perrie v. perrie

1 COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES: [PATENT INVENTORSHIP]

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SCHWEDLER LAW GROUP Carl J. Schwedler SBN: 244189 216 F Street #125 Davis, CA 95616 Telephone: (530) 210-3104 Email: [email protected] Attorney for Plaintiff SALLY PERRIE

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA SALLY PERRIE, Plaintiff, v. KENNETH ALLAN PERRIE

Defendant.

) ) ) ) ) ) ) ) ) ) )

Case No.: 14-993 COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES: [PATENT INVENTORSHIP] DEMAND FOR JURY TRIAL

This is an action arising under the patent laws of the United States, arising under 35 U.

S.C. § 100 et seq., seeking declaratory relief under 28 U.S.C. §§ 2201 and/or 2202, correcting the

inventorship and ownership of several patents pursuant to 35 U.S.C. § 256. This is also an action

for unjust enrichment, breach of fiduciary duty and an action for breach of express contract and

breach of implied contract arising under the statutory and common laws of California.

THE PARTIES

1. Sally Perrie is a resident of California, 504 Nursery Street, Nevada City, CA 95959.

2. On information and belief, Defendant Kenneth Allan Perrie, is a resident of California,

residing at 74075 Alpine Lane, Palm Desert, CA 92211.


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3. On information and belief Defendant Kenneth Allan Perrie is an employee of Spa Resort

Casinos, located at 401 East Amado Road, Palm Springs, CA, 92262.

JURISDICTION AND VENUE

4. This Court has jurisdiction over this action under 28 U.S.C. §§ 1331, 1338(a) (as this

case civil action is based on statute relating to patents, plant variety protection, copyrights and

trademarks), 1338(b) (as to unfair competition claims joined to the action), 1367 (as to the state

law based claims), 2201 and 2202.

5. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b), 1391(c), 1391(d), and

1400(b).

GENERAL ALLEGATIONS

PATENTS

6. U.S. Patent No. 8,435,106 ("the ‘106 patent") titled "Wagering game with

persistent selection state" issued on May 7, 2013, with Kenneth Allan Perrie an Olaf Vancura

incorrectly listed as the sole joint inventors.

7. Sally Perrie is an inventor of the ‘106 patent.

8. On information and belief, the entire right to the ‘106 patent was improperly

applied for and subsequently improperly assigned by Kenneth Allan Perrie and Olaf Vancura

without the authorization of Sally Perrie.

9. U.S. Patent No. 7,771,265 ("the ‘265 patent") titled "Method of operating a

casino game having a hidden pattern" issued on August 10, 2010, with Kenneth Allan Perrie an

Olaf Vancura incorrectly listed as the sole joint inventors.






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12. U.S. Patent No. 7,032,901 ("the ‘901 patent") titled “Poker dice casino game

method of play" issued on April 25, 2006, with Kenneth Allan Perrie an Olaf Vancura






15. U.S. Patent No. 6,988,948 ("the ‘948 patent") titled “Casino bonus game using

player input" issued on January 24, 2006, with Kenneth Allan Perrie an Olaf Vancura incorrectly

listed as the sole joint inventors.





18. U.S. Patent No. 6,855,055 ("the ‘055 patent") titled “Method for controlling

length of casino game" issued on February 15, 2005, with Kenneth Allan Perrie an Olaf Vancura







method of play" issued on June 8, 2004, with Kenneth Allan Perrie an Olaf Vancura incorrectly




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24. U.S. Patent No. 6,645,071 ("the ‘071 patent") titled “Casino bonus game using

player strategy" issued on November 11, 2003, with Kenneth Allan Perrie an Olaf Vancura



26. On information and belief, the entire right to the ’071 patent was improperly




method of play" issued on May 20, 2003, with Kenneth Allan Perrie an Olaf Vancura incorrectly







method of play" issued on November 19, 2002, with Kenneth Allan Perrie an Olaf Vancura







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33. U.S. Patent No. 6,398,644 ("the ‘644 patent") titled “Pattern reverse keno game

method of play" issued on June 4, 2002, with Kenneth Allan Perrie an Olaf Vancura incorrectly







method of play" issued on October 23, 2001, with Kenneth Allan Perrie an Olaf Vancura






39. U.S. Patent No. 6,193,235 ("the ‘235 patent") titled “Like kind card game" issued

on February 27, 2001, with Kenneth Allan Perrie an Olaf Vancura incorrectly listed as the sole

joint inventors.





