`13380 Streamside Court Lake Oswego, OR 97035
`(503) 764-5614 stacy@olympiangaming.com
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`SUMMARY
`
`Creative technology product consultant with over 25 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 several dozen 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 over 50 disputes or litigations in US and
`internationally (Canada, UK, Australia, Costa Rica).
` Matters include patent infringement, trade secret
`misappropriation, USPTO proceedings (IPR, CBM, PGR, ex parte reexamination), breach of contract, criminal
`proceedings, and pre-litigation analysis. Over 80 written expert reports or declarations. More than 25 appearances
`at deposition, hearing or trial, including appearances in U.S. district courts, U.S. state courts, and patent courts in
`UK and Canada.
`
`Expert analysis tasks included: patent acquisition advice, software source code analysis, review of specialty hardware
`(regulated gaming equipment), game mathematics analysis, technical systems analysis, prior art search/analysis,
`regulatory compliance analysis, patent claim construction, patent validity and infringement, trade secret analysis,
`trade secret reverse engineering, gaming operations data, analysis of other experts’ opinions.
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`EXPERT CONSULTANT EXPERIENCE
`
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`Patent infringement, wagering systems and methods
`Client: counsel for defendant. Analyses: claim construction, validity. 2022-ongoing.
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`Patent infringement, casino management systems
`Client: counsel for defendant. 2022-ongoing.
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`Patent infringement, casino management systems
`Client: counsel for plaintiff. Analyses: infringement, practicing product, source code. 2022-ongoing.
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`Patent infringement, networked gaming systems
`Client: counsel for plaintiff. Analyses: infringement, source code. 2022-ongoing.
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`Acquisition consultation, networked gaming patents
`Client: patent acquisition/monetization firm. Analyses: infringement claim charts, validity in view of same. 2022.
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`Deceptive business practices, networked gaming technology
`Client: counsel for plaintiff. Analyses: contracts, documentary evidence, financial data. 2022-ongoing.
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`Fortunet v. Playbook Publishing, misappropriation of trade secrets, proprietary wagering methods
`Client: Hartwell Thalacker for plaintiff. Analysis: comparison of both parties’ wagering methods. Testimony: trial.
`2022-ongoing.
`
`Epic Tech LLC v. Pen-Tech LLC, patent infringement, networked gaming systems/methods
`Client: Fisher Broyles for defendant. Analyses: claim construction, validity, infringement. Testimony: declaration.
`2021-ongoing.
`
`Zenergy Systems, LLC v. Everi Payments, Inc., breach of contract, casino charitable donation systems
`Client: Pisanelli Bice for defendant. Analyses: contracts, documentary evidence, prior art, source code. Testimony:
`deposition. 2021-ongoing.
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`Stacy Friedman Expert CV | August 18, 2022
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`IGT EXHIBIT 2019
`Zynga v. IGT, IPR2022-00200
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`Pre-litigation analysis, networked gaming technology
`Client: counsel for potential defendant. Analyses: validity, infringement. 2021.
`
`Skillz Platform, Inc. v AviaGames, Inc, patent infringement and IPR, networked gaming
`systems/methods
`Client: Perkins Coie for defendant/IPR petitioner AviaGames. Analyses: claim construction, validity, infringement,
`source code. Testimony: declaration. 2021-ongoing.
`
`Interactive Communications Int’l, Inc. v. Blackhawk Network, Inc., PGR, lottery system
`Client: Cooley for patent owner. Analyses: claim construction, validity. Testimony: declaration, deposition.
`Disposition: patent claims found unpatentable. 2021-2022.
`
`Playtika Ltd. v. NEXRF Corp., IPRs, networked gaming systems/methods
`Client: Finnegan, Henderson for petitioner. Analysis: validity. Testimony: declarations, deposition. Disposition:
`Terminated after ineligibility appeals waived. 2021-2022.
`
`MQ Gaming v. LEGO Systems, patent infringement and IPR, networked gaming systems/methods
`Client: Finnegan, Henderson for plaintiff/patent owner MQ Gaming. Analyses: validity, infringement, source code.
