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Stacie Foster (WSBA # 23397) INVICTA LAW GROUP, PLLC 1000 2nd Avenue, Suite 3310 Seattle, Washington 98104-1019 Telephone: 206-903-6364 Facsimile: 206-903-6365 Email: sfoster@invictalaw.com Michael D. Rounds (NV SBN 4734) (pro hac vice pending) Adam P. McMillen (NV SBN 10678) (pro hac vice pending) Adam K. Yowell (NV SBN 11748) (pro hac vice pending) WATSON ROUNDS 5371 Kietzke Lane Reno, Nevada 89511 Telephone: 775-324-4100 Facsimile: 775-333-8171 Email: mrounds@watsonrounds.com Email: amcmillen@watsonrounds.com Email: ayowell@watsonrounds.com Attorneys for Plaintiff GALAXY GAMING, INC. UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON GALAXY GAMING, INC., a Nevada Corporation, Plaintiff, vs. UNAX SERVICE LLC, a Washington Limited Liability Company; XUMING SHANGGUAN aka SEAN SHANGGUAN, an individual, dba UNAX GAMING, an unknown entity, and dba UNAX SERVICES, a Sole Proprietorship, Defendants. Plaintiff Galaxy Gaming, Inc., (Galaxy Gaming) alleges the following in support of its Complaint for Patent Infringement and Demand for Jury Trial against Unax Service LLC, Unax Gaming, Unax Services, Xuming Shangguan and Sean Shannguan (Defendants). \\\ COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL Case No.

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JURISDICTION AND VENUE This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and

1338(a) because this action arises under the patent laws of the United States, including 35 U.S.C. 271 et seq. This Court has personal jurisdiction over Defendants because they are domiciled and do business in the State of Washington and have committed acts within Washington and this judicial district giving rise to this action. 2. Defendants have committed infringing acts within this judicial district and the

Western District of Washington giving rise to this action and do business and/or reside in this district and division, including one or more of the infringing acts of making, offering for sale, selling and using card games that combine the play of Blackjack with a 3-card Poker wager, including Double Action Blackjack and Squeezit Blackjack games, and providing service and support to its respective customers in this district. Venue is proper in this district and division pursuant to 28 U.S.C. 1391(b) and (c) and 1400(b). THE PARTIES Galaxy Gaming, Inc. is a Nevada corporation having its principle place of business

at 6980 OBannon Drive, Las Vegas, Nevada. 4. Upon information and belief, Unax Gaming is an unknown Washington entity with

its principle place of business at 5418 NE 198th Place, Seattle, Washington. 5. Washington. 6. Washington. 7. Upon information and belief, Unax Services is a Washington sole proprietorship Upon information and belief, Xuming Shangguan is domiciled in the State of Upon information and belief, Sean Shanguan is domiciled in the State of

with its principal place of business at 5418 NE 198th Place, Seattle, Washington. 8. Upon information and belief, Unax Service LLC is a Washington Limited Liability

Company with its principal place of business at 5418 NE 198th Place, Seattle, Washington.

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FACTUAL ALLEGATIONS AS TO ALL CLAIMS Galaxy Gaming develops, manufactures and distributes over 60 casino table games

and has expended considerable resources in developing, patenting and marketing its games. 10. Galaxy Gamings Blackjack with a Three Card Poker Wager ("21+3) game

retains all the features and advantages of Blackjack (and Blackjack variants) as well as provides the dynamics of 3-card Poker, without interfering with the card sequence, for enhanced player anticipation and enjoyment. The 21+3 game is covered by all three of the patents-in-suit,

referenced in paragraphs 8, 9 and 10 below. 11. Galaxy Gaming is the assignee of U.S. Patent 6,012,719 (the 719 patent), which

is directed to a method for card games that combine the play of Blackjack with a 3-card Poker wager (21+3). The 719 patent issued in January of 2000 based on a U.S. application filed in July 1998. A true and correct copy of the 719 patent is attached as Exhibit 1. 12. Galaxy Gaming is the assignee of U.S. Patent 6,371,867 B1 (the 867 patent),

which is directed to a method and apparatus for card games that combine the play of Blackjack with a 3-card Poker wager (21+3). The 867 patent issued in April of 2002 based on a U.S.

application filed in December 1999. A true and correct copy of the 867 patent is attached as Exhibit 2. 13. Galaxy Gaming is the assignee of U.S. Patent 6,481,719 B2 (the 719 B2

patent), which is directed to a method and apparatus for card games that combine the play of Blackjack with a 3-card Poker wager (21+3). The 719 B2 patent issued in November of 2002 based on a U.S. application filed in May 2001. A true and correct copy of the 719 B2 patent is attached as Exhibit 3. 14. Defendants are competitors of Galaxy Gaming and have been making, offering for

sale, selling and using its competing and infringing card games that combine the play of Blackjack with a 3-card Poker wager, including Double Action Blackjack and Squeezit Blackjack games. \\\ \\\ 3

