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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: carl@schwedlerlaw.com 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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COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES: [PATENT INVENTORSHIP]
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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. 10.
Sally Perrie is an inventor of the ‘265 patent. 11.
On information and belief, the entire right to the ‘265 patent was improperly applied for and subsequently improperly assigned by Kenneth Allan Perrie and Olaf Vancura without the authorization of Sally Perrie.
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COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES: [PATENT INVENTORSHIP]
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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 incorrectly listed as the sole joint inventors. 13.
Sally Perrie is an inventor of the ‘901 patent. 14.
On information and belief, the entire right to the ‘901 patent was improperly applied for and subsequently improperly assigned by Kenneth Allan Perrie and Olaf Vancura without the authorization of Sally Perrie. 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. 16.
Sally Perrie is an inventor of the ‘948 patent. 17.
On information and belief, the entire right to the ‘948 patent was improperly applied for and subsequently improperly assigned by Kenneth Allan Perrie and Olaf Vancura without the authorization of Sally Perrie. 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 incorrectly listed as the sole joint inventors. 19.
Sally Perrie is an inventor of the ‘055 patent. 20.
On information and belief, the entire right to the ‘055 patent was improperly applied for and subsequently improperly assigned by Kenneth Allan Perrie and Olaf Vancura without the authorization of Sally Perrie. 21.
U.S. Patent No. 6,746,016 ("the ‘016 patent") titled “Poker dice casino game method of play" issued on June 8, 2004, with Kenneth Allan Perrie an Olaf Vancura incorrectly listed as the sole joint inventors. 22.
Sally Perrie is an inventor of the ‘016 patent.
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