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Global Out of Band S/W Market Grows 27% by 2020
Global Out of Band Authentication Software Market to Grow at a CAGR of 23.57% during the period 2015-2020
Love it and love it even more that Amazon itself is one of the sellers.
Winnerpicker again I did not mean to literally "shootdown" your estimate, and again I meant no disrepect.
I really think it's to early at this stage to make a guesstimate.
See this Post for more info
Thank You Phoenix, I try base things on facts and Fundamentals
I appreciate the Vote of confidence.
I maybe half smart in many areas, be able to do reseach and evaluate.
To me .30 would seems low. Granted the SFOR has 2.28 Billion shares.
And $0.30. is a nice number. Who knows Winnerpickermay be right on the money.
But there are just to many Unknowns at this time to for me to make a a shareprice call.
How Large is $SFOR's ActuaL Market ? To consumers (MT & GID) the industry for ProductID.
What are $ wise and how many Future Settlements are there going to be with those that would settle the Lawsuit for $9m ala Microsoft. Google, Facebook, Banks, Brokages the Government, Healthcare, etc. For ProtectID ?
How many Lawsuits will the be against companies Selling Consumer products like GuardeDID and Mobile Trust and then the Royities SFOR would receive? Not to mention the Damages recieved due to lost Profits.
Mobile Trust - There are 2 Billion Cell phone users worldwide not including Tablets and other mobile devices.
How many countries will end up honoring US Patents?
GuardedID - PC's still take 29% of the Market.
This is just a few of the unknown Variables.
If I were to ask you to Judge how many Jellybeans are in this Jar given what you see.
Do you know how large the Jar is? It might be Huge.
Do you know the size of the Jellybeans?
Could the center be filled with Smaller Jellybeans?
How many Yellow Jellybeans are in the Jar?
Just for fun say SFOR won a 100 Lawsuits on just ProtectID and received the same Settlement as MSFT even without Royalties.
$9.7M x 100 thats over $1B.
In the consumer market how many companies are infringing?
How much in average Settlement for each?
How much in Royalities?
How much in lost profit?
How many units does SOFR sell as the Boxes Start rolling off Store Shelves?
Online sales?
QVC is a good begining but what if there eventually Infomercials?
I LOVE MY Pillow... I Mean My MOBILE TRUST.
Sorry for my explanation on the unknown Variables
I could leave Reference links on stats on to how many cell phones in the world and other stuff you can find on your own.
But I will leave a link showing
Antivirus and Compromised Device Report Jan. 15, 2015 showing Market share by company
If you scan over the above link:
I might add, in the Anti-Virus world does just one company have PATENTS that need to be used by every Vendor.
And a link on Mobile Marketing Statistics compilation
Someone far more astute in this area than I, can make a call on Share Price. I'm just a what some joking say a Rocket Scientist and part of the Range Safety Team that has launched every Rocket and Space Shuttle in the past 22 Years at Cape Canaveral. No one Launches without Range Saftey. Not NASA, Long Musk (SpaceX), United Space Alliance (consisting of Boeing and Lockheed Martin).
Not boosting, just showing that evaluating the Share Price of and Up and coming Powerhouse with a Few Very Valuable Patents is Not my area of Expertise, especially at this Stage.
Really, I'm just a Rock Picker looking for Gold with ma mule Pointer.
Let's me know if you find anythin shiny or something that is worth looking at.
A buyout at .30-maybe .25 ??? I know you have been one of the longs on SFOR.
And not to be disrespectful
But a buyout at .30 ?
With Part of SOFR' strategy being Lawsuits for Patent infringement and considering that 1000's of companies are infringing and the potential for Monetary Awards, Future Royalities and damages for Lost Profits, IMO SFOR is worth far more than .30 a share.
I may have just come on board this Space Shuttle a few weeks ago, but after researching the Management Team, Patents, Previous cases,Current filings, along with seeing them ramping up Production facilities for Consumer Products, at a time where Cybersecurity is becoming REDHOT, this is Right time, Right Place.
SFOR's Consumer Marketing Savvy is being shown this month with attempting to Capitalize on Cypher Security Awareness Month by showcasing it's Consumer Products on QVC in Oct.
Although I do believe SFOR's Industry Product ProtectID will overshadow Consumer Product sales in $$$$ terms as the Lawsuits Proliferate and the Dominoes begin to Fall one by one or in Concert.
Back to a Buyout:
Granted Management would be open to a buyout, but Kay is not stupid.
.30 ????
With Patents '599, 698 and 701 a precedent has already been set in the Courts. SFOR own the Patents and defendants have Lost where they infringed on SFOR Patents.
All that is needed is to prove infringement in future Cases.
Currently we have Lawsuits against 3 companies at once, but you can go after DOZENS at one time in the future.
With a precedent already Set, Settling before trial with consolidated pretrial proceedings is also less expensive for the Plaintiff (SFOR) rather than full trial Proceedings.
So .30 per share? Not unless it was a Hostile takeover attempt.
