Case 1:15-cv-00350-UNA Document 1 Filed 05/01/15 Page 1 of 5 PageID #: 1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`AGINCOURT GAMING, LLC,
`
`
`
`Plaintiff,
`
`
`v.
`
`
`
`ELECTRONIC ARTS INC.
`
`
`
`Defendants.
`
`
`
`)
`)
`
`)
`
`) Civil Action No. __________
`
`)
`) JURY TRIAL DEMANDED
`
`
`)
`
`)
`
`)
`
`)
`COMPLAINT
`
`For its Complaint, Plaintiff Agincourt Gaming, LLC ("Agincourt Gaming"), by and
`
`through the undersigned counsel, alleges as follows:
`
`THE PARTIES
`
`1.
`
`Agincourt Gaming is a Delaware limited liability company with a place of
`
`business located in Plano, Texas.
`
`2.
`
`Defendant Electronic Arts Inc. is a Delaware corporation with, upon information
`
`and belief, a place of business located in Redwood City, California.
`
`JURISDICTION AND VENUE
`
`This action arises under the Patent Act, 35 U.S.C. § 1 et seq.
`
`Subject matter
`
`jurisdiction
`
`is proper
`
`in
`
`this Court under 28 U.S.C.
`
`3.
`
`4.
`
`§§ 1331 and 1338.
`
`5.
`
`Venue is proper in this district.
`
`THE PATENTS-IN-SUIT
`
`6.
`
`On October 23, 2001, United States Patent No. 6,306,035 (the '035 patent") was
`
`duly and legally issued for an invention entitled "Graphical User Interface For Providing Gaming
`
`And Prize Redemption Capabilities." A true and correct copy of the '035 patent is attached as
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`AGINCOURT GAMING, LLC,
`
`
`
`Plaintiff,
`
`
`v.
`
`
`
`ELECTRONIC ARTS INC.
`
`
`
`Defendants.
`
`
`
`)
`)
`
`)
`
`) Civil Action No. __________
`
`)
`) JURY TRIAL DEMANDED
`
`
`)
`
`)
`
`)
`
`)
`COMPLAINT
`
`For its Complaint, Plaintiff Agincourt Gaming, LLC ("Agincourt Gaming"), by and
`
`through the undersigned counsel, alleges as follows:
`
`THE PARTIES
`
`1.
`
`Agincourt Gaming is a Delaware limited liability company with a place of
`
`business located in Plano, Texas.
`
`2.
`
`Defendant Electronic Arts Inc. is a Delaware corporation with, upon information
`
`and belief, a place of business located in Redwood City, California.
`
`JURISDICTION AND VENUE
`
`This action arises under the Patent Act, 35 U.S.C. § 1 et seq.
`
`Subject matter
`
`jurisdiction
`
`is proper
`
`in
`
`this Court under 28 U.S.C.
`
`3.
`
`4.
`
`§§ 1331 and 1338.
`
`5.
`
`Venue is proper in this district.
`
`THE PATENTS-IN-SUIT
`
`6.
`
`On October 23, 2001, United States Patent No. 6,306,035 (the '035 patent") was
`
`duly and legally issued for an invention entitled "Graphical User Interface For Providing Gaming
`
`And Prize Redemption Capabilities." A true and correct copy of the '035 patent is attached as
`
`
`
`Case 1:15-cv-00350-UNA Document 1 Filed 05/01/15 Page 2 of 5 PageID #: 2
`
`Exhibit A.
`
`7.
`
`On June 3, 2013, United States Patent No. 8,454,432 (the "'432 patent"), entitled
`
`"Method for Providing Network Gaming System," was duly and lawfully issued by the U.S.
`
`Patent and Trademark Office. A true and correct copy of the '432 patent is attached hereto as
`
`Exhibit B.
`
`8.
`
`The '035 patent and the '432 patent issued from a series of applications extending
`
`back to November 14, 1996.
`
`9.
`
`Agincourt Gaming was assigned the '035 patent and the '432 patent, and continues
`
`to hold all rights and interest in the patents.
`
`10.
`
`Defendant designs, makes, markets, uses, offers for sale, and/or sells the
`
`following products that infringe the '035 patent: Origin.
`
`11.
`
`Defendant designs, makes, markets, uses, offers for sale, and/or sells the
`
`following products that infringe the '432 patent: Origin-enabled games, including, but not
`
`limited to, Mass Effect 3 and FIFA 15.
`
`12.
`
`To redress Defendant's infringement of the '035 patent and the '432 patent,
`
`Agincourt Gaming seeks actual damages.
`
`FACTUAL BACKGROUND
`
`13.
`
`Agincourt Gaming was formed in April 2011. Agincourt Gaming provided online
`
`social network games. Its business plan focused on developing its own online social network
`
`games and then launching the games for play online.
