WhatsApp Sues NSO Group For WhatsApp Hack

Case 3:19-cv-07123 Document 1 Filed 10/29/19 Page 1 of 15
1 COOLEY LLP
TRAVIS LEBLANC (251097) ([email protected])
2 JOSEPH D. MORNIN (307766) ([email protected])
101 California Street, 5th floor
3 San Francisco, CA 94111-5800
Telephone: (415) 693-2000
4 Facsimile: (415) 693-2222
5 DANIEL J. GROOMS (D.C. Bar No. 219124) (pro hac vice forthcoming)
([email protected])
6 1299 Pennsylvania Avenue, NW, Suite 700
Washington, DC 20004-2400
7 Telephone: (202) 842-7800
Facsimile: (202) 842-7899
8
Attorneys for Plaintiffs
9 WHATSAPP INC. and FACEBOOK, INC.
10
UNITED STATES DISTRICT COURT
11
NORTHERN DISTRICT OF CALIFORNIA
12
13
WHATSAPP INC., a Delaware corporation, Case No.
14 and FACEBOOK, INC., a Delaware
corporation, COMPLAINT
15
DEMAND FOR JURY TRIAL
16 Plaintiffs,
17 v.
18 NSO GROUP TECHNOLOGIES LIMITED

and Q CYBER TECHNOLOGIES LIMITED,
19
Defendants.
20
21
22
23
24
25
26
27
28
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1 Plaintiffs WhatsApp Inc. and Facebook, Inc. (collectively, “Plaintiffs”) allege the following
2 against Defendants NSO Group Technologies Ltd. (“NSO Group”) and Q Cyber Technologies Ltd.
3 (“Q Cyber”) (collectively, “Defendants”):
4 INTRODUCTION
5 1. Between in and around April 2019 and May 2019, Defendants used WhatsApp servers,
6 located in the United States and elsewhere, to send malware to approximately 1,400 mobile phones
7 and devices (“Target Devices”). Defendants’ malware was designed to infect the Target Devices for
8 the purpose of conducting surveillance of specific WhatsApp users (“Target Users”). Unable to break
9 WhatsApp’s end-to-end encryption, Defendants developed their malware in order to access messages
10 and other communications after they were decrypted on Target Devices. Defendants’ actions were
11 not authorized by Plaintiffs and were in violation of WhatsApp’s Terms of Service. In May 2019,
12 Plaintiffs detected and stopped Defendants’ unauthorized access and abuse of the WhatsApp Service
13 and computers.
14 2. Plaintiffs bring this action for injunctive relief and damages pursuant to the Computer
15 Fraud and Abuse Act, 18 U.S.C. § 1030, and the California Comprehensive Computer Data Access
16 and Fraud Act, California Penal Code § 502, and for breach of contract and trespass to chattels.
17 PARTIES
18 3. Plaintiff WhatsApp Inc. (“WhatsApp”) is a Delaware corporation with its principal
19 place of business in Menlo Park, California.
20 4. Plaintiff Facebook, Inc. (“Facebook”) is a Delaware corporation with its principal place
21 of business in Menlo Park, California. Facebook acts as WhatsApp’s service provider for security-
22 related issues.
23 5. Defendant NSO Group was incorporated in Israel on January 25, 2010, as a limited
24 liability company. Ex. 1. NSO Group had a marketing and sales arm in the United States called
25 WestBridge Technologies, Inc. Ex. 2 and 3. Between 2014 and February 2019, NSO Group obtained
26 financing from a San Francisco–based private equity firm, which ultimately purchased a controlling
27 stake in NSO Group. Ex. 4. In and around February 2019, NSO Group was reacquired by its founders
28
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1 and management. Id. NSO Group’s annual report filed on February 28, 2019, listed Defendant Q
2 Cyber as the only active director of NSO Group and its majority shareholder. Ex. 5.
3 6. Defendant Q Cyber was incorporated in Israel on December 2, 2013, under the name
4 L.E.G.D. Company Ltd. Ex. 6 and 7. On May 29, 2016, L.E.G.D. Company Ltd. changed its name
5 to Q Cyber. Ex. 7. Until at least June 2019, NSO Group’s website stated that NSO Group was “a Q
6 Cyber Technologies company.” Ex. 8. Q Cyber’s annual report filed on June 17, 2019, listed OSY
7 Technologies S.A.R.L. as the only Q Cyber shareholder and active Director. Ex. 9
8 7. At all times material to this action, each Defendant was the agent, partner, alter ego,
9 subsidiary, and/or coconspirator of and with the other Defendant, and the acts of each Defendant were
10 in the scope of that relationship. In doing the acts and failing to act as alleged in this Complaint, each
11 Defendant acted with the knowledge, permission, and consent of each other; and, each Defendant
12 aided and abetted each other.
13 JURISDICTION AND VENUE
14 8. The Court has federal question jurisdiction over the federal causes of action alleged in
15 this Complaint pursuant to 28 U.S.C. § 1331.
16 9. The Court has supplemental jurisdiction over the state law causes of action alleged in
17 this Complaint pursuant to 28 U.S.C. § 1367 because these claims arise out of the same nucleus of
18 operative fact as Plaintiffs’ federal claims.
19 10. In addition, the Court has jurisdiction over all the causes of action alleged in this
20 Complaint pursuant to 28 U.S.C. § 1332 because complete diversity between the Plaintiffs and each
21 of the named Defendants exists, and because the amount in controversy exceeds $75,000.
22 11. The Court has personal jurisdiction over Defendants because they obtained financing
23 from California and directed and targeted their actions at California and its residents, WhatsApp and
24 Facebook. The claims in this Complaint arise from Defendants’ actions, including their unlawful
25 access and use of WhatsApp computers, several of which are located in California.
26 12. The Court also has personal jurisdiction over Defendants because Defendants agreed
27 to WhatsApp’s Terms of Service (“WhatsApp Terms”) by accessing and using WhatsApp. In relevant
28 part, the WhatsApp Terms required Defendants to submit to the personal jurisdiction of this Court.
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1 13. Venue is proper in this Judicial District pursuant to 28 U.S.C. § 1391(b), as the
2 threatened and actual harm to WhatsApp and Facebook occurred in this District.
3 14. Pursuant to Civil L.R. 3-2(d), this case may be assigned to either the San Francisco or
4 Oakland division because WhatsApp and Facebook are located in San Mateo County.
5 FACTUAL ALLEGATIONS
6 A. Background on Facebook
7 15. Facebook is a social networking website and mobile application that enables its users
8 to create their own personal profiles and connect with each other on their personal computers and
9 mobile devices. As of June 2019, Facebook daily active users averaged 1.59 billion and monthly active
10 users averaged 2.41 billion.
11 16. In October 2014, Facebook acquired WhatsApp. At all times relevant to this action,
12 Facebook has served as WhatsApp’s service provider, which entails providing both infrastructure and
13 security for WhatsApp.
14 B. Background on WhatsApp
15 1. The WhatsApp Service
16 17. WhatsApp provides an encrypted communication service available on mobile devices
17 and desktop computers (the “WhatsApp Service”). Approximately 1.5 billion people in 180 countries
18 use the WhatsApp Service. Users must install the WhatsApp app to use the WhatsApp Service.
19 18. Every type of communication (calls, video calls, chats, group chats, images, videos,
20 voice messages, and file transfers) on the WhatsApp Service is encrypted during its transmission
21 between users. This encryption protocol was designed to ensure that no one other than the intended
22 recipient could read any communication sent using the WhatsApp Service.
23 2. WhatsApp’s Terms of Service
24 19. Every WhatsApp user must create an account and agree and consent to WhatsApp’s
25 Terms (available at https://www.whatsapp.com/legal?eea=0#terms-of-service).
26 20. The WhatsApp Terms stated that “You must use our Services according to our Terms
27 and policies” and that users agreed to “access and use [WhatsApp’s] Services only for legal,
28 authorized, and acceptable purposes.”

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1 21. The WhatsApp Terms prohibited using the WhatsApp services in ways that (a) “violate,
2 misappropriate, or infringe the rights of WhatsApp, our users, or others, including privacy;” (b) “are
3 illegal, intimidating, harassing, . . . or instigate or encourage conduct that would be illegal, or otherwise
4 inappropriate;” [or] . . . (e) “involve sending illegal or impermissible communications.”
5 22. The WhatsApp Terms prohibited users from “exploiting [WhatsApp’s] Services in
6 impermissible or unauthorized manners, or in ways that burden, impair, or harm us, our Services,
7 systems, our users, or others.” The Terms also required users to agree not to: “(a) reverse engineer,
8 alter, modify, create derivative works from, decompile, or extract code from our Services; (b) send,
9 store, or transmit viruses or other harmful computer code through or onto our Services; (c) gain or
10 attempt to gain unauthorized access to our Services or systems; (d) interfere with or disrupt the safety,
11 security, or performance of our Services; [or] . . . (f) collect the information of or about our users in
12 any impermissible or unauthorized manner.”
13 23. The WhatsApp Terms prohibited users not just from personally engaging in the conduct
14 listed above, but also from assisting others in doing so.
15 C. Background on NSO Group and Pegasus

16 24. Defendants manufactured, distributed, and operated surveillance technology or
17 “spyware” designed to intercept and extract information and communications from mobile phones and
18 devices. Defendants’ products included “Pegasus,” a type of spyware known as a remote access trojan.
19 Ex. 10 and 11. According to Defendants, Pegasus and its variants (collectively, “Pegasus”) were
20 designed to be remotely installed and enable the remote access and control of information—including
21 calls, messages, and location—on mobile devices using the Android, iOS, and BlackBerry operating
22 systems. Id.
23 25. On information and belief, in order to enable Pegasus’ remote installation, Defendants
24 exploited vulnerabilities in operating systems and applications (e.g., CVE-2016-4657) and used other
25 malware delivery methods, like spearphishing messages containing links to malicious code. Id.
26 26. According to media reports and NSO documents, Defendants claimed that Pegasus
27 could be surreptitiously installed on a victim’s phone without the victim taking any action, such as
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1 clicking a link or opening a message (known as remote installation). 1 Id. Defendants promoted that
2 Pegasus’s remote installation feature facilitated infecting victims’ phones without using spearphishing
3 messages that could be detected and reported by the victims.
4 27. According to NSO Group, Pegasus could “remotely and covertly extract valuable
5 intelligence from virtually any mobile device.” Id. Pegasus was designed, in part, to intercept
6 communications sent to and from a device, including communications over iMessage, Skype,
7 Telegram, WeChat, Facebook Messenger, WhatsApp, and others. Id. On information and belief,
8 Pegasus was modular malware, which meant that it could be customized for different purposes,
9 including to intercept communications, capture screenshots, and exfiltrate browser history and
10 contacts from the device. Id.
11 28. Defendants used a network of computers to monitor and update the version of Pegasus
12 implanted on the victims’ phones. Id. These Defendant-controlled computers relayed malware,
13 commands, and data between a compromised phone, Defendants, and Defendants’ customers. This
14 network served as the nerve center through which Defendants supported and controlled their
15 customers’ operation and use of Pegasus. In some instances, Defendants limited the number of
16 concurrent devices that their customers could compromise with Pegasus to 25. Ex. 11.
17 29. Defendants profited by licensing Pegasus and selling support services to their
18 customers, which included Pegasus installation, monitoring, and training. Ex. 10 and 11. Defendants
19 also offered technical support to customers using Pegasus to infect victims’ phones, including: (a)
20 technical support by email and phone; and (b) remote troubleshooting by Defendants’ engineers
21 through remote desktop software and a virtual private network. Id.
22
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24
25
26
1
See Financial Times, “Israel’s NSO: the business of spying on your iPhone” (May 14, 2019),
27 available at https://www.ft.com/content/7f2f39b2-733e-11e9-bf5c-6eeb837566c5; Vice, “They Got
Everything” (September 20, 2018), available at https://www.vice.com/en_us/article/qvakb3/inside-
28 nso-group-spyware-demo.
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1 D. Defendants Agreed to the WhatsApp Terms
2 30. Between January 2018 and May 2019, Defendants created and caused to be created
3 various WhatsApp accounts and agreed to the WhatsApp Terms. Defendants’ employees and agents
4 accepted and agreed to be bound by the Terms on behalf of Defendants.
5 31. At all times relevant to this Complaint, Defendants were bound by the WhatsApp
6 Terms.
7 E. Defendants Accessed and Used Plaintiffs’ Servers Without Authorization
8 and Infected Target Users’ Devices With Malware
9 1. Overview
10 32. Defendants took a number of steps, using WhatsApp servers and the WhatsApp Service
11 without authorization, to send discrete malware components (“malicious code”) to Target Devices.
12 First, Defendants set up various computer infrastructure, including WhatsApp accounts and remote
13 servers, used to infect the Target Devices and conceal Defendants’ identity and involvement. Second,
14 Defendants used and caused to be used WhatsApp accounts to initiate calls through Plaintiffs’ servers
15 that were designed to secretly inject malicious code onto Target Devices. Third, Defendants caused
16 the malicious code to execute on some of the Target Devices, creating a connection between those
17 Target Devices and computers controlled by Defendants (the “remote servers”). Fourth, on
18 information and belief, Defendants caused Target Devices to download and install additional
19 malware—believed to be Pegasus or another remote access trojan developed by Defendants—from
20 the remote servers for the purpose of accessing data and communications on Target Devices.
21 2. Defendants Set Up Computer Infrastructure Used to Infect the Target
22 Devices
23 33. Between approximately January 2018 and May 2019, Defendants created WhatsApp
24 accounts that they used and caused to be used to send malicious code to Target Devices in April and
25 May 2019. The accounts were created using telephone numbers registered in different counties,
26 including Cyprus, Israel, Brazil, Indonesia, Sweden, and the Netherlands.
27 34. Beginning no later than 2019, Defendants leased and caused to be leased servers and
28 internet hosting services in different countries, including the United States, in order to connect the
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1 Target Devices to a network of remote servers intended to distribute malware and relay commands to
2 the Target Devices. This network included proxy servers and relay servers (collectively, “malicious
3 servers”). The malicious servers were owned by Choopa, Quadranet, and Amazon Web Services
4 (“AWS”), among others. The IP address of one of the malicious servers was previously associated
5 with subdomains used by Defendants.
6 3. Defendants’ Unauthorized Access of Plaintiff’s Servers