I doubt a Hostile Takeover would be attempted with SFOR, because the acquiring company would only be going after SFOR for its Patents. So in a Hostile Attempt SFOR would more than likely use the Crown-Jewel Defense.
Crown Jewel Defense. In business, when a company is threatened with takeover, the crown jewel defense is a strategy in which the target company sells off its most attractive assets to a friendly third party or spin off the valuable assets in a separate entity.
As the Lawsuit Domino's Fall in line, I'll be watching for this set
$SFOR Named 1 of 4 Key Vendors in Report
Global Out of Band Authentication Software Market 2016-2020
Technavio's report, global OOB authentication software market 2016-2020, has been prepared based on an in-depth market analysis with inputs from industry experts. The report covers the market landscape and its growth prospects over the coming years. The report also includes a discussion of the key vendors operating in this market.
Key vendors
• CA Technologies
• Gemalto
• Strikeforce Technologies
• Swivel Secure
Singtel Market Cap FYI
SingTel has a market Cap of US $46,908,919.06 Million . SGD $63M
Singtel Market Cap
Yes Filing Lawsuits is part of SFOR' 4 Part Strategy
But not just your Average Lawsuits.
Patent Infringement Lawsuits against some of the VERY Largest Companies By Market Cap in the World.
1st Microsoft via Phonefactor
And Now
Singtel via TRUSTWAVE
To Quote the Company Web Site
"Singtel is one of the largest listed Singapore companies on the Singapore Exchange by market capitalisation. The Group has a vast network of offices throughout Asia Pacific, Europe and the USA, and employs more than 23,000 staff worldwide."
SingTel
COURT DOCUMENT CLAIM ON TRUSTWAVE
If you happen not to believe the Facts on the Board then Read for Yourself.
BLANK ROME LLP
A Pennsylvania LLP
Seth J. Lapidow
New Jersey Resident Partner
301 Carnegie Center, 3rd Floor
Princeton, NJ 08540
Telephone: (609) 750-2644
Facsimile: (609) 897-7284
Lapidow@BlankRome.com
Attorneys for Plaintiff
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
STRIKEFORCE TECHNOLOGIES, INC.,
Plaintiff,
v.
TRUSTWAVE HOLDINGS, INC.,
Defendant.
Civil Action No.
Electronically Filed
COMPLAINT FOR PATENT
INFRINGEMENT
Jury Trial Demanded
StrikeForce Technologies, Inc. (hereinafter “Plaintiff”), files this Complaint for patent
infringement against Trustwave Holdings, Inc. (hereinafter “Defendant”), and, in support
thereof, further states and alleges as follows:
THE PARTIES
1. Plaintiff, StrikeForce Technologies, Inc. (“StrikeForce”) is a corporation
incorporated in the state of Wyoming, with its principal place of business located at 1090 King
Georges Post Road, Edison, New Jersey 08837.
2. Upon information and belief, Defendant Trustwave Holdings, Inc. (“Trustwave”)
is a corporation incorporated in the state of Delaware, having its principal place of business at 70
W. Madison Street, Chicago, Illinois 60602. The registered agent for service of process is
Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808.
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 1 of 12 PageID: 1
____
2
JURISDICTION AND VENUE
3. This is a civil action for patent infringement under the laws of the United States,
Title 35 United States Code §§ 1, et seq.
4. This Court has subject-matter jurisdiction over this action under 28 U.S.C.
§§ 1331 (federal question) and 1338(a) (patent-exclusive jurisdiction).
5. Defendant Trustwave’s website,
https://www.trustwave.com/Resources/Library/Documents/?page=1&product=0&topic=0&type
=5, discloses that Defendant Truswave engages in systematic and continuous contacts with the
state of New Jersey, including Crest Savings Bank, headquartered in Wildwood, NJ. Further,
Trustwave discloses on the same website that it engages in business with Intergraph and Qdoba,
which both have physical operations in this District. Trustwave further discloses at
https://www.trustwave.com/Resources/Library/Documents/Top-10-Things-to-Know-About-
Trustwave/ that it provides products and services to over three million customers worldwide
through its website, https://www.trustwave.com.
6. Due to at least the business interactions outlined in paragraph 5, this Court has
personal jurisdiction over Defendant Trustwave because Trustwave maintains continuous and
systematic contacts with the state of New Jersey and because Trustwave has purposefully
directed its activities at residents of the state of New Jersey. Defendant Trustwave has injected
its infringing products into the stream of commerce through its website and through its
solicitation of business in this District. StrikeForce’s claims arise, in part, out of, or relate to
Trustwave’s acts of infringement committed in the state of New Jersey, and the assertion of
personal jurisdiction over Trustwave in this forum would not offend traditional notions of fair
play and substantial justice.
7. Venue is proper under 28 U.S.C. §§ 1391(b) and (c) and § 1400(b), because
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 2 of 12 PageID: 2
____
3
Defendant is subject to personal jurisdiction in this judicial district.
