IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) VERINT SYSTEMS INC.

and ) VERINT AMERICAS INC. ) ) Plaintiffs, ) ) v. ) ) VOICE PRINT INTERNATIONAL, INC. ) ) Defendant. ) ) ) COMPLAINT Plaintiffs, Verint Systems Inc. (VSI) and Verint Americas Inc. (VAI) (collectively Verint), for their Complaint against Defendant, Voice Print International, Inc. (VPI), allege as follows: THE PARTIES 1. Plaintiff VSI is a corporation organized under the laws of the State of

Civil Action No. ___________ JURY TRIAL DEMANDED

Delaware, having its principal place of business at 330 South Service Road, Melville, NY 11747. 2. Plaintiff VAI is a corporation organized under the laws of the State of

Delaware, having its principal place of business at 800 North Point Parkway,

Alpharetta, GA 30022. VAI is a wholly-owned subsidiary of VSI. 3. Upon information and belief, Defendant VPI is a corporation

organized and existing under the laws of the State of California, having its principal place of business at 160 Camino Ruiz, Camarillo, CA 93012. JURISDICTION AND VENUE 4. This action arises under Title 35 of the United States Code.

Jurisdiction of this Court is based on 28 U.S.C. 1331 and 1338(a). Venue is proper in this district pursuant to 28 U.S.C. 1391(b), 1391(c), and 1400(b). BACKGROUND 5. Verint is engaged in the business of inventing, developing,

manufacturing, selling, installing, and/or distributing computer software and hardware products and systems. The products and systems are directed to, inter alia, the analysis, recording, monitoring, transmission, and/or security of electronic communications, such as but not limited to telephonic, facsimile, and e-mail communications to and from contact centers and call centers that handle incoming and/or outgoing contacts with actual and prospective customers and clients. Verints technology can provide an end user with the ability to capture, analyze and act on large volumes of complex, and often underused, information sources, such as voice, video, and unstructured text, which can enhance the ability of 2

organizations of all sizes to make timelier and effective decisions based on such information. 6. Verints products and systems are used by more than 10,000

organizations in over 150 countries, including over 80 percent of the Fortune 100. For example, Verints workforce optimization and voice of the customer solutions are designed to, inter alia, help organizations enhance customer service operations in contact centers, branches, and back-office environments, which in turn can increase customer satisfaction, reduce operating costs, identify revenue opportunities, and improve profitability. Verint uses its core competencies to develop highly scalable solutions with advanced, integrated analytics for both unstructured and structured information. Verint has expended substantial

resources inventing and developing this technology. For example, Verint utilizes more than 1,000 employees and contractors in research and development throughout the world, and has obtained more than 600 patents and applications worldwide. In fiscal year 2012 alone, Verint obtained issuance or allowance of 50 patents in the United States. Verint has licensed one or more of the patents to others in the industry under reasonable terms, through its Open Innovation NetworkTM (OIN) licensing program. 7. On information and belief, VPI manufactures, uses, sells, offers to 3

sell, installs, distributes, exports, and/or imports computer software and hardware products and systems in Georgia and elsewhere, directed to and for use in connection with methods involving the analysis, recording, monitoring, transmission, and security of electronic communications, such as telephonic communications to and from contact centers and call centers. VPI maintains, or has maintained, a web site that claims more than 1,500 loyal customers worldwide. A true and correct copy of the relevant web page is attached hereto as part of Exhibit 1. ALLEGATIONS COMMON TO MULTIPLE COUNTS 8. Verint is the sole owner of the entire right, title, and interest in and to

U.S. Patent No. 5,790,798 (the 798 patent); U.S. Patent No. 6,510,220 (the 220 patent); U.S. Patent No. 7,203,285 (the 285 patent); U.S. Patent No. 7,376,735 (the 735 patent); U.S. Patent No. 7,574,000 (the 000 patent); U.S. Patent No. 7,774,854 (the 854 patent); U.S. Patent No. 7,852,994 (the 994 patent); U.S. Patent No. 8,130,926 (the 926 patent); U.S. Patent No. 8,204,056 (the 056 patent); U.S. Patent No. RE43,324 (the 324 patent); and U.S. Patent