7 35. On information and belief, Defendants reverse-engineered the WhatsApp app and
8 developed a program to enable them to emulate legitimate WhatsApp network traffic in order to
9 transmit malicious code—undetected—to Target Devices over WhatsApp servers. Defendants’
10 program was sophisticated, and built to exploit specific components of WhatsApp network protocols
11 and code. Network protocols generally define rules that control communications between network
12 computers, including protocols for computers to identify and connect with other computers, as well as
13 formatting rules that specify how data is packaged and transmitted.
14 36. In order to compromise the Target Devices, Defendants routed and caused to be routed
15 malicious code through Plaintiffs’ servers—including Signaling Servers and Relay Servers—
16 concealed within part of the normal network protocol. WhatsApp’s Signaling Servers facilitated the
17 initiation of calls between different devices using the WhatsApp Service. WhatsApp’s Relay Servers
18 facilitated certain data transmissions over the WhatsApp Service. Defendants were not authorized to
19 use Plaintiffs’ servers in this manner.
20 37. Between approximately April and May 2019, Defendants used and caused to be used,
21 without authorization, WhatsApp Signaling Servers, in an effort to compromise Target Devices. To
22 avoid the technical restrictions built into WhatsApp Signaling Servers, Defendants formatted call
23 initiation messages containing malicious code to appear like a legitimate call and concealed the code
24 within call settings. Disguising the malicious code as call settings enabled Defendants to deliver it to
25 the Target Device and made the malicious code appear as if it originated from WhatsApp Signaling
26 Servers. Once Defendants’ calls were delivered to the Target Device, they injected the malicious code
27 into the memory of the Target Device—even when the Target User did not answer the call.
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1 38. For example, on May 9, 2019, Defendants used WhatsApp servers to route malicious
2 code, which masqueraded as a series of legitimate calls and call settings, to a Target Device using
3 telephone number (202) XXX-XXXX. On information and belief, the malicious code concealed
4 within the calls was then installed in the memory of the Target Device.
5 39. Between April and May 2019, Defendants also used and caused to be used WhatsApp’s
6 Relay Servers without authorization to send encrypted data packets designed to activate the malicious
7 code injected into the memory of the Target Devices. When successfully executed, the malicious code
8 caused the Target Device to send a request to one of the malicious servers controlled by Defendants.
9 40. On information and belief, the malicious servers connected the Target Devices to
10 remote servers hosting Defendants’ malware. The malicious code on the Target Devices then
11 downloaded and installed Defendants’ malware from those servers.
12 41. On information and belief, after it was installed, Defendants’ malware was designed to
13 give Defendants and their customers access to information and data stored on the Target Devices,
14 including their communications.
15 42. Between approximately April 29, 2019, and May 10, 2019, Defendants caused their
16 malicious code to be transmitted over WhatsApp servers in an effort to infect approximately 1,400
17 Target Devices. The Target Users included attorneys, journalists, human rights activists, political
18 dissidents, diplomats, and other senior foreign government officials.
19 43. The Target Users had WhatsApp numbers with country codes from several countries,
20 including the Kingdom of Bahrain, the United Arab Emirates, and Mexico. According to public
21 reporting, Defendants’ clients include, but are not limited to, government agencies in the Kingdom of
22 Bahrain, the United Arab Emirates, and Mexico as well as private entities. 2
23
24 2
See Fast Company, “Israeli cyberweapon targeted the widow of a slain Mexican journalist” (March
20, 2019), available at https://www.fastcompany.com/90322618/nso-group-pegasus-cyberweapon-
25 targeted-the-widow-of-a-slain-mexican-journalist; New York Times, “Hacking a Prince, and Emir and
a Journalist to Impress a Client” (August 31, 2018), available at
26 https://www.nytimes.com/2018/08/31/world/middleeast/hacking-united-arab-emirates-nso-
group.html; The Guardian, “Israeli firm linked to WhatsApp spyware attack faces lawsuit” (May 18,
27 2019), available at https://www.theguardian.com/world/2019/may/18/israeli-firm-nso-group-linked-
to-whatsapp-spyware-attack-faces-lawsuit.
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1 44. On or about May 13, 2019, Facebook publicly announced that it had investigated and
2 identified a vulnerability involving the WhatsApp Service (CVE-2019-3568). WhatsApp and
3 Facebook closed the vulnerability, contacted law enforcement, and advised users to update the
4 WhatsApp app.
5 45. Defendants subsequently complained that WhatsApp had closed the vulnerability.
6 Specifically, NSO Employee 1 stated, “You just closed our biggest remote for cellular . . . It’s on the
7 news all over the world.”
8 F. Defendants’ Unlawful Acts Have Caused Damage and Loss to WhatsApp and
9 Facebook
10 46. Defendants’ actions and omissions interfered with the WhatsApp Service and burdened
11 Plaintiffs’ computer network.
12 47. Defendants’ actions injured Plaintiffs’ reputation, public trust, and goodwill.
13 48. Defendants have caused Plaintiffs damages in excess of $75,000 and in an amount to
14 be proven at trial.
15 FIRST CAUSE OF ACTION
16 (Computer Fraud and Abuse Act, 18 U.S.C. § 1030)
17 49. Plaintiffs reallege and incorporate by reference all preceding paragraphs.
18 50. At various times between April 29, 2019, and May 10, 2019, Defendants accessed,
19 used, or caused to be accessed or used Plaintiffs’ Signaling Servers and Relay Servers without
20 authorization in an effort to compromise approximately 1,400 Target Devices.
21 51. Plaintiffs’ Signaling Servers and Relay Servers and the Target Devices were
22 “computers” as defined by 18 U.S.C. § 1030(e)(1).
23 52. Plaintiffs’ Signaling Servers and Relay Servers and the Target Devices were “protected
24 computers” as defined by 18 U.S.C. § 1030(e)(2)(B) because they are “used in or affecting interstate
25 or foreign commerce or communication.”
26 53. Defendants violated 18 U.S.C. § 1030(a)(2) because they intentionally accessed and
27 caused to be accessed (a) Plaintiffs’ computers, and (b) Target Devices, without authorization and, on
28 information and belief, obtained data from the Target Devices.

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1 54. Defendants violated 18 U.S.C. § 1030(a)(4) because they knowingly and with intent to
2 defraud accessed and caused to be accessed (a) Plaintiffs’ protected computers and (b) Target Devices
3 without authorization, and by means of such conduct furthered the intended fraud and obtained
4 something of value. Defendants’ fraud included falsely agreeing to the WhatsApp Terms, sending
5 unauthorized commands to Plaintiffs’ computers and concealing the commands as legitimate network
6 traffic, in order to gain access of the Target Devices without the Target Users’ knowledge or consent.
7 As a result of the fraud, Defendants obtained money, customers, remote access and control of the
8 Target Devices, data from the Target Devices, and unauthorized use of the WhatsApp service, the
9 value of which exceeds $5,000.
10 55. Defendants violated 18 U.S.C. § 1030(b) by conspiring and attempting to commit the
11 violations alleged in the preceding paragraphs.
12 56. Defendants’ conduct caused a loss to Plaintiffs and the Target Users in excess of $5,000
13 during a one-year period.
14 57. Defendants’ actions caused Plaintiffs to incur a loss as defined in 18 U.S.C.
15 § 1030(e)(11), including the expenditure of resources to investigate and remediate Defendants’ fraud
16 and unauthorized access. Plaintiffs are entitled to be compensated for losses and damages, and any
17 other amount to be proven at trial.
18 SECOND CAUSE OF ACTION
19 (California Comprehensive Computer Data Access and Fraud Act,

California Penal Code § 502)
20
21 58. Plaintiffs reallege and incorporate by reference all of the preceding paragraphs.
22 59. Defendants knowingly accessed and without permission altered and used Plaintiffs’
23 data, computer, computer system, and computer network in order to (a) devise and execute a scheme
24 and artifice to defraud and deceive, and (b) wrongfully control and obtain money, property, and data
25 in violation of California Penal Code § 502(c)(1).
26 60. Defendants knowingly and without permission used and caused to be used WhatsApp
27 Signaling Servers and Relay Servers, including servers located in California, in violation of California
28 Penal Code § 502(c)(3).

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1 61. Defendants knowingly and without permission provided and assisted in providing a
2 means of accessing Plaintiffs’ computers, computer systems, and computer networks, including those
3 located in California, in violation of California Penal Code § 502(c)(6).
4 62. Defendants knowingly and without permission accessed and caused to be accessed
5 Plaintiffs’ computers, computer systems, and computer networks, including those located in
6 California, in violation of California Penal Code § 502(c)(7).
7 63. Defendants knowingly introduced a computer contaminant into Plaintiffs’ computers,
8 computer systems, and computer networks in violation of California Penal Code § 502(c)(8).
9 64. Defendants’ actions caused Plaintiffs to incur losses and damages, including, among
10 other things, the expenditure of resources to investigate and remediate Defendants’ conduct, damage
11 to Plaintiffs’ reputation, and damage to the relationships and goodwill between Plaintiffs and their
12 users and potential users. Plaintiffs have been damaged in an amount to be proven at trial.
13 65. Because Plaintiffs suffered damages and a loss as a result of Defendants’ actions and
14 continue to suffer damages as result of Defendants’ actions, Plaintiffs are entitled to compensatory
15 damages, attorneys’ fees, and any other amount of damages to be proven at trial, as well as injunctive
16 relief under California Penal Code §§ 502(e)(1) and (2).
17 66. Because Defendants willfully violated California Penal Code § 502, and there is clear
18 and convincing evidence that Defendants acted with malice and oppression and committed “fraud” as
19 defined by section 3294 of the Civil Code, Plaintiffs are entitled to punitive and exemplary damages
20 under California Penal Code § 502(e)(4).
21 THIRD CAUSE OF ACTION
22 (Breach of Contract)
23 67. Plaintiffs reallege and incorporate by reference all preceding paragraphs.
24 68. Access to and use of WhatsApp is governed by the WhatsApp’s Terms and related
25 WhatsApp policies.
26 69. Defendants agreed to and became bound by the WhatsApp’s Terms when they used
27 WhatsApp and the WhatsApp Service.
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1 70. WhatsApp and Facebook have performed all conditions, covenants, and promises
2 required of it in accordance with the WhatsApp’s Terms.
3 71. Defendants’ violations of the WhatsApp’s Terms have directly and proximately caused
4 and continue to cause harm and injury to WhatsApp.
5 72. When Defendants agreed to and became bound by the WhatsApp Terms, both Plaintiffs
6 and Defendants knew or could have reasonably foreseen that the harm and injury to Plaintiffs was
7 likely to occur in the ordinary course of events as a result of Defendants’ breach.
8 73. Defendants’ actions caused Plaintiffs to incur losses and other economic damages,
9 including, among other things, the expenditure of resources to investigate and remediate Defendants’
10 conduct, damage to Plaintiffs’ reputation, and damage to the relationships and goodwill between
11 Plaintiffs and their users and potential users. Plaintiffs have been damaged in an amount to be proven
12 at trial, and in excess of $75,000.
13 FOURTH CAUSE OF ACTION
14 (Trespass to Chattels)
15 74. Plaintiffs reallege and incorporate by reference all of the preceding paragraphs.
16 75. At all times mentioned in this Complaint, Plaintiffs had legal title to and actual
17 possession of their computer systems.
18 76. Defendants intentionally and without authorization interfered with Plaintiffs’
19 possessory interest in their computer systems, including by accessing and using Plaintiffs’ servers to
20 transmit malicious code for the purpose of unlawfully compromising Target Users’ devices, all
21 without authorization from Plaintiffs and Target Users.
22 77. Defendants’ access to Plaintiffs’ computer systems exceeded the scope of the
23 conditional access that Plaintiffs grant to legitimate users of the WhatsApp Service.
24 78. Defendants’ actions caused Plaintiffs to incur losses and other economic damages,
25 including, among other things, the expenditure of resources to investigate and remediate Defendants’
26 conduct, damage to Plaintiffs’ reputation, and damage to the relationships and goodwill between
27 Plaintiffs and their users and potential users. Plaintiffs have been damaged in an amount to be proven
28 at trial, and in excess of $75,000.

