`13380 Streamside Court Lake Oswego, OR 97035
`(503) 764-5614 stacy@olympiangaming.com
`
`SUMMARY
`
`Creative technology product consultant with over 20 years’ experience in product design, development, and IP
`strategy across several industry sectors, including enterprise software, mobile and online gaming, and casino
`gambling. Harvard degree in computer science, magna cum laude. Key product design resource for several small
`technology companies leading to over $500M in total M&A activity.
`
`Named inventor on over 30 U.S. Patents. Managing an IP portfolio of over 40 assets including patents and
`trademarks. Pro se and counsel-assisted patent prosecution including initial specification/claims drafting, office
`action responses, and appeal brief drafting. Successfully negotiated several IP transactions.
`
`Subject matter expert consulting and expert witness testimony in nearly 40 disputes or litigations in US and
`internationally (Canada, UK, Costa Rica). Matters include patent infringement, trade secret misappropriation,
`USPTO proceedings (inter partes review, covered business method review, ex parte reexamination), breach of
`contract, criminal proceedings, and pre-litigation analysis. Over 50 written expert reports or declarations.
`Testimony at deposition, 8 times. Testimony at hearing or trial, 7 times, including appearances in U.S. district
`courts, U.S. state courts, and patent courts in UK and Canada.
`
`Expert analysis tasks included: software source code review, review of specialty hardware (regulated gaming
`equipment), technical systems analysis, prior art search/analysis, regulatory compliance analysis, patent claim
`construction, patent validity and infringement, trade secret analysis, trade secret reverse engineering, analysis of
`other experts’ opinions.
`
`EXPERT CONSULTANT EXPERIENCE
`
`Inter partes review, networked gaming system
`Client: counsel for petitioner. Tasks: validity analysis, expert declarations. 2019-ongoing.
`
`Patent infringement, networked gaming system
`Client: plaintiff. Tasks: infringement analysis, validity analysis, expert report. 2018-ongoing.
`
`Patent infringement, electronic gaming machines
`Client: plaintiff. Tasks: infringement analysis, validity analysis, expert report. 2018-ongoing.
`
`Inter partes review, electronic gaming machines
`Client: patent owner. Tasks: validity analysis, expert declarations. 2018-ongoing.
`
`Bookman v. Resorts World Casino, Genting New York and Int’l Game Technology (IGT), breach of
`contract & negligence, slot machine abnormality/withheld jackpot
`Client: Alan Ripka for plaintiff. Tasks: technical investigation, expert affidavit. 2018.
`
`Inter partes review, networked gaming system
`Client: counsel for patent owner. Tasks: validity analysis. 2017-2018.
`
`Aristocrat Technologies v. High 5 Games, inter partes review, slot machine method
`Client: Covington Burling for petitioner. Tasks: prior art research, validity analysis, IPR declaration, deposition
`testimony. 2017-ongoing.
`
`Misappropriation of intellectual property, networked gaming machines
`Client: counsel for plaintiff. Tasks: functional analysis of network-connected gaming machines, trade secret analysis,
`source code review, expert report, deposition testimony. 2017-ongoing.
`
`Compliance investigation, electronic gaming machines
`Client: counsel for petitioner. Tasks: examine behavior of electronic gaming machines with respect to regulations
`and state court opinions. 2015-2018.
`
`Supercell
`Exhibit 1004
`Page 1
`
`
`
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`Int’l Game Technology (IGT) v. Aristocrat Technologies, patent infringement, gaming machines
`Client: Covington Burling for defendant. Tasks: prior art research, validity analysis, IPR declarations. Disposition:
`confidential settlement. 2015-2016.
`
`Misappropriation of intellectual property, networked gaming system
`Client: counsel for plaintiff. Tasks: technical analysis, trade secret analysis. 2015-2018.
`
`Patent infringement (pre-litigation), networked gaming system
`Client: counsel for defendant. Tasks: validity analysis. Disposition: litigation averted due to my analysis. 2015.
`
`International Internet Technologies, LLC v. Sweepstakes Patent Company, LLC, covered business
`method review, networked gaming system
`Client: Schneider Rothman for patent owner. Tasks: validity and infringement analysis, written reports, deposition
`testimony. Disposition: patent found invalid during CBM review. 2015-2016.
`
`
`Abnormality analysis, networked gaming machines
`Client: counsel for defendant. Tasks: log file forensic analysis, source code analysis. Disposition: confidential
`settlement. 2015-2016.
`
`MEI-GSR Holdings, LLC d/b/a Grand Sierra Resort v. Peppermill Casinos, Inc., misappropriation of
`trade secrets, slot machine par settings
`Client: Robison, Belaustegui, Sharp & Low for defendant. Tasks: trade secret analysis, trade secret reverse
`engineering, damages analysis, written reports, trial testimony. Disposition: jury verdict for defendant. 2014-2016.
`
`MGT Gaming v. Aruze, patent infringement, slot machine system
`Client: Watson Rounds for defendant. Tasks: claim construction analysis, declaration. Disposition: confidential
`settlement. 2014-2015.
`
`SHFL Entertainment v. GTECH, patent infringement, online gaming system
`Client: McCarter & English for defendant. Tasks: validity analysis. Disposition: confidential settlement. 2014.
`
`Stephenson v. Worldwinner, inter partes review, networked tournament system patent
`Client: Merchant & Gould for patent owner. Tasks: validity analysis, expert declaration, deposition testimony.
`Disposition: patent invalid for anticipation. 2013-2015.
`
`Agincourt Gaming v. Zynga, patent infringement, network gaming system
`Client: Quinn Emanuel Urquhart & Sullivan for defendant. Tasks: prior art research, validity analysis. Disposition:
`confidential settlement. 2013-2014.
`
`eLot v. GTECH, patent infringement, networked lottery system
`Client: Finnegan, Henderson, Farabow, Garrett & Dunner for defendant. Tasks: infringement analysis and validity
`analysis. Disposition: confidential settlement. 2013.
`
`Big Daddy Games v. Reel Spin Studios, copyright infringement, gaming machines
`Client: Michael Best for defendant. Tasks: source code analysis, written report, deposition testimony. Disposition:
`confidential settlement. 2012.
`
`Seneca Nation of Indians v. State of New York, regulatory dispute, video lottery terminals
`Client: Kanji & Katzen / Harter Secrest & Emery for plaintiff. Tasks: systems and network protocol analysis,
`gameplay analysis, regulation analysis, written reports, testimony at hearing. Disposition: public settlement of over
`$600M dispute. 2012-2013.
`
`Safe Gaming System Inc. v. Atlantic Lottery Corp., patent infringement, networked gaming system
`Client: Borden Ladner Gervais for defendant. Tasks: infringement analysis, validity analysis, written reports, trial
`testimony (Federal Court of Canada). Disposition: dismissal / judgment for defendant. 2012-2018.
`
`eLot v. Atlantic Lottery Corporation, patent infringement, Internet lottery system
`Client: Borden Ladner Gervais for defendant. Tasks: infringement analysis, validity analysis, written report.
`Disposition: favorable settlement shortly after my report was submitted. 2012-2014.
`
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`Supercell
`Exhibit 1004
`Page 2
`
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`Fortunet v. Playbook Publishing, misappropriation of trade secrets, proprietary wagering methods
`Client: Watson Rounds for plaintiff. Tasks: evaluation of differences between wagering methods produced by both
`parties, written report, trial testimony. Disposition: jury verdict partly in favor of plaintiff. 2011-2013.
`
`McKee v. Isle of Capri Casinos, breach of contract & consumer fraud, slot machine
`abnormality/withheld jackpot
`Client: Donnelly Nelson Depolo Murray for plaintiff. Tasks: analysis of slot machine forensic report. My engagement
`was terminated when I disputed counsel’s technical interpretations. Disposition: summary dismissal. 2011-2012.
`
`Legal iGaming / Zynga v. Int’l Game Technology (IGT), patent interference, networked gaming system
`Client: Morrison Foerster for senior party defendant. Tasks: patent analysis, expert declaration. Disposition: PTO
`verdict for defendant. 2011.
`
`Gaming patent review (pre-litigation/confidential), networked gaming machine methods
`Tasks: prior art research, infringement analysis, validity analysis. 2011.
`
`Lottotron v. Allgames Casino, patent infringement, remote wagering system
`Client: Stadheim Grear for plaintiff. Tasks: damages analysis and testimony at damages hearing. Disposition:
`plaintiff awarded damages over $14M. 2011.
`
`WMS Gaming v. Bally Technologies, patent infringement, slot machine technologies
`Client: Quinn Emanuel Urquhart & Sullivan for defendant. Tasks: prior art research, validity analysis. Disposition:
`confidential settlement. 2011.
`
`Lottotron v. EH New Ventures, patent infringement of remote wagering system
`Client: Stadheim Grear for plaintiff. Tasks: Infringement analysis, written testimony, deposition testimony, trial
`testimony. Disposition: jury verdict for defendant. 2010-2012.
`
`Compliance investigation, charitable bingo machines
`Client: Thunderbird Casino, Costa Rica. Tasks: investigation and analysis of gameplay on electronic bingo machines
`relative to regulatory language, written report submitted to national legislator. 2010-2011.
