15. StrikeForce offers a product called ProtectID® that performs out-of-band
authentication according to the teachings of one or more of the Asserted Patents. StrikeForce has
offered this product since August 2003, and ProtectID® has displayed the statutory patent notice
for its issued patents at its website, www.strikeforcetech.com, since about February 2011. In
particular, StrikeForce’s website identified the ’599 patent at least as early as February 2011;
StrikeForce’s website identified the ’698 patent at least as early as October 2013; and
StrikeForce’s website identified the ’701 patent at least as early as June 2014.
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.