UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION WMS GAMING INC., Plaintiff, v.

ARISTOCRAT TECHNOLOGIES, INC., Defendant. COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, WMS Gaming Inc., for its complaint for patent infringement against Defendant, Aristocrat Technologies, Inc., states as follows: NATURE OF CASE 1. This is an action for patent infringement arising under the Patent Laws of the Civil Action No. 12 CV 367 Jury Trial Demanded

United States, 35 U.S.C. 1 et seq., and particularly 35 U.S.C. 271 and 281. THE PARTIES Plaintiff WMS Gaming Inc. 2. WMS Gaming Inc. (WMS) is a Delaware corporation with principal places of

business at 3401 North California Avenue, Chicago, Illinois 60618, and 800 South Northpoint Boulevard, Waukegan, Illinois 60085. 3. WMS is engaged in the business of, inter alia, designing, manufacturing and

marketing video and reel-spinning gaming machines. 4. WMS is the owner of U.S. Patent No. 7,458,890 directed to a Reel Spinning Slot

Machine with Superimposed Video Image, which legally and duly issued on December 2, 2008

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(the 890 patent). A true and correct copy of the 890 patent is attached as Exhibit A. 5. WMS is the owner of U.S. Patent No. 7,585,220 directed to a Gaming Machine

with Superimposed Display Image, which legally and duly issued on September 8, 2009 (the 220 patent). A true and correct copy of the 220 patent is attached as Exhibit B. 6. WMS has the right to enforce U.S. Patent No. 7,322,884 directed to a Gaming

Machine Having a Variable Display, which legally and duly issued on January 29, 2008 (the 884 patent). A true and correct copy of the 884 patent is attached as Exhibit C. 7. WMS owns or has the right to enforce other patents, including but not limited to

U.S. Patent Nos. 6,937,298; 7,097,560; 7,140,963; 7,159,865; 7,207,883; 7,219,893; 7,220,181; 7,234,697; 7,281,980; 7,329,181; 7,355,660; 7,390,259; 7,465,228; 7,479,061; 7,479,066; 7,485,039; 7,510,476; 7,520,812; 7,695,364; 7,892,094; 7,972,206; 8,007,360; 8,016,669, 8,096,867, and patents that issue from U.S. Publication Nos. 2004/0147303; 2004/0209668; 2004/0209683; 2004/0214637; 2005/0282617; 2008/0020820; 2008/0176653; 2009/0247276; and 2011/0124411. After WMS has an opportunity to conduct discovery, including discovery of Defendants infringing gaming machines, WMS may seek leave to amend its complaint to assert additional patents. Defendant Aristocrat Technologies, Inc. 8. Aristocrat Technologies, Inc. (Aristocrat) is a Nevada corporation with its

principal place of business at 7230 Amigo Street, Las Vegas, Nevada 89119. 9. Aristocrat is engaged in the business of, inter alia, designing, manufacturing,

marketing, selling, and distributing video and reel-spinning gaming machines. 10. 11. Aristocrat is registered to do business in Illinois, and is doing business in Illinois. Aristocrats registered agent in Illinois is C T Corporation System, 208 South Page 2 of 13

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LaSalle Street, Suite 814, Chicago, Illinois 60604. JURISDICTION AND VENUE 12. This Court has subject matter jurisdiction over this dispute pursuant to 28 U.S.C.

1331 and 1338(a). 13. On information and belief, this Court has personal jurisdiction over Aristocrat at

least because (i) Aristocrat has sold gaming machines in Illinois, and within this District, including to riverboat casinos in Illinois; (ii) Aristocrat has sales representatives and/or distributor(s) in Illinois; (iii) Aristocrat is registered with the Illinois Secretary of State to do business in Illinois; (iv) Aristocrat is registered with and is licensed as a gaming equipment supplier by the Illinois Gaming Board (http://www.igb.state.il.us/Pending/ILSUPPUBweb.pdf); (v) Aristocrat has a registered agent in Illinois; and/or (vi) WMS believes Aristocrat has pursued regulatory approval in Illinois for at least some of the gaming machines at issue in this lawsuit. 14. 1400(b). GENERAL ALLEGATIONS WMSs TRANSMISSIVE REELS Technology 15. technology. 16. WMSs TRANSMISSIVE REELS technology combines the visceral appeal of The 890, 220, and 884 patents relate to WMSs TRANSMISSIVE REELS Venue is proper in this District pursuant to at least 28 U.S.C. 1391(b) and

