Now Germalto & Safenet Dropped
I haven't seen this Posted Yet..
Case 1:17-cv-10422-RGS Document 70 Filed 05/01/19 Page 1 of 4
UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS
STRIKEFORCE TECHNOLOGIES, INC.,
Plaintiff,
v.
GEMALTO, INC., GEMALTO N.V., and SAFENET, INC.
Defendants.
CIVIL ACTION NO. 1:17-CV-10422-RGS
JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE
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.
Respectfully submitted,
/s/ Samuel L. Brenner _ Samuel L. Brenner (BBO # 677812) ROPES & GRAY LLP Prudential Tower 800 Boylston Street Boston, MA 02199-3600 samuel.brenner@ropesgray.com Tel.: (617) 951-7000
Steven Pepe (pro hac vice) Kevin J. Post (pro hac vice) Josef B. Schenker (pro hac vice) ROPES & GRAY LLP 1211 Avenue of the Americas New York, NY 10036-8704 steven.pepe@ropesgray.com kevin.post@ropesgray.com josef.schenker@ropesgray.com Tel.: (212) 596-9000
Attorneys for Plaintiff StrikeForce Technologies, Inc.
Dated: May 1, 2019
Respectfully submitted,
/s/ Robert F. Kramer _ Robert F. Kramer (pro hac vice) DENTONS US LLP
1530 Page Mill Road, Suite 200 Palo Alto, California 94304-1125 Ph: (650) 798-0300 Fax: (650) 798-0310 robert.kramer@dentons.com
William M. Gantz (BBO#568429) DENTON US LLP
101 Federal Street, Suite 2750 Boston, Massachusetts 02110-1873 Ph: 61-235-6800 Fax: 617-235-6899 bill.gantz@dentons.com
Attorneys for Defendants Gemalto, Inc.,
CERTIFICATE OF SERVICE
I hereby certify that the foregoing document was filed through the ECF system and will
be sent electronically to the registered participants as identified on the Notice of Electronic Filing
(NEF) this May 1, 2019.
By: /s/ Samuel L. Brenner _ Samuel L. Brenner
I haven't seen this Posted Yet..
Case 1:17-cv-10422-RGS Document 70 Filed 05/01/19 Page 1 of 4
UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS
STRIKEFORCE TECHNOLOGIES, INC.,
Plaintiff,
v.
GEMALTO, INC., GEMALTO N.V., and SAFENET, INC.
Defendants.
CIVIL ACTION NO. 1:17-CV-10422-RGS
JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE
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.
Respectfully submitted,
/s/ Samuel L. Brenner _ Samuel L. Brenner (BBO # 677812) ROPES & GRAY LLP Prudential Tower 800 Boylston Street Boston, MA 02199-3600 samuel.brenner@ropesgray.com Tel.: (617) 951-7000
Steven Pepe (pro hac vice) Kevin J. Post (pro hac vice) Josef B. Schenker (pro hac vice) ROPES & GRAY LLP 1211 Avenue of the Americas New York, NY 10036-8704 steven.pepe@ropesgray.com kevin.post@ropesgray.com josef.schenker@ropesgray.com Tel.: (212) 596-9000
Attorneys for Plaintiff StrikeForce Technologies, Inc.
Dated: May 1, 2019
Respectfully submitted,
/s/ Robert F. Kramer _ Robert F. Kramer (pro hac vice) DENTONS US LLP
1530 Page Mill Road, Suite 200 Palo Alto, California 94304-1125 Ph: (650) 798-0300 Fax: (650) 798-0310 robert.kramer@dentons.com
William M. Gantz (BBO#568429) DENTON US LLP
101 Federal Street, Suite 2750 Boston, Massachusetts 02110-1873 Ph: 61-235-6800 Fax: 617-235-6899 bill.gantz@dentons.com
Attorneys for Defendants Gemalto, Inc.,
CERTIFICATE OF SERVICE
I hereby certify that the foregoing document was filed through the ECF system and will
be sent electronically to the registered participants as identified on the Notice of Electronic Filing
(NEF) this May 1, 2019.
By: /s/ Samuel L. Brenner _ Samuel L. Brenner
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