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

Case 1:10-cv-09648-BSJ -MHD Document 28 Filed 04/01/11 Page 6 of 32
V. PASSLOGIX’S PRODUCTS
33. At the time the License Agreement was executed, and throughout the
2FA/Passlogix relationship, Passlogix’s suite of solutions was sold under the brand v-GO
Access Accelerator Suite and contained six software products: 1) v-GO Single Sign-on
(v-GO SSO), 2) v-GO Authentication Manager (v-GO AM), 3) v-GO Self-Service
Password Reset (v-GO SSPR), 4) v-GO Provisioning Manager (v-GO PM), 5) v-GO
Session Manager, and 6) v-GO Credential Manager (v-GO CM), Passlogix’s name for the
software licensed by 2FA under the License Agreement.
34. Passlogix discontinued the marketing and sale of v-GO CM in August of 2008.
35. In March 2010, Passlogix released v-GO Universal Authentication Manager (v-
GO UAM) and took v-GO AM off the market.
36. Although v-GO AM had limited strong authentication functionality, v-GO UAM
was marketed by Passlogix as their only strong authentication product.
37. In March 2010 Passlogix merged v-GO AM into v-GO SSO, and granted over 10
million free licenses of v-GO AM to its existing customers.
VI.
2FA’S TECHNOLOGY
38. Greg Salyards, 2FA’s President and CEO and Shaun Cuttill, 2FA’s Chief
Technology Officer, are the two remaining co-founders of 2FA. Together they have more
than twenty years of experience in the still emerging strong authentication/credential
management market.
39. A credential management system in the software security industry is a software
system created to facilitate authentication events and manage the lifecycle of credential
related data that is bound to an individual.
FIRST AMENDED COMPLAINT Page 6 of 32