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1 REQUEST FOR RELIEF
2 WHEREFORE, Plaintiffs request judgment against Defendants as follows:
3 1. That the Court enter judgment against Defendants that Defendants have:
4 a. Violated the Computer Fraud and Abuse Act, in violation of 18 U.S.C. § 1030;
5 b. Violated the California Comprehensive Computer Data Access and Fraud Act, in
6 violation California Penal Code § 502;
7 c. Breached their contracts with WhatsApp in violation of California law;
8 d. Wrongfully trespassed on Plaintiffs’ property in violation of California law.
9 2. That the Court enter a permanent injunction enjoining and restraining Defendants and
10 their agents, servants, employees, successors, and assigns, and all other persons acting in concert with
11 or conspiracy with any of them or who are affiliated with Defendants from:
12 a. Accessing or attempting to access WhatsApp’s and Facebook’s service, platform,
13 and computer systems;
14 b. Creating or maintaining any WhatsApp or Facebook account;
15 c. Engaging in any activity that disrupts, diminishes the quality of, interferes with the
16 performance of, or impairs the functionality of Plaintiffs’ service, platform, and
17 computer systems; and
18 d. Engaging in any activity, or facilitating others to do the same, that violates
19 WhatsApp’s or Facebook’s Terms;
20 3. That WhatsApp and Facebook be awarded damages, including, but not limited to,
21 compensatory, statutory, and punitive damages, as permitted by law and in such amounts to be proven
22 at trial.
23 4. That WhatsApp and Facebook be awarded their reasonable costs, including reasonable
24 attorneys’ fees.
25 5. That WhatsApp and Facebook be awarded pre- and post-judgment interest as allowed
26 by law.
27 6. That the Court grant all such other and further relief as the Court may deem just and
28 proper.
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1 PLAINTIFFS RESPECTFULLY DEMAND A JURY TRIAL.
2
Dated: October 29, 2019 Respectively submitted,
3
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/s/ Travis LeBlanc
6
Travis LeBlanc
7 Daniel J. Grooms
Joseph D. Mornin
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Attorneys for Plaintiffs
9 WHATSAPP INC. and FACEBOOK, INC.
10 Platform Enforcement and Litigation

Facebook, Inc.
11 Jessica Romero
Tyler Smith
12 Michael Chmelar
Bridget Freeman
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Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 1 of 111
EXHIBIT 1
Ministry of Justice [emblem] Registrar of Companies

State of Israel
Companies Law, 5760-1999
Company Incorporation Certificate

This is to certify that
N.S.O. GROUP TECHNOLOGIES LTD

[bilingual text]
got incorporated and registered according to the Companies Law as a Limited Liability Company
25/01/2010
10th of Sh’vat, 5770
Company no. 514395409

[stamp:]
Ministry of Justice
Registrar of Companies
[emblem:] State of Israel
[signature]
Einat Messika, Adv.
[stamp:]
[logo]
Corporations Authority
A confirmation that this document has
been signed electronically, it is a copy of
the document (original or copy) that is in
the file of the Corporations Authority on
the day of the signature

Ministry of Justice
This document is a copy scanned in its entirety on the indicated day and hour, via
trusted digital scanning of the document found in the file, in accordance to the
inspection regulation at the Ministry of Justice.
Signed by
Ministry of Justice (institutional signature). [stamp:]
[logo]
PUBLIC0637849
EXHIBIT 2
09/25/2019 - Screenshot from https://www.documentcloud.org/documents/6401851-NSO-Emails-with-DEA.html
EXHIBIT 3
09/25/2019 - Screenshot from https://www.documentcloud.org/documents/6401851-NSO-Emails-with-DEA.html
EXHIBIT 4
09/23/2019 - Screenshot of https://www.franciscopartners.com/news/nso-group-acquired-by-its-management
09/23/2019 - Screenshot of https://www.franciscopartners.com/news/nso-group-acquired-by-its-management
EXHIBIT 5
[emblem:] State of Israel [logo:]
State of Israel Ministry of Justice [text cut off]
Corporations Authority [barcode:] 17042-905
Private Company Annual Report

(Section 141 of the Companies Law 5759-1999 (hereinafter: “the Law”))
The data can be typed in or filled out in clear handwriting without using black ink.
Company name Company number Address of the registered office1

NSO Group Technologies Ltd. 514395409 22 Galgalei Haplada, Hertsliya, Israel 4672222
Telephone Company Email (if any)
The report is updated as of (state the date of signing the Annual meeting was conducted on the day2
report in order to submit it to the Registrar of
Companies) 7.1.2019
[hw:] 7/1/19
Share Capital Distribution

Total registered capital of the company Share name and its set value Share type
(for shares with set value)
Ordinary, set value – 0.01 Ordinary
10,000 Ordinary A, set value – 0.01 Ordinary A
Preferred A, set value – 0.01 Preferred A
Number of shares in the registered capital Number of allotted shares Share value
Ordinary – 548,940 Ordinary – 185,716 0.01

Ordinary A – 26,290 Ordinary A – 8,936
Preferred A – 424,770 Preferred A – 295,170
Shareholders and their shares

Shareholder name ID number3 Address (city, street, house no., zip code)
22 Galgalei Haplada, Hertsliya, Israel Zip Code
Q Cyber Technologies Ltd 514971522
4672222
Type of shares Number of shares Unpaid amount in exchange for the shares
Ordinary 118,263
Ordinary A 8,936
Preferred A 295,170
22 Galgalei Haplada, Hertsliya, Israel Zip Code
NSO Group Technologies Ltd. 514395409
4672222
Ordinary 67,453
_____________________
1 Listing a P.O. Box as the company’s address is not enough.
2
The last date on which the annual meeting was conducted, indicate below in the appropriate place whether the company is exempt from conducting
annual meetings according to Section 61 of the Law. [stamp:]
3
A non-holder of the Israeli ID shall indicate his passport number and the country it was issued in, and in the first report of[logo]
this person, a copy shall
be attached, as stated in Regulation 16 of the Companies Regulations (reporting, registration details and forms), 5760-1999. If the shareholder is a
corporation, a registration number of the corporation shall be indicated, and if it is a foreign corporation, the copy of incorporation certificate and the
required certificates as stated in Regulation 16, shall be attached in the first report of the corporation.
[emblem:] Case 3:19-cv-07123 State
Document
of Israel1-1 Filed 10/29/19 Page 13 of 111
[logo:]
State of Israel Ministry of Justice Corporations Authority
Bearer Shares for the period
* Fill out if bearer shares have been issued before 17.09.2016, and the update has not been performed as stated below:
In accordance with the Amendment no. 28 to the Companies Law 5759-1999, which came into force on 17.09.2016, bearer shares can
be no longer issued. A holder of bearer shares issued on the eve of the law coming into force shall be entitled to return the banknote to
the company, and the company shall cancel it and issue a share for him that is registered in the Registry of Shareholders of the
Company. A bearer share that is not returned as stated shall become a frozen share, as stated in Section 308 of the Law, and it shall not
grant him rights until the date stated on the share, which will be recorded in the Registry of Shareholders of the Company.
Total bearer shares for the period No. of shares in each note Note no.
Details of active directors

Director name ID number Starting date as a director (year, month, day)
Q Cyber Technologies Ltd 514971522 19/3/2014
Address (city, street, house no., zip code)
22 Galgalei Haplada, Hertsliya, Israel 4672222
Details of directors who stopped their activity (since the date of the previous annual report)
Director name ID number End date as a director (year, month, day)
Mark the appropriate option with X:

No change has occurred in the details that were reported regarding the foreign directors according to Regulation 16 from the mentioned
regulations.
Change has occurred in the details that were reported regarding the foreign directors, and the documents required under Regulation 16 have been
attached to the annual report.
Authorized party to report to the registrar on behalf of the company, according to Section 39 of the Law
Filling out the details of the authorized party to report according to Section 39 in this Form will allow the party whose details are entered
here to relay updates about the company in a digital manner.
For more information, see: http://www.justice.gov.il/Units/RasutHataagidim/units/RashamHachvarot/TfasimNew/Pages/Online.aspx
Full name ID number Position in the company

[hw:] [illegible] Idisis 032063521 Financial director
[stamp:]
[logo]
EXHIBIT 6
State of Israel Ministry of Justice – Corporations Authority Corporations Authority
Registrar of Companies and Partnerships
Company Incorporation Certificate

This is to certify that the company:
L.E.G.D. COMPANY LTD

[bilingual text]
whose number is 514971522
got incorporated and registered on 02/12/2013 - 29th of Kislev 5774,

according to the Companies Law, 5760-1999, as a Limited Liability Company.
Issued in Jerusalem on:

02/12/2013
29th of Kislev 5774
[signature]
Zohar Horan
[stamp:]
Ministry of Justice
[stamp:] Registrar of Companies
[logo] and Partnerships
Corporations Authority [emblem:] State of Israel
Ministry of Justice
This document is a copy scanned in its entirety on the indicated day and hour, via
trusted digital scanning of the document found in the file, in accordance to the
inspection regulation at the Ministry of Justice.
Signed by
Ministry of Justice (institutional signature). [stamp:]
[logo]
PUBLIC0637849
EXHIBIT 7
[stamp:]
[emblem:] Document Start State of Israel [logo:]
State of Israel Ministry of Justice – Corporations Authority Corporations Authority
Company Name Change Certificate

This is to certify that the company
L.E.G.D. COMPANY LTD
[bilingual text]
whose number is 514971522
has changed its name, and it shall be called from now on
Q CYBER TECHNOLOGIES LTD
[bilingual text]
[stamp:]
Issued in Jerusalem on [emblem:] State of Israel
Ministry of Justice
29/05/2016
Registrar of Companies and
21st of Iyyar, 5776
Partnerships
[signature]
Eyal Globus, Adv.
Head of Corporations Authority
[stamp:]
[logo]
Issued by Eyal Goldring the day of the signature
EXHIBIT 8
06/26/19 - web.archive.org screenshot
Case 3:19-cv-07123 of10/29/19
Document 1-1 Filed nsogroup.com
Page 20 of 111
MAY JUN JUL 👤 ⍰❎
100 captures 26 f 🐦
2012 2019 ▾
OUR TECHNOLOGY
Helping Governments Maintain Public Safety

NSO Group, a Q Cyber Technologies company, develops best-in-class technology to help government
agencies detect and prevent a wide-range of local and global threats.
Our products help government intelligence and law-enforcement agencies use technology to meet the
challenges of encryption to prevent and investigate terror and crime.
NSO technology is designed by telecommunications and intelligence experts who, positioned at the
forefront of their fields, are dedicated to keeping pace with the ever-changing cyber world.
LEARN MORE
EXHIBIT 9
[emblem:] [logo:]
Case 3:19-cv-07123 State of Israel
Document 1-1 Filed 10/29/19 Page 22 of 111
State of Israel Ministry of Justice [text cut off]
Corporations Authority [barcode:] 17903-560
Private Company Annual Report

(Section 141 of the Companies Law 5759-1999 (hereinafter: “the Law”))
The data can be typed in or filled out in clear handwriting without using black ink.
Company name Company number Address of the registered office1

Q Cyber Technologies Ltd 514971522 22 Galgalei Haplada, Hertsliya, Israel 4672222
Telephone Company Email (if any)
The report is updated as of (state the date of signing the Annual meeting was conducted on the day2
report in order to submit it to the Registrar of
Companies) 7.1.2019
[hw:] 16/6/19
Share Capital Distribution

Total registered capital of the company Share name and its set value Share type
(for shares with set value)
100,000 Ordinary, set value – 0.01 Ordinary
Number of shares in the registered capital Number of allotted shares Share value
Ordinary – 10,000,000 Ordinary – 100,000 0.01
Shareholders and their shares

OSY TECHNOLOGIES S.A.R.L. B184226 Luxembourg
Ordinary 100,000
Bearer Shares for the period*
* Fill out if bearer shares have been issued before 17.09.2016, and the update has not been performed as stated below:
In accordance with the Amendment no. 28 to the Companies Law 5759-1999, which came into force on 17.09.2016, bearer shares can
be no longer issued. A holder of bearer shares issued on the eve of the law coming into force shall be entitled to return the banknote to
the company, and the company shall cancel it and issue a share for him that is registered in the Registry of Shareholders of the
Company. A bearer share that is not returned as stated shall become a frozen share, as stated in Section 308 of the Law, and it shall not
grant him rights until the date stated on the share, which will be recorded in the Registry of Shareholders of the Company.
_____________________ [stamp:]
1 Listing a P.O. Box as the company’s address is not enough.
[logo]
2 The last date on which the annual meeting was conducted, indicate below in the appropriate place whether the company is exempt from conducting
annual meetings according to Section 61 of the Law.
3 A non-holder of the Israeli ID shall indicate his passport number and the country it was issued in, and in the Afirst
confirmation that
report of this this document
person, a copy shallhas
been signed electronically,
be attached, as stated in Regulation 16 of the Companies Regulations (reporting, registration details and forms), 5760-1999. If the shareholder it is aiscopy
a of
thecopy
corporation, a registration number of the corporation shall be indicated, and if it is a foreign corporation, the document (originalcertificate
of incorporation or copy)and thatthe
is in
required certificates as stated in Regulation 16, shall be attached in the first report of the corporation. the file of the Corporations Authority on
State of Israel Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 23 of Corporations
Ministry of Justice 111 Authority
Total bearer shares for the period No. of shares in each note Note no.
Details of active directors

Director name ID number Starting date as a director (year, month, day)
OSY TECHNOLOGIES S.A.R.L. B184226 17/3/2014
Address (city, street, house no., zip code)
Luxembourg
Details of directors who stopped their activity (since the date of the previous annual report)
Mark the appropriate option with X:

No change has occurred in the details that were reported regarding the foreign directors according to Regulation 16 from the mentioned
regulations.
Change has occurred in the details that were reported regarding the foreign directors, and the documents required under Regulation 16 have been
attached to the annual report.
Authorized party to report to the registrar on behalf of the company, according to Section 39 of the Law
Filling out the details of the authorized party to report according to Section 39 in this Form will allow the party whose details are entered
here to relay updates about the company in a digital manner.
For more information, see: http://www.justice.gov.il/Units/RasutHataagidim/units/RashamHachvarot/TfasimNew/Pages/Online.aspx
Full name ID number Position in the company

Yifa Idisis 032063521 Financial director
Fulfillment of the instructions of Section 171 (C) of the Law

The Board of Directors has approved the financial reports __ (mark X if done).
Fulfillment of the instructions of Section 173 of the Law – (mark the appropriate option with X)
The financial documents have been presented at the last annual meeting as required.
If the company is not required to conduct annual meetings according to Section 61 (A) of the Law, indicate whether the financial reports have
been sent to the shareholders according to Section 61 (A) of the Law.
The company is not required to submit financial reports at the annual meeting, as stated in Section 172 (G) of the Law.
Controlling accountant (mark the appropriate option with X).