No. RE43,386 (the 386 patent) (collectively, the Patents-in-Suit).1, 2 9. The 285 and 000 patents are related, i.e., share a common effective

filing date and have similar or identical specifications; the 324 and 386 patents are related; the 798 and 220 patents are related. 10. Verint owns all right, title, and interest to the Patents-in-Suit,

including the right to sue for infringement thereof. As the owner of the Patents-inSuit, Verint has the right to bring actions for infringement of the Patents-in-Suit. 11. Upon information and belief, VPI has been manufacturing, using,

selling, offering to sell, installing, distributing, exporting, and/or importing computer software and hardware products and systems directed to and for use in connection with methods involving the analysis, recording, transmission, and

Verint has accused CallCopy, Inc. of infringing the 798 patent, the 220 patent, and the 386 patent in an action currently in its early stages in the Northern District of Georgia, Verint Systems Inc. and Verint Americas Inc. v. CallCopy, Inc. d/b/a Uptivity, 1:14-cv-00523-TWT. Verint has accused Envision Telephony, Inc. of infringing the 798 patent, the 220 patent, the 854 patent, the 324 patent, and the 386 patent in another action currently in its early stages in the Northern District of Georgia, Verint Systems Inc. and Verint Americas Inc. v. Envision Telephony, Inc., 1:14-cv-00260-TWT. 2 CallCopy, Inc. filed with the U.S. Patent and Trademark Office, Petitions for Inter Partes Review of the 994 patent and the 324 patent (IPR2013-00490; IPR2013-00492). Both of these petitions were denied in their entirety, with the Patent Trial and Appeal Board finding that the petitioner did not demonstrate a reasonable likelihood that at least one of the challenged claims was unpatentable based on the grounds asserted in the petitions. 5

security of electronic communications under the following trade designations in, into, or from the United States: VPI Empower Suite; VPI Capture Essential; VPI Capture; VPI Capture Pro; VPI Quality; VPI Quality Pro; VPI Fact Finder; VPI Insight; VPI Performance; VPI Coaching; VPI Foresight; and VPI VirtualSource. 12. The use of the above-identified products by VPIs customers

constitutes direct infringement of one or more of the Patents-in-Suit. 13. The VPI product VPI Empower is a software suite specifically

adapted for use in workforce management in the contact center industry or other related industries, and on information and belief has no other substantial use. Most, if not all, of the other VPI products identified in paragraph 11 are individual modules that are, or optionally can be provided as part of the Empower suite. 14. VPI on its web site states that the Empower suite provides its

customers with powerful Call Center Recording systems that deliver actionable insights and tools for effective Call Center Quality Assurance and real-time monitoring of contact center performance, with tightly integrated processes for targeted, timely improvement. VPI also states that the Empower suite can

provide proof of regulatory compliance by 100 percent Call Center Recording of voice and data interactions with optional filtering of sensitive data (PCI-DSS, 6

HIPAA, etc.) in high-volume, single or multi-site environments of any size. VPIs web site also states that the Empower suite can [i]ntelligently select and deliver high-value recordings for evaluation, combining the objectivity of random selection with the tools to focus on the types of interactions that drive your revenue and customer satisfaction goals. True and correct copies of the relevant VPI web pages are attached hereto as part of Exhibit 1. 15. VPI on its web site states: VPI EMPOWER is an award-winning

suite of innovative contact center applications that work in concert to help you record, analyze and optimize your workforce performance faster and easier than you thought possible, and without breaking a bank. Mix and match an array of software modules, features and integrations at your own pace. VPI characterizes the Empower suite as having a [u]nified Web-based access and architecture and a reliable and adaptable open architecture for easy, cost effective scaling, customization, integrations, security and administration. A true and correct copy of the relevant web page is attached hereto as part of Exhibit 1. 16. VPI on its web site states that the Empower suite can be used