FACTUAL BACKGROUND
8. On July 9, 2013, the United States Patent and Trademark Office duly and legally
issued U.S. Patent No. 8,484,698, entitled “Multichannel Device Utilizing a Centralized Out-of-
Band Authentication System (COBAS)” (“the ’698 Patent”). A true and correct copy of the ’698
Patent is attached hereto as Exhibit A.
9. Plaintiff StrikeForce is the owner by assignment of the ’698 Patent.
10. The ’698 Patent is directed to multichannel security systems and methods for
authenticating a user seeking to gain access to, for example, Internet websites and VPN
networks, such as those used for conducting banking, social networking, business activities,
and other online services. Such technology is sometimes known as “out-of-band” authentication.
When coupled with more traditional processes, they are more commonly known as two factor-
authentication.
11. StrikeForce offers a product that performs out-of-band authentication, known as
ProtectID®. Since about July 2013, the statutory patent notice was placed on the ProtectID®
product.
12. Defendant Trustwave engages in electronic commerce conducted on and using at
least, but not limited to, its website, https://www.trustwave.com/, in the United States and in this
District.
13. Defendant Trustwave owns, operates, and/or directs the operation of its website,
https://www.trustwave.com/, in the United States and in this District.
14. Defendant Trustwave provides access to its website, https://www.trustwave.com/,
in the United States and in this District.
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 3 of 12 PageID: 3
_____
4
15. Through its website, https://www.trustwave.com/, Defendant Trustwave offers its
Trustwave Managed Two Factor Authentication Service product with multi-factor out-of-band
authentication functionalities for Windows, Android, and iOS devices in the United States and in
this District.
COUNT I
(Direct Infringement of the ’698 Patent)
16. Plaintiff StrikeForce incorporates by this reference the averments set forth in
paragraphs 1 through 15.
17. Defendant Trustwave has infringed claims 53 and 54 of the ’698 Patent in this
district and elsewhere by making, using, offering for sale, or selling systems and methods for
out-of-band authentication, all in violation of 35 U.S.C. § 271(a). Defendant Trustwave has
infringed claims 53 and 54 of the ’698 Patent in this District and elsewhere by making, using,
offering for sale, or selling systems and methods for out-of-band authentication, including the
Trustwave Managed Two-Factor Authentication product, which are offered for sale and sold in
this District and elsewhere.
18. Defendant Trustwave infringes claims 53 and 54 of the ‘698 Patent because its
Trustwave Managed Two-Factor Authentication Service product performs and/or controls the
performance of each step of method claim 53 and because Defendant Trustwave makes, uses,
sells, and/or offers for sale of the Trustwave Managed Two Factor Authentication Service
product, which includes all of the elements recited by claim 54. Additional details on the
infringing Trustwave Two Factor Authentication Service systems and methods, as marketed and
offered for sale in the United States and this District by Defendant Trustwave, may be
exemplarily found at https://www.trustwave.com/Services/Managed-Security/Managed-Two-
Factor-Authentication/.
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 4 of 12 PageID: 4
___
5
19. Defendant Trustwave sold infringing products to consumers located in New
Jersey.
20. As a direct and proximate result of Defendant Trustwave’s acts of infringing
claims 53 and 54 of the ’698 Patent, Plaintiff has suffered injury and monetary damages for
which Plaintiff is entitled to relief in the form of damages for lost profits and in no event less
than a reasonable royalty to compensate for Defendant Trustwave’s infringement.
21. Defendant Trustwave will continue to directly infringe claims 53 and 54 of
the ’698 Patent, causing immediate and irreparable harm to Plaintiff unless this Court enjoins
and restrains its activities, specifically the acts of making, using, selling, and offering for sale as
previously outlined. There are inadequate remedies available at law to compensate for this harm.
22. Upon information and belief, the direct infringement of claims 53 and 54 of the
’698 Patent by Defendant Trustwave has deprived, and will deprive, Plaintiff of sales proceeds,
subscription fees, licensing fees, royalties and other related revenue which Plaintiff would have
made or would enjoy in the future; has injured Plaintiff in other respects; and will cause Plaintiff
added injury and damage unless Defendant Trustwave is enjoined from infringing claims 53 and
54 of the ’698 Patent on all products and web services Defendant Trustwave will make, use,
offer for sale, sell, import, distribute, market, or advertise until the expiration of the ’698 Patent.
23. Upon information and belief, Defendant Trustwave has knowingly, willfully, and
deliberately infringed claims 53 and 54 of the ’698 Patent in conscious disregard of Plaintiff
StrikeForce’s rights, making this case exceptional within the meaning of 35 U.S.C. § 285 and
justifying treble damages pursuant to 35 U.S.C. § 284.
COUNT II
(Active Inducement of Infringement of the ’698 Patent)
24. Plaintiff StrikeForce incorporates by this reference the averments set forth in
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 5 of 12 PageID: 5
__
6
paragraphs 1 through 23.
