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Aristocrat Techs. Australia Pty, Ltd. v. Int'l Game Tech.

The appellants, referred to collectively as “Aristocrat,” are the owner and exclusive licensee of U.S. Patent No. 6,093,102 (“the ’102 patent”). The patent is directed to an electronic slot machine that allows a player to select winning combinations of symbol positions. The appellees, referred to collectively as “IGT,” manufacture and sell gaming products that Aristocrat asserts infringe the ’102 patent. In an infringement action brought by Aristocrat against IGT in the United States District Court for the District of Nevada, the district court held all of the claims of the ’102 patent invalid for indefiniteness.

The game disclosed in the ’102 patent purportedly increases player interest in slot machines by providing the player with greater control over the definition of winning opportunities. It allows the player to define the winning opportunities based on symbols displayed on the top and side of a multi-line screen representing slot machine reels. Using the invention on a 3x5 screen, for example, the player can define numerous different arrangements that will allow the player to win for some subset of the 243 possible winning combinations. The player can do so by selecting symbol positions and thereby activating winning opportunities for combinations in which the symbols are not necessarily aligned with one another. The only constraint is that the selected combination must contain at least one symbol from each column. Figure 2 from the ’102 patent shows a 3x5 screen with selections, and the figure on the right shows one of the winning combinations for the selection in Figure 2.

On summary judgment, the trial court held all of the claims of the ’102 patent invalid. Aristocrat does not dispute that all of the claims rise and fall together. Like the parties, we therefore focus on independent claim 1.

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