[stamp:]
The company has a controlling accountant, as stated in Section 154 of the Law.
[logo]
EXHIBIT 10
https://www.documentcloud.org/documents/4599753-NSO-Pegasus.html
Pegasus – Product Description

Contents
Introduction ....................................................................................................................... 1
Overcoming Smartphone Interception Challenge ................................................... 1
Standard Interception Solutions Are Not Enough ................................................... 1
Cyber Intelligence for the Mobile World ......................................................................... 3
Benefits of Pegasus ................................................................................................ 3
Technology Highlights ............................................................................................ 3
High Level Architecture ........................................................................................... 4
Agent Installation .............................................................................................................. 6
Agent Purpose ........................................................................................................ 6
Agent Installation Vectors ....................................................................................... 6
Agent Installation Flow ............................................................................................ 7
Supported Operating Systems & Devices .............................................................. 8
Installation Failure ................................................................................................... 8
Remote Installation Benefits ................................................................................... 9
Data Collection ................................................................................................................ 10
Initial Data Extraction ............................................................................................ 11
Passive Monitoring................................................................................................ 11
Active Collection ................................................................................................... 11
Description of Collected Data ............................................................................... 12
Collection Buffer ....................................................................................................15
Data Transmission .......................................................................................................... 16
Data Transmission Security .................................................................................. 17
Pegasus Anonymizing Transmission Network ..................................................... 17
Data Presentation & Analysis ........................................................................................ 18
Rules & Alerts ......................................................................................................21
Data Export ....................................................................................................... ..22
Agent Maintenance ......................................................................................................... 23
Agent Upgrade ...................................................................................................... 23
Agent Settings .......................................................................................................23
Agent Uninstall ...................................................................................................... 23
Solution Architecture ......................................................................................................25
Customer Site ......................................................................................................25
Public Networks .................................................................................................... 26
Target Devices ...................................................................................................... 27
Solution Hardware .......................................................................................................... 28
Operators Terminals ............................................................................................. 28
System Hardware ................................................................................................. 28
System Setup and Training ............................................................................................31
System Prerequisites ............................................................................................ 31
System Setup ......................................................................................................31
Training ............................................................................................................. 31
High Level Deployment Plan ................................................................................ 32
System Acceptance Test (SAT) ............................................................................ 33
Maintenance, Support and Upgrades ........................................................................... 34

Maintenance and Support ..................................................................................... 34
Upgrades ............................................................................................................ 34
List of Tables
Table 1: Collection Features Description .......................................................................... 12
Table 2: Presentation of Collected Data ........................................................................... 20
Table 3: Pegasus Deployment Plan ................................................................................. 32
List of Figures
Figure 1: Pegasus High Level Architecture ........................................................................ 5
Figure 2: Agent Installation Flow ........................................................................................ 7
Figure 3: Agent Installation Initiation ................................................................................... 8
Figure 4: Collected Data ................................................................................................... 10
Figure 5: Data Transmission Process ............................................................................... 16
Figure 6: Data Transmission Scenarios ............................................................................ 16
Figure 7: Calendar Monitoring .......................................................................................... 18
Figure 8: Call Log & Call Interception ............................................................................... 19
Figure 9: Location Tracking............................................................................................... 19
Figure 10: Solution Architecture ....................................................................................... 25
Figure 11: Pegasus Hardware .......................................................................................... 29
Introduction
Pegasus is a world-leading cyber intelligence solution that enables law enforcement and
intelligence agencies to remotely and covertly extract valuable intelligence from virtually any
mobile device. This breakthrough solution was developed by veterans of elite intelligence
agencies to provide governments with a way to address the new communications interception
challenges in today's highly dynamic cyber battlefield. By capturing new types of information
from mobile devices, Pegasus bridges a substantial technology gap to deliver the most
accurate and complete intelligence for your security operations.
Overcoming Smartphone Interception Challenge

The rapidly growing and highly dynamic mobile communications market - characterized by
the introduction of new devices, operating systems and applications on virtually a daily basis
– requires a rethinking of the traditional intelligence paradigm. These changes in the
communications landscape pose real challenges and obstacles that must be overcome by
intelligence organizations and law enforcement agencies worldwide:
Encryption: Extensive use of encrypted devices and applications to convey

messages
Abundance of communication applications: Chaotic market of sophisticated
applications, most of which are IP-based and use proprietary protocols
Target outside interception domain: Targets' communications are often outside the
organization's interception domain or otherwise inaccessible (e.g., targets are roaming,
face-to-face meetings, use of private networks, etc.)
Masking: Use of various virtual identities which are almost impossible to track and
trace
SIM replacement: Frequent replacement of SIM cards to avoid any kind of
interception
Data extraction: Most of the information is not sent over the network or shared with
other parties and is only available on the end-user device
Complex and expensive implementation: As communications become increasingly
complex, more network interfaces are needed. Setting up these interfaces with service
providers is a lengthy and expensive process, and requires regulation and
standardization
Standard Interception Solutions Are Not Enough

Until the above mentioned challenges are addressed and resolved, criminal and terrorist
targets are likely "safe" from standard and legacy interception systems, meaning that
valuable intelligence is being lost. These standard solutions (described in the sections below)
deliver only partial intelligence, leaving the organizations with substantial intelligence gaps.
Passive Interception
Passive interception requires very deep and tight relationships with local service providers
(cellular, Internet and PSTN providers) and traditionally has allowed for proper monitoring of
text messages and voice calls. However, most contemporary communications is comprised
of IP-based traffic, which is extremely difficult to monitor with passive interception due to its
use of encryption and proprietary protocols.
Even when this traffic is intercepted, it typically carries massive amounts of technical data
that is not related to the actual content and metadata being communicated. Not only does this
result in frustrated analysts and wasted time wading through irrelevant data, it also provides a
partial snapshot (at best) of the target's communications. In addition, the number of interfaces
required to cover the relevant service providers broadens the circle of entities exposed to
sensitive information and increases the chance of leakage.
Tactical GSM Interception

Tactical GSM interception solutions effectively monitor voice calls and text messages in GSM
networks. When advanced cellular technologies are deployed (3G and LTE networks), these
solutions become less efficient. In such cases, it is required to violently downgrade the target
to a GSM-based network, which noticeably impacts the user experience and functionality.
These solutions also require a well-trained field tactical team located near the monitored
target. Thus, in the majority of cases where the target location is unknown, these solutions
become irrelevant. In other cases, placing a tactical team close to the target may pose
serious risk both to the team and to the entire intelligence operation.
Malicious Software (Malware)

Malware presumably provides access to the target's mobile device. However, it is not
completely transparent and requires the target's involvement to be installed on their devices.
This type of engagement usually takes the form of multiple confirmations and approvals
before the malware is functional. Most targets are unlikely to be fooled into cooperating with
malware due to their high level of sensitivity for privacy in their communications.
In addition, such malware is likely to be vulnerable to most commercially available anti-virus

and anti-spyware software. As such, they leave traces and are fairly easily detected on the
device.
Cyber Intelligence for the Mobile World

Pegasus is a world-leading cyber intelligence solution that enables law enforcement and
intelligence agencies to remotely and covertly extract valuable intelligence from virtually any
mobile device. This breakthrough solution was developed by veterans of elite intelligence
agencies to provide governments with a way to address the new communications interception
challenges in today's highly dynamic cyber battlefield.
By capturing new types of information from mobile devices, Pegasus bridges a substantial
technology gap to deliver the most accurate and complete intelligence for your security
operations. This solution is able to penetrate the market's most popular smartphones based
on BlackBerry, Android, iOS and Symbian operating systems.
Pegasus silently deploys invisible software ("agent") on the target device. This agent then
extracts and securely transmits the collected data for analysis. Installation is performed
remotely (over-the-air), does not require any action from or engagement with the target, and
leaves no traces whatsoever on the device.
Benefits of Pegasus
Organizations that deploy Pegasus are able to overcome the challenges mentioned above to
achieve unmatched mobile intelligence collection:
Unlimited access to target's mobile devices: Remotely and covertly collect

information about your target's relationships, location, phone calls, plans and
activities – whenever and wherever they are
Intercept calls: Transparently monitor voice and VoIP calls in real-time
Bridge intelligence gaps: Collect unique and new types of information (e.g., contacts,
files, environmental wiretap, passwords, etc.) to deliver the most accurate and complete
intelligence
Handle encrypted content and devices: Overcome encryption, SSL, proprietary
protocols and any hurdle introduced by the complex communications world
Application monitoring: Monitor a multitude of applications including Skype,
WhatsApp, Viber, Facebook and Blackberry Messenger (BBM)
Pinpoint targets: Track targets and get accurate positioning information using GPS
Service provider independence: No cooperation with local Mobile Network Operators
(MNO) is needed
Discover virtual identities: Constantly monitor the device without worrying about
frequent switching of virtual identities and replacement of SIM cards
Avoid unnecessary risks: Eliminate the need for physical proximity to the target or
device at any phase
Technology Highlights
The Pegasus solution utilizes cutting-edge technology specially developed by veterans of
intelligence and law enforcement agencies. It offers a rich set of advanced features and
sophisticated intelligence collection capabilities not available in standard interception
solutions:
Penetrates Android, BlackBerry, iOS and Symbian based devices

Extracts contacts, messages, emails, photos, files, locations, passwords, processes

list and more
Accesses password-protected devices
Totally transparent to the target
Leaves no trace on the device
Minimal battery, memory and data consumption
Self-destruct mechanism in case of exposure risk
Retrieves any file from the device for deeper analysis
High Level Architecture

The Pegasus system is designed in layers. Each layer has its own responsibility forming
together a comprehensive cyber intelligence collection and analysis solution.
The main layers and building blocks of the systems are:
Installations: The Installation layer is in charge of issuing new agent installations,

upgrading and uninstalling existing agents.
Data Collection: The Data Collection layer is in charge of collecting the data from the
installed device. Pegasus offers comprehensive and complete intelligence by employing
four collection methods:
– Data Extraction: Extraction of the entire data that exists on the device upon
agent installation
– Passive Monitoring: Monitor new arrival data to the device
– Active Collection: Activate the camera, microphone, GPS and other elements to
collect real-time data
– Event-based Collection: Define scenarios that automatically triggers specific
data collection
Data Transmission: The Data Transmission layer is in charge of transmitting the
collected data back to the command and control servers, using the most efficient and
safe way.
Presentation & Analysis: The Presentation & Analysis component is a User Interface
that is in charge of presenting the collected data to the operators and analysts, turning
the data into actionable intelligence. This is done using the following modules:
– Real-Time Monitoring: Presents real-time collected data from specific or multiple

targets. This module is highly important when dealing with sensitive targets or during
operational activities, where each piece of information that arrives is crucial for
decision making.
– Offline Analysis: Advanced queries mechanism that allows the analysts to query
and retrieve any piece of information that was collected. The advanced mechanism
provides tools to find hidden connections and information.
– Geo-based Analysis: Presents the collected data on a map and conduct
geo-based queries.
– Rules & Alerts: Define rules that trigger alerts based on specific data that arrives or
event that occurred.
Administration: The administration component is in charge of managing the entire
system permission, security and health:
– Permission: The permissions mechanism allows the system administrator to

manage the different users of the system. Provide each one of them the right
access level only to the data they are allowed to. This allows to define groups in the
organization that handle only one or more topics and other groups which handles
different topics.
– Security: The security module monitors the system security level, making sure
the collected data is inserted to the system database clean and safe for future
review.
– Health: The health component of the Pegasus solution monitor the status of all
components making sure everything is working smoothly. It monitors the
communication between the different parts, the system performance, the storage
availability and alerts if something is malfunction.
The system layers and components are shown in Figure 1.
Figure 1: Pegasus High Level Architecture