25. Defendant Trustwave has, under 35 U.S.C. § 271(b), indirectly infringed, and
continues to indirectly infringe the ’698 Patent by, inter alia, inducing others to make, use, sell,
and/or offer for sale in the United States the above-mentioned products and services covered by
the ’698 Patent, and distributing, marketing, and/or advertising those products and web services
covered by the ’698 Patent in this judicial district and elsewhere in the United States.
26. The customers of Defendant Trustwave directly infringe claims 53 and 54 of the
’698 Patent by, for example, using the claimed systems and directly benefiting from the use of
those systems. For example, Defendant Trustwave’s customers utilize the two-factor
authentication system claimed in the ‘698 Patent for the purpose of gaining secure access to,
exemplarily, various Internet websites and other secure networks.
27. Upon information and belief, Defendant Trustwave is aware that it provides its
customers with products and web services that are used in a manner that infringes claims 53 and
54 of the ’698 Patent.
28. Upon information and belief, through its marketing activities and through the
sales and offers for sale of infringing systems and methods, Defendant Trustwave specifically
intends for its customers to use its products and web services and knows that its customers are
using its products and web services in an infringing manner.
29. Upon information and belief, Defendant Trustwave specifically encourages and
instructs its customers to use its products and web services in a manner that Defendant
Trustwave knows constitutes infringement of claims 53 and 54 of the ’698 Patent.
30. As a result of Defendant Trustwave’s activities, as foresaid, and its customers’
activities in utilizing the systems and methods of claims 53 and 54 of the ’698 Patent, Defendant
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 6 of 12 PageID: 6
_____
7
Trustwave is liable for indirect infringement.
31. As a direct and proximate result of Defendant Trustwave’s acts of infringing
claims 53 and 54 of the ’698 Patent, Plaintiff StrikeForce has suffered injury and monetary
damages for which Plaintiff StrikeForce is entitled to relief in the form of damages for lost
profits and in no event less than a reasonable royalty to compensate for Defendant Trustwave’s
infringement.
32. Upon information and belief, Defendant Trustwave has knowingly, willfully, and
deliberately induced infringement of the ’698 Patent in conscious disregard of Plaintiff
StrikeForce’s rights, making this case exceptional within the meaning of 35 U.S.C. § 285 and
justifying treble damages pursuant to 35 U.S.C. § 284.
33. Defendant Trustwave will continue to induce infringement of claims 53 and 54 of
the ’698 Patent, causing immediate and irreparable harm to Plaintiff StrikeForce unless this
Court enjoins and restrains its activities, specifically the acts of making, using, selling, and
offering for sale, as outlined above. There are inadequate remedies available at law to
compensate for this harm.
34. The induced infringement of claims 53 and 54 of the ’698 Patent by Defendant
Trustwave has, and will, deprive Plaintiff StrikeForce of sales, licensing fees, royalties, and other
related revenue which Plaintiff StrikeForce would have made or would enjoy in the future; has
injured Plaintiff StrikeForce in other respects; and will cause Plaintiff StrikeForce added injury
and damage unless Defendant Trustwave is enjoined from inducing infringement of claims 53
and 54 of the ’698 Patent for all products and web services Defendant Trustwave will make, use,
offer for sale, sell, import, distribute, market, or advertise until the expiration of the ’698 Patent.
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 7 of 12 PageID: 7
____
8
COUNT III
(Contributory Infringement of the ’698 Patent)
35. Plaintiff StrikeForce incorporates by this reference the averments set forth in
paragraphs 1 through 34.
36. Defendant Trustwave has, under 35 U.S.C. § 271(c), indirectly infringed, and
continues to indirectly infringe the ’698 Patent by, inter alia, knowingly providing to its
customers the Trustwave Managed Two Factor Authentication Service, which constitutes a
material component of an out-of-band authentication system that was especially made or adapted
for use in that system, which is not a staple article or commodity of commerce and which has
no substantial, non-infringing use.
37. Upon information and belief, Defendant Trustwave had and/or has knowledge of
the ’698 Patent.
38. As a direct and proximate result of Defendant Trustwave’s acts of infringing the
’698 Patent, Plaintiff has suffered injury and monetary damages for which Plaintiff StrikeForce
is entitled to relief in the form of damages for lost profits and in no event less than a reasonable
royalty to compensate for Defendant Trustwave’s infringement.
39. Upon information and belief, Defendant Trustwave has knowingly, willfully,
and deliberately contributed to infringement of the ’698 Patent in conscious disregard of Plaintiff
StrikeForce’s rights, making this case exceptional within the meaning of 35 U.S.C. § 285 and
justifying treble damages pursuant to 35 U.S.C. § 284.
40. Defendant Trustwave will continue to contribute to infringement of the
’698 Patent, causing immediate and irreparable harm to Plaintiff unless this Court enjoins
and restrains Defendant Trustwave’s activities, specifically the acts of making, using, selling,
and offering for sale, as outlined above. There are inadequate remedies available at law to
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 8 of 12 PageID: 8
___
9
compensate for this harm.