42. U.S. Patent No. 6,186,505 ("the ‘505 patent") titled “Like kind money board table

game" issued on February 13, 2001, with Kenneth Allan Perrie an Olaf Vancura incorrectly




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without the authorization of Sally Perrie


method of play" issued on January 16, 2001, with Kenneth Allan Perrie an Olaf Vancura






48. The above games all represent some adaptation of a popular family board game to

the requirement for a table or electronic game for the casino industry.

49. In particular, the ‘901, ‘016, ‘088, ‘713, ‘686 and ‘955 patents relate to the

adaptations of the board game Yahtzee to casino applications (the “YAHTZEE PATENTS”)

50. In particular, the ‘106, ‘265, ‘948, ‘055, ‘071 and ‘644 patents relate to

adaptations of the board game Battleship to casino applications (the “BATTLESHIP

PATENTS”).

51. In particular, the ‘235 and ‘505 patents relate to the adaptations of the board game

Monopoly to casino applications (the “MONOPOLY PATENTS”).

SALLY PERRIE'S RELATIONSHIP WITH KENNETH ALLAN PERRIE

52. Sally Perrie and Kenneth Allan Perrie (collectively the “Perries”) were married

February 14, 1982, and remained married at all times during the development of the above

inventions.

53. Throughout their marriage, Kenneth Allan Perrie has been employed variously at

positions within the casino industry.

54. In September of 1982, the Perries moved to Tahoe City, CA.


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55. Sally Perrie and Kenneth Allan Perrie formed a company, Gaming Concepts,

Inc., in 1982 for the purpose of game development. Under Gaming Concepts, Inc., the Perries

jointly developed concepts for electronic and table games for the casino industry.

56. Sally Perrie and Kenneth Allan Perrie acted as partners in game development, and

as business partners for the exploitation of the intellectual property developed therefrom.

57. In or around the mid to late 1980’s, on a trip to Toys R Us together, Sally Perrie

suggested to Kenneth Allan Perrie that they use popular board games as a basis for casino games.

58. From that time forward, their business efforts were increasingly directed toward

the adaptation of popular board games for use as table or electronic casino games.

59. Their efforts eventually gave rise to patentable inventions referenced herein as the

YAHTZEE PATENTS, the BATTLESHIP PATENTS and the MONOPOLY PATENTS.

60. In addition to the patented board game developments, the Perries also worked on

the development of casino games based on the board games Trivial Pursuit, Stratego and Clue.

61. In or around February of 1992, Kenneth Allan Perrie relocated to the east coast

from the couple’s home in Nevada. Sally Perrie and their daughter, Kate Perrie, remained in

their home in Nevada.

62. In the period from the beginning of their board game development in the 1980s to

the time Kenneth Allan Perrie moved to the east coast, numerous friends, relatives and business

colleagues were made aware of the development efforts of the Perries.

63. During the development period, the couple kept various materials readily visible

around the house relating the game development, including “mock-ups” of games relating to the

YAHTZEE PATENTS, the BATTLESHIP PATENTS and the MONOPOLY PATENTS and

casino games based on the board games Trivial Pursuit, Stratego and Clue.

64. The games Yahtzee, Monopoly, Battleship, Trivial Pursuit, Stratego and Clue at

that time were all owned by Milton Bradley, a manufacturer of these and other popular board

games.


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65. In order to market any of the games, the Perries understood they would need to

acquire permission from Milton Bradley. To that end, in or around 1991 the Perries took a trip

together to the east coast to visit the offices of Milton Bradley, in order to pitch their concept of

electronic and table casino games for a suite of games including Yahtzee, Monopoly, Battleship,

Trivial Pursuit, Stratego and Clue.

66. Even before the trip to Milton Bradley, the Perries had needed to advance the

game concept significantly in that casino odds are strictly regulated, and the games required

significant adaptation in order to work as a casino betting game.

67. The Perries were understandably excited about the visit to Milton Bradley, and

even before leaving numerous friends, relatives and business colleagues were aware of the

advance work that had been accomplished in the development of the games, and were impressed

that the difficult issues of re-configuring the games for casino style betting were sufficiently

resolved to take the concept to Milton Bradley.

68. In the Perries’ visit to Milton Bradley’s offices, they took mock-ups of several of

the games, showing the general layout and providing explanations regarding the requirements of

casino odds and betting regulations, and the proposed solutions.

69. In the Perries’ visit to Milton Bradley’s offices, Milton Bradley representatives

expressed initial hesitation, due to the “family nature” of the traditional board games, and

expressed especial concern about their “flagship” Yahtzee.

70. In the visit to Milton Bradley’s offices, the Perries sought to make Milton Bradley

aware of the general threat of video games to traditional board games, and argued that Milton

Bradley would need to appeal to a new, electronic generation.

