Case 1:17-cv-00309-CMH-TCB Document 99 Filed 09/13/17 Page 1 of 24 PageID# 2356

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION


STRIKEFORCE TECHNOLOGIES, INC.,
Plaintiff,
v.
ENTRUST, INC., ENTRUST DATACARD
CORPORATION, and CYGNACOM
SOLUTIONS, INC.,
Defendants.


JURY TRIAL DEMANDED

Civil Action No. 1:17-cv-00309-CMH-TCB

MEMORANDUM IN SUPPORT OF PLAINTIFF’S
OPPOSITION TO DEFENDANTS’ MOTION FOR PROTECTIVE ORDER

Blank areas in the following red print were blacked out......

In the briefing ordered by this Court, StrikeForce has already discussed in depth the factors
set forth in Flame, demonstrating that Entrust, Inc., EDC, and EDL are so closely intertwined that
Entrust, Inc. and EDC can properly be ordered to produce information from EDL. Dkt. No. 82.
Additional information uncovered since the parties’ Flame briefing only reinforces this
conclusion. For example, Mr. Wetmore testified that,
Further, EDL apparently
has the ability
. Additionally, during development of the Accused
Products,
Moreover, Entrust, Inc. and EDL also have

III. CONCLUSION
For the foregoing reasons, StrikeForce respectfully requests that Entrust’s motion for
protective order be denied.

12 StrikeForce was intending on filing a cross-motion to compel concerning the 30(b)(6)
depositions. Counsel for Entrust and StrikeForce conferred and agreed that StrikeForce’s crossmotion
would be unnecessary in view of Entrust’s motion. In view of this, StrikeForce believes
that is appropriate in this Response to request that the Court issue an order compelling the second
deposition.