`
`Compliance investigation, charitable bingo machines
`Client: Alabama Attorney General. Tasks: investigation and analysis of gameplay on multiple manufacturers’
`electronic bingo machines in view of Alabama Supreme Court ruling, pre-litigation technical support. Disposition:
`project terminated due to Governor’s intervention. 2010.
`
`State of California v. Wilkins, theft, casino loyalty club points
`Client: Public Defender, Humboldt County, CA for defendant. Tasks: evaluation of casino accounting data, damages
`calculation, written testimony. Disposition: case settled for the amount I calculated. 2009-2010.
`
`Dottie Janousek v. Canyon Casino, breach of contract, slot machine abnormality/withheld jackpot
`Client: Helmer McElyea for plaintiff. Tasks: analysis of slot machine forensic report and supporting evidence, written
`testimony. Disposition: based on my testimony, plaintiff received satisfactory settlement. 2009.
`
`Golden Route v. Ardent Gaming, breach of contract, casino accounting system
`Client: John Peter Lee for defendant. Tasks: contract review, software specification review, system data analysis,
`written report. Disposition: confidential settlement. 2009.
`
`Cranway v. Playtech (United Kingdom), patent infringement, online gaming system
`Client: Herbert Smith for plaintiff. Tasks: infringement and validity analysis, written testimony and testimony at
`trial. Disposition: patent was found invalid as excluded matter under UK patent law. 2008-2009.
`
`International Gamco v. Multimedia Games, patent infringement, video lottery system
`Client: Luce, Forward, Hamilton & Scripps for defendant. Tasks: infringement and validity analysis, written
`testimony and deposition testimony. Disposition: summary judgment for defendant. 2006-2010.
`
`Aristocrat Technologies v. Multimedia Games, patent infringement, video lottery machines
`Client: Luce, Forward, Hamilton & Scripps for defendant. Tasks: infringement and validity analysis, written
`testimony and deposition testimony. Disposition: settled in favor of defendant shortly after my deposition was taken.
`2006-2008.
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`Supercell
`Exhibit 1004
`Page 3
`
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`HomeBingo v. Multimedia Games, patent infringement, electronic bingo system
`Client: Fish & Richardson for defendant. Tasks: infringement and validity analysis, written testimony. Disposition:
`settled in defendant’s favor after Judge, in Markman ruling, opined that defense construction was “in all respects,
`proper.” 2006-2007.
`
`State of Mississippi v. (unknown defendant), felony cheating at gambling
`Client: Mississippi Gaming Commission. Tasks: provided statistical evidence for cheating vs. probability of random
`outcomes. Disposition: indictment handed down by grand jury. 2005.
`
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`PUBLICATIONS AND MEDIA INTERVIEWS
`
`
`April 2014
`
`Web radio interview for Casino Enterprise Management podcast “Casino Talk with Brooke Dunn”
`regarding new casino game concepts.
`
`
`January 2011 Video interview for CBS News show “60 Minutes” regarding video slot machine gameplay. Published
`on the CBS News website.
`
`
`March 2010 Written article in Casino Journal: “Gaming’s Greatest Hits: 6 Ideas that Changed the Industry”
`
`March 2007
`
`Radio interview for National Public Radio show “Justice Talking” regarding slot machine design and
`mathematics.
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`WORK AND BOARD EXPERIENCE
`
`
`2001-present OLYMPIAN GAMING, LLC, Beaverton, OR
`Gaming industry consulting, intellectual property consulting and game development
`President
` Developed profitable consulting practice around casino gameplay development and analysis,
`including custom software simulation and analysis
` Designed slot game models and new game features for land-based and online gaming vendors.
`Client list includes WagerWorks (IGT), Chartwell Technology, Parlay Entertainment, Diamond
`Game, Phantom EFX, and DEQ Systems.
` Designed and/or analyzed keno, bingo, lottery, blackjack, craps, roulette, poker, video poker, and
`many novel gaming propositions
` Advised clients in IP strategy, including patent clearance and potential design-arounds
` Provided expert witness testimony in many gaming-related lawsuits
` Developed IP portfolio including over 30 issued US patents and several trademarks
`o Executed IP licenses with several casino operators and gaming vendors
` Currently licensed by Washington State Gambling Commission; achieved regulatory game
`approvals in WA, NV, MS.