Agent Installation
In order to start collecting data from your target’s smartphone, a software based component
("Agent") must be remotely and covertly installed on their device.
Agent Purpose
The “Agent”, a software based component, resides on the end point devices of the monitored
targets and its purpose is to collect the data it was configured to. The agent is supported on
the most popular operating systems: BlackBerry, Android, iOS (iPhone) and Symbian based
devices.
Each agent is independent and is configured to collect different information from the device
and to transmit it via specific channels in defined timeframes. The data is sent back to the
Pegasus servers in a hidden, compressed and encrypted manner.
The agent continuously collects the information from the device and will transmit it once
reliable internet connection becomes available.
Communications encryption, the use of many applications and other communications

concealing methods are no longer relevant when an agent is installed on the device.
Agent Installation Vectors

Injecting and installing an agent on the device is the most sensitive and important phase of
intelligence operation conducted on the target device. Each installation has to be carefully
planned to ensure it is successful. The Pegasus system supports various installation
methods. The installation methods variety answers the different operational scenarios which
are unique to each customer, resulting in the most comprehensive and flexible solution.
Following are the supported installation vectors:
Remote Installation (range free):

Over-the-Air (OTA): A push message is remotely and covertly sent to the mobile
device. This message triggers the device to download and install the agent on the
device. During the entire installation process no cooperation or engagement of the target
is required (e.g., clicking a link, opening a message) and no indication appears on the
device. The installation is totally silent and invisible and cannot be prevented by the
target. This is NSO uniqueness, which significantly differentiates the Pegasus solution
from any other solution available in the market.
Enhanced Social Engineering Message (ESEM): In cases where OTA installation

method is inapplicable1, the system operator can choose to send a regular text message
(SMS) or an email, luring the target to open it. Single click, either planned or
unintentional, on the link will result in hidden agent installation. The installation is entirely
concealed and although the target clicked the link they will not be aware that software is
being installed on their device.
The chances that the target will click the link are totally dependent on the level of
1 e.g., some devices do not support it; some service providers block push messages; target phone number in unknown.
content credibility. The Pegasus solution provides a wide range of tools to compose
a tailored and innocent message to lure the target to open the message.
NOTE: Both OTA and ESEM methods require only a phone number or an email address that
is used by the target. Nothing else is needed in order to accomplish a successful installation
of the Pegasus agent on the device.
Close to the target (range limited):

Tactical Network Element: The Pegasus agent can be silently injected once the
number is acquired using tactical network element such as Base Transceiver Station
(BTS). The Pegasus solution leverages the capabilities of such tactical tools to perform a
remote injection and installation of the agent. Taking a position in the area of the target
is, in most cases, sufficient to accomplish the phone number acquisition. Once the
number is available, the installation is done remotely.
Physical: When physical access to the device is an option, the Pegasus agent can be
manually injected and installed in less than five minutes. After agent installation, data
extraction and future data monitoring is done remotely, providing the same features of
any other installation method.
NOTE: Tactical and Physical installations are usually used where no target phone number or
email address are available.
Agent Installation Flow

Remote agent installation flow is shown in Figure 2.
Figure 2: Agent Installation Flow
In order to initiate a new installation, the operator of the Pegasus system should only insert
the target phone number. The rest is done automatically by the system, resulting in most
cases with an agent installed on the target device.
Agent installation initiation is shown in Figure 3.
Figure 3: Agent Installation Initiation
Supported Operating Systems & Devices
NOTE: Android-based devices are often added to the supported list. An updated list can be
sent upon customer request.
Installation Failure
The installation can sometimes fail due to following reasons:
1. Unsupported device: the target device is not supported by the system (which appears
above).
2. Unsupported OS: the operating system of the target device is not supported by the
system.
3. Unsupported browser: the default browser of the device was previously replaced by
the target. Installation from browsers other than the device default (and also Chrome for
Android based devices) is not supported by the system.
In any of the above mentioned cases, if the operator initiates a remote installation to a
non-supported device, operating system or browser, the injection will fail and the installation
will be aborted. In these cases the process is finished with an open browser on the target
device pointing and showing the URL page which was defined by the operator prior the
installation.
The device, OS and browser are identified by the system using their HTTP user agent. If by
any reason the user agent was manipulated by the target, the system might fail to correctly
identify the device and OS and provide the wrong installation payload. In such case, the
injection will fail and the installation will be aborted, showing again the above mentioned URL
page.
Data Collection
Upon successful agent installation, a wide range of data is monitored and collected from the
device:
Textual: Textual information includes text messages (SMS), Emails, calendar

records, call history, instant messaging, contacts list, browsing history and more.
Textual information is usually structured and small in size, therefore easier to
transmit and analyze.
Audio: Audio information includes intercepted calls, environmental sounds
(microphone recording) and other audio recorded files.
Visual: Visual information includes camera snapshots, photos retrieval and screen
capture.
Files: Each mobile device contains hundreds of files, some bear invaluable
intelligence, such as databases, documents, videos and more.
Location: On-going monitoring of the device location (Cell-ID and GPS).
The variety of data that is collected by the Pegasus system is shown in Figure
4.
Figure 4: Collected Data
The data collection is divided into three levels:
Initial data extraction

Passive monitoring
Active collection
Initial Data Extraction

Once the agent is successfully injected and installed on the device, the following data that
resides and exists on the device can be extracted and sent to the command and control
center:
SMS records
Contacts details
Call history (call log)
Calendar records
Emails
Instant Messaging
Browsing history
As opposed to other intelligence collection solutions which provide only future monitoring of
partial communications, Pegasus allows the extraction of all existing data on the device. As a
result the organization benefits from accessing historical data about the target, which assists
in building a comprehensive and accurate intelligence picture.
NOTE: Initial data extraction is an option and not a must. If the organization is not allowed to
access historical data of the target, such option can be disabled and only new arrival data will be
monitored by the agent.
Passive Monitoring
From the point the agent was successfully installed it keeps monitoring the device and
retrieves any new record that becomes available in real-time (or at specific condition if
configured differently). Below is the full list of data that is monitored by the agent:
SMS records
Contacts details
Call history (call log)
Calendar records
Emails
Instant Messaging
Browsing history
Location tracking (Cell-ID based)
Active Collection
In addition to passive monitoring, upon successful agent installation a wide set of active
collection features becomes available. Active collection refers to active requests sent by the
operator to collect specific information from the installed device. These set of features are
called active, as they carry their collection upon explicit request of the operator. Active
collection allows the operator to perform real-time actions on the target device, retrieving
unique information from the device and from the surrounding area of the target, including:
Location tracking (GPS based)

Voice calls interception

File retrieval
Environmental sound recording (microphone recording)
Photo taking
Screen capturing
Active collection differentiates Pegasus from any other intelligence collection solution, as the
operator controls the information that is collected. Instead of just waiting for information to
arrive, hoping this is the information you were looking for, the operator actively retrieves
important information from the device, getting the exact information he was looking for.
Description of Collected Data

The different types of data available for extraction, passive monitoring and active collection
with their respective features are listed in Table 1.
Table 1: Collection Features Description

2 For active collection features, initial data is not extracted before a request is initiated by the user.
The above mentioned data is the potential data that could be collected by an agent. The
agent will collect the data that is applicable and available on the device. If one or more of the
above mentioned applications does not exist and/or removed from the device, the agent will
operate in the same manner. It will collect the data from the rest of the services and
applications which are in use in the device. Also, all the collected data from the removed
application will still be saved on the servers or at the agent, if it was not yet transmitted back
to the servers.
In addition, the above mentioned data that is collected by the agent covers the most popular
applications used worldwide. Since applications popularity differs from country to country, we
understands that data extraction and monitoring of other applications will be required as time
evolves and new applications are adopted by targets. When such requirement is raised, we
can fairly easily extract the important data from virtually any application upon customer
demand and release it as a new release that will become available to the customer.
Collection Buffer
The installed agent monitors the data from the device and transmits it to the servers. If
transmission is not possible3 the agent will collect the new available information and transmits
it when connection will become available. The collected data is stored in a hidden and
encrypted buffer. This buffer is set to reach no more than 5% of the free space available on
the device. For example – if the monitored device has 1GB of free space, the buffer can store
up to 50MB. In case the buffer has reached its limit, the oldest data is deleted and new data
is stored (FIFO). Once the data has been transmitted, the buffer content is totally deleted.
.
3 No data channels are available; Device is roaming; Device is shut down.

Data Transmission
By default, the collected data (initial data extraction, passive monitoring and active collection)
is sent back to the command and control center in real-time. The data is sent via data
channels, where Wi-Fi is the preferred connection to use when it is available. In other cases
data is transmitted via cellular data channels (GPRS, 3G and LTE). Extra thought was put
into compression methods and focusing on textual content transmission whenever possible.
The data footprints are very small and usually take only few hundred bytes. This is to make
sure that the collected data is easily transmitted, ensuring minimal impact on the device and
on the target cellular data plan.
If data channels are not available, the agent will collect the information from the device and
store it in a dedicated buffer, as explained in Data Collection section.
Data transmission is automatically ceased in the following scenarios:
Low battery: When the device battery level is below the defined threshold (5%) all
data transmission processes are immediately ceased until the device is recharged.
Roaming device: When the device is roaming, cellular data channels become pricy,
thus data transmission is done only via Wi-Fi. If Wi-Fi does not exist, transmission will
be ceased.
When no data channels are available, and no indication for communication is coming back
from the device, the user can request the device will communicate and/or send some crucial
data using text messages (SMS).
CAUTION: Communication and/or data transmission via SMS may incur costs by the target
and appear in his billing report thus should be used sparingly.
The communication between the agent and the central servers is indirect (through
anonymizing network), so trace back to the origin is non-feasible.
The Pegasus system data transmission process is shown in Figure 5.
Figure 5: Data Transmission Process
The channels and scenarios for transmitting the collected data are shown in Figure 6.
Figure 6: Data Transmission Scenarios

Data Transmission Security

All connections between the agents and the servers are encrypted with strong algorithms and
are mutually authenticated. While data encryption is probably the most urging issue, extra
care was given to ensure minimal data, battery and memory are consumed within the agents
requirements. This is meant to make sure that no concerns are raised by the target.
Detecting an operating agent by the target is almost impossible. The Pegasus agent is
installed at the kernel level of the device, well concealed and is untraceable by antivirus and
antispy software.
The transmitted data is encrypted with symmetric encryption AES 128-bit.
Pegasus Anonymizing Transmission Network

Agent transparency and source security are the guiding principles of the Pegasus solution.
To assure that trace back to the operating organization is impossible, the Pegasus
Anonymizing Transmission Network (PATN), a network of anonymizers is deployed to serve
each customer. The PATN nodes are spread in different locations around the world, allowing
agent connections to be redirected through different paths prior to reaching the Pegasus
servers. This ensures that the identities of both communicating parties are highly obscured.
Data Presentation & Analysis

Successful data collection from hundreds of targets and devices generates massive amounts
of data for visualization, presentation and analysis. The system provides a set of operational
tools to help the organization to transform data into actionable intelligence. This is to view,
sort, filter, query and analyze the collected data. The tools include:
Geographical analysis: Track target's real-time and historical location, view several
targets on map
Rules and alerts: Define rules to generate alerts upon important data arrival
Favorites: Mark important and favorite events for subsequent review and deeper
analysis
Intelligence dashboard: View highlights and statistics of target's activities
Entity management: Manage targets by groups of interest (e.g., drugs, terror, serious
crime, location, etc.)
Timeline analysis: Review and analyze collected data from a particular time frame
Advanced search: Conduct search for terms, names, code words and numbers to
retrieve specific information
The collected data is organized by groups of interest (e.g., drugs group A, terror group B,
etc.) and each group consists of targets. Each target consists of several devices which some
have installed agents on them.
The collected data is displayed in an easy-to-use intuitive user interface and when applicable
emulates popular display of common applications. The intuitive user interface is designed for
a day-to-day work. Operators can easily customize the system to fit their preferred working
methods, define rules and alerts for specific topics of interest.
The operator can choose to view the entire collected data from specific target or only specific
type of information such as location information, calendar record, emails or instant messages.
Pegasus calendar monitoring screen is shown in Figure 7.
Figure 7: Calendar Monitoring

Pegasus call log and call interception screen is shown in Figure 8.
Figure 8: Call Log & Call Interception
Pegasus location tracking screen is shown in Figure 9.
Figure 9: Location Tracking

The presentation fields of the collected data are listed in Table 2.
Table 2: Presentation of Collected Data

