-X VERTICAL), and TOWER STACK FEATURE ROSE (CUBE-X VERTICAL
17 80) (collectively, Exhibit 35), and ULTRA STACK FEATURE FAMILY (Exhibit 36) slot machine
18 games, as described in the claim charts attached hereto as Exhibits 26-36 as well as slot machine
19 games exhibiting similar features, including at least RAINBOW WHEEL LEPRECHAUN,
20 RAINBOW WHEEL BLOSSOM and WHEELS GO ROUND ORB LEGEND.
24 establishments, and their customers, of the 100LINES STACK FEATURE FAMILY, 500G
25 FAMILY, ANCIENT WHEEL BIG 5, ANCIENT WHEEL PANDA, GOD FAMILY, JIN II
26 FAMILY, JUNGLE CASH ULTRA STACK BIG 5, JUNGLE CASH ULTRA STACK FEATURE
27 BUTTERFLY, JUNGLE CASH ULTRA STACK FEATURE PANDA, MOONLIGHT OWL,
28 RAINBOW CASH ULTRA STACK FEATURE FAMILY, SPIRIT FAMILY, TOWER STACK
40
1 FEATURE PANDA (CUBE-X VERTICAL), TOWER STACK FEATURE PANDA (CUBE-X

2 VERTICAL 80), TOWER STACK FEATURE ROSE (CUBE-X VERTICAL), TOWER STACK
3 FEATURE ROSE (CUBE-X VERTICAL 80), ULTRA STACK FEATURE FAMILY and slot
4 machine games exhibiting similar features. On information and belief, AGA has the specific intent
5 to encourage or direct the end users to infringe the ’790 patent by practicing all the limitations of at
6 least one claim of the ’790 patent. AGA induces these users to operate the 100LINES STACK
7 FEATURE FAMILY, 500G FAMILY, ANCIENT WHEEL BIG 5, ANCIENT WHEEL PANDA,
8 GOD FAMILY, JIN II FAMILY, JUNGLE CASH ULTRA STACK BIG 5, JUNGLE CASH
9 ULTRA STACK FEATURE BUTTERFLY, JUNGLE CASH ULTRA STACK FEATURE
10 PANDA, MOONLIGHT OWL, RAINBOW CASH ULTRA STACK FEATURE FAMILY,
11 SPIRIT FAMILY, TOWER STACK FEATURE PANDA (CUBE-X VERTICAL), TOWER
12 STACK FEATURE PANDA (CUBE-X VERTICAL 80), TOWER STACK FEATURE ROSE
13 (CUBE-X VERTICAL), TOWER STACK FEATURE ROSE (CUBE-X VERTICAL 80), ULTRA
14 STACK FEATURE FAMILY and slot machine games exhibiting similar features knowing that
15 these acts constitute infringement of the ’790 patent and with specific intent to encourage those acts
16 and encourage infringement.
20 establishments, and their customers, of the SPIRIT FAMILY slot machine games. On information
21 and belief, AGA with knowledge and without authorization provides the SPIRIT FAMILY slot
22 machine games as a unit and/or as one or more components including replacement parts or to be
23 assembled. The SPIRIT FAMILY slot machine games are dedicated slot machine games, with one
24 or more components being specifically adapted, shaped and/or fitted, including at least the reel
25 wheels, for such slot machine games, which infringe claims of the ’790 patent. These non-
26 interchangeable, discrete, specially designed and engineered components, including at least the reel
27 wheels, constitute a material part of the claimed invention, with AGA knowing that at least the reel
28 wheels are made and/or especially adapted for use in an infringement of the patent. Accordingly,
41
1 the one or more non-interchangeable, discrete, specially designed and engineered components,
2 including at least the reel wheels, are not staple articles of commerce, commodities or commonly
3 available items and have no substantial non-infringing uses other than as a component of the
4 infringing SPIRIT FAMILY slot machine games and AGA has provided these non-interchangeable,
5 discrete, specially designed and engineered components, including at least the reel wheels with this
6 knowledge.
7
8 COUNT FIVE
15 slot machines, including without limitation, the EXTREME FAMILY (Exhibit 37), GOD FAMILY
16 (Exhibit 38), GOLDEN FAMILY (Exhibit 39), MASTER OF WEALTH (Exhibit 40), SHEN
17 LONG FEVER (Exhibit 41), SINBAD (Exhibit 42), ULTIMATE ERUPTION (Exhibit 43), and
18 VEGAS CASH FAMILY (Exhibit 44) slot machine games, as described in the claim charts
19 attached hereto as Exhibits 37-44 as well as slot machine games exhibiting similar features,
20 including at least FEATURE STREAK DRAGON.
24 establishments, and their customers, of the EXTREME FAMILY, GOD FAMILY, GOLDEN
25 FAMILY, MASTER OF WEALTH, SHEN LONG FEVER, SINBAD, ULTIMATE ERUPTION,
26 VEGAS CASH FAMILY and slot machine games exhibiting similar features. On information and
27 belief, AGA has the specific intent to encourage or direct the end users to infringe the ’479 patent
