COMPLAINT

Plaintiff Treehouse Avatar Technologies Inc. with a principal place of business at 11

Holland Avenue, Suite 608, Ottawa ON, K1Y 4S1, Canada (“Treehouse“), alleges the following

for its complaint against Snail Games USA Inc. (“Snail Games“), a company located at 1424

Lincoln Boulevard, Santa Monica, CA 90401, and incorporated in the state of California:

NATURE OF THE SUIT

1. This is a civil action for infringement of United States Patent No. 8,180,858 (the

“’858 Patent”). This action arises under the laws of the United States related to patents,

including 35 U.S.C. § 281.