41. The contributory infringement of the ’698 Patent by Defendant Trustwave has,
and will, deprive Plaintiff StrikeForce of sales, licensing fees, royalties and other related revenue
which Plaintiff StrikeForce would have made or would enjoy in the future; has injured Plaintiff
StrikeForce in other respects; and will cause Plaintiff StrikeForce added injury and damage
unless Defendant Trustwave is enjoined from inducing infringement of the ’698 Patent on all
products and web services Defendant Trustwave will make, use, offer for sale, sell, import,
distribute, market, or advertise until the expiration of the ’698 Patent.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff, StrikeForce, respectfully requests this Court to:
A. Enter judgment for Plaintiff StrikeForce that the ’698 Patent was duly and legally
issued, is valid, enforceable, and has been infringed, directly and/or indirectly, by Defendant
Trustwave;
B. Enter judgment for Plaintiff StrikeForce that Defendant Trustwave has willfully
infringed, and is willfully infringing, claims 53 and/or 54 of the ’698 Patent;
C. Order Defendant Trustwave to account in written form for and to pay to Plaintiff
StrikeForce actual damages to compensate Plaintiff StrikeForce for Defendant Trustwave’s
infringement of the ’698 Patent through and including the date of entry of the judgment on the
jury’s verdict, including but not limited to, damages for lost profits and in no event less than a
reasonable royalty, together with interest and costs under 35 U.S.C. § 284;
D. Award Plaintiff StrikeForce treble damages due to Defendant Trustwave’s
deliberate, willful, and knowing conduct;
E. Issue a preliminary injunction restraining Defendant Trustwave, its directors,
officers, agents, employees, successors, subsidiaries, assigns, affiliates and all persons acting in
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 9 of 12 PageID: 9
___
10
privity or in concert or participation with any of them from the continued infringement, direct or
contributory, or active inducement of infringement by others, of the ’698 Patent;
F. Issue a permanent injunction restraining Defendant Trustwave, its directors,
officers, agents, employees, successors, subsidiaries, assigns, affiliates and all persons acting in
privity or in concert or participation with any of them from the continued infringement, direct
or contributory, or active inducement of infringement by others, of the ’698 Patent;
G. Direct Defendant Trustwave to file with this Court, and to serve on Plaintiff
StrikeForce, a written report under oath setting forth in detail the manner and form in which it
has complied with the injunction;
H. In lieu of a permanent injunction, order Defendant Trustwave to pay to Plaintiff
StrikeForce monetary damages that will be suffered as a result of Defendant Trustwave’s
continuing post-verdict infringement of the ’698 Patent by requiring Defendant Trustwave to
take a compulsory license at a reasonable royalty rate to be determined by the Court on all
products that it makes, uses, offers for sale, sells, imports, distributes, markets, or advertises that
infringe the ’698 Patent until the expiration of the ’698 Patent, which royalty payments shall
commence three months after entry of the judgment and shall be made quarterly thereafter, and
shall be accompanied by an accounting of the sales of infringing products by the Defendant
Trustwave;
I. Order such other measures in the form of audit rights, interest on late payments,
and appropriate security to protect Plaintiff StrikeForce’s rights;
J. Order Defendant Trustwave to pay Plaintiff StrikeForce its costs, expenses, and
fees, including reasonable attorneys’ fees pursuant to 35 U.S.C. § 285, and pre-judgment and
post-judgment interest at the maximum rate allowed by law; and
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 10 of 12 PageID: 10
____
11
K. Grant Plaintiff StrikeForce such other and further relief as the Court may deem
just and proper.
Dated: June 20, 2016
BLANK ROME LLP
By: /s/ Seth J. Lapidow
Seth J. Lapidow
301 Carnegie Center, 3rd Floor
Princeton, NJ 08540
Tel.: (609) 750-2644
Fax: (609) 897-7284
E-mail: Lapidow@BlankRome.com
Nicholas R. Tambone (pro hac vice
application forthcoming)
The Chrysler Building
405 Lexington Avenue
New York, NY 10174
Telephone: (212) 885-5120
Fax: (917) 332-3023
NTambone@BlankRome.com
Attorneys for Plaintiff
OF COUNSEL FOR PLAINTIFF
STRIKEFORCE TECHNOLOGIES, INC.
Charles R. Wolfe, Jr.
Ameya V. Paradkar
BLANK ROME LLP
600 New Hampshire Ave NW, Suite 1200
Washington, DC 20037
Telephone: (202) 772-5800
E-mail: Wolfe@BlankRome.com
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 11 of 12 PageID: 11
___
12
DEMAND FOR JURY TRIAL
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands that the
issues in this case be tried by a jury.
CERTIFICATION PURSUANT TO LOCAL RULE 11.2
The undersigned certifies that the matter in controversy is not the subject of any other
action pending in any court, or of any pending arbitration or administrative proceeding.