Rules & Alerts

The Rules & Alerts module in the system alerts when important event takes place. Rules
must be defined in advance and they help the operators to review and take actions in
real-time, for example:
Geo-fencing:
o Access hot zone - Alert when target reached an important location
o Leave hot zone - Alert when target left a certain location
Geo-fence alerts are based on a perimeter around a certain location, where the
operator defines the size of the perimeter.
Meeting detection: Alert when two targets meet (share the same location)
Connection detection:
o Alert when a message is sent from/to a specific number
o Alert when a phone call is performed from/to a specific number
Content detection: Alert when a defined word/term/code word is used in a message
Data Export
The system is designed as an end-to-end system, providing its users with collection and
analysis tools. However, we understands that there are advanced analysis capabilities and
data fusion requirements from other sources, therefore the system allows the exporting of the
collected information and seamless integration with 3rd party backend or analysis systems
available.
Agent Maintenance
Once agent is installed on a certain device, it has to be maintained in order to support new
features and change its settings and configurations or to be uninstalled when it is no longer
providing valuable intelligence to the organization.
Agent Upgrade
When agents' updates are released they become available to install. These new agents are
now ready for installation on new targets' devices or as upgrades for existing agents installed
on target's devices. These updates provide new functionalities, bug fixing, support for new
services or improve the agents overall behavior. Such updates are crucial to keep the agent
functional and operational in the endless progress of the communication world and especially
the smartphone arena.
There are two types of agent upgrades:
Optional upgrade: agent upgrade is not mandatory by the system. The user decides
when, if at all, to upgrade the agent.
Mandatory upgrade: agent upgrade is mandatory by the system. The supervisor
must upgrade the agent otherwise no new information will be monitored from the
device.
Upgrade sometimes requires an installation of a new agent and sometimes just a small
update of the existing agent. In both cases the user is the only one to decide when to conduct
the upgrade, and therefore should plan this accordingly.
Once the command for upgrade was sent by the user, the process should take only few
minutes. The process might take longer if the device is turned off or has bad data connection.
In either case, the upgrade will be accomplished once a decent data connection becomes
available.
Agent Settings
Agent settings are set for the first time during its installation. From this point, these settings
serve the agent, but can always be changed if required. The settings include the IP address
for transmitting the collected data, the way commands are sent to the agent, the time until the
agent is automatically uninstall itself (see self-destruct mechanism for more details) and
more.
Agent Uninstall
When the intelligence operation is done or in case where the target is no longer with interest
to the organization, the software based component ("Agent") on the target's device can be
removed and uninstalled. Uninstall is quick, requires a single user request and has no to
minimal effect on the target device. The user issues a request for agent uninstall which is
sent to the device.
Once agent is uninstalled from a certain device it leaves no traces whatsoever or indications
it was ever existed there4. As long as the agent is operational on the device and a connection
exists between him and the servers it can be easily and remotely uninstalled.
.
Uninstall can always be done remotely no matter what was the method used for installation.
Physical uninstall is also an option, if needed.
Uninstalling an agent does not mean losing the entire collected data – the entire data that
was collected during the time that the agent was installed on the device will be kept in the
servers for future analysis.
Self-Destruct Mechanism
The Pegasus system contains self-destruct mechanism for the installed agents. In general,
we understand that it is more important that the source will not be exposed and the target will
suspect nothing than keeping the agent alive and working. The mechanism is activated in the
following scenarios:
Risk of exposure: In cases where a great probability of exposing the agent exists, a
self-destruct mechanism is automatically being activated and the agent is uninstalled.
Agent can be once again installed at a later time.
Agent is not responding: In cases where the agent is not responding and did not
communicate with the servers for a long time5, the agent will automatically uninstall
itself to prevent being exposed or misused.
4 In some cases, uninstall can result in device reboot. If reboot takes place, it happens once agent removal is done. The
device comes up clean with no agent installed.
5 The default time is 60 days, but can be reconfigured for any period of time required
Solution Architecture
The Pegasus system’s major architectural components are shown in Figure 10.
Figure 10: Solution Architecture
Customer Site
NSO is responsible to deploy and configure the Pegasus hardware and software at the
customer premises, making sure the system is working and functioning properly. Below are
the main components installed at the customer site:
WEB Servers
Residing at the customer's premises, the servers are responsible for the following:
Agent installation and monitoring

Agent maintenance: Remotely control, configure and upgrade installed agents
Data transmission: Receive the collected data transmitted from the installed agents
Serve the operators' terminals
Communications Module
The communications module allows interconnectivity and internet connection to the servers.
Cellular Communication Module

The cellular communication module enables remote installation of the Pegasus agent to the
target device using cellular modems and/or SMS gateways.
Permission Module
The Pegasus permission management module defines and controls the features and
available content allowed for each user based on their role, rank and hierarchy.
Data Storage
The collected data that was extracted and monitored by the agents is stored on an external
storage device. The data is well backed-up and with full resiliency and redundancy to prevent
failures and downtime.
Servers Security
All the servers reside inside the customer's trusted network, behind any security measures it
may deploy as well as security measures that we supply specifically for the system.
Hardware
The system standard hardware is deployed on several servers connected together on couple
of racks. The equipment takes care of advanced load balancing, content compression,
connection management, encryption, advanced routing, and highly configurable server health
monitoring.
Operator Consoles
The operator's end-point terminals (PC) are the main tool which the operators activate the
Pegasus system, initiate installations and commands, and view the collected data.
Pegasus Application
The Pegasus application is the user interface that is installed on the operator terminal. It
provides the operators with range of tools to view, sort, filter, manage and alert to analyze the
large amount of data collected from the targets' agents.
Public Networks
Apart from local hardware and software installation at the customer premises, the Pegasus
system does not require any physical interface with the local mobile network operators.
However, since agent installations and data are transferred over the public networks, we
makes sure it is transferred in the most efficient and secured way, all the way back to the
customer servers:
Anonymizing Network
Pegasus Anonymizing Transmission Network (PATN) is built from anonymizing connectivity
nodes which are spread in different locations around the world, allowing agent connections to
be directed through different paths prior to reaching the Pegasus servers. The anonymized
nodes serve only one customer and can be set up by the customer if required.
See more information in Pegasus Anonymizing Transmission Network section.

Target Devices
The above mentioned architecture allows the operators to issue new installations, extract,
monitor and actively collect data from targets’ devices. See more details in Supported
Operating Systems & Devices.
NOTE: The Pegasus is an intelligence mission-critical system, therefore it is fully redundant

to avoid malfunctions and failures. The system handles large amounts of data and traffic 24
hours a day and is scalable to support customer growth and future requirements.
Solution Hardware
The hardware specifications for operating the Pegasus system depends on the number of
concurrent installed agents, the number of working stations, the amount of data stored and
for how long should it be stored.
All the necessary hardware is supplied with the system upon deployment and may require
local customization that has to be handled by the customer based on we directions. If
required, hardware can be purchased by the customer based on the specifications provided
by we.
Operators Terminals
The operator terminals are standard desktop PCs, with the following specifications:
Processor: Core i5
Memory: 3GB RAM
Hard Drive: 320GB
Operating System: Windows 7
System Hardware
To fully support the system infrastructure, the following hardware is required:
Two units of 42U cabinet

Networking hardware
10TB of storage
5 standard servers
UPS
Cellular modems and SIM cards
The system hardware scheme is shown in Figure 11.
Figure 11: Pegasus Hardware

System Setup and Training

We are responsible for the system setup and training before its hand-over to the customer.
System Prerequisites
Successful installation of the Pegasus system requires the following preparations of the
servers' room:
Sufficient room to contain two 42U racks cabinet, 5x5x2.5m (LxWxH)

Air conditioned (18°C) room
Access restriction
Routing from end-point terminals to servers room
Reliable cellular network reception (at least -95 dBm)
2 x Electrical outlets (20A) per rack
2 x Symmetric ATM lines from different ISP's. Each line with a bandwidth of 10MB
containing 8 external static IP addresses:
o ISP #1: Fiber optic-based network
o ISP #2: Ethernet category-7 cable-based network
The mission-critical system requires two parallel networks to ensure system
resilience and downtime is kept to an absolute minimum.
2 x E1 PRI connections, each contains 10 extensions (two different service providers is

recommended)
2 x anonymous SIM cards for each local Mobile Network Operator
3rd party services registration as required
System Setup
The solution will be deployed at the customer site by we personnel
Deployment duration usually requires 10-15 working weeks
Operating environment prerequisites must be met
System setup includes hardware and software installation, and in addition integration
to local environment and systems
Support and adaptations to the different local device firmware versions
Training
Upon system installation, we personnel will conduct full training sessions. Training can take
place onsite or in any other location required by the customer, including we headquarters.
Training session includes the following:
Basic system usage

System architecture
Advanced system usage and roles
Real-world simulation exercises

The recommended number of attendees is with respect to the number of installed operator
consoles.
High Level Deployment Plan

The process of adapting, installing and testing the system in a new customer site in listed in
Table 3.
Table 3: Pegasus Deployment Plan
Phase 1 – Preparations:
Requirements for an Acceptance Test Procedure (ATP) are defined together with the
customer
Hardware and software acquisition and customization to answer customer
requirements and needs
When required, the Pegasus system is integrated with local infrastructures and
systems
System adaptations to the local mobile networks
Phase 2 – Implementation:
System testing
Hardware installation
System adaptations to local device firmware versions
Phase 3 – Training and Completion:

Detailed system training, real-life scenarios practicing and simulation
Customer ATP as defined during phase 1
System Acceptance Test (SAT)

We have gained substantial experience in installing and implementing the Pegasus system.
The following acceptance test plan verifies that the system works as required and validates
that the correct functionality has been delivered. It describes the scope of the work to be
performed and the approach taken to execute the proper tests to validate that the system
functions as mutually agreed with the customer.
The tests are divided into 3 stages:
Functionality tests
Network and providers tests
Customer tailor specific tests
An official system hand-over from we to the customer is done once the system has been
deployed, tested and demonstrated.
Maintenance, Support and Upgrades

We provides, as default, one year of maintenance, support and upgrades services. These
services include:
Maintenance and Support

We provides maintenance services and three-tier level support that includes:
Tier-1: Standard system operations problems

o Email and phone support
Tier-2: Proactive resolving of technical problems
o Dedicated engineers will inspect, examine and resolve common technical
issues, putting their best efforts
o Remote assistance using remote desktop software and a Virtual Private
Network (VPN) where requested
Tier-3: Bug fixing and system updates of substantial system malfunctions
Phone support: In addition to the above mentioned, we provide phone and email
support to any question and problem that is raised.
In addition, the customer will be able to add the following support:
Planned or emergency onsite assistance

Health monitoring system
Upgrades
We have releases major upgrades to the Pegasus system few times a year. Such upgrades
usually include:
New features
New devices/operating system support
Tailored features based on customer requirements
Bugs fix
EXHIBIT 11
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This Agreement (the "Agreement") is entered into on Decernber I7'h, 2015 (the "Effective Date")
between Infraloks Development Limited, a company incorporated.urder the.laws of the Republic of
Ghana (company registration number CA-66,115), having its registered offices at HSE number 1 plot 50,
7'' Avenue Extension, North Ridge ACCRA, P.o. Box 30712 KrA, ACCRA (the "Company") and tJre
National Communication Authorify of the Republic of Ghana (the "End-User").
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Whereas, the Company is engaged in tbe business of resellilg and supplying cyber intelligence
solutions developed, integrated and supplied by the NSO Group Technologies Ltd. (company regisfration
il number 514395409), an Israeli Company, having its registered offices at 9 Hamada St., Herzliya, Israel
(tie "System Provider") which has developed the System (as defined below); and
'Whereas, the End-User is interested to purchase from the Company a License (as defined below) to
il use the System (as defined below), and obtain services related to it, soleiy for the use of the End-User as
further set forth herein, and the Company has agreed to provide a License to use the System and related
services to the End-User; and
'ii Whereas, tlie parties wish to set forth the terms under which such sale and purchase shall be made.
Now, therefore, in consideration of the foregoing premises and the mutual covenants herein contained,
and for other good and yaluable consideration, the parties agree as follows:
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1. Definitions and Exhibits
1.1. In this Agreemen! unless the context otherwise requires, terms defined in the preamble
il and the recitals shall have the same meaning when used elsewhere in this Agreement and
the following terms shall have the meanings ascribed thereto below:
"Agreement" has the meaning ascribed to it in the preamble.

i1
. "Approval" has the meaning ascribed to it in Section 5.1.
"Bu-siness Day" rneans a day (other than a Friday, Saturday or Sunday) on which banks
tl are generally open in Israel and in the Republic of Ghana for normal business.
"Certificate" has the meaning ascribed to it in Section 5.1 ,
il "Commissioning Notice" has the meaning ascribed to it in Exhibit B.

"Company" has the meaning ascribed to it in the preamble.
I "Confidential Informatiotr" means any information provided by the Company to the
and/or the End-User.
"Deployment" has the meaning ascribed to it in Exhibit A.

il "Effective Date" has the meaning ascribed to it in the preamble.
;l "Etrd-{Jser" has the meaning ascribed to it in tbe preamble.

il "X'irst fnstallment" has the meaning ascribed to it in Exhibit B.
"Force Majeure" has the meaning ascribed to it in Section 14.
il "Hardware Equipment" has the meaning ascribed to it in Exhibit A.
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"fiVlOD'means the Israeli Ministry of Defense,
il "License" has the meaning ascribed to it in Section 2.1.
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I "Reseller" N/A.
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it " Reseller Representative" N/A.

