PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for j

PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against SecureAuth as follows:

A.Declaring that the ’599 patent was duly and legally issued, and is valid and enforceable;

B.Declaring that the ’698 patent was duly and legally issued, and is valid and enforceable;

C.Declaring that the ’701 patent was duly and legally issued, and is valid and enforceable;

D.Declaring that SecureAuth has infringed the ’599 patent;

E.Declaring that SecureAuth has willfully infringed the ’599 patent;

F.Declaring that SecureAuth has infringed the ’698 patent;

G.Declaring that SecureAuth has willfully infringed the ’698 patent;27Case 2:17-cv-04314-JAK-SK Document 1 Filed 03/16/17 Page 27 of 29 Page ID #:27

H.Declaring that SecureAuth has infringed the ’701 patent;

I.Declaring that SecureAuth has willfully infringed the ’701 patent;

J.Awarding to Plaintiff damages caused by SecureAuth’s infringement, including all lost profits resulting from SecureAuth’s acts of infringement, and in no event less than reasonable royalties, together with pre-judgment and post-judgment interest and supplemental damages for any continuing post-verdict infringement up until entry of the final judgment, with an accounting, as needed, pursuant to 35 U.S.C. § 284;

K.Awarding to Plaintiff treble damages for infringement of the ’599, ’698, and ’701 patents as a consequence of SecureAuth’s willful infringement;

L.Enjoining SecureAuth, its officers, agents, servants, employees, attorneys, all parent and subsidiary corporations and affiliates, its assigns and successors in interest, and those persons in active concert or participation with SecureAuth who receive notice of the injunction, from continuing acts of infringement of the ’599, ’698, and ’701 patents;

M.Ordering that, in the event a permanent injunction preventing future acts of infringement is not granted, Plaintiff be awarded a compulsory ongoing license fee;

N.Adjudging this an exceptional case and awarding to Plaintiff its reasonable attorneys fees pursuant to 35 U.S.C. § 285; and

O.Awarding to Plaintiff such other and further relief as this Court may deem just and proper