Dated: June 20, 2016
BLANK ROME LLP
By: /s/ Seth J. Lapidow
Seth J. Lapidow
301 Carnegie Center, 3rd Floor
Princeton, NJ 08540
Tel.: (609) 750-2644
Fax: (609) 897-7284
E-mail: Lapidow@BlankRome.com
Nicholas R. Tambone (pro hac vice
application forthcoming)
The Chrysler Building
405 Lexington Avenue
New York, NY 10174
Telephone: (212) 885-5120
Fax: (917) 332-3023
NTambone@BlankRome.com
Attorneys for Plaintiff
OF COUNSEL FOR PLAINTIFF
STRIKEFORCE TECHNOLOGIES, INC.
Charles R. Wolfe, Jr.
Ameya V. Paradkar
BLANK ROME LLP
600 New Hampshire Ave NW, Suite 1200
Washington, DC 20037
Telephone: (202) 772-5800
E-mail: Wolfe@BlankRome.com
Case 2:16-cv-03573-JMV-MF Document 1 Filed 06/20/16 Page 12 of 12 PageID: 12
That part about the Product TV Channel appears to have been edited since the first time I heard it, where the channel was stated and sounded as it was cut right at that point, but they missed it.
Then I went back to listen again later and the name was cut completely, and now it states a tv product channel.
I don't want to name the channel as obviously it was removed on purpose, But there is not that many channels it could be, so take your pick.
and Quite interesting, if the interview had been Video a simple Cut and paste would not have been the answer, a video retake of the shot would had to have to been made. Audio is easy in comparision. pardon my capitalizing of words cough cough, ummm must be catching a cold.
Thanks King - Did you see the Post I posted yesterday about SFOR's Advisor Cooper, that I found extreamly awesome.
What Coopers Job Covers as CIO at the Dept. Of Commerce
Thanks Again
DD - "It's only Facts that Count"
A German S/W Co. is Selling GuardedID
They have an International Site in many Languages.
It is the 2nd Product on their Encrypts Browsing Page
UpdateStar Web Site
movin movin movin keep those doggies movin SFOR... Yea!
Go Ahead, Make My Day!
SFOR Advisor AMAZING What He COVERS
We know StrikeForce has Steven I Cooper CIO of the Dept. Of Commerce as an advisor, this says what he is in charge of:
From the very begining of the Video Below:
Appointed inted the CIO Dept of Commerce, serves as the Principal Advisor to Commerce’s 12 Agencies 12 CIOs and the Deputy Secretary.
Cooper leads the Development and Implementation of the Departments Enterprise Wide Information Technology and Strategy and Operations, over sees the Building and Operation of a robust and IT Security Risk Program and Serves as an Advisor on Misson and Business IT Systems Services.
Video:
Here is What Steven I. Cooper is in charge of
Nothing more in the video worth watching except the Introduction of Cooper. Stating the Above.
You know JD perhaps I read it wrong, I am after all an Old Gold49er, but Pointer (that's ma Mule) bites me on the ass every time I'm headed in the wrong direction.
Dag naggit I had to put on ma glasses, but its looks pretty straight foreword to me. What do you think JD ?
Well I guess I've done picked the Tailings from this place clean, time to mosey over to Gold Bar.
Even though this has a Current Release Date, it seems it was submitted initially to BLM in July 2011 for review.
Release Date: 09/21/15
Tonkin Springs LLC (TSLLC), a wholly owned subsidiary of McEwen Mining Inc., submitted an Amendment to Plan of Operations #NVN-067881 – Final Plan for Permanent Closure for the Tonkin Springs Mine, dated November 2012. The Plan includes closure modifications, relocation of sulfide ore stockpiles and waste rock back into the open pit, decommissioning and clean-closure of the existing tailings impoundment, and construction of a new evaporation pond for post-closure fluid management of pit seepage water and heap leach pad draindown
Seems it took a year for this Govt agency to Review, then another 3 Years to release this Final Closer Doc Below?
BLM Issues Decision on the Environmental Assessment For the Amendment to Plan of Operations - Final Plan for Permanent Closure for the Tonkin Springs Mine
See Top of Page 4
BATTLE MOUNTAIN DISTRICT BATTLE MOUNTAIN DISTRICT ADVISORY COUNSIL DISTRICT MANAGER’S REPORT JULY 21, 2011
January 14, 2005 - Denver, CO. - January 14, 2005 - U.S. Gold Corporation (OTC BB: USGL; Berlin Exchange: US 8) reported today that BacTech Mining Corporation (BacTech)(TSX-V: BM) released positive results of their internal study for the Tonkin Springs gold project in north central Nevada. BacTech is the manager of Tonkin Springs with 55% interest and U.S. Gold owns 45%. The study was undertaken to identify a production strategy at Tonkin Springs which would maximize the use of the existing infrastructure and resources, and also address the metallurgical issues identified by BacTech this past August.