71. After an all-day meeting with Milton Bradley, the couple returned home happy

that Milton Bradley had not outright rejected the proposal. Numerous friends, relatives and

business colleagues heard the reports of the trip and noted the Perries excitement about the

prospects of selling the games, and the increased energy devoted to finalizing the deal.


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72. In 1994 Sally Perrie and Kenneth Allan Perries became separated.

73. Until separation, and for some time afterwords, Sally Perrie and Kenneth Allan

Perrie spoke nearly daily about the game concepts and the prospects of closing a deal with

Milton Bradley

74. In 1995 the Perries took a cruise trip to the Bahamas, and during a visit to Black

Beard’s Tower in Nassau Kenneth Allan Perrie informed Sally Perrie that a deal had been

completed with Milton Bradley for the name rights, and that Mikohn gaming would distribute

the resulting games based on the popular Milton Bradley board games.

75. The Perries agreed at this time to treat the casino gaming opportunity relating to

the Milton Bradley board game adaptations within the family business.

76. After the separation, Kenneth Allan Perrie increasingly took on the role of

running the business for the family.

77. At all times after separation and up until the filing of papers for a divorce, the

game development relationship remained the same, with Kenneth Allan Perrie managing the

business for the family, and making regular payments to Sally Perrie.

78. On information and belief, Kenneth Allan Perrie met Olaf Vancura in 1994.

79. On information and belief, Olaf Vancura at the time was a professor working at

Cornell, in the field physics.

80. On information and belief, Kenneth Allan Perrie and Olaf Vancura completed

patent applications for the YAHTZEE PATENTS, the BATTLESHIP PATENTS and the

MONOPOLY PATENTS beginning in the late nineties on concepts developed by Sally Perrie

with Kenneth Allan Perrie during their time together living in South Lake Tahoe and before the

separation.

81. Sally Perrie did not understand that patents had been filed solely in the names of

Kenneth Allan Perrie and Olaf Vancura, effectively securing ownership away from Sally Perrie,

without her being named as an inventor.


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82. Sally Perrie was not informed that the rights to the intellectual property had been

assigned to Mikohn, Inc., without her authorization.

83. Sally Perrie was not provided with copies of agreements or account statements

relating to the disposition of the business.

84. Sally Perrie has never received a full accounting of the money generated from

licensing, sale, and/or assignment or other disposition of rights in, to or relating to the patents.

85. Sally Perrie has never received a full accounting of the money generated from

other intellectual property relating to the board gaming development of the business.

86. In all respects, and at all time, Kenneth Allan Perrie took on the responsibility nd

acted as a fiduciary for Sally Perrie in their business partnership for the development and

marketing of the

COUNT ONE

(CAUSE OF ACTION FOR DECLARATORY RELIEF SEEKING CORRECTION OF

PATENT INVENTORSHIP OF THE YAHTZEE PATENTS)

87. Sally Perrie hereby incorporates and fully realleges by this reference, a though

fully set forth herein, each and every allegation contained in paragraphs 1 through 86 of this

Complaint.

88. Kenneth Allan Perrie knew, or should have known that the discoveries, creations

and inventions described above were conceived, created and invented by Sally Perrie.

89. Sally Perrie is the sole inventor or, in the alternative, a joint inventor of the

subject matter disclosed and claimed in the YAHTZEE PATENTS. As the sole inventor or, in

the alternative, joint inventor of the subject matter disclosed and claimed in the YAHTZEE

PATENTS, Sally Perrie owns or, in the alternative, jointly owns the YAHTZEE PATENTS and

maintains sole or, in the alternative, joint equitable title therein.

90. The inventorship of the YAHTZEE PATENTS must be corrected pursuant to 35

U.S.C. § 256 to name Sally Perrie as the sole inventor or, in the alternative, a joint inventor.


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91. As a direct, legal and proximate result of being omitted as an inventor or, in the

alternative, a joint inventor of the YAHTZEE PATENTS, Sally Perrie has suffered damage and

is entitled to declaratory relief and other relief and remedies as described in paragraphs A

through T of this complaint.

92. WHEREFORE, Sally Perrie prays for judgment as hereinafter set forth.

COUNT TWO

(CAUSE OF ACTION FOR DECLARATORY RELIEF SEEKING CORRECTION

OF PATENT INVENTORSHIP OF THE BATTLSHIP PATENTS)



Complaint.




subject matter disclosed and claimed in the BATTLESHIP PATENTS. As the sole inventor or, in

the alternative, joint inventor of the subject matter disclosed and claimed in the BATTLESHIP

PATENTS, Sally Perrie owns or, in the alternative, jointly owns the BATTLESHIP PATENTS

and maintains sole or, in the alternative, joint equitable title therein.