28 by practicing all the limitations of at least one claim of the ’479 patent. AGA induces these users to
42
1 operate the EXTREME FAMILY, GOD FAMILY, GOLDEN FAMILY, MASTER OF WEALTH,
2 SHEN LONG FEVER, SINBAD, ULTIMATE ERUPTION, VEGAS CASH FAMILY and slot
3 machine games exhibiting similar features knowing that these acts constitute infringement of the
4 ’479 patent and with specific intent to encourage those acts and encourage infringement.
5
6 COUNT SIX
9 all the preceding paragraphs, ¶¶ 1 – 128.
12 providing, selling, offering to sell, importing and/or distributing without authority, several
13 infringing slot machines, including without limitation the GODDESSES FAMILY of slot machine
14 games, as described in the claim chart attached hereto as Exhibit 45 as well as slot machine games
15 exhibiting similar features.
19 establishments, and their customers, of the GODDESSES FAMILY of slot machine games and slot
20 machine games exhibiting similar features. On information and belief, AGA has the specific intent
21 to encourage or direct the end users to infringe the ’656 patent by practicing all the limitations of at
22 least one claim of the ’656 patent. AGA induces these users to operate the GODDESSES FAMILY
23 of slot machine games and slot machine games exhibiting similar features knowing that these acts
26
27
28
43
1 COUNT SEVEN
6 literally or under the doctrine of equivalents, at least claim 1 and/or claim 2 of the ’816 patent by
7 manufacturing, providing, selling, offering to sell, importing and/or distributing without authority,
8 several infringing slot machines, including without limitation the JIN II FAMILY (Exhibit 46),
9 SHEN LONG FEVER (Exhibit 47), ULTRA SLIDE RYUKO (Exhibit 48), and ULTRA STACK
10 FEATURE AFRICA (CUBE-X) and ULTRA STACK FEATURE AFRICA (G-SERIES)
11 (collectively, Exhibit 49) slot machine games, as described in the claim charts attached hereto as
12 Exhibits 46-49 as well as slot machine games exhibiting similar features.
14 infringement of the claims of the ’816 patent (for example, claim 1 and/or claim 2). On information
15 and belief, the direct infringement induced by AGA includes at least the unlicensed operation by
16 gaming establishments, and their customers, of the JIN II FAMILY, SHEN LONG FEVER,
17 ULTRA SLIDE RYUKO, ULTRA STACK FEATURE AFRICA (CUBE-X), ULTRA STACK
18 FEATURE AFRICA (G-SERIES) and slot machine games exhibiting similar features. On
19 information and belief, AGA has the specific intent to encourage or direct the end users to infringe
20 the ’816 patent by practicing all the limitations of at least one claim of the ’816 patent. AGA
21 induces these users to operate the JIN II FAMILY, SHEN LONG FEVER, ULTRA SLIDE
22 RYUKO, ULTRA STACK FEATURE AFRICA (CUBE-X), ULTRA STACK FEATURE
23 AFRICA (G-SERIES) and slot machine games exhibiting similar features knowing that these acts
26
27
28
44
1 COUNT EIGHT
2 (Infringement of the ’767 patent)
8 slot machines, including without limitation the ALIBABA (Exhibit 50), CYBER SEVEN (Exhibit
9 51), FU LU SHOU (Exhibit 52), PLATINUM JACKPOT (Exhibit 53), RAPID SHOT FAMILY
10 (Exhibit 54), and ULTIMATE DIAMOND (Exhibit 55) slot machine games, as described in the
11 claim charts attached hereto as Exhibits 50-55 as well as slot machine games exhibiting similar
12 features.
16 establishments, and their customers, of the ALIBABA, CYBER SEVEN, FU LU SHOU,
17 PLATINUM JACKPOT, RAPID SHOT FAMILY, ULTIMATE DIAMOND and slot machine
18 games exhibiting similar features. On information and belief, AGA has the specific intent to
19 encourage or direct the end users to infringe the ’767 patent by practicing all the limitations of at
20 least one claim of the ’767 patent. AGA induces these users to operate the ALIBABA, CYBER
21 SEVEN, FU LU SHOU, PLATINUM JACKPOT, RAPID SHOT FAMILY, ULTIMATE
22 DIAMOND and slot machine games exhibiting similar features knowing that these acts constitute
23 infringement of the ’767 patent and with specific intent to encourage those acts and encourage
24 infringement.
28 establishments, and their customers, of the ALIBABA, CYBER SEVEN, FU LU SHOU,
45
2 games exhibiting similar features. On information and belief, AGA with knowledge and without
3 authorization provides the ALIBABA, CYBER SEVEN, FU LU SHOU, PLATINUM JACKPOT,