`
`
`2014-present CONGREGATION BETH ISRAEL, Portland, OR
`Board Treasurer, 2018-present
`Member, Board of Trustees, 2014-2018
`
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`2011-2013
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`DOUBLE DOWN INTERACTIVE / INTERNATIONAL GAME TECHNOLOGY, Seattle, WA
`Social casino operator
`Game Design Consultant / Gaming Strategist
` Redesigned and corrected casino game implementations for DDI's social casino game website
` Led casino-industry education efforts for non-casino casual games staff
` Designed all of DDI's casino gameplay prior to its $500M acquisition by IGT
` Product integration between DDI's social games platform and IGT's slot machine content
` Internal gaming expert for evaluating new product submissions and patent filings
`
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`2011-present VIZKINECT, Reno, NV
`
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`A visual data capture and analysis company
`
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`Member, Board of Advisors
` Advising early-stage technology company on strategic direction and application of biometric
`capture technology, including eye tracking and galvanic skin response, across several verticals
`
`Supercell
`Exhibit 1004
`Page 4
`
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`2006-2008
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`2003-2005
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`2002-2003
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`2000-2001
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`1998-2000
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`1996-1998
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`NIKE, Beaverton, OR
`A leading athletic footwear and apparel brand
`Senior Enterprise Architect
` Delivered service-oriented architecture (SOA) strategy and web service solutions
` Facilitated application and service architecture for key eCommerce initiatives
`o Resulted in over $1.4M in incremental revenue in first quarter after go-live
` Authored and delivered executive-education presentations on SOA and Web 2.0 collaboration
`
`SYSTEMS RESEARCH AND DEVELOPMENT (acquired by IBM), Las Vegas, NV
`A boutique software consultancy and developers of a fraud/collusion detection platform
`Senior Software Engineer and Technical Consultant
` Developed high-throughput data analysis software for use in identifying casino cheating rings and
`international terrorist cells: prevented at least two domestic terrorist incursions
` Derived computational algorithms for uncovering connections in biographical data
`Improved processing efficiency and throughput by 66%
`o
` Directed technical team during onsite implementation of secure web services for DoD/U.S. Navy
`Horizontal Fusion initiative, and provided military-spec technical documentation.
`o Successful deployment resulted in $90M acquisition by IBM
`
`PLUMTREE SOFTWARE (acquired by BEA), San Francisco, CA
`A pure-play portal software vendor
`Senior Software Engineer
` Delivered web service-based portal application (portlet) SDK for both Java and MS .NET
`o Contributed to over $50M in portal software sales
` Delivered .NET custom controls and Visual Studio plug-ins for no-code portlet development
` Contributed to web standards committees and helped architect remote portlet infrastructure
`
`RAPT (acquired by Microsoft), San Francisco, CA
`A supply-planning and pricing optimization software vendor
`Technical Implementation Engineer
` Managed client integration for software implementations at Sun Microsystems and H-P
`o Resulted in top-line uplift of $30M/quarter or roughly 2% revenue growth
` Developed custom SQL and PL/SQL database extraction/reporting software to deliver real-time
`intelligence to supply planning staff
`o Resulted in $15M/quarter cost reduction or roughly 2% profit growth
`
`SILICON GAMING (acquired by IGT), Palo Alto, CA
`A casino slot machine manufacturer
`Game Model Engineer
` Self-education in probability theory and combinatorics led to successful employment as a casino
`gaming mathematician
` Designed game flow and storyboards for slot machines, and developed and shipped mathematical
`models for over 50 games
`o Resulted in sales of hundreds of slot machines and over $10M in revenue
` Managed statistical verification and mathematical gameplay testing
` Liaison to state regulatory agencies; corrected prior errors in gaming lab submissions
`o Saved over $50,000 in regulatory fees
`
`ORACLE, Redwood Shores, CA
`A leading database and application software vendor
`Software Engineer / Senior Software Engineer
` Responsible for final-tier maintenance engineering for premier Oracle clients
` Proposed and achieved consensus on enhancements to worldwide support process, and rolled out
`new process within my own organization.
`o Resulted in 50% decrease in defect reports and 10% increase in CSR response
` Earned promotion to Senior Engineer within 12 months
` Managed scalability and performance testing process, and designed scalability test suite
` Directed performance testing during pre-sales engagement with the Norwegian tax authority
`o Resulted in a 10-year, $3.5M license
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`Supercell
`Exhibit 1004
`Page 5
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`1992-1996
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`EDUCATION
`
`HARVARD UNIVERSITY, Cambridge, MA
`Bachelor of Arts in Computer Science, magna cum laude
` John Harvard and Harvard College scholarship awards
` “Empirical Testing of Algorithms for Variable-Sized Label Placement” published in 1997 Journal
`of the Symposium on Computational Geometry
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`Supercell
`Exhibit 1004
`Page 6
`
`