IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN

TOTALUP, INC., a Canadian Corporation Plaintiff v. ARUZE GAMING AMERICA, INC., a Nevada Corporation Defendant

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Case No.: _________________

JURY TRIAL DEMANDED

COMPLAINT Plaintiff TOTALUP, Inc. (TOTALUP) by and through its attorneys, Carlson, Gaskey & Olds, P.C., and for its Complaint against Defendant Aruze Gaming America, Inc (Aruze) states as follows: INTRODUCTION 1. This is an action for patent infringement brought by TOTALUP against Aruze

pursuant to Title 35 of the Unites States Code. PARTIES 2. TOTALUP is a Canadian corporation having a place of business at 391 Steelcase

Road West, Markham, Ontario, Canada L3R 3V9. 3. Aruze is a Nevada corporation having a place of business at 745 Grier Drive, Las

Vegas, Nevada 89119. JURISDICTION AND VENUE 4. This Court has original subject matter jurisdiction over the claims in this action

pursuant to 28 U.S.C. 1331 (federal question) and 1338 (patents).

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Aruze is subject to personal jurisdiction in this Court. In particular, this Court has

personal jurisdiction over Aruze because Aruze has engaged in continuous, systematic and substantial activities within this judicial district, including substantial marketing and sales of products in this judicial district. Furthermore, upon information and belief, this Court has personal jurisdiction over Aruze in this case because Aruze has committed acts giving rise to TOTALUPs claim for patent infringement within and directed to this judicial district. 6. Venue is proper in this judicial district under 28 U.S.C. 1391(b) and (c) and 28

U.S.C. 1400(b). TOTALUPS PATENT 7. On July 25, 2000, the United States Patent and Trademark Office duly and

lawfully issued United States Patent No. 6,093,101 (the TOTALUP patent), entitled Gaming Apparatus Including Slot Machine. attached hereto as Exhibit 1. 8. 9. 10. Raphael Mourad is the sole inventor of the Mourad Patent. On October 17, 2013, Mr. Mourad assigned the TOTALUP Patent to TOTALUP. The TOTALUP Patent generally relates to, inter alia, a novel multi-player A true and correct copy of the TOTALUP Patent is

electronic gambling system. DIRECT INFRINGEMENT 11. forth herein. 12. 13. The TOTALUP Patent remains valid, enforceable and unexpired. Upon information and belief, Aruze is directly infringing and has directly TOTALUP incorporates by reference paragraphs 1 through 9 as though fully set

infringed the TOTALUP Patent, including, without limitation, by making, using, selling, offering

for sale, and/or importing, without license or authority, gaming apparatus covered by the TOTALUP Patent, including but not limited to Aruzes Shoot to Win Craps and Lucky Big Wheel games (hereinafter the accused systems). 14. The accused systems fall within the scope of one or more claims of the

TOTALUP Patent. 15. Upon information and belief, Aruzes has had actual knowledge of the TOTALUP

Patent since at least November 2012. 16. Upon information and belief, Aruzes infringement has been and continues to be

willful and deliberate. 17. As a result of Aruzes infringement, TOTALUP will suffer severe and irreparable

harm, unless that infringement is enjoined by this Court, and has suffered substantial damages. PRAYER FOR RELIEF WHEREFORE, TOTALUP requests judgment in its favor against Aruze for the following relief: A. B. C. An Order adjudging that Aruze has infringed the TOTALUP Patent; An order adjudging Aruze to have willfully infringed the TOTALUP Patent. A preliminary and permanent injunction enjoining Aruze, its officers, directors,

agents, servants, employees and those persons in active concert or participation with Aruze, from directly or indirectly infringing the TOTALUP Patent in violation of 35 U.S.C. 271; D. infringement; E. An order for a trebling of damages and/or exemplary damages because of Aruzes An award of damages adequate to compensate TOTALUP for Aruzes

willful infringement pursuant to 35 U.S.C. 284;

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An Order adjudging that this is an exceptional case; An award to TOTALUP of its attorney fees and its costs and expenses incurred in

connection with this action pursuant to 35 U.S.C. 285; H. I. An award of prejudgment and post-judgment interest and costs of this action; and Such other and further relief that this Court deems just and proper. JURY DEMAND Pursuant to Fed R. Civ. P. 38(b) and 5(d), Plaintiff demands a trial by jury for all issues so triable.

Dated: October 31, 2013

/s/ Steven Susser________________ Steven Susser John E. Carlson Carlson, Gaskey & Olds, P.C. 400 W. Maple Rd., Suite 350 Birmingham, MI 48009 Telephone: (248) 988-8360 Facsimile: (248) 988-8363 ssusser@cgolaw.com jcarlson@cgolaw.com