4 RAPID SHOT FAMILY, ULTIMATE DIAMOND and slot machine games exhibiting similar
5 features as a unit and/or as one or more components including replacement parts or to be
6 assembled. The ALIBABA, CYBER SEVEN, FU LU SHOU, PLATINUM JACKPOT, RAPID
7 SHOT FAMILY, ULTIMATE DIAMOND and slot machine games exhibiting similar features are
8 dedicated slot machine games, with one or more components being specifically adapted, shaped
9 and/or fitted, including at least the reel wheels, for such slot machine games, which infringe claims
10 of the ’767 patent. These non-interchangeable, discrete, specially designed and engineered
11 components, including at least the reel wheels, constitute a material part of the claimed invention,
12 with AGA knowing that at least the reel wheels are made and/or especially adapted for use in an
13 infringement of the patent. Accordingly, the one or more non-interchangeable, discrete, specially
14 designed and engineered components, including at least the reel wheels, are not staple articles of
15 commerce, commodities or commonly available items and have no substantial non-infringing uses
16 other than as a component of the infringing ALIBABA, CYBER SEVEN, FU LU SHOU,
18 games exhibiting similar features, and AGA has provided these non-interchangeable, discrete,
19 specially designed and engineered components, including at least the reel wheels with this
20 knowledge.
21
22 COUNT NINE
46
1 slot machines, including without limitation the ALIBABA (Exhibit 56), CYBER SEVEN (Exhibit
2 57), FU LU SHOU (Exhibit 58), PLATINUM JACKPOT (Exhibit 59), RAPID SHOT FAMILY
3 (Exhibit 60), and ULTIMATE DIAMOND (Exhibit 61) slot machine games, as described in the
4 claim charts attached hereto as Exhibits 56-61 as well as slot machine games exhibiting similar
5 features.
7 infringement of the claims of the ’808 patent (e.g., claim 14). On information and belief, the direct
8 infringement induced by AGA includes at least the unlicensed operation by gaming establishments,
9 and their customers, of the ALIBABA, CYBER SEVEN, FU LU SHOU, PLATINUM JACKPOT,
11 features. On information and belief, AGA has the specific intent to encourage or direct the end
12 users to infringe the ’808 patent by practicing all the limitations of at least one claim of the ’808
13 patent. AGA induces these users to operate the ALIBABA, CYBER SEVEN, FU LU SHOU,
15 games exhibiting similar features knowing that these acts constitute infringement of the ’808 patent
16 and with specific intent to encourage those acts and encourage infringement.
18 the infringement of the claims of the ’808 patent (for example, claim 14). On information and
19 belief, the direct infringement contributed to by AGA includes at least the unlicensed operation by
20 gaming establishments, and their customers, of the ALIBABA, CYBER SEVEN, FU LU SHOU,
22 games exhibiting similar features. On information and belief, AGA with knowledge and without
23 authorization provides the ALIBABA, CYBER SEVEN, FU LU SHOU, PLATINUM JACKPOT,
25 features as a unit and/or as one or more components including replacement parts or to be
26 assembled. The 4 ALIBABA, CYBER SEVEN, FU LU SHOU, PLATINUM JACKPOT, RAPID
27 SHOT FAMILY, ULTIMATE DIAMOND and slot machine games exhibiting similar features are
28 dedicated slot machine games, with one or more components being specifically adapted, shaped
47
1 and/or fitted, including at least the reel wheels, for such slot machine games, which infringe claims
2 of the ’808 patent. These non-interchangeable, discrete, specially designed and engineered
3 components, including at least the reel wheels, constitute a material part of the claimed invention,
4 with AGA knowing that at least the reel wheels are made and/or especially adapted for use in an
5 infringement of the patent. Accordingly, the one or more non-interchangeable, discrete, specially
6 designed and engineered components, including at least the reel wheels, are not staple articles of
7 commerce, commodities or commonly available items and have no substantial non-infringing uses
8 other than as a component of the ALIBABA, CYBER SEVEN, FU LU SHOU, PLATINUM
9 JACKPOT, RAPID SHOT FAMILY, ULTIMATE DIAMOND and slot machine games exhibiting
10 similar features, and AGA has provided these non-interchangeable, discrete, specially designed and
11 engineered components, including at least the reel wheels with this knowledge.
12
13 COUNT TEN
14 (Inducement of Patent Infringement – Okada)
15 143. UEC repeats and re-alleges, as if fully set forth herein, the allegations contain in all
16 the preceding paragraphs ¶¶ 1 through 142.
17 AGA’s Acts of Direct Infringement:
18 144. As alleged above, with respect to Counts One through Nine, Defendant AGA has
19 directly infringed the Asserted Patents by pursuant to 35 U.S.C. § 271(a) at least by manufacturing,
20 selling and offerings for sale the Accused Products.
21 Okada Directed and Controlled AGA’s Acts of Infringement:
22 145. This additional transfer process began in 2009 and was completed such that AGA
23 ceased to operate as a UEC subsidiary in 2009.
24 146. Upon information and belief, Okada is the sole shareholder of AGA, as well as a
