Pursuant to Federal Rule of Civil Procedure 41(a)(

Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii), Plaintiff Strikeforce Technologies, Inc. (“Strikeforce”) and Defendants Gemalto, Inc., Gemalto N.V., and Safenet, Inc. (“Defendants”) have stipulated that (1) all claims brought or that could have been brought in this action by the StrikeForce are dismissed with prejudice; and (2) all defenses and
counterclaims brought in this action by the Defendants are dismissed with prejudice.

StrikeForce has further stipulated that Strikeforce, on behalf of itself and any affiliates and any successors-in-interest to any ownership or license rights in the patents that were asserted against Defendants in this action, including U.S. Patent 8,484,698 (“the ’698 patent”) and U.S. Patent 8,713,701 (“the ’701 patent”) (collectively, “the Asserted Patents”) and any patents issued
now or in the future that are in the same family as the Asserted Patents, including continuations, continuations in part, divisionals or any patents that claim priority to any patent application in the same family as the Asserted Patents (the “Asserted Patent Family”), hereby releases from any claims for infringement up to the date of this Stipulation and hereby unconditionally and irrevocably covenants not to assert at any time any claim of patent infringement including direct infringement, contributory infringement and/or inducing infringement against Defendants or any subsidiaries, parents, affiliates, successors in interest (“Defendants’ Affiliates”) or any customers
of Defendants or Defendants’ Affiliates based on use or incorporation of their products into customers’ products under any claim of the Asserted Patents or the Asserted Patent Family, or any parents of the Asserted Patents or the Asserted Patent Family or any continuations, continuations-in-part, divisionals, reexaminations, reissues, certificates and foreign counterparts to the Asserted Patents or Asserted Patent Family or parents of the Asserted Patents or the Asserted Patent Family. Defendants reserve the right that if an action for patent infringement is ever asserted against Defendants or Defendants’ Affiliates, they have the right to assert any and
all defenses available to them in any court or administrative body, including in a US Patent Office proceeding.

Based on the foregoing stipulations, StrikeForce and Defendants jointly move for an order dismissing this action with prejudice, with each party to bear its own costs, expenses and attorneys’ fees.