96. The inventorship of the BATTLESHIP PATENTS must be corrected pursuant to

35 U.S.C. § 256 to name Sally Perrie sd the sole inventor or, in the alternative, a joint inventor.


alternative, a joint inventor of the BATTLESHIP PATENTS, Sally Perrie has suffered damage

and is entitled to declaratory relief and other relief and remedies as described in paragraphs A




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COUNT THREE

(CAUSE OF ACTION FOR DECLARATORY RELIEF SEEKING CORRECTION

OF PATENT INVENTORSHIP OF THE MONOPOLY PATENTS)



Complaint.




subject matter disclosed and claimed in the MONOPOLY PATENTS. As the sole inventor or, in

the alternative, joint inventor of the subject matter disclosed and claimed in the MONOPOLY

PATENTS, Sally Perrie owns or, in the alternative, jointly owns the MONOPOLY PATENTS

and maintains sole or, in the alternative, joint equitable title therein.

102. The inventorship of the MONOPOLY PATENTS must be corrected pursuant to

35 U.S.C. § 256 to name Sally Perrie as the sole inventor or, in the alternative, a joint inventor.


alternative, a joint inventor of the MONOPOLY PATENTS, Sally Perrie has suffered damage

and is entitled to declaratory relief and other relief and remedies as described in paragraphs A



COUNT FOUR

(CAUSE OF ACTION FOR DECLARATORY RELIEF AND DAMAGES ARISING

FROM BREACH OF EXPRESS CONTRACT AGAINST DEFENDANT)



Complaint.


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106. During the development of the patents, Kenneth Allan Perrie at all times managed

the business for the Perries, including marketing of the business to casinos and game developers,

such as MiKohn, Inc., and received all funds resulting from the commercialization of the

YAHTZEE PATENTS, the BATTLESHIP PATENTS and the MONOPOLY PATENTS in his

own name.

107. The Parties operated their casino game development business under an express

oral agreement that Kenneth Allan Perrie would manage the business for the Parties, as partners

in the game development business, as co-developers of the games, and for the benefit of their

mutual family interests.

108. The Parties operated their casino game development business as under an express

oral agreement that Kenneth Allan Perrie would manage the licensing and contracting of the

developed games for the mutual benefit of both Parties and disburse all funds accordingly and

fairly.

109. During the marriage, Kenneth Allan Perrie regularly, and for much of the

marriage on a monthly basis, paid over to Sally Perrie a portion of the proceeds of the business.

110. In light of the divorce proceedings between the parties, Sally Perrie now comes to

see that she was wrongly omitted as an inventor on the YAHTZEE PATENTS, the

BATTLESHIP PATENTS and the MONOPOLY PATENTS, as alleged in Counts One, Two and

Three herein.

111. Further in light of the divorce proceedings, Sally Perrie now comes to see that she

was wrongly denied her true share in the remuneration received by Kenneth Allan Perrie from

the business.

112. Further in light of the divorce proceedings, Sally Perrie now comes to see that she

was wrongly denied an accounting of the proceeds, monetary or otherwise, received by Kenneth

Allan Perrie from the business.


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113. Sally Perrie has performed all of her obligations under the terms of the express

contract between the Parties as to promotion of the gaming business, except insofar as Sally

Perrie was prevented from fulfilling her obligations as a result of Kenneth Allan Perrie’s conduct

or was excused from such obligations as a result of being deliberately excluded and prevented

from performing same by Kenneth Allan Perrie.

114. Kenneth Allan Perrie has breached the express contract between the Parties as

alleged in paragraphs 1 through 104 of this complaint.

115. As a direct, legal and proximate result of Kenneth Allan Perrie’s breach of the

express contract, Sally Perrie has suffered damage and is entitled to declaratory relief, monetary

compensation and other relief and remedies as described in paragraphs A through T of this

complaint.


COUNT FIVE

(CAUSE OF ACTION FOR DECLARATORY RELIEF AND DAMAGES ARISING

FROM BREACH OF THE IMPLIED CONTRACT AGAINST DEFENDANT)



Complaint.

118. The Parties operating their casino game development business as co-developers

and partners, with an implied contractual understanding that actions taken by Kenneth Allan

Perrie in promotion, sales, licensing or other business arrangements or agreement for monetary

or other remuneration would inure to the benefit of the partnership and/or the family interest.