25 director of AGA and makes all of AGA’s important business decisions.
26 147. Specifically, upon information and belief, Okada directed employees of AGA located
27 in Nevada to develop and produce the Accused Products, which made use of the technology claimed
28
48
1 in the Asserted Patents, without obtaining a license or permission from UEC, and thereby infringing
2 the Asserted Patents.
3 148. Further, upon information and belief, Okada directs AGA employees and their
4 activities involving the design, manufacture and/or sale of infringing game machines.
5 149. Okada is personally licensed by the Nevada Gaming Commission.
6 Okada Was Aware of the UEC Asserted Patents and that AGA Would Infringe:
7 150. Okada was aware of the Asserted Patents and knew that AGA’s manufacture, sale and
8 offers for sale of the Accused Products would constitute infringement of the Asserted Patents or,
9 alternatively, believed that there was a high probability that AGA’s manufacture, sale and offers for
10 sale of the Accused Products would constitute infringement of the Asserted Patents and took
11 deliberate steps to avoid learning of that infringement.
12 151. Okada was the founder of UEC and served as “Representative Director” from June
13 1972 to September 2004. Under Japanese law, Representative Director is generally equivalent to
14 Chief Executive Officer. From January 2006 until June 2017, Okada was a Director and Chairman of
15 the Board of Directors for UEC.
16 152. In approximately July 2010, Okada, who was the Chairman of the Board of Directors,
17 was placed in charge of UEC’s foreign business, including the United States. This included Okada
18 being placed in charge of the foreign (United States) activities of UEC’s patent department.
19 Accordingly, Okada had supervising authority and management responsibility over UEC’s portfolio
20 of U.S. patents, including the Asserted Patents since at least as early as July 2010 until his removal as
21 Chairman of the UEC Board in June of 2017. However, because Okada owned and controlled AGA,
22 Okada needed to seek and receive the permission of UEC’s Board to grant his own company, AGA,
23 any rights to UEC patents.
24 153. Further, upon information and belief, Okada initially instructed AGA employees to
25 license the UEC patent rights necessary for AGA to continue manufacturing gaming devices.
26 154. Beginning in approximately March 2009, the General Manager of the UEC patent
27 department held discussions with AGA employees regarding a patent license agreement between
28 UEC and AGA, the license was to include the Asserted Patents. Okada, as Chairman of the Board of
49
1 Directors of UEC, wielded substantial influence and directly controlled the UEC Patent Department
2 and also knew that AGA would be transferred to his sole ownership and control.
3 155. As noted by Sam Basile, Executive Vice President and General Counsel to AGA in a
4 September 2010 email to Yoshiyuki Shoji of UEC: “the US and the Australian issued patents that
5 cover Rescue Spin/Rescue Pay are incorporated into every video and hybrid game that AGA
6 currently sells worldwide and is the basis of our defense to the Dynamite Gaming lawsuit in
7 Australia. Further, we still use transmissive reels for hybrid product currently in the field and in the
8 first version of Jackpot Battle Royal. Lastly, all AGA games incorporate patents that cover
9 anticipation sounds and excitement video graphics that are played and displayed on the last three
10 reels when at the first two reels contained feature symbols in a typical base game spin outcome.
11 Given that there are over 1200 patents and patent applications, I am certain that there are additional
12 patents that are incorporated into AGA’s games or gaming equipment but these few key examples
13 hopefully would be sufficient to demonstrate to Mr. Okada the need to grant AGA an exclusive
14 license to Universal’s patents.” (emphasis added)
15 156. Despite the explicit acknowledgement that AGA was using UEC’s patents without a
16 license, upon information and belief, Okada later instructed UEC’s patent department to cease all
17 discussions relating to the execution of a license agreement between UEC and AGA and not to seek
18 compensation from AGA for the use of any of UEC’s patents. Okada did not inform any of the other
19 members of the UEC Board of Directors Board of Directors for UEC of the failure of AGA to agree
20 to a license with UEC and never sought or obtained approval from the UEC Board of Directors to
21 grant any type of royalty-free license to AGA.
22 157. As a result, AGA has never executed a license agreement with UEC and AGA has
23 never paid any monetary consideration to UEC for use of any of UEC’s patent rights and, in
24 particular, never paid any monetary consideration to UEC for the use of the Asserted Patents.
25 158. Okada, based on the foregoing, has induced the infringement of the Asserted Patents
26 by AGA in violation of 35 U.S.C. § 271(b).
27 159. UEC has been damaged by Okada’s actions in an amount to be proven at trial.
28
50
1 PRAYER FOR RELIEF