"Reseller Appointment Letter" N/A.
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"Reseller Appointment Letter" N/A,
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ri "End-User Responsibilities" has the meaning ascribed to it in Section 4.
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"Services" has the meaning ascribed to it in Exhibit A.

rl "SLAU has the meaning ascribed to in Section 6.2
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"support Period" has the meaning ascribed to it in Section 6.1.
"Support Period Consideration" has the meaning ascribed to it in Exhibit B
"support Services" has the meaning ascribed to it in Section 6.
. "System" has the meaning ascribed to it in Exhibit A.
"system Considerafion" has the meaning ascribed to it in Exhibit B.
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' "system Provider" has the meaning ascribed to it at the preamble.
il "Training" has the meaning ascribed to it in.Exhibit A.
"'Warranfi/" has the meaning ascribed to it in Exhibit A.

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tl "Warrant5r Period" has the meaning ascribed to it in Exhibit A.
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1.2. The following are the exhibits in this Agreement;
t.l
ri Exhibit A - Description of System and Services
Exhibit A- I - Features and Capabilities
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rl Exhibit A-2 - List of Hardware Equipment and Software
Exhibit B - Consideration
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Exhibit C - Installation Requirements
Exhibit D - Service Level Agreement
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2 Provision of License and Services.
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2-1. Subject to the terms of this Agreement and the payment of the System Consideration in
full, the System Provider shall provide the End-User a limited, exclusive, non-
transferable, non.pledgeable and non-assignabte license to use the System solely for the
ll End-User's internal use, and for the purpose that it is intended for (the "License"),
2.2. Subject to provisions of Sections 2.3 and 5.2 below, within one-hundred (100) Business
rl Days following the occurrenoe of the later of (i) receipt by the System Provider of the
Approval, (ii) the completion of the Due-Diligence Process, and (iii) the receipt by the
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Company of the First Installmen! in full, the System Provider shall complete the
r 2.3.
Deployment and shall conduot the Training.
The provision of the Systern, the License and the Services by the System Provider in
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accordance with the time schedule set forth in Section 2.2 above and the performance by
the Company of all its obligations under this Agteement is conditioned upon (i) the
fulfillment by the End-User of all of the End-User Responsibilities when due, and (ii) the
i
actual receipt by the Company of each payment of the System Consideration rvhen due,
in tull.
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It is hereby clarified that the Company shall not be held responsible or liable for any
delay in the provis.ion of the System, the License and/orthe Services, if such delay was
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il due to any miss-performance or delay in the fulfillment of any of the End-User

Responsibilities and/or payment obligations and/or due to a delay in the performance or
achievement of the pre-requisite conditions set fbrth in Section 5 below. In the event of a
delay in the performance of any of rhe End-User Responsibilities and/or payment
it ubl.igul,ious uul/ur [hu purlunrrullue ur uchieventeut of the pre requisitc conditions set
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forth in Section 5 below, the Company's obligations shall be postponed by such number
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2.4. If any sum payable pursuant to this Agreement shall not have been paid to the Company
ji, by its due date, then, without prejudice to any other right or remedy available to the
Company in accordance with the terms of this Agreement or by law, the End-User shail
pay interest thereon at a daily rate of 0.04yo, accumulated on a daily basis, in respect of
ir the period starting on the due date of the delayed payment and ending on the date of the
ilt;
actual payment. In addition, the Company reserves the right to suspend contractual
performance or the use of the System or the Services until the End-User has made
payment of the overdue amount together with interest that has accrued thereupon, in full.
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2.5, So long as the System Consideration is not received by the Company, in full, and so long
as the Company has not provided the Commissioning Notice, the End-User shall not be
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entitled to use the System and no license to use the System shall be deemed granted.
J Consideration; Payment Terms
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3.1 . In consideration for the provision of the License, the System and the Services, the End-
User shall pay the Company the System Consideration 6s set forth in Exhibit B.
3.2. The System Consideration shall be paid by the End-User to the Company in instaliments
as set forth in Exhibit B.
il 3.3. The System Consideration, the Support Period Consideration and any other payments
I made to the Company under this Agreement are exciusive of all state, provincial,
municipal or other government, excise, use, sales, VAT or iike taxes, tariffs, duties or
I
,
surcharges, now in force or as may be enacted in the future, which shall be bome by the
Company, provided, however that the Company shall bear all income taxes imposed on
li
the Company in connection with this Agreement. Each payment under this Agreement
i1
shall be paid by the End-User against an invoice to be issued by the Company.
3.4. Any and all amounts paid to the Company under this Agreement are non-refundable, and
may not be claimed or reclaimed by the End-User.
4. The End-User's Reqponsibilitie!. The End-User undertakes to perform all of the following
obligations in a timely manner (the "End-User Responsibilities"):
ii 4.1. fulfillment of all of the technical and installation requirements listed in Exhibit C at the
End-User's site, prior to the delivery of the Hardware Equipment;
4.2. obtainment and maintenance of all permits and approvals required to be obtained from
any regulatory and governmental authority relating.to the End-User, under any and all
applicable legal requirements for the performance of this Agreement;
4.3.
I
I
delivery of the Certificate to the Company;
4.4, provision of any and all applicable information and documents required by the System
Provider for the performance of the Due-Diligence Process, on a timely manner; and
tl
4.5. provision of any and all additional required conditions to enable the performance of the
Company's obligations under this Agreernent when due, including without limitation,
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release of the Hardware Equipment from custom (if required) and assuring availability
the End-User's personnel for participation in the Training.
of
5 Pre-Conditions,
l
[l 5.1 The provision of the License. the System and the Scrviccs and the performance by the
Company of its obligations under this Agreement arc subject to (i) the receipt by the
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Syntcrl Proyidcr of thc originol certificote indicating the ldentity nf tht: Enrl-Ilscr. irt
il accordance with the requirements of the IMOD (the "Certificate"), (ii) the receipt by the
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Systom Providor of tho approval of the IMOD forthc provision of thc I.iccnsc, Systcm
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and the Services as set forth herein (the "Approval"), (iii) the completion of a due-
ijl diligence process to the Company by the System Provider (the "Due-Diligence
Process").
5.2. For the avoidance of any doubt, no products, Iicenses, equipment or services shall be
provided by the Company under this Agreement until the Certificate is delivered to the
System Provider and the Approval is obtained. In the event that the Certificate is not
I
received by the System Provider andJor the Approvai is not obtained within six (6)
!j months as ofthe date hereof, or in the event that the System Provider receives, earlier, a
formal notice from the IMOD that the application for the Approval is denied, or in the
event that the Approval is canceled, terminated or suspended, the Company shall have
tlI
,
the right to terminate this Agreement by providing the End-User a written notice, and
ll such termination shall not be considered a breach of this Agreement, and the Company
shal1 not be held responsible or liable in connection with such tennination. Fulther, the
Company hereby acknowledges and agrees that the actual performance of the activities
lr
ll contemplated herein is conditioned upon the completion of the Due Diligence Process to
the System Provider's fuli satisfaction which otherwise may terminate this Agreement at
Itl its sole discretion, by providing the Company a written notice, and such termination shall
tlir not be considered a breach of this Agreemen! and the Company. shall not be held
responsible or liable in connection with such termination.
it 6. Technical Support and Maintenance Services. F ollowing the expiration of the Waranty Period,
lr
li the End-User shall be entitled to purchase technical support and maintenance services (the
"support Services") under the following terms:
rl 6.1. The End-User may purchase Support Services for periods of twelve (12) month each
ti11
(each such period - a "Support Period").
rl 6.2. The Support Services shall be provided in accordance with the System Provide/s
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standard services level agreement, as may be amended from time to time. A copy of the
i,
System Provider's current service level agreement is aftached hereto as Exhibit D (the
il 'sLA").
,lii
i,l 6,3. The consideration for the Support Services for each Support Period and the payment
terms of such consideration are as set forth in Exhibit B.
i1 7 Additional Remedy. tn the event a breach has occurred, in addition to the Company's rights and
:i
il remedies under applicable law and this Agreemen! the Company may suspend or cancel the
License or the provision of any ofthe Services, or take such actions necessary to prevent access
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to the System unti-l such time as it has received confirmation to its satisfaction that such breach
it
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was cured. The Company shall not be liable towards the End-User for any claim, losses or
damages whatsoever related to its decision to suspend or cancel the provision of any of the
il Services, the License, or to prevent access to the System under this section.
1l
]l 8 Intellectual Property Rights. All the rights pertaining to the System, the Services and the License,
including, but not limited to, all patents, trademarks, copyrights, service matks, trade names,
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technology, know how, moral rights and trade secrets, al1 applications for any of the foregoing,
and all permits, grants and licenses or other rights relating to the System and the Services are and
shall remain the sole properry of the System Provider,
l
,.1 The End-User hereby acknowledges that, other than as set forth in Section 2.1, no title to the
1t System (including the software embedded therein) is transferred to it under this Agreement or in
rl
connection hereoi and it is not granted any right in the System, including without limitation,
I
it1l intellectual property right'
il direcrlv either
The End-User shall not, whether directiy or indirectly eirher by rhems or through any olrher
hv themselves
i person, reproduce, modify, disassemble or reverse-engineer the System (including any software
I
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contained therein).
I,I
rl 9 Conficlentiality. The Encl-User undertakes to keep thc Confidcntial information in strict
I confldence ond not to disclose it to any third partv withor.it thc prinr writtcn connent of the
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AE eernent 1 00/20 1 5 Page 4 of 46 *r

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System Provider; provided, however, that the End-User may disclose such information to its
respective employees and consultants having a need to know such information in order to carry
out the provisions of this Agxeement. The End-User warrants that any such employees and
consultants to which Confidential Information is disclosed will be bound and will abide by terms
:.i no less onerous than those contained herein and shall be responsible for any breach of
ijti confidentiality by such employees and consultants.
Foliowing the termination of this Agreement for any reason, or upon the Company's first written
demand, the End-User shall retum to the Company atl Confidential Information, including all
records, products and samples received, and any copies thereof whether in its possession or
under its controi, and shall erase all electronic records thereof, and shall so certify to the
Company in writing
10. Limited Warrarfy It should be noted that the System Provider does not warrant that the License,
the System and the Services provided hereunder will be uninterrupted, error-free, or completely
secure. The System Provider does not make, and hereby disclaims, any and all implied
ii warranties, including impiied warranties of merchantability, fitness for a particular purpose ald
non-infringement. Except as otherwise expressly set forth in this Agreement (including any
exhibits), the System Provider does not make and hereby disclaim's all express warranties. All
ii products, the System and Services provided pursuant to this Agreement are provided or
performed on an "as is", "as available" basis.
il ii Limitation of Liabilitv. In no event shall the Company be liable for any consequential, incidental,
special, indirect or exemplary damages whatsoever, including lost profits, loss of business, Ioss
of revenues, or any other type of damages, whether arising under tort, contract or law. The
1t Company's aggregate liability under this Agreement shall be limited to the consideration actually
I {l received by the Company under this Agreement.
1.) Governing Law and Jurisdiction. This Agreement shall be governed, construed and enforced in
ii accordance with the laws of the Republic of Ghana.