[r]egardless of your size, number of locations, blend of local or home-based agents, type of PBX, CRM, helpdesk and other systems. VPI provides specific examples of how the accused products can be integrated into such platforms. For 7

example, VPIs web site includes a brochure that depicts the integration of the Empower software suite into the Cisco Systems Unified Communications Manager system. VPIs web site also depicts integration of Empower into Ciscos Unified Contact Center Enterprise system. VPIs web site also depicts integration of VPI software applications into the Avaya Communication Manager and/or IP Office. True and correct copies of the relevant web pages are attached hereto as part of Exhibit 1. 17. On information and belief, VPI implements and integrates its products

into the contact centers of its customers, and the use of the VPI products by its customers constitutes direct infringement of one or more of the Patents-in-Suit. For example, VPIs website includes a pages that states, under the heading System Implementation: A system engineer and your project manager will help to verify the completion of your site preparation. The VPI Operations Team will be involved in preparing the system build and burnin testing for your solution, and scheduling an onsite or remote installation date (acceptable to you or certified dealer) and technical resource to complete the installation of your solution. These details will be communicated through your assigned VPI Project Manager. A true and correct copy of the above-referenced web page is attached hereto as part of Exhibit 1. 18. On information and belief, VPI trains the personnel of its customers to 8

use its products. For example, VPIs website includes a page that states, under the heading Installation and Training: Your VPI installation technician (or certified dealer) will install equipment any purhcased [sic] hardware components, load software, and perform testing of all systems to your satisfaction. Once system verification is completed, your installation technician will train your technical system administrators, and a VPI Corporate Trainer will be scheduled to train your users on your new VPI applications. A true and correct copy of the above-referenced web page is attached hereto as part of Exhibit 1. 19. On information and belief, VPI has continuous and systematic

contacts with the State of Georgia. On information and belief, VPI maintains a permanent staff located in and/or supporting its activities in Georgia. Exhibit 2, which includes a printout from yatedo.com, indicates that VPI maintains a Sales Engineer in the greater Atlanta area. On information and belief, VPI has hired, seeks to hire, or has sought to hire personnel who are or will be located in, and/or support or will support VPIs activities in Georgia. Exhibit 3, which includes printouts from linkedin.com, indicates that VPI is seeking, or has sought to hire an Account ExecutiveSmall Medium Business, in Atlanta, Georgia. 20. On information and belief, VPI participated in the 2013 International

Customer Management Institute (ICMI) Contact Center Demo & Conference 9

(the 2013 ICMI Conference), which was held on October 21-23, 2013, in Atlanta, Georgia. On information and belief, the 2013 ICMI Conference included between 500 and 600 attendees, and on information and belief, VPI offered for sale and/or sold at the 2013 ICMI Conference one or more of the VPI products identified in paragraph 11. A true and correct copy of the Media Kit and

Prospectus for the 2014 ICMI Contact Center Demo & Conference, which indicates VPIs participation in the Conference, is attached hereto as part of Exhibit 4. 21. Upon information and belief, one or more companies located in

Georgia, or with operations in Georgia attended the 2013 ICMI Conference. A true and correct list of at least some of the attendees at the 2013 ICMI Conference is attached hereto as part of Exhibit 4. See Declaration of Amanda Dingus, attached hereto as Exhibit 5; see also Verint Systems Inc. and Verint Americas Inc. v. CallCopy, Inc. d/b/a Uptivity, 1:14-cv-00523-TWT (N.D. Ga.), Dkt. Nos. 1 at 15; 1-9; 1-10; 1-11. 22. On information and belief, attendees at the 2013 ICMI Conference,

including VPI, were allowed opportunities to visit and tour four companies in Atlanta, Georgia during the 2013 ICMI Conference These companies included Delta Air Lines, Convergent, AutoTrader.com, and The Home Depot. A true and 10

correct copy of ICMIs website showing the 2013 ICMI Conference site tours is attached hereto as Exhibit 6. Further, on information and belief, Atlanta-based companies such as Delta Air Lines and The Home Depot attended the 2013 ICMI Conference. 23. On information and belief, VPI has customers in Georgia and/or

customers with operations in Georgia, and on information and belief, VPI has offered for sale and/or has sold one or more of the VPI products identified in paragraph 11 to such customers. For example, VPIs website lists CNN and Turner Broadcasting System, Inc., both of which are headquartered in Atlanta, Georgia, as VPIs customers. True and correct copies of the relevant VPI web pages are attached hereto as part of Exhibit 1. True and correct copies of the relevant CNN and Turner web pages are attached hereto as Exhibit 7. 24. Further, in the Customer Testimonials section of its website, VPI lists

Manheim Auctions; HealthPort Technologies; and The College Life Fund Division as VPI customers. Manheim Auctions is headquartered in Atlanta, Georgia.