2 WHEREFORE, Plaintiff respectfully requests that the Court:
3 A. Hold that AGA has directly infringed and indirectly infringed (through inducement
4 and contributory infringement) claims of the Asserted Patents, literally and/or under the doctrine of
5 equivalents pursuant to 35 U.S.C. § 271 and 35 U.S.C. § 289; hold that Okada has induced the
6 infringement of AGA pursuant to 35 U.S.C. § 271(b);
7 B. Preliminarily and permanently enjoin AGA as well as its respective agents, servants,
8 officers, directors (including Okada), employees and all persons acting in concert with them,
9 directly or indirectly, from infringing, inducing others to infringe, or contributing to the
10 infringement of the Asserted Patents pursuant to 35 U.S.C. § 283;
11 C. Order AGA and Okada to account for and pay to UEC the damages to which UEC is
12 entitled as a consequence of AGA’s infringement and Okada’s inducement of infringement of the
13 Asserted Patents and to which is available under 35 U.S.C. § 284;
14 D. Find that AGA’s infringement and Okada’s inducement of same is willful and
15 accordingly award UEC enhanced damages in accordance with 35 U.S.C. § 284;
16 E. Declare this case exceptional pursuant to 35 U.S.C. § 285 and award UEC its
17 reasonable attorneys’ fees and costs in this action;
18 F. Award to UEC its’ costs, expenses, disbursements, and attorneys’ fees incurred
19 herein;
20 G. Award to UEC pre-judgment and post-judgment interest on the foregoing amounts at
21 the maximum rate recoverable by law; and
22 H. Award to Plaintiff such other and further relief as the Court deems just and proper.
23
24
DEMAND FOR JURY TRIAL
25
Plaintiff demands trial by jury of all issues triable by a jury.
26
27
28
51
1 RESPECTFULLY SUBMITTED this 20th Day of September 2019.
2
Respectfully submitted,
3
5 /s/ Jay J. Schuttert