April 12, 2005 - Denver, CO. - April 12, 2005 - U.S. Gold Corporation (OTC BB: USGL; Berlin Exchange: US 8) reports that BacTech Mining Corporation (BacTech) issued a press release today announcing their intent to relinquish to U.S. Gold their 55% interest in Tonkin Springs LLC which owns the Tonkin Springs gold project in north central Nevada. U.S. Gold currently owns the remaining 45% interest. U.S. Gold welcomes 100% ownership of this significant property position and assets located on one of the world's greatest gold trends, the prolific Cortez Gold Trend in Nevada.
Looks like our Cleanup is from when BacTech Mining owned the Property.
Credits: I kinda borrowed these Photos from the SI Board. Thanks Guys, feel free to use this Post
Tonkin 1994 Pre-U.S. Gold
Tonkin 2014
Did you know that MUX
Is closing Tonkin?
JD400 – I’m sure you are familiar with NGE's groundwater chemistry Based your post on 12/1/13
JD's Post from 12/1/2013
I too followed the MUX / NGE Deal back then. The MUX Press Releases did not reveal the whole story.
It seems Rob may have lost more than a few nights sleep over NGE. The NGE story you just posted, brought back memories and digging back in my MUX archive I thought this might be of interest.
Seems that NGE’s Wade Hodges pulled a fast one on Rob and Staked claims in Grass Valley before giving the findings of his Groundwater Survey to McEwen. Not that Wade did not deserve it, as Wade had been attempting to prove his proprietary Hydrogechemistry (groundwater chemistry) for years before he met McEwen. Rob probably should have bought NGE way back then. But Wade being a Gold Miner in search of a Mine did not Jump any Claims, but might have played a little underhanded.
Anyway I thought you might like to know the backdoor story on what unfolded. Included are a few stories about what happened that go far beyond the few paragraphs I’m including as a teaser to wet ones appetite for more. Enjoy….
What does Rob McEwen see that Pierre Lassonde does not see? Feb 8, 2013
Excerpt:
Based on earlier sampling work NGE knew it would generate some sort of anomaly, but the results of the McEwen grubstaked sampling program were so stunning, at least relative to the 20 other targets sampling had already established elsewhere in northern Nevada, that NGE staked the ground before presenting it to McEwen lest somebody unwittingly or perhaps treacherously stake what management felt was the best anomaly it had to date found while sampling half the basin flanks of the Upper Plate/Lower Plate overlap area of northern Nevada.
What NGE management had not realized was that in addition to being a "visionary", Rob McEwen is a hard-nosed businessman who would not hesitate to exploit another's weakness given the opportunity. And NGE had certainly weakened its own hand by staking the ground with a near empty treasury, sparing McEwen the anxiety that while he spent 60 days "pondering" his decision the Grass Valley project might be scooped by Barrick on the basis of new insights gleaned from the intensive geophysical surveys on its own ground to the north. For 60 days McEwen played poker with NGE management, but as KRO members now know (see SVH Comment - September 24, 2012), a check confirming McEwen's selection was hand delivered in the eleventh hour with a grudging congratulation to NGE's Wade Hodges for having called Mr McEwen's bluff
What does Rob McEwen see that Pierre Lassonde does not see?
__________________________________________________________________
Understanding the implications of NGE's new Grass Valley story September 24, 2012
Excerpt:
Under the terms of the agreement NGE could designate any part of the area of interest and present it to McEwen for acquisition, which McEwen had 60 days to decide. But the Grass Valley play was so sensitive that NGE decided to stake critical claims with its own money in case word leaked out or some other "ignorant junior" decided it might once again be timely to have property with a view of the Cortez Hills Mine. Around the third week of July NGE submitted the paperwork to McEwen, and commenced a nerve-wracking period during which the company could not disclose details about the Grass Valley project, was continually harassed by shareholders about the status of the McEwen deal, and once again its treasury was perilously low. It was during this period that it became apparent to me that NGE was nervously awaiting a decision from McEwen, and it dawned on me that it might perhaps be better for NGE to have 100% of this project if management was on such tenterhooks about it. I also began to worry why, if this project was so good, McEwen was not jumping on it, and its spokespeople like Ian Ball and Simon Quick were telling everybody McEwen Mining had no further exploration plans for Nevada. No doubt there was a game afoot which we will learn about if the need to write a book about the Grass Valley Trend ever arises.
Athough McEwen waited the full 60 days allowed from submission of the designated Grass Valley area to make a decision, arriving at the eleventh hour with a check, there are now signs that McEwen management wishes to move very aggressively with further exploration. NGE has proposed about $125,000 of additional targeting work such as detailed gravity surveys to better establish the depth of the gravels overlying the bedrock, mapping and sampling of the outcrop in the western part of the property to better outline the south-southeast trending fold structures of the Toiyabe Mountain range which cross-cut the south-southwest strike of the 15 km elongate hydrogeochemical anomaly, seismic surveys to define the high angle fault structures inferred to run the length of the property, and sage brush sampling to provide another level of detail to the gold-in-groundwater anomaly. Once this work is done and compiled, which could take until the end of 2012, the Grass Valley play will be ready for what will need to be at least a $2 million drill program whose initial purpose will be to map the bedrock stratigraphy of Grass Valley and set the stage for focused gold deposit discovery drilling
Understanding the implications of NGE's new Grass Valley story
As an added Bonus
From 2010 Wade Hodges NGE - A History Channel Video - Explanation of Hydrogechemistry (groundwater chemistry)
"I don't know whether to be flattered that you consider my posts to be so intellectually challenging that you go back weeks and months searching for them or, on the other hand, to be saddened that you believe that is the best way to use the time and oxygen that the Powers that Be have given to you."
