$SFOR Toyota, refer the Court doc- Lost Contracts

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20. Duo has also used its position in the out-of-band authentication market to attempt to force StrikeForce out of the marketplace. StrikeForce has lost the following contracts for out- of-band authentication to Duo:

1. Toyota Corporation ($182B) ( world's eighth-largest company by revenue)
2. Boston University,
3. Facebook, ($508B)
4. Bechtel, ($35B)
5. eBay, ($39B)
6. Google, ($853B)
7. Intel Corporation, ($223B)
8. Pennsylvania State University, and
9. Thycotic

21. Bechtel, Toyota Corporation, eBay, Google and Intel are examples of customers that chose between only Duo and StrikeForce for out-of-band authentication services. All chose
Duo over StrikeForce.

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Incredibly, defendants tell this Court that StrikeForce does not compete with defendants for sales. Brief at 9. The opposite is true; StrikeForce competed head-to-head with Duo several times and lost. Waller Decl. at For example, StrikeForce and Duo were both competing for sales to the Bechtel company. Id. StrikeForce was attempting to sell its ProtectID® product and Duo was attempting to sell its infringing product. Id. at . That customer chose Duo’s product over StrikeForce’s. Id. at Were it not for Duo’s infringing product, StrikeForce very likely would have made that sale since, at the time, only Duo and StrikeForce were being considered. Id.

3 StrikeForce later learned that, during the negotiations, Duo cautioned Bechtel to check StrikeForce’s financials before purchasing StrikeForce’s product, and that StrikeForce was essentially out of money. Id. at.
In other words, not only is defendant Duo willfully infringing the ’698 patent, but it uses its strong financial position—a position gained through its infringement—against StrikeForce to undermine StrikeForce’s sales opportunities. This type of egregious activity will only continue, and likely worsen, during a stay as it would embolden defendants to continue infringing and interfering with StrikeForce’s sales opportunities. Notably, defendants do not offer to stay their sales efforts for the next 17 months. To the contrary, by the end of this year, Duo’s annual sales could reach up to $170M. During a stay, Duo’s annual sales could increase to more than $350M.

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