By:_________________________________
6 Jay J. Schuttert, Esq.
Nevada Bar No. 8656
7 David W. Gutke, Esq.
Nevada Bar No. 9820
8 EVANS FEARS & SCHUTTERT LLP
2300 West Sahara Avenue, Suite 950
9 Las Vegas, NV 89102
Telephone (702) 805-0290
10 Facsimile (702) 805-0291
Email: [email protected]
11 Email: [email protected]
12 ATTORNEYS FOR PLAINTIFF

UNIVERSAL ENTERTAINMENT
13 CORPORATION
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
52
Case 2:19-cv-01657 Document 1-1 Filed 09/20/19 Page 1 of 2
Universal Entertainment Corporation v. Aruze Gaming America

Exhibits List
Exhibit Description
No.
1 U.S. Patent No. D573,200 (the ’200 Patent)
2 Patent Prosecution History of ’200
3 U.S. Patent No. D573,201 (the ’201 Patent)
5 U.S. Patent No. 8,083,582 (the ’582 Patent)
15 U.S. Reissue Patent No. 46,767 (the ’767 Patent)
17 U.S. Reissue Patent No. 46,808 (the ’808 Patent)
19 ’582 Infringement Claim Chart: COAT OF ARMS GRIFFIN
20 ’582 Infringement Claim Chart: FEATURE RUSH ANUBIS
21 ’582 Infringement Claim Chart: FU LU SHOU
22 ’582 Infringement Claim Chart: JUNGLE CASH ULTRA STACK BEAUTY IN
THE WILD
23 ’582 Infringement Claim Chart: STACKIN’ WEALTH
24 ’582 Infringement Claim Chart: STREAKING FAMILY
25 ’582 Infringement Claim Chart: ULTRA STACK POSEIDON FAMILY
26 ’790 Infringement Claim Chart: 100LINES STACK FEATURE FAMILY
27 ’790 Infringement Claim Chart: 500G FAMILY
28 ’790 Infringement Claim Chart: ANCIENT WHEEL BIG 5 and ANCIENT
WHEEL PANDA
29 ’790 Infringement Claim Chart: GOD FAMILY
30 ’790 Infringement Claim Chart: JIN II FAMILY
31 ’790 Infringement Claim Chart: JUNGLE CASH ULTRA STACK FAMILY
32 ’790 Infringement Claim Chart: MOONLIGHT OWL
33 ’790 Infringement Claim Chart: RAINBOW CASH ULTRA STACK FEATURE
FAMILY
34 ’790 Infringement Claim Chart: SPIRIT FAMILY
35 ’790 Infringement Claim Chart: TOWER STACK FAMILY
36 ’790 Infringement Claim Chart: ULTRA STACK FEATURE FAMILY
37 ’479 Infringement Claim Chart: EXTREME FAMILY
38 ’479 Infringement Claim Chart: GOD FAMILY
39 ’479 Infringement Claim Chart: GOLDEN FAMILY
40 ’479 Infringement Claim Chart: MASTER OF WEALTH
Case 2:19-cv-01657 Document 1-1 Filed 09/20/19 Page 2 of 2
Exhibit Description
No.
41 ’479 Infringement Claim Chart: SHEN LONG FEVER
42 ’479 Infringement Claim Chart: SINBAD
43 ’479 Infringement Claim Chart: ULTIMATE ERUPTION
44 ’479 Infringement Claim Chart: VEGAS CASH FAMILY
45 ’656 Infringement Claim Chart: GODDESSES FAMILY
46 ’816 Infringement Claim Chart: JIN II FAMILY
47 ’816 Infringement Claim Chart: SHEN LONG FEVER
48 ’816 Infringement Claim Chart: ULTRA SLIDE RYUKO
49 ’816 Infringement Claim Chart: ULTRA STACK FEATURE AFRICA
50 ’767 Infringement Claim Chart: ALIBABA
51 ’767 Infringement Claim Chart: CYBER SEVEN
53 ’767 Infringement Claim Chart: PLATINUM JACKPOT
54 ’767 Infringement Claim Chart: RAPID SHOT FAMILY
55 ’767 Infringement Claim Chart: ULTIMATE DIAMOND
56 ’808 Infringement Claim Chart: ALIBABA
57 ’808 Infringement Claim Chart: CYBER SEVEN
59 ’808 Infringement Claim Chart: PLATINUM JACKPOT
60 ’808 Infringement Claim Chart: RAPID SHOT FAMILY
61 ’808 Infringement Claim Chart: ULTIMATE DIAMOND