HealthPort Technologies is headquartered in Alpharetta, Georgia. The College Life Fund Division has an office in Norcross, Georgia. A true and correct copy of the relevant VPI web page is attached hereto as part of Exhibit 1. True and correct copies of the relevant Manheim Auctions, HealthPort Technologies, and College 11

Life Fund Division web pages are attached hereto as Exhibits 8, 9, and 10, respectively. 25. Further, VPI lists AirTran as one of its more than 1,500 loyal

customers. A true and correct copy of the relevant VPI web page is attached hereto as part of Exhibit 1. Upon information and belief, AirTran operated call centers in Carrollton, Georgia, and Savannah, Georgia, until July 2013. Upon AirTrans merger with Southwest Airlines, AirTran and Southwest Airlines began operating call centers in Atlanta, Georgia. A true and correct copy of the an online news article referring to Southwest Airlines/AirTrans Atlanta call center operations is attached hereto as Exhibit 11. 26. VPIs web site is interactive. For example, the website allows users to

request a demo, and permits the user to specifically select Georgia from a dropdown menu (after selecting United States as the country). The website can also be used to request quotes or additional information, and again permits the user to specifically select Georgia from a dropdown menu. True and correct copies of the relevant VPI web pages referenced in this paragraph are attached hereto as part of Exhibit 1. 27. On information and belief, VPI has resellers in Georgia. For instance,

VetConnexx, a company headquartered in Atlanta, Georgia, partners with VPI. A 12

true and correct copy of the relevant page from VetConnexxs website is attached hereto as Exhibit 12. By way of its partnership with VetConnexx, VPI has offered for sale and/or sold one or more of the VPI products listed in paragraph 11, through VetConnexx, to customers in Georgia and/or to customers with operations in Georgia. 28. On information and belief, VPI plans to host the Public Safety

Answering Points (PSAP) Forum to be held in in Atlanta, Georgia on November 13, 2014. A true and correct copy of the web site for the PSAP Forum is attached hereto as Exhibit 13. 29. On information and belief, Defendant VPI is infringing and has

infringed the Patents-in-Suit in violation of 35 U.S.C. 271 as follows: a. by making, using, offering to sell, and/or selling in the United

States or importing into the United States computer software and/or hardware and/or systems, including the following products: VPI Empower Suite; VPI Capture Essential; VPI Capture; VPI Capture Pro; VPI Quality; VPI Quality Pro; VPI Fact Finder; VPI Insight; VPI Performance; VPI Coaching; VPI Foresight; and VPI VirtualSource. (hereinafter, collectively the Accused Products), and/or by engaging in or practicing in the United States methods or processes covered by the Patents13

In-Suit, including such methods or processes which utilize one or more of the Accused Products; and/or b. by offering to sell or selling within the United States or

importing into the United States a component of a product or system (e.g., various components of the Empower Suite) covered by one or more of the Patents-In-Suit; or a component for use in practicing a method or process within one or more of the aforementioned patents, constituting a material part of one or more of the aforementioned patents, knowing the same to be especially made or especially adapted for use in an infringement of one or more of the aforementioned patents, and not a staple article or commodity of commerce suitable for substantial non-infringing use; and/or c. by supplying or causing to be supplied in or from the United

States all or a substantial portion of components (e.g., hardware required to accomplish to form a product or system covered by one or more of the Patents-In-Suit), including by supplying or causing to be supplied in or from the United States the Accused Products, in such a manner as to actively induce the combination of such components outside of the United States in a manner that would infringe one or more of the Patents-In-Suit if such combination occurred within the United States; and/or 14

d.

