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16. VASCO has been aware of StrikeForce’s out-of-band authentication products, including ProtectID®, since at least March 8, 2010, and at least the ’599 patent since at least November 10, 2011. For example, at the 2010 RSA Conference, StrikeForce met with representatives from VASCO, including Giovanni Verhaeghe, and showed VASCO its ProtectID® products. Upon information and belief, according to his LinkedIn profile, Mr. Verhaeghe has been Director Corporate Strategy and IPR at VASCO Data Security since October 2007.

17. StrikeForce remained in communication with representatives at VASCO, including Tom Barber, through November 2011. Upon information and belief, Mr. Barber was Director of Business Development at VASCO Data Security from February 2011 through December 2013. During this time, StrikeForce and VASCO discussed a potential partnership, with VASCO investing in StrikeForce’s technology. At least as early as November 10, 2011, StrikeForce provided materials to Mr. Barber describing its Multi-Factor Authentication Platform and identifying StrikeForce’s intellectual property, including the ’599 patent. Upon information and belief, VASCO did not offer its own out-of-band authentication product until after it had learned of StrikeForce’s Multi-Factor Authentication Platform and StrikeForce’s intellectual property.

Clear case of Willful Infringement/Treble DAMAGES