Universal Ent. v. Aruze Gaming Am. - Complaint (Sans Exhibits)

Uploaded by

Copyright:

Available Formats

Universal Ent. v. Aruze Gaming Am. - Complaint (Sans Exhibits)

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Universal Ent. v. Aruze Gaming Am. - Complaint (Sans Exhibits)

Uploaded by

Copyright:

Available Formats

Case 2:19-cv-01657 Document 1 Filed 09/20/19 Page 1 of 52

1 Jay J. Schuttert, Esq.

16 UNIVERSAL ENTERTAINMENT CASE NO.:

1 PARTIES, JURISDICTION, AND VENUE

3 The ’200 Patent:

3 different.” ’582 patent, 1:47-55.

1 Ancient Wheel Family:

3 machine games (hereinafter “ANCIENT WHEEL FAMILY”). AGA’s ANCIENT WHEEL

3 games (hereinafter “GODDESSES FAMILY”). AGA’s GODDESSES FAMILY of slot machine

3 operation can be found at the same websites.

3 (hereinafter “PLATINUM JACKPOT”). AGA’s PLATINUM JACKPOT slot machine game is

1 Shen Long Fever:

3 games (hereinafter “STREAKING FAMILY”). AGA’s STREAKING FAMILY of slot machine

1 https://aruzegaming.com/innovator-deluxe/ultimate-diamond/, and a video depicting aspects of its

1 FAMILY, THE GOLD, GOLDEN FAMILY, GOLDEN FRONTIER, HAPPY FESTIVAL

3 MASTER OF WEALTH, MOONLIGHT OWL, PLATINUM JACKPOT, RAINBOW CASH

1 ANUBIS, FU LU SHOU, JUNGLE CASH ULTRA STACK BEAUTY IN THE WILD,

1 FEATURE PANDA (CUBE-X VERTICAL), TOWER STACK FEATURE PANDA (CUBE-X

3 authorization provides the ALIBABA, CYBER SEVEN, FU LU SHOU, PLATINUM JACKPOT,

1 PRAYER FOR RELIEF

1 RESPECTFULLY SUBMITTED this 20th Day of September 2019.

5 /s/ Jay J. Schuttert

12 ATTORNEYS FOR PLAINTIFF

Universal Entertainment Corporation v. Aruze Gaming America

You might also like