mechanical-reel gaming with the visually engaging, interactive animation of video slots by projecting graphically-rich video content on a display screen (e.g., a LCD) over a mechanicalreel slot machine. This creates a unique gaming experience unlike anything ever played before and provides virtually unlimited bonus game opportunities. COMPLAINT FOR PATENT INFRINGEMENT Page 3 of 13

17.

WMSs TRANSMISSIVE REELS technology is found, for example, in WMSs

BRUCE LEE gaming machine shown in Illustration 1. The BRUCE LEE gaming machine practices at least claim 1 of the 890 patent.

Illustration 1. BRUCE LEE game 18. As shown in Illustrations 2, 3, and 4, the BRUCE LEE gaming machine has a

LCD providing video images overlaying mechanical reels.

Illustration 2. BRUCE LEE game

Illustration 3. BRUCE LEE game

Illustration 4. BRUCE LEE game COMPLAINT FOR PATENT INFRINGEMENT Page 4 of 13

19.

As shown in Illustration 5, a player of the BRUCE LEE gaming machine can

see the symbols on the mechanical reels through the LCD in the portions of the LCD located over the mechanical reels.

Illustration 5. BRUCE LEE game 20. The LCD of the BRUCE LEE gaming machine provides video images that

interact with the symbols on the mechanical reels. For example, as shown in Illustration 6, the video image provided by the LCD includes boxes around each of the reels, the video image has changed from transparent to opaque over the symbols on the left and right reels, and the video image includes the word WILD superimposed over the symbols on the left and right reels. The video image also includes a red pay line over symbols on the reels.

Illustration 6. BRUCE LEE game

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21.

The LCD of the BRUCE LEE gaming machine also provides video images that

present a special event of the wagering game, the special event including one or more game indicia selectable by the player. For example, as shown in Illustrations 7, 8, and 9, the BRUCE LEE gaming machines includes a bonus feature that is played on the touch sensitive LCD. The player may touch one of the stars to potentially receive a bonus.

Illustration 7. BRUCE LEE game

Illustration 8. BRUCE LEE game

Illustration 9. BRUCE LEE game Aristocrats Infringing Activities 22. On information and belief, Aristocrat has copied WMSs TRANSMISSIVE

REELS technology into its gaming machines in the Viridian Hybrid cabinet with Active Reel Technology, including at least the Winning Wishes gaming machines (Persian Prize, Pixie Riches, and Tahitian Treasures), the Zorro gaming machines (The Legend Returns and The Mask COMPLAINT FOR PATENT INFRINGEMENT Page 6 of 13

& The Rose), the Ultra Spin gaming machines (Diamond Destiny and Ruby Saloon), and the Stormin Jackpots gaming machines. 23. Aristocrat describes its gaming machines in its Viridian Hybrid cabinet with

Active Reel Technology as follows: VIRIDIAN HYBRID with Active Reel Technology is the standard-setting new line of games that has the potential to feature a 5-reel stepper base game, a full screen video and a 3-reel stepper bonus, all in the same game! The magic is made possible with Aristocrats innovative LCD with reel windows and shutters. The shutter technology brings an incredible level of interactivity to the stepper world. In addition to the exciting stepper game, the shutters open and close to create an LCD touch-screen to further engage the player. Stunning graphics stretch top to bottom and awesome sound surrounds the player. (See http://www.aristocrat.com.au/products/cabinets/Pages/CabinetDeta il.aspx?Title=Viridian%20Hybrid.) 24. A video demo of Aristocrats Zorro - The Legend Returns gaming machine is

available on Aristocrats website at http://www.aristocrat.com.au/products/games/Pages/ gamedetail.aspx?GameTitle=Zorro - The Legend Returns. 25. is available A video demo of Aristocrats Winning Wishes - Pixie Riches gaming machine on Aristocrats website at http://www.aristocrat.com.au/products/games/

Pages/gamedetail.aspx? GameTitle=Winning Wishes. 26. A video demo of Aristocrats Ultra Spin - Diamond Destiny gaming machine is

available on Aristocrats website at http://www.aristocrat.com.au/products/games/Pages/ gamedetail.aspx? GameTitle=Ultra Spin. 27. The video demo referenced in paragraph 25 for Aristocrats Winning Wishes -

Pixie Riches gaming machine demonstrates Aristocrats infringement of at least claim 1 of the 890 patent, at least claim 48 of the 220 patent, and at least claim 1 of the 884 patent, as

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described further in paragraphs 28 through 31 below. 28. paragraph 25. Illustration 10 is an annotated excerpt from the video demo referenced in As shown in Illustration 10, Aristocrats Winning Wishes - Pixie Riches

gaming machine has a LCD providing video images overlaying mechanical reels, and a player of the gaming machine can see the symbols on the mechanical reels through the LCD in the portions of the LCD located over the mechanical reels.
Mechanical reels

LCD providing video images overlaying the mechanical reels

Illustration 10. Winning Wishes - Pixie Riches game 29. Illustration 11 is an excerpt from the video demo referenced in paragraph 25. As

shown in Illustration 11, the LCD of Aristocrats Winning Wishes - Pixie Riches gaming machine provides video images that interact with the symbols on the mechanical reels. In this example, the video image provided by the LCD includes boxes around each of the reels and the video image has changed from transparent to opaque over the symbols on the fourth reel.

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Illustration 11. Winning Wishes - Pixie Riches game 30. As also shown in Illustration 11, the LCD of Aristocrats Winning Wishes -

Pixie Riches gaming machine displays a specific image simultaneously on at least partially the area not over the symbols on the reels and on at least partially the area over the symbols on the fourth reel, such that the LCD prevents the player from seeing the symbols on the fourth reel. Alternatively, as shown in Illustration 10, the LCD of Aristocrats Winning Wishes - Pixie Riches gaming machine displays the specific image on at least partially the area not over the symbols on the reels, but not on any of the areas over the symbols on the reels, such that the LCD permits the player to see the symbols on the reels along with at least a portion of the specific image displayed only on the areas not over the symbols on the reels. 31. Illustration 12 is an excerpt from the video demo referenced in paragraph 25. As

shown in Illustration 12, the LCD of Aristocrats Winning Wishes - Pixie Riches gaming machine also provides video images that present a special event of the wagering game, the special event including one or more game indicia selectable by the player. In this example, Aristocrats Winning Wishes - Pixie Riches gaming machine includes a bonus feature that is played on the touch sensitive LCD. The player may touch one of the lamps to potentially receive

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a bonus.

Illustration 12. Winning Wishes - Pixie Riches game COUNT I INFRINGEMENT OF U.S. PATENT NO. 7,458,890 32. 33. WMS incorporates herein the allegations of paragraphs 1 through 31 above. WMS has never licensed or permitted Aristocrat to practice any of the legal rights

granted under the 890 patent. 34. Aristocrat has infringed, and is infringing, one or more claims of the 890 patent

under at least 35 U.S.C. 271(a) by making, using, selling, offering to sell, and/or importing into the United States gaming machines in its Viridian Hybrid cabinet with Active Reel Technology. 35. On information and belief, Aristocrats infringement of the 890 patent has been,

and continues to be, with full knowledge of the 890 patent and is a deliberate and willful infringement thereof. 36. By reason of Aristocrats infringement of the 890 patent, Aristocrat has caused

and continues to cause WMS to suffer damage and irreparable harm. 37. WMS has no adequate remedy at law for Aristocrats infringement of the 890

