FIRST AMENDED COMPLAINT Page 1 of 32 Laurence Singer (LS ...

Case 1:10-cv-09648-BSJ -MHD Document 28 Filed 04/01/11 Page 18 of 32
112. The Defendants have caused damage to 2FA’s rights to dominion and control
over its property, and damage to the confidential nature of 2FA’s Materials. As a result,
Defendants caused 2FA’s Materials to greatly diminish in value and deprived 2FA of the
intended uses of its Materials.
113. In March 2010, Passlogix bundled v-GO AM with v-GO SSO and granted over
10,000,000 free licenses of v-GO SSO which contained trade secrets that were
misappropriated from 2FA.
114. From November 2007 to December 31, 2010, Passlogix and Defendants sold
products containing trade secrets that were misappropriated from 2FA through their
OEMs and major resellers, including, but not limited to: BMC Software, Carahsoft
Technology, CRGT, Diebold, EMC Corporation, International Business Machines
Corporation, Krung Thia Computer Services, Oracle Corporation, RWE Systems, Sun
Microsystems, Quest (Questsys).
115. From November 2007 to the present, Passlogix and Defendants sold and/or
distributed products containing 2FA’s trade secrets that were misappropriated from 2FA
to over 2,500 customers around the world, representing over 10,000,000 end-user
licenses, including, but not limited to: AT&T, Alberta Health Systems, Avery Dennison,
AXA Group, BP Amoco, Calgary Health Services, Canadian Imperial Bank of
Commerce, Capitol Health, Christus Health, Clarian Health Partners, Commonwealth
Bank, Commerzbank, Deutsche Bank, Finnish National ID, Government of Alicuanda,
Goodrich, Hess Corporation, HSBC, Irish Life, Kaiser Permanente, National Australia
Bank, National Australia Group, OCBC Bank, National Grid UK, Network Rail, PPD
Development, Prudential Financial, Publix Super Markets, Sears and Roebucks, SABIC,
FIRST AMENDED COMPLAINT Page 18 of 32