by supplying or causing to be supplied in or from the United

States a component of a product or system within one or more of the Patents-In-Suit that is especially made or especially adapted for use according to one or more of the Patents-In-Suit and is not a staple article or commodity of commerce suitable for substantial non-infringing use, knowing that such component is so made or adapted and intending that such component will be combined outside of the United States in a manner that would infringe one or more of the Patents-In-Suit if such combination occurred within the United States, including by supplying or causing to be supplied in or from the United States one or more of the Accused Products; and/or e. by actively inducing one or more of the activities identified in

subparagraphs (a) through (d) hereof with respect to at least the 798 patent; the 220 patent; the 285 patent; the 735 patent; the 000 patent; and the 854 patent. 30. VPI actively encourages its customers to purchase third party

equipment for the purpose of using systems and methods covered by one or more of the Patents-In-Suit. For example, VPI states on its web site that [w]hen configured for the Avaya H.323 option, VPI CAPTURE performs recording of 15

VoIP calls by collecting the Real-time Transport Protocol (RTP) voice packets bound for the agents IP telephones or softphones. A true and correct copy of the relevant VPI web page is attached hereto as part of Exhibit 1. 31. VPI actively induces its customers to directly infringe systems and

methods covered by one or more of the Patents-In-Suit by encouraging and training those customers to combine software, e.g., the Empower Suite, with telecommunications hardware provided by third party venders. A true and correct copy of the relevant VPI web page is attached hereto as part of Exhibit 1. 32. VPI contributes to the direct infringement of its customers by

providing software which is specially adapted for use in systems and in performing methods covered by one or more of the Patents-In-Suit. VPIs software is not a staple of commerce and the features of its software are not suitable for any noninfringing use. 33. VPI had actual knowledge and/or notice of at least the 798 patent; the

220 patent; the 285 patent; the 735 patent; the 000 patent; and the 854 patent from a time prior to the filing of the present complaint, and/or subjectively believed that there was a high probability that one or more of the aforementioned patents existed prior to the filing of the present complaint, and took deliberate actions to avoid learning of the existence of the aforementioned patents. 16

34.

By letter dated August 23, 2010, VSI contacted VPI and invited VPI

to participate in the OIN. A true and correct copy of the August 23rd letter is attached hereto as Exhibit 14. OIN is a licensing program under which VSI offers to grant, under reasonable terms, a world-wide license to its extensive portfolio of patents directed, in part, to the analysis, recording, monitoring, transmission, and/or security of electronic communications such as telephonic, facsimile, and email communications. 35. In its August 23rd correspondence, VSI provided VPI with claim

charts showing how VPIs activities fall within the claim scope of various patents within the OIN, including the 798 patent; the 220 patent; the 285 patent; the 735 patent; the 000 patent; and the 854 patent. True and correct copies of the claim charts directed to these patents are attached hereto as Exhibit 15. 36. In its August 23, 2010, correspondence, VSI also provided VPI with a

Patent Marking Notice, a true and correct copy of which is attached hereto as Exhibit 16. The Patent Marking notice listed the 798 patent; the 220 patent; the 285 patent; the 735 patent; the 000 patent; and the 854 patent. (Id.) The Patent Marking notice also listed the pending applications that subsequently issued as the 926 patent (U.S. Application Serial No. 11/608,358) and the 056 patent (U.S. Application Serial No. 11/395,759). 17

37.

Verints on-line Intellectual Property Notice is updated no less All of the Patents-in-Suit were listed on the on-line

frequently than yearly.

Intellectual Property Notice no later than January 15, 2013. Exhibit 17 attached hereto is a true and correct copy of the on-line Intellectual Property Notice as of January 15, 2013. 38. Andrew Marsh, President and CEO of VPI, replied to VSIs August

23, 2010 letter in correspondence dated September 30, 2010, in which Mr. Marsh requested additional time to study the documents provided by Verint. A true and correct copy of the September 30th correspondence is attached hereto as Exhibit 18. 39. By letter dated October 14, 2010 from VSI to Mr. Marsh, VSI

acknowledged Mr. Marshs correspondence of September 30th, and invited Mr. Marsh to discuss this matter in a telephone conference. A true and correct copy of the October 14th correspondence is attached hereto as Exhibit 19. 40. Upon receiving no further response from Mr. Marsh, Verint on

January 4, 2011 sent follow-up correspondence to Mr. Marsh requesting a response. A true and correct copy of this correspondence is attached hereto as Exhibit 20. 41. Having received no response from Mr. Marsh as of March 8, 2012, 18

Verint on that date sent further correspondence to Mr. Marsh informing him that Verint had recently obtained another participant in the OIN, and once again asking Mr. Marsh to provide an indication of his availability for a discussion relating to licensing and business opportunities. A true and correct copy of this

correspondence is attached hereto as Exhibit 21. 42. On April 16, 2013, Verint, through its outside counsel, sent

correspondence to Mr. Marsh forwarding a copy of a complaint in which seven of the patents being asserted in the present complaint were asserted against another entity, CallCopy, Inc. Verint, in this correspondence, also reiterated its invitation for VPI to obtain a license relating to Verints patent portfolio on reasonable terms. A true and correct copy of the forwarding correspondence is attached hereto as Exhibit 22. 43. On August 15, 2013, Verints outside counsel sent additional

correspondence to Mr. Marsh forwarding copies of complaints for patent infringement filed in two other actions. In one of these actions, the named

defendant, Interactive Intelligence, Inc., was accused of infringing all of the patents being asserted in the present complaint. In the other action, the named defendant, CallCopy, was accused of infringing three of the patents being asserted in the present complaint. A true and correct copy of the forwarding correspondence is 19

attached hereto as Exhibit 23. 44. On November 7, 2013, Verints outside counsel sent a confidentiality

agreement to Mr. Marsh for his review and signature. Verints outside counsel also indicated that outside counsel would be contacting Mr. Marsh shortly regarding the OIN. A true and correct copy of the forwarding correspondence is attached hereto as Exhibit 24. Notwithstanding Verints efforts to contact Mr. Marsh, substantive licensing discussions between Verint and VPI have not occurred. 45. Despite Verint providing VPI with multiple opportunities for an

amicable resolution, no licensing arrangement has been reached between the parties. 46. Verint has been damaged as a result of VPIs acts of patent

infringement in an amount to be determined at trial. 47. Verint will suffer imminent and irreparable injury unless this Court

enjoins VPI from further acts of infringement. COUNT I (Infringement of the 798 patent) 48. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 47 above. 49. The 798 patent, entitled Method and Apparatus for Simultaneously 20

Monitoring Computer User Screen and Telephone Activity From a Remote Location, was duly and legally issued on August 4, 1998, and is currently in full force and effect and has been since the date of issuance. A copy of the 798 patent is attached hereto as Exhibit 25. COUNT II (Infringement of the 220 patent) 50. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 49 above. 51. The 220 patent, entitled Method and Apparatus for Simultaneously

Monitoring Computer User Screen and Telephone Activity From a Remote Location, was duly and legally issued on January 21, 2003, and is currently in full force and effect and has been since the date of issuance. A copy of the 220 patent is attached hereto as Exhibit 26. COUNT III (Infringement of the 285 patent) 52. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 51 above. 53. The 285 patent, entitled System and Method for Recording Voice

and the Data Entered by a Call Center Agent and Retrieval of These Communication Streams for Analysis or Correction, was duly and legally issued 21

on April 10, 2007 and is currently in full force and effect and has been since the date of issuance. A copy of the 285 patent is attached hereto as Exhibit 27. COUNT IV (Infringement of the 735 patent) 54. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 53 above. 55. The 735 patent, entitled Method, Apparatus, and System for

Capturing Data Exchanged Between a Server and a User, was duly and legally issued on May 20, 2008 and is currently in full force and effect and has been since the date of issuance. A copy of the 735 patent is attached hereto as Exhibit 28. COUNT V (Infringement of the 000 patent) 56. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 55 above. 57. The 000 patent, entitled System and Method for Analysing

Communications Streams, was duly and legally issued on August 11, 2009 and is currently in full force and effect and has been since the date of issuance. A copy of the 000 patent is attached hereto as Exhibit 29.