As I stated in another post, when entering a new board looking for information on a Company, I like to go back a few months and read individuals posts, to see who is credible in their observations as time moves forward.
"I got fooled early on and just am saying that while I believe that precious metals will appreciate in value, to not put your blind trust into gurus who most always are wrong in their predictions but will gladly cash your checks."
In your post you stated "People like McEwen, Sprott, Keiser, and the rest of them have been perpetually wrong yet people continue to believe in them. "
Then perhaps you can explain you starting off with McEwen?
McEwen is not trying to sell me a Newsletter or asking for my Money!
Granted he is the CEO of McEwen Mining and owns 25% of the Stock, but he never asks me to invest, just his view point on where the price of Gold is heading.
He was the founder and CEO of Gold Corp, which he took from a $50M company to a $10B + company and had an Annual Return to shareholders over a 10 year period year over year of 31%.
And McEwen is well on his way to building another Gold Corp in MUX, with an Aim to be on the S&P 500 by 2015. Newmont is currently the only other miner on the S&P and he feels they need some company. The S&P opens the door to $1 Tillion + in capital that can only be invested in S&P 500 Companies.
So why did you choose to add Rob McEwen to your list of "Worse than hacks" ?
49er
Not really a strange post at all.
"You pooled someone's old message to brag about your success? Plus, you think people, who are buying PMs now, are late to the party?"
No eik, I was reading the board, and I saw Retiredyoung was dissing experts who have been in the field for decades. Yet he calls them " worse than hacks"
They have been right in that the price of has continued to rise.
My post was NOT to brag, but to show McEwen's view Point has been correct and worked well for me for the past 5+ years. Contrary to Retiredyoungs comments.
I was not saying people buying now are late to the party, just Retired. If he had been listening to the "hacks" for any period of time he would not be so condescending, it's obvious he came in to PM's late.
My charts and Sprott triggered me to USGIF, as well as many mining Co's. and I thought I would review the board to see what the Company had in the works. I always go back 8 - 12 months on a board to begin reading, to see how members view points pan out as I read forward.
Sorry if my first post was a little rough eik, but I can't stand the average Joe who believes he is so knowledgeable and wiser than experts in the field, especially calling them worse than hacks.
USGIF looks interesting, and the fact that the company rejected the Hecla offer and Sprott was on board with the rejection adds to my interest.
I guess Retired thinks Sprott is worse than a hack also.
I will be looking into the Warrants (USL.WT).
Things are changing faster than most think.
http://www.indiavision.com/news/article/business/339477/china-launching-gold-backed-worldwide-currency--now-the-americans-will-have-to-find-a-reason-to-go-to-war-against-china-/#ixzz259UEM8XG
Take care eik, and it's good to be suspicious of new posters.
49er
(Retiredyoung99) "People like McEwen, Sprott, Keiser, and the rest of them have been perpetually wrong yet people continue to believe in them. There is a saying:
"Fool me once-shame on you--fool me twice--shame on me"
These people who make predictions about the price of precious metals are worse than hacks--yet some people continue to believe in them. "
Reviewing some of your older posts, I ran across the one quoted below.
Gee, I listened to McEwen in 2007 and bought 50 Gold Buffalo's at $645, and purchased 2000 Oz of Silver in the markets darkest hour in Nov. 2008.
Granted McEwen's $2000 oz by the end of 2010 did not make it, but the price continues to rise.
Just because you came to the party late and have no patience does not mean McEwen and Sprott are wrong, it just means the Govt manipulation has slowed the process down.
My Gold Buffalo's are worth $86K, and are up $54K and my Silver worth $67K, is up $48K.
Today I'm still buying silver to add to my 3rd Safe Deposit box, Silver is the better investment as you can buy 52oz of Silver for one oz of Gold. and Silver will go up equal or 1:1 to gold.
At $200oz for Silver my original purchase of 2000oz by itself will be worth $400K.
You came to the party late, most of the fun was over for the present and you're trying to be the Party Crasher.. But only the opening act has played and you seem not to know there are many more acts to follow.
Would someone please send Retiredyoung the complete Program Guide for the Party!
What's That? Oh Act Two is beginning.... See ya, Got to go...
49er
(Retiredyoung99) "People like McEwen, Sprott, Keiser, and the rest of them have been perpetually wrong yet people continue to believe in them. There is a saying:
"Fool me once-shame on you--fool me twice--shame on me"
These people who make predictions about the price of precious metals are worse than hacks--yet some people continue to believe in them. "