119. Sally Perrie has performed all of her obligations under the terms of the implied

contractual or other understanding between the Parties as to promotion of the gaming business,

except insofar as Sally Perrie was prevented from fulfilling her obligations as a result of Kenneth


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Allan Perrie’s conduct or was excused from such obligations as a result of being deliberately

excluded and prevented from performing same by Kenneth Allan Perrie.

120. Kenneth Allan Perrie has breached the implied contractual understanding between

the Parties as alleged in paragraphs 1 through 116 of this complaint.

121. As a direct, legal and proximate result of Kenneth Allan Perrie’s breach of the

implied contractual understanding, Sally Perrie has suffered damage and is entitled to declaratory

relief, monetary compensation and other relief and remedies as described in paragraphs A



COUNT SIX

(CAUSE OF ACTION FOR AN INJUNCTION ORDERING KENNETH ALLAN

PERRIE TO ABIDE BY HIS FIDUCIARY DUTY TO SALLY PERRIE AND PROVIDE

AN ACCOUNTING OF THE BUSINESS)



Complaint.

124. Sally Perrie seeks an award of specific performance requiring Defendant Kenneth

Allan Perrie to provide a full and honest accounting of the compensation received by Kenneth

Allan Perrie for the YAHTZEE PATENTS, the BATTLESHIP PATENTS and the MONOPOLY

PATENTS.

125. As a direct, legal and proximate result of Kenneth Allan Perrie’s breach of his

fiduciary duty, Sally Perrie has suffered damage and is entitled to declaratory relief, monetary


complaint.



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COUNT SEVEN

(CAUSE OF ACTION FOR DAMAGES ARISING FROM THE UNJUST

ENRICHMENT OF KENNETH ALLAN PERRIE BASED ON HIS BREAH OF

FIDUCIARY DUTY TO SALLY PERRIE))



Complaint.

128. Through a pattern of activity Kenneth Allan Perrie Sally Perrie has received extra

compensation from the managing of the Parties’ gaming business, by breaching his duties and

obligations of a contractual and fiduciary nature, as alleged in Counts Four, Five and Six, herein.

129. As a direct, legal and proximate result of Kenneth Allan Perrie’s breach of his

contractual and fiduciary duties, Kenneth Allan Perrie has been unjustly compensated, and to

that extent Sally Perrie has suffered damage and is entitled to declaratory relief, monetary


complaint.


PRAYER FOR RELIEF

WHEREFORE, Sally Perrie prays that this Court enter judgment in her favor against the

Defendant, including judgment that:

A. Sally Perrie is the sole or a joint inventor of the ‘106 patent;

B. Sally Perrie is the sole or a joint inventor of the ‘265 patent;

C. Sally Perrie is the sole or a joint inventor of the ‘901 patent;

D. Sally Perrie is the sole or a joint inventor of the ‘948 patent;

E. Sally Perrie is the sole or a joint inventor of the ‘055 patent;

F. Sally Perrie is the sole or a joint inventor of the ‘016 patent;

G. Sally Perrie is the sole or a joint inventor of the ‘071 patent;


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H. Sally Perrie is the sole or a joint inventor of the ‘088 patent;

I. Sally Perrie is the sole or a joint inventor of the ‘713 patent;

J. Sally Perrie is the sole or a joint inventor of the ‘644 patent;

K. Sally Perrie is the sole or a joint inventor of the ‘686 patent;

L. Sally Perrie is the sole or a joint inventor of the ‘235 patent;

M. Sally Perrie is the sole or a joint inventor of the ‘505 patent;

N. Sally Perrie is the sole or a joint inventor of the ‘955 patent;

O. An award of damages is entered against Kenneth Allan Perrie for breach of

express contract and breach of implied contract arising under the statutory and

common law of California;

P. An award of damages is entered against Kenneth Allan Perrie for unjust

enrichment breach of fiduciary duty;

Q. An injunction is entered against Kenneth Allan Perrie preventing further

violations of his fiduciary duty to Sally Perrie with regard to their game

development business;

R. That Kenneth Allan Perrie be ordered to provide a full, accurate and honest

accounting of all funds received by the Perries’ gaming business;

S. An award of damages is entered against Kenneth Allan Perrie adequate to

compensate Sally Perrie for his failure to provide her with just compensation for

his share in their game development business, together with pre-judgment interest

and costs;

T. Any and all such other relief as this Court deems just and proper.

DEMAND FOR JURY TRIAL

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Sally Perrie hereby

demands a trial by jury of all issues properly triable to a jury.


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Dated: August 1, 2014 SCHWEDLER LAW GROUP

/s/ Carl J. Schwedler CARL J. SCHWEDLER Attorney for Plaintiff,

SALLY PERRIE

perrie v. perrie

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