An essential element of K-12 AI literacy is educating learners about the ethical and societal implications of AI systems. Previous work in AI ethics literacy have developed curriculum and classroom activities that engage learners in reflecting on the ethical implications of AI systems and developing responsible AI. There is little work in using game-based learning methods in AI literacy. Games are known to be compelling media to teach children about complex STEM concepts. In this work, we developed a competitive card game for middle and high school students called “AI Audit” where they play as AI start-up founders building novel AI-powered technology. Players can challenge other players with potential harms of their technology or defend their own businesses by features that mitigate these harms. The game mechanics reward systems that are ethically developed or that take steps to mitigate potential harms. In this paper, we present the game design, teacher resources for classroom deployment and early playtesting results. We discuss our reflections about using games as teaching tools for AI literacy in K-12 classrooms.