Any controversy or claim arising under, out of or in connection with this Agreemenl its validity,
its i-nterpretation, its execution or any breach or claimed breach thereof, are hereby submitted to
the sole and exclusive jurisdiction of the competent courts in the Republic of Ghana.
il t3 Assignment. This Agreement and the rights and obligations hereunder are not ffansferable,
pledgeable or assignable, by either party without the prior written consent of the other party.
tl However, the System Provider may assign its rights and obiigations to a parent, affiliate or
subsidiary company and, in the case of a merger or acquisition, to a successor company upon
notice to the Company, and provided that the rights of the Company shall not be derogated
pursuant to such assignment.
it
14 Force Maieure. The System Provider and the Company shall not be liable for any failure to
perform its obligations under this Agreement due to any action beyond its conffol, including
i] without limiktion: (i) acts of God, such as fires, floods, electrical storms, unusualiy severe
I weather and natural catastrophes; (ii) civil disturbances, such as strikes and riots; (iii) acts of
aggression, such as explosions, wars, and terrorism; (iv) acts of government, including, without
limitation, the actions of regulatory bodies which significantly inhibits or prohibits the System
[l Provider and the Company from performing its obligations under this Agreement (each, a "Force
l
i Majeure").
In the event of a Force Majeure, the performance of the Company's obligations shall be
I
il suspended dwing the period of existence of such Force Majeure as well as the period reasonably
I required thereafter to resume the performance of the obligation.
i] 15 No Third Party Beneficiary, This Agreement shall not confer any rights or remedies upon any
I
person other than the parties to this Agreement and their respective successors and permitted
I
i assigns.
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tl 16. Comnlete Agreement. This Agreement ancl the Exhihjts hereto constitute the full and entire
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uurderstanding and agreement befween the parties with regard to the subject malters hereof and
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thereof and any other written or oral agreernent relating to the subject matter hereof existing
between the parties is expressly canceled.
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17 Representations. N/A.
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18. No Set-Off. Not*ithstanding any right available to the End-User under law, the End-User shall
not be entitled to set-off any amounts due to the Company under this Agreement'
']
19 Severabitity. Should any court of competent jurisdiction declare any term of this Agreement void
or unenforceable, such declaration shail have no effect on the remaining terms hereof'
ii 20 Interpretation. The titles and headings of the various sections and paragraphs in this Agreement
,l are intended solely for reference and are not intended for any other purpose whatsoever or to
:itl explain, modify, or place any construction on any of the provisions of this Agreement.
i\
21 No Waiver. The failure of either parfy to enforce any rights granted hereunder or to take action
by that
:t
ll Auiott tf," other parly in the evenl of any breach hereunder shall not be deemed a waiver
ll puny as to subsiquent enforcement of rights or subsequent actions in the event of future
breaches.
il
lt '22 Notices. notices and demands hereunder shall be in writing and shall be served by personal
All
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li r"rui." o. by mail at the address of the .receiving party set forth in this Agreement (or at such
different address as may be designated by such party by written notice to the other pa(y). A11
i) notices or demands by mail shail be certified or registered mail, return receipt requested, by
it
rl nationally-recognized private express courier, or sent by electronic transmission, with
confirmation received, to the telecopy numbered specified below, and shall be deemed complete
il, upon receipt,
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,t fn Witness Whereof, the parties hereto have executed this Agreement the day and year first above
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Development Limited National Com munication Agency
r'i By: By:
ij Mr. George Dgreffippong Mr. William Tevie
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t'l Position: Di'rector, Business Development Position: Director General
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100/2015
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Exhibit A
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Description of the System and Services

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;i The System;
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The System Provider's Pegasus system is comprised of the
following (the ,,system,,):
(a) the features and capabilities detailed in the table atlached
ij respect fo the Republic
as Exhibit A-i. operational with
hereto
of Ghana mobile numbers (residing in the Republic of Ghana), using the
System Provider's supported devices running the Sysiem Provider's
certified versions of
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Blackberry, Android and ios operating systems,incluaing zs
concurrent targets; and
(b) the hardware equipment (the "flardware Equipment") and software
which are required for the
installation of the System, including s confolitaiions, as listed
in &dibit A-2 attachedherero.
ti
The Services:
'llii The services related to the system include the following (the ,'services,'):
.
(a) Depl6yment of the System at the End-User's site for use with respect
to the Republic of Ghana
mobile numbers residing in the Republic of Ghana (as set forifr in
Section'(a) above) (the
ll "Deployment,');
(b) Two (2) week training course and one (1) week on-site handover, which
shalt be held in English
ilii (the "Training,,);
(c) 12 months warranty (the "Warranty Period") commencing at the
date of the provision of the
Commissioning Notice, which shall be provided in accordanc-e with
il the Company,s SLA.
i1 No warranty is provided by the System Provider with respect to the hardware
components of the
System' To the extent permissible, Hardware Equipment warranty
will be provided ty tne System
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Provider back to back with the warranty provided by the suppliers of
the Hardware Equipment.
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Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 75 of 111 )
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Exhib it A-1
Features and Capabilities
Supported OS:
ios 7.x-9"1 Safari
. Clicking on a link will
always result in Safari browser
Android 4.x-5 . Native browser (Webkit
based)
. Chrome versions lg up to 45 (excl. 1g.0.1025.166)
. Focus mainly on Samsung
Galaxy devices
BlackBerry 5.x - 7.1
Native browser (w based)
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Page 9 of46 i1
Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 76 of 111 ::: :- f=: r-:: r"**1
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Insta llation:
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Remote Installation Push Message Infection is done by silently . Works on most BlackBerry devices V
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pushing an installation to the . Works on a variety of V
Android
l:....:r
device. devices (OS a.x). Depends on rhe
This rnethod does not require the local ROM settings
Crafted Message An innocent message is sent to the
:,,.r:
(SMS, Email and target device which contains text
\/
other 3rd party and link.
.'.'.' applications) The message content and link lure
the target to click (only once) and
c(
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browse to an innocent website.
Clicking the link triggers a silent
.tu:..
:.... :
installation which runs in the (F

Infcction Assisting Tools MMS Reveal the target device and OS This fearure may be blocked by the
Fingerprint version by sending an MMS to the V V
..:..ti
local mobile network operator.
device. Feature implementation subjects to
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No user interactiorl engagement site survey results.
or message opening is required to Note: MMS content appears on the
receive the device
.l:r,
device.
Sender ID Set an alphanumeric sender This feature may be blocked by the
.'.. Spoofing identification for SMS and MMS. V V
local mobile network operator.
.:::::.
Feature implementation subjects to
site stwey results.
Control tink URL Set any DNS to be used as the
installation link
Domains to be defined and purchased \/ V V
the customer
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Page 10 of46 i\,
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Blackllerrw a -.I -î.r :nc
Agent Sun'ivability Pcrsistency The installed collection tool Device reboot refers to
.
survives device reboot. . Device restart
. Device tum off
. Device battery drain
Factory Reset The agent collection tool endures
device factory reset.
V
Factory reset, also known as m€$ter
reset, restores the device original
manufacturer settings resulting in
:,.i
perrnanent erasing all ofthe
informafion stored on the device.
Blocking OS The agent collection tool blocks The device acts like it has the latest
V
Upgrade the user from upgrading the OS
version.
OS version or is not allowed to
perform off-the-air OS upgrade.
G
Note: Physical OS upgrade is still (,"
Agent Uninstall Uninstall ):
Permanently remove the agent Done remotely without any us€r V V
collection tool
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Page 11 of46 ,:,,no
Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 78 of 111 i::t ,m:_] r: r: r-::l ! - .i j
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2 BlackBerrv :Android ios
f{istorical Contact details Extracts all contacts available on
Data Extraction is done for all available V
e the device including V V
g Extraction: their (non-empty) fields.
Extract all
existing data SMS Extracts all incoming and
v,
m outgoing text V V
from the messages (sMS)
7
s device. the device
Gain access to
E
(t historical data.
iMessage Extracts all incoming and Messages sent only between iOS
outgoing iMessages from the devices
6r device
-
[,mails Extracts all emails that exist on
= Extracts only from the device slock
V 4
the device application and Gmail application.
g Emails are presented in HTML N
c format. (r
Call Log Extracts the history of all
H
incoming/outgoing calls made V V
=,
to/from the device
WhatsApp Call Log Extracts the history of all
incoming/outgoing calls made V
to/fiom the device using
Skype Call Log the
Extracts history of all
V
incoming/outgoing calls made
to/from the device
I Due
to some limitations and restrictions of the operating
system, certain devices might not support all listed features. +
Agreement 100/2015
Page 12 of46
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Calendar Extracts all calendar records that
exist on the device V
Browsing History Extract the entire list of browsed Extracts only from the device native
websites that exists on the device browser ication
BBM l.zqLnDur r Jr urcns€Illlel Extracts all existing incoming Extracts only instant messages (text) V
w and outgoing instant messages
from the device, including V V
Viber personal and group chat
S
Facebook t-
V V TF
Kakao Talk
V
;
Line
V
Odnoklassniki
V
WeChat
V
fa
V
VKontakte
V V
NIail.Ru
Data Contact details V
Monitors addition, deletion and
Monitoriug: editin of contacts on the device V
Real-time
monitor ofnelv SMS Monitors incoming and outgoing
data that text mes
arrives/sent iMessage
_S
Monitors incoming and outgoing
to/from rhe Messages sent
devices
only between iOS P
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Agreemert 10012015
Page 13 of46
l_ 80 of 111
Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page t ;: ffii (:= ffi: r.,T:
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Emails
Monitors incoming and outgoing Monitors
emails
only the device stock
application and Gmail application.
Emails are presented in gfUI.
format.
Call Log
call records
WhatsApp Call Log
call records of WhatsApp V
on
Skype CatI Log
Monitors lncomlng and outgoi ng
call records of ication
Calendar t-?
Mon itors addifi on and editing of T,N
calendar records on the device V V
Browsing History
Monitors new browsed websites
Monitors only
-u\l
the device nati ve
BBM
browser
I_vlon]tors only instant
\li
lnstant messages, including (text). messages
Indication for file transier
personal and group chat
Vilrcr appear and their retrieval is possible v
using file retrieval feature.
V V
Iiakao Talk \/ V
f V V
Line V
Odnoklass nihi V V _s
|.."
WeChat
(>
a V V
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Agreement 100i2015
Page 14 of46
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Tango
VKontakte V
Mail.Ru V V
sures V
USSD V
Monitors incoming network
messages from the device V
Call recording (call Record incoming and outgoing Calls are recorded
interception) locally on the V V V
voice calls made to/from thi device and then sent
to the system
device servers.
Device Information Monitors general details about
the device, network and V
Cell-ID Location
connection
Monitors the device cell_ID
6
within every connection to the V bJ
command and control servers -q-
Keystroke logging Monitors keystroke typing by the Helps monitoring texting in
regular keyboard unsupported applications and even
usernames and passwords for
sensitive accounts.
Active Data Front Camera Snapshot Take a snapshot using the device No indication appears on the device
Collection: V V
frontcamera and flash is never used.
User raluest's
real-:ime Back Camera Snapshot Take a snapshot using the device No indication appears on the device
actions on rear cantera and flash is never used.
target device Screenshot capturing
a \
Capture screenshot of the
V
device -E
File System listing Retrieve a full list of files and
V
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Agreement 100/2015
Page 15 of46
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folder in target device --BlackBerrv. ,:.iOS
File retrieval Retrieve any file from the target File retrieval is allowed from the V V V
device including photos, device intemal storage and SD card.
docum audio and video
GPS Location Locate device using the device
V V
GPS
Room Tap (environmental Tum on the microphone and Tuming on the microphone is done
sound recording) listen in real-time to the by issuing an incoming silent call to V
surrounding sounds of the the device. No indication of the
device. The surrounding sounds recording or the silent call appears
are recorded and saved for later on the device at any point. The
playback and analysis. quality of the recording depends on
the device's microphone sensitivity, t-
the surrounding noise and the device
model.
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Page 16 of 46
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Data Transmission:
'lii . [sac:re' l: orted in
Data .il.+u r.!Jrtr
GPRSruTMS/LTE Transmit collected data uslng Data is sent in very small packets. This
Transmission: cellular data channels V V
Channels used to has very small impact on target's data
exfiltratethe
co[ected da-a back wi-ri Transmit collected data using Wi_Fi Has no impact on target's data plan at
to the command V V
all.
and control servers
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Agreement 10012015
Page 17 of46
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Presentation:
Contact details Entire values stored in the contact entry including
available
photo if . Grid
. Contact card with the entire details
SMS . Type (SMS /USSD) . Grid
. Direction (incoming,
outgoing)
. Contact name
USSD . Phone number
. Message content
iMessage . Date & Time G
Emails . From
.To
. Grid tA
.CC
.Iull HTML presentation (emulates popular email
. Subject clients)
. Folder
. Account
. Message content
. Date & Time
Call . Direction
(Cellular catts, WhatsOOO, . Grid
a,Olll* . Contact name
. Phone number
. Duration
. Date & Time
Calendar . Meeting subject
. Grid
. Location
' Event date and start time
. Monthly calendar view (emulates
clients)
popular calendar +
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Agreement 100,201S
Page 18 of46
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Browsing History . Website name (as saved by the targe!
usually the default . List
website name)
. Website URL address
BBM . Type of application
. Grid
'Chat participants Qrlames & phones) . Conversation rnode
. Conversation content
Viber . Date & Time
. Attachments metadata (without
the attachment)
Facebook
Kakao Talk
T
Line
Odnoklass niki
In
WeChat
?r
Tango {-
\rKontakte
Mail.Ru
sures
Call recording . Direction . Grid
(call interception) . Contact name . Playback interface
. Phone number
. Duration
& Tirne
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Agreement -00/201S
Page 19 of46
Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 86:"-::
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Deyice and Network Information . Battery level . Dashboard
. Last location
. Connection type (e.g., 3G, WiFi)
. MSISDN
.IMEI
.IMSI
. Device Manufacturer
. Device model
. Operating System version
. Installation type (remote, physical or
other)
. Installation date
. Last communication time
. Next communication expected
. Device current country
. Device home country
. Serving network
. Home serving network
GPS/Cell-ID Location . Data source (GPS/Cell-ID) . Grid
. I,atitude
. Longitude 'Map:
- On map display
. Enter Tirne & Date
- Full trail
. Leave Time & Date
- Type of locarion data (GpS or Cell-ID based)
Text the board . List
Front Camera . Date & Time . Grid
. Photo . Photo viewer
Back Camera
. Source ofphoto
Screenshot
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Agreement 100/2015 Page 20 of 46
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Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 87 of 111 [.-:: f:.": rI r+:" 'f
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File System listing . List of folders (tuee)
. Grid
. List of files (grid):
. Tree view
- Filename
File retrievel - Modified date
- File size
- Retrieval status
Room Tap (environmental sound . Recorded audio
recording) . Grid
. Recording Date & Time
. Playