SETTLEMENT AGREEMENTSettlement Agreement • April 9th, 2009 • SCM Microsystems Inc • Computer peripheral equipment, nec • California
This Settlement Agreement (the “Settlement Agreement”) is hereby entered into this 8th day of April, 2009 (the “Effective Date”) between and among Secure Keyboards, Ltd., a California Limited Partnership (“Secure Keyboards”); Secure Networks, Ltd., a California Limited Partnership (“Secure Networks”); Luis Villalobos, an individual (“Villalobos”); Howard B. Miller, an individual (“Miller”); Lawrence W. Midland, an individual (“Midland”); Robert J. Parsons, an individual (“Parsons”); Hirsch Electronics Corporation, a California corporation (“Hirsch”); SCM Microsystems, Inc., a Delaware corporation (“SCM”); and Felix Marx, an individual (“Marx”) (each a “Party” and collectively the “Parties”). Secure Keyboards, Villalobos and Miller are also sometimes collectively referred to herein as “Plaintiffs,” and each as a “Plaintiff.” SCM, Hirsch and Marx are also sometimes collectively referred to herein as “Defendants,” and each as a “Defendant.”