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patent. 38. Court. COUNT II INFRINGEMENT OF U.S. PATENT NO. 7,585,220 39. 40. WMS incorporates herein the allegations of paragraphs 1 through 31 above. WMS has never licensed or permitted Aristocrat to practice any of the legal rights Aristocrats infringement of the 890 patent will continue unless enjoined by this

granted under the 220 patent. 41. Aristocrat has infringed, and is infringing, one or more claims of the 220 patent

under at least 35 U.S.C. 271(a) by making, using, selling, offering to sell, and/or importing into the United States gaming machines in its Viridian Hybrid cabinet with Active Reel Technology. 42. On information and belief, Aristocrats infringement of the 220 patent has been,

and continues to be, with full knowledge of the 220 patent and is a deliberate and willful infringement thereof. 43. By reason of Aristocrats infringement of the 220 patent, Aristocrat has caused

and continues to cause WMS to suffer damage and irreparable harm. 44. patent. 45. Court. COUNT III INFRINGEMENT OF U.S. PATENT NO. 7,322,884 46. 47. WMS incorporates herein the allegations of paragraphs 1 through 31 above. WMS has never licensed or permitted Aristocrat to practice any of the legal rights Page 11 of 13 Aristocrats infringement of the 220 patent will continue unless enjoined by this WMS has no adequate remedy at law for Aristocrats infringement of the 220

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granted under the 884 patent. 48. Aristocrat has infringed, and is infringing, one or more claims of the 884 patent

under at least 35 U.S.C. 271(a) by making, using, selling, offering to sell, and/or importing into the United States gaming machines in its Viridian Hybrid cabinet with Active Reel Technology. 49. On information and belief, Aristocrats infringement of the 884 patent has been,

and continues to be, with full knowledge of the 884 patent and is a deliberate and willful infringement thereof. 50. By reason of Aristocrats infringement of the 884 patent, Aristocrat has caused

and continue to cause WMS to suffer damage and irreparable harm. 51. patent. 52. Court. JURY DEMAND In accordance with the Seventh Amendment of the United States Constitution, WMS demands a trial by jury on all issues so triable. PRAYER FOR RELIEF WHEREFORE, WMS prays that: a) Pursuant to 35 U.S.C. 271, this Court enter judgment that Aristocrat has been Aristocrats infringement of the 884 patent will continue unless enjoined by this WMS has no adequate remedy at law for Aristocrats infringement of the 884

and is currently infringing the 890, 220, and 884 patents; b) Aristocrat, its officers, agents, servants, employees, assigns, successors in interest,

parents, and attorneys, and all those in active concert or participation with them who received COMPLAINT FOR PATENT INFRINGEMENT Page 12 of 13

actual notice of the injunction, by personal service or otherwise, be permanently enjoined from infringing the 890, 220, and 884 patents; c) Aristocrat be directed to pay WMS the amount of damages WMS has sustained as

a result of Aristocrats acts of patent infringement, and that such damages be trebled under 35 U.S.C. 284; d) e) f) This be declared an exceptional case under 35 U.S.C. 285; WMS be awarded its attorneys fees; Aristocrat be directed to pay an award of pre-judgment interest, post-judgment

interest, and costs of the suit to WMS; and g) WMS be granted such other further relief as the Court may deem proper and just.

Respectfully submitted, Dated: January 18, 2012 /s/ Michael J. Harris Timothy C. Meece (IL Bar No. 06226967) tmeece@bannerwitcoff.com V. Bryan Medlock bmedlock@bannerwitcoff.com Michael J. Harris (IL Bar No. 06280168) mharris@bannerwitcoff.com BANNER & WITCOFF, LTD. 10 South Wacker Drive, Suite 3000 Chicago, Illinois 60606 Telephone: (312) 463-5000 Facsimile: (312) 463-5001 Attorneys for Plaintiff, WMS Gaming Inc.

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