`Disposition: confidential settlement. 2020-2021.
`
`GREE v. Supercell Oy, patent infringement, networked gaming systems/methods (multiple matters)
`Client: Fenwick & West for defendant. Analyses: claim construction, validity, infringement, source code. Testimony:
`declarations, depositions, trials. Dispositions: Jury verdicts for plaintiff, then confidential settlement. 2019-2021.
`
`INAG, Inc. v. Richar, Inc., patent infringement, casino gaming equipment
`Client: Fisher Broyles for defendant. Analyses: claim construction, validity, infringement. Testimony: deposition.
`2020-ongoing.
`
`Epic Tech LLC v. Fusion Skill, Inc. et al., patent infringement, networked electronic gaming machines
`Client: Dunlap Codding for defendant Texas Wiz. Analyses: validity, infringement, source code. Testimony:
`declarations, deposition. Disposition: Asserted patents found ineligible under Alice. 2020-2022.
`
`Patent infringement, electronic gaming machines
`Client: counsel for defendant. Analysis: validity. 2020, on hold.
`
`Bot M8 LLC v. Sony Corporation of America, patent infringement, networked gaming system
`Client: Kramer Levin Naftalis & Frankel for plaintiff. Analyses: validity, infringement, source code. Testimony:
`declarations, deposition. Disposition: Asserted patent found invalid. 2019-2020.
`
`Savvy Dog Systems LLC v. Pennsylvania Coin LLC, patent infringement, electronic gaming machines
`Client: Morgan, Lewis & Bockius for defendant. Analyses: claim construction, validity, source code. Testimony:
`declaration, deposition. 2019-ongoing.
`
`Tipping Point Gaming v. Caesars Entertainment, trade secret misappropriation, casino system
`Client: Greenberg Traurig for defendant. Analyses: trade secret, prior art. Disposition: claims dismissed with
`prejudice. 2019.
`
`MGM National Harbor v. Markel Insurance, damage assessment, electronic gaming machines
`Client: DeCaro Doran for defendant. Analyses: gaming machine evaluation after water damage, financial damages.
`Disposition: satisfactory settlement. 2019-2022.
`
`Aristocrat v. Ainsworth, trade secret misappropriation, gaming machine technology
`Client: Gilbert + Tobin for plaintiff. Analyses: forensic par sheet examination, mathematical analysis. Disposition:
`confidential settlement. 2019-2020.
`
`Treehouse Avatar v. Valve Corp., patent infringement, networked gaming system
`Client: plaintiff. Analyses: validity, infringement, source code. Testimony: deposition. Disposition: case dismissed.
`2018-2021.
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`Stacy Friedman Expert CV | August 18, 2022
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`FigureFun LLC v. LEGO Systems, patent infringement and IPR, electronic gaming machines
`Client: plaintiff/patent owner. Analyses: claim construction, validity. Testimony: declarations. Disposition: Final
`written decision. 2018-2019.
`
`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. Analysis: forensic gaming machine investigation. Testimony: expert affidavit. 2018.
`
`IPR, networked gaming system
`Client: counsel for patent owner. Analysis: validity. Removed from case. 2017-2018.
`
`Aristocrat Technologies v. High 5 Games, IPR, slot machine method
`Client: Covington & Burling for petitioner. Analysis: validity. Testimony: declaration, deposition. Disposition: all
`claims unpatentable. 2017-2019.
`
`Video Gaming Technologies (VGT) v. Castle Hill Gaming, misappropriation of intellectual property,
`Class II gaming machines
`Client: Covington & Burling for plaintiff. Analyses: Class II gaming machine functionality, trade secret, trade dress,
`source code. Testimony: declarations, deposition. Disposition: public settlement of $3M. 2017-2019.
`
`Kentucky Horse Racing Commission, et al. v Family Trust Foundation of Kentucky, compliance
`investigation, electronic gaming machines
`Client: Stoll Keenon Ogden for petitioner Keeneland Association. Analyses: behavior of historical horse racing (HHR)
`machines in view of regulations and state court opinions. 2015-2018.
`
`Int’l Game Technology (IGT) v. Aristocrat Technologies, patent infringement, gaming machines
`Client: Covington & Burling for defendant. Analysis: validity. Testimony: declarations. Disposition: confidential
`settlement. 2015-2016.
`
`AmTote International v. Kentucky Downs, misappropriation of intellectual property, networked
`gaming system
`Client: Gilbert’s LLP for plaintiffs AmTote and PariMAX. Analysis: historical horse racing (HHR) machines, system
`architecture, pari-mutuel mathematics, trade secret. Disposition: confidential settlement. 2015-2018.
`
`IGT v. AmTote International, patent infringement (pre-litigation), networked gaming system
`Client: Gilbert’s LLP for defendant. Analysis: validity. Disposition: litigation averted due to my analysis. 2015.
`
`International Internet Technologies, LLC v. Sweepstakes Patent Company, LLC, CBM review,
`networked gaming system
`Client: Schneider Rothman for patent owner. Analyses: validity, infringement. Testimony: deposition. Disposition:
`patent found invalid during CBM review. 2015-2016.
`
`
`Abnormality analysis, networked gaming machines
`Client: counsel for defendant. Analyses: log file, source code. 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. Analyses: trade secret, reverse engineering, damages.
`Testimony: trial. Disposition: jury verdict for defendant. 2014-2016.
`
`MGT Gaming v. Aruze, patent infringement, slot machine system
`Client: Watson Rounds for defendant. Analyses: claim construction, validity. Testimony: declaration. Disposition:
`confidential settlement. 2014-2015.
`
`SHFL Entertainment v. GTECH, patent infringement, online gaming system
`Client: McCarter & English for defendant. Analysis: claim construction, validity. Disposition: confidential settlement.
`2014.
`
`Stephenson v. Worldwinner, IPR, networked tournament system
`Client: Merchant & Gould for patent owner. Analyses: claim construction, validity. Testimony: declaration,
`deposition. Disposition: patent invalid for anticipation. 2013-2015.
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`Stacy Friedman Expert CV | August 18, 2022
`3
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`Agincourt Gaming v. Zynga, patent infringement, network gaming system
`Client: Quinn Emanuel Urquhart & Sullivan for defendant. Analysis: validity. Disposition: confidential settlement.
`2013-2014.
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`eLot v. GTECH, patent infringement, networked lottery system
`Client: Finnegan, Henderson, Farabow, Garrett & Dunner for defendant. Analysis: validity. Disposition: confidential
`settlement. 2013.
`
`Big Daddy Games v. Reel Spin Studios, copyright infringement, gaming machines
`Client: Michael Best for defendant. Analysis: graphical assets, source code. Testimony: declaration, deposition.
`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. Analyses: hardware functionality, network protocol,
`gameplay, regulatory. Testimony: sworn witness statement, 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. Analyses: claim construction, validity, infringement. Testimony: trial
`in 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. Analyses: claim construction, validity. Disposition: favorable
`settlement shortly after my report was submitted. 2012-2014.
`
`Fortunet v. Playbook Publishing, misappropriation of trade secrets, proprietary wagering methods
`Client: Watson Rounds for plaintiff. Analysis: comparison of both parties’ wagering methods. Testimony: trial.
`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. Analysis: 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. Analysis: claim construction, validity. 2011.
`
`Gaming patent review (pre-litigation/confidential), networked gaming machine methods
`Client: Counsel for potential plaintiff. Analyses: prior art research, validity, infringement. 2011.
`
`Lottotron v. Allgames Casino, patent infringement, remote wagering system
`Client: Stadheim Grear for plaintiff. Analyses: damages for defaulting defendants. Testimony: declaration, 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. Analysis: validity. Disposition: confidential settlement.
`2011.
`
`Lottotron v. EH New Ventures, patent infringement of remote wagering system
`Client: Stadheim Grear for plaintiff. Analyses: infringement. Testimony: declarations, deposition, trial. Disposition:
`jury verdict for defendant. 2010-2012.
`
`Compliance investigation, charitable bingo machines
`Client: Thunderbird Casino, Costa Rica. Analyses: investigation of gameplay on electronic bingo machines,
`comparison to regulatory language. Written report submitted to national legislator. 2010-2011.
`
`Compliance investigation, charitable bingo machines
`Client: Alabama Attorney General. Analyses: investigation of 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.
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`Stacy Friedman Expert CV | August 18, 2022
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`State of California v. Wilkins, theft, casino loyalty club points
`Client: Public Defender, Humboldt County, CA for defendant. Analyses: evaluation of casino accounting data,
`damages calculation. Disposition: case settled for the amount I calculated. 2009-2010.
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`Dottie Janousek v. Canyon Casino, breach of contract, slot machine abnormality/withheld jackpot
`Client: Helmer McElyea for plaintiff. Analysis of slot machine forensic report. Disposition: based on my analysis,
`plaintiff received satisfactory settlement. 2009.
`
`Golden Route v. Ardent Gaming, breach of contract, casino accounting system
`Client: John Peter Lee for defendant. Analyses: contract language, software specification, system data. Disposition:
`confidential settlement. 2009.
`
`Cranway v. Playtech (United Kingdom), patent infringement, online gaming system
`Client: Herbert Smith for plaintiff. Analyses: infringement, validity. Testimony: declaration, trial in High Court in
`London. Disposition: patent found invalid. 2008-2009.
`
`International Gamco v. Multimedia Games, patent infringement, video lottery system
`Client: Luce, Forward, Hamilton & Scripps for defendant. Analyses: infringement, validity. Testimony: declarations,
`deposition. Disposition: summary judgment for defendant. 2006-2010.
`
`Aristocrat Technologies v. Multimedia Games, patent infringement, video lottery machines
`Client: Luce, Forward, Hamilton & Scripps for defendant. Analyses: infringement, validity. Testimony: declarations,
`deposition. Disposition: settled in favor of defendant shortly after my deposition was taken. 2006-2008.
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`HomeBingo v. Multimedia Games, patent infringement, electronic bingo system
`Client: Fish & Richardson for defendant. Analyses: claim construction, infringement, validity. Testimony:
`declaration. Disposition: settled in defendant’s favor after claim construction order. 2006-2007.
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`State of Mississippi v. (unknown defendant), felony cheating at gambling
`Client: Mississippi Gaming Commission. Analysis: 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.
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`January 2011 Video interview for CBS News show “60 Minutes” regarding video slot machine gameplay. Published
`on the CBS News website.
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`March 2010 Written article in Casino Journal: “Gaming’s Greatest Hits: 6 Ideas that Changed the Industry”
`
`March 2007
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`Radio interview for National Public Radio show “Justice Talking” regarding slot machine design and
`mathematics.
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`WORK AND BOARD EXPERIENCE
`
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`2001-present OLYMPIAN GAMING, LLC, Lake Oswego, 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
`• Social game design and virtual economy design for casual mobile or web games
`• Advised clients in IP strategy, including patent clearance and potential design-arounds
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`Stacy Friedman Expert CV | August 18, 2022
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`2014-2020
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`2011-2013
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`2011-2014
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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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`• 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
`• Held licenses from Washington State Gambling Commission and Nisqually Tribal Gaming
`Commission; achieved regulatory game approvals in WA, NV, MS.
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`CONGREGATION BETH ISRAEL, Portland, OR
`Board Treasurer, 2018-2020
`Member, Board of Trustees, 2014-2018
`
`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
`
`VIZKINECT, Reno, NV
`A visual data capture and analysis company
`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
`
`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
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`Stacy Friedman Expert CV | August 18, 2022
`6
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`1998-2000
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`1996-1998
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`1992-1996
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`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 over 50
`mathematical game models
`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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`EDUCATION
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`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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`Stacy Friedman Expert CV | August 18, 2022
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