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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

LIGHTNING BOX GAMES PTY LTD., Plaintiff, v. INTERNATIONAL GAME TECHNOLOGY and CAESARS ENTERTAINMENT CORPORATION, Defendants. COMPLAINT FOR PATENT INFRINGEMENT For its original complaint for patent infringement, Lightning Box Games Pty Ltd. (LBG), by and through its undersigned counsel, alleges as follows: THE PARTIES 1. Plaintiff LBG is a proprietary limited company organized under the laws of Case No. 13-cv-5423

Australia with a place of business at 118 Wyndham Street, Alexandria, NSW 2015, Australia. 2. On information and belief, Defendant International Game Technology (IGT) is

a corporation organized under the laws of the State of Nevada, has a principal place of business at 9295 Prototype Drive, Reno, Nevada 89521-8986, and owns and operates places of business and does substantial business within this district. 3. On information and belief, Defendant Caesars Entertainment Corporation

(CEC) is a corporation organized under the law of the State of Delaware, has a principal place of business at One Caesars Palace Drive, Las Vegas, Nevada 89109, and owns and operates places of business and does substantial business within this district including, by way of example

and not limitation, owning and operating Harrahs Joliet Casino at 151 N. Joliet Street, Joliet, Illinois 60432. JURISDICTION AND VENUE 4. This action arises under the Patent Laws of the United States, 35 U.S.C. 1 et

seq. This Court has jurisdiction over the subject matter of this action under 28 U.S.C. 1331 and 1338(a). 5. 6. 1400(b). PATENTS-IN-SUIT 7. On August 2, 2011, the United States Patent and Trademark Office (the This Court has personal jurisdiction over each Defendant. Venue for this action is proper in this district pursuant to 28 U.S.C. 1391 and

USPTO) duly and legally issued U.S. Patent No. 7,988,549 (the 549 Patent) titled Electronic System for Playing of Reel-Type Games. A copy of the 549 Patent is attached as Exhibit A. 8. On July 2, 2013, the USPTO duly and legally issued U.S. Patent No. 8,475,261

(the 261 Patent) titled Electronic System for Playing of Reel-Type Games. A copy of the 261 Patent is attached as Exhibit B. The 261 Patent is a continuation of, and claims priority to, the 549 Patent. COUNT ONE INFRINGEMENT OF THE 549 PATENT 9. LBG repeats and realleges the allegations of the preceding paragraphs 1-8 as if

fully set forth herein.

10.

IGT has infringed and continues to infringe one or more claims of the 549 Patent

in violation of 35 U.S.C. 271(a) by making, using, selling, and/or offering for sale throughout the United States, including in this judicial district, IGTs MultiPLAY Video Slot machines. 11. CEC has infringed and continues to infringe one or more claims of the 549 Patent

in violation of 35 U.S.C. 271(a) by using and/or offering for use throughout the United States, including in this judicial district, IGTs MultiPLAY Video Slot machines. By way of example, and not limitation, CEC features IGTs Sex and the City MultiPLAY Video Slot machine at its Harrahs Joliet Casino in Joliet, Illinois. COUNT TWO INFRINGEMENT OF THE 002 PATENT 12. LBG repeats and realleges the allegations of the preceding paragraphs 1-11 as if

fully set forth herein. 13. IGT has infringed and continues to infringe one or more claims of the 261 Patent

in violation of 35 U.S.C. 271(a) by making, using, selling, and/or offering for sale throughout the United States, including in this judicial district, IGTs MultiPLAY Video Slot machines. 14. CEC has infringed and continues to infringe one or more claims of the 261 Patent

in violation of 35 U.S.C. 271(a) by using and/or offering for use throughout the United States, including in this judicial district, IGTs MultiPLAY Video Slot machines. By way of example, and not limitation, CEC features IGTs Sex and the City MultiPLAY Video Slot machine at its Harrahs Joliet Casino in Joliet, Illinois. PRAYER FOR RELIEF WHEREFORE, LBG respectfully requests entry of judgment in its favor and the following relief, including:

A.

That each Defendant be adjudged to have infringed one or more claims of each of

the 549 and 261 Patents; B. That each Defendant and all related entities and their officers, agents, employees,

representatives, servants, successors, assigns and all persons in active concert or participation with any of them, directly or indirectly, be preliminarily and permanently enjoined from using, or contributing or inducing the use of, any product or system that infringes any claim of the 549 or 261 Patents; C. That each Defendant account for damages sustained by LBG as a result of such

Defendants infringement of the 549 and 261 Patents, including both pre- and post-judgment interest and costs as fixed by this Court under 35 U.S.C. 284; and D. and proper. JURY DEMAND LBG demands a trial by jury on all issues so triable. That the Court grant LBG such other and further relief as the Court may deem just

Respectfully submitted,

Dated: July 30, 2013

/s/ Matthew G. McAndrews Matthew G. McAndrews NIRO, HALLER & NIRO 181 West Madison St., Suite 4600 Chicago, Illinois 60602 Telephone: (312) 236-0733 Facsimile: (312) 236-3137 E-mail: mmcandrews@nshn.com Attorney for Plaintiff, LIGHTNING BOX GAMES PTY LTD.