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COUNT I Patent Infringement Galaxy Gaming incorporates by reference and realleges the allegations set forth in

paragraphs 1 through 14 above. 16. This claim arises under the Patent Laws of the United States and is a claim by

Galaxy Gaming against Defendants for infringement of the 719 patent, the 867 patent and the 719 B2 patent (the patents-in-suit). 17. Defendants are not licensed or otherwise authorized by Galaxy Gaming to make,

use, offer for sale or sell any of the inventions embodied in the patents-in-suit. 18. On information and belief, Galaxy Gaming alleges that Defendants are infringing

at least one or more claims of the patents-in-suit by making, having made, using, selling and/or offering to sell its Double Action Blackjack and Squeezit Blackjack games, and variants thereof, which embody the invention(s) of the patents-in-suit. True and correct copies of three versions of Double Action Blackjack are attached hereto as Exhibit 4 (version 1), Exhibit 5 (version 2) and Exhibit 6 (version 3). A true and correct copy of Squeezit Blackjack is attached hereto as Exhibit 7. 19. On information and belief, Galaxy Gaming alleges that Defendants actively induce

the infringement of the patents-in-suit by intentionally persuading or inducing third parties to make, use, offer for sale, or sell the inventions embodied in the patents-in-suit. 20. On information and belief, Galaxy Gaming alleges that Defendants sold or

supplied to others, with knowledge of the Galaxy Gaming products and patents, games that infringe the patents-in-suit. 21. On information and belief, Galaxy Gaming alleges that Defendants will continue

to infringe the patents-in-suit with resulting damage to Galaxy Gaming being substantial, continuing, and irreparable unless enjoined by this Court. 22. On information and belief, Galaxy Gaming alleges that the infringement by

Defendants, as alleged herein, was undertaken with knowledge of the patents-in-suit and their infringement has been done willfully, wantonly, and in bad faith. 4

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23.

As a direct and proximate result of the infringement by Defendants, as alleged

hereinabove, Galaxy Gaming has suffered and will suffer damages. 24. On information and belief, Galaxy Gaming alleges that Defendants, unless

permanently enjoined, will continue to engage in the aforementioned acts and conduct, to Galaxy Gamings further and continuing damage. Such continuing acts committed by Defendants will, unless enjoined, cause irreparable damage in that Galaxy Gaming will have no adequate remedy at law to compel Defendants to cease such acts. PRAYER FOR RELIEF WHEREFORE, Galaxy Gaming prays for judgment on this Complaint against Defendants as follows: A. That Defendants be required to pay to Galaxy Gaming such damages as Galaxy

Gaming has sustained as a consequence of Defendants acts of infringement, to be determined more fully at trial; B. That Galaxy Gaming be awarded such damages that constitute at least its lost

profits, lost royalties and lost convoyed sales damages as a result of the wrongful acts of Defendants; C. That the Court enter a preliminary and permanent injunction against Defendants

pursuant to which Defendants, including all of their employees, representatives, officers, directors, shareholders, investors, and all persons acting in concert or participating with them, are enjoined or restrained as follows from making, using, selling or offering to sell any method and/or apparatus for card games that combine the play of Blackjack with a 3-card Poker wager found to infringe the patents-in-suit or any such act for a method and/or apparatus for card games that combine the play of Blackjack with a 3-card Poker wager which is insubstantially changed from the design of any infringing method and/or apparatus; D. That Defendants be required to pay to Galaxy Gaming exemplary damages under

35 U.S.C. 285; E. That Galaxy Gaming be awarded its costs and reasonable attorneys' fees under 35

U.S.C. 285 and Fed. R. Civ. P. 54; and 5

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F.

That Galaxy Gaming have such other relief as the Court deems just and proper. DEMAND FOR JURY TRIAL Pursuant to the Federal Rules of Civil Procedure Rule 38, Galaxy Gaming hereby

demands a jury trial on all issues triable by jury.

Dated March 14, 2012

Respectfully submitted, By: /s/Stacie Foster Stacie Foster INVICTA LAW GROUP, PLLC 1000 2nd Avenue, Suite 3310 Seattle, Washington 98104-1019 Of counsel: /s/ Michael D. Rounds Michael D. Rounds Adam P. McMillen Adam K. Yowell WATSON ROUNDS 5371 Kietzke Lane Reno, NV 89511 Attorneys for Plaintiff Galaxy Gaming, Inc.

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