22

COUNT VI (Infringement of the 854 patent) 58. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 57 above. 59. The 854 patent, entitled Systems and Methods for Protecting

Information, was duly and legally issued on August 10, 2010 and is currently in full force and effect and has been since the date of issuance. A copy of the 854 patent is attached hereto as Exhibit 30. COUNT VII (Infringement of the 994 patent) 60. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 59 above. 61. The 994 patent, entitled Systems and Methods for Recording

Audio, was duly and legally issued on December 14, 2010 and is currently in full force and effect and has been since the date of issuance. A copy of the 994 patent is attached hereto as Exhibit 31. COUNT VIII (Infringement of the 926 patent) 62. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 61 above.

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63.

The 926 patent, entitled Systems and Methods for Recording Data,

was duly and legally issued on March 6, 2012 and is currently in full force and effect and has been since the date of issuance. A copy of the 926 patent is attached hereto as Exhibit 32. COUNT IX (Infringement of the 056 patent) 64. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 63 above. 65. The 056 patent, entitled Systems and Methods for Endpoint

Recording Using a Media Application Server, was duly and legally issued on June 19, 2012 and is currently in full force and effect and has been since the date of issuance. A copy of the 056 patent is attached hereto as Exhibit 33. COUNT X (Infringement of the 324 patent) 66. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 65 above. 67. The 324 patent, entitled VOIP Voice Interaction Monitor, was duly

and legally issued on April 24, 2012 and is currently in full force and effect and has been since the date of issuance. A copy of the 324 patent is attached hereto as Exhibit 34. 24

COUNT XI (Infringement of the 386 patent) 68. Plaintiffs incorporate by reference each and every allegation contained

in paragraphs 1 through 67 above. 69. The 386 patent, entitled Communication Management System for

Network-Based Telephones, was duly and legally issued on May 15, 2012 and is currently in full force and effect and has been since the date of issuance. A copy of the 386 patent is attached hereto as Exhibit 35. PRAYER FOR RELIEF WHEREFORE, Plaintiffs pray for judgment as follows: 1. That Defendant VPI has been and is infringing, is contributing to the

infringement of, and is actively inducing infringement of the Patents-in-Suit; 2. That Defendant and its officers, agents, and employees and all others

in concert or participation with them be preliminarily and permanently enjoined from further acts of infringement of the Patents-in-Suit under 35 U.S.C. 283; 3. That Plaintiffs be awarded damages adequate to compensate them for

Defendants infringement of the Patents-in-Suit, together with interest and costs under 35 U.S.C. 284; 4. That Defendant be directed to file with this Court and serve on

Plaintiffs within thirty (30) days after service of an injunction, a report in writing, 25

under oath, setting forth in detail the manner and form in which Defendant has complied with this injunction ordered by this Court; 5. That Defendant be required to pay all of Plaintiffs costs and

expenses, including expert witness fees; and 6. That Plaintiffs be awarded such other and further relief as this Court

deems just and proper. DEMAND FOR JURY TRIAL Plaintiffs hereby demand trial by jury on all issues raised by the Complaint.

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Respectfully submitted, this 11th day of March, 2014. MEUNIER CARLIN & CURFMAN, LLC /s/ Walter Hill Levie, III Stephen M. Schaetzel Georgia State Bar No. 628653 sschaetzel@mcciplaw.com Walter Hill Levie, III Georgia State Bar No. 415569 tlevie@mcciplaw.com David S. Moreland Georgia State Bar No. 521998 dmoreland@mcciplaw.com 817 West Peachtree Street, NW Suite 500 Atlanta, Georgia 30308 Telephone: (404) 645-7700 Facsimile: (404) 645-7707 Attorneys for Plaintiffs Verint Systems Inc. and Verint Americas Inc. Of Counsel: Joseph F. Posillico, Esq. Frank T. Carroll, Esq. Ryan N. Miller, Esq. FOX ROTHSCHILD LLP 2000 Market Street, 20th Floor Philadelphia, PA 19103-3222 Telephone: (215) 299-2000

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