`
`14.
`
`In 2013, Agincourt Gaming launched its online social network game, Battle
`
`Conquest. Battle Conquest incorporates strategy, simulation, and role-play elements in an online
`
`platform that utilizes social interaction to enhance the gaming experience. As players interact
`
`with the game, they have opportunities to make in-game purchases of virtual goods and other
`
`2
`
`
`
`
`
`Case 1:15-cv-00350-UNA Document 1 Filed 05/01/15 Page 3 of 5 PageID #: 3
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`game-related items. To date, Battle Conquest has been played over one million times. In
`
`addition.
`
`15.
`
`Agincourt Gaming's patents-in-suit, which claim priority to 1996, were both far
`
`ahead of their time in anticipating the development of credits-based online gaming. Long before
`
`the explosion of online games, Agincourt Gaming's patents-in-suit recognized that allowing
`
`online gamers to earn and redeem prizes – including, in particular, game enhancements – based
`
`on the outcome of game play would be desirable to players but difficult for game providers to
`
`effectively maintain and display.
`
`COUNT I – INFRINGEMENT OF U.S. PATENT NO. 6,306,035
`
`16.
`
`Agincourt Gaming repeats and realleges the allegations of paragraphs 1 through
`
`15 as if fully set forth herein.
`
`17.
`
`Defendant has been and still is infringing the '035 patent, literally or under the
`
`doctrine of equivalents, by making, using, importing, offering to sell, and/or selling certain
`
`software products, including, but not limited to the products identified in paragraph 10 above.
`
`18.
`
`As a direct and proximate result of Defendant's acts of infringement, Agincourt
`
`Gaming has been, is being, and will be damaged. Defendant's infringement of Agincourt
`
`Gaming's exclusive rights under the '035 patent will continue to damage Agincourt Gaming.
`
`19.
`
`Agincourt Gaming also is entitled to recover from Defendant the damages
`
`sustained by Agincourt Gaming as a result of Defendant's wrongful acts in an amount subject to
`
`proof at trial.
`
`COUNT II – INFRINGEMENT OF U.S. PATENT NO. 8,454,432
`
`20. Agincourt Gaming repeats and realleges the allegations of paragraphs 1 through 19
`
`as if fully set forth herein.
`
`3
`
`
`
`
`
`Case 1:15-cv-00350-UNA Document 1 Filed 05/01/15 Page 4 of 5 PageID #: 4
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`21.
`
`Defendant has been and still is infringing the '432 patent, literally or under the
`
`doctrine of equivalents, by making, using, importing, offering to sell, and/or selling certain
`
`software products, including, but not limited to the products identified in paragraph 11 above.
`
`22.
`
`As a direct and proximate result of Defendant's acts of infringement, Agincourt
`
`Gaming has been, is being, and will be damaged. Defendant's infringement of Agincourt
`
`Gaming's exclusive rights under the '432 patent will continue to damage Agincourt Gaming.
`
`23.
`
`Agincourt Gaming also is entitled to recover from Defendant the damages
`
`sustained by Agincourt Gaming as a result of Defendant's wrongful acts in an amount subject to
`
`proof at trial.
`
`JURY DEMAND
`
`Agincourt Gaming hereby demands a trial by jury on all issues so triable.
`
`PRAYER FOR RELIEF
`
`Agincourt Gaming respectfully requests entry of judgment in its favor and against
`
`Defendant as follows:
`
`A.
`
`Declaring that Defendant has infringed and continues to infringe the '035 and '432
`
`patents;
`
`B.
`
`Awarding actual damages arising out of Defendant's infringement of the '035 and
`
`'432 patents, together with prejudgment and post-judgment interest, in an amount according to
`
`proof and an accounting of all infringing acts including, but not limited to, those acts not
`
`presented at trial;
`
`C.
`
`Awarding attorney's fees pursuant to 35 U.S.C. § 285 or as otherwise permitted
`
`4
`
`by law; and
`
`
`
`
`
`Case 1:15-cv-00350-UNA Document 1 Filed 05/01/15 Page 5 of 5 PageID #: 5
`
`D.
`
`Awarding such other costs and further relief as the Court may deem just and
`
`
`
`
`
`STAMOULIS & WEINBLATT LLC
`
`
`
`
`
`/s/ Richard C. Weinblatt
`Stamatios Stamoulis #4606
`Richard C. Weinblatt #5080
`Two Fox Point Centre
`6 Denny Road, Suite 307
`Wilmington, DE 19809
`Telephone: (302) 999-1540
`Facsimile: (302) 762-1688
`stamoulis@swdelaw.com
`weinblatt@swdelaw.com
`
`Attorneys for Plaintiff
`Agincourt Gaming, LLC
`
`5
`
`proper.
`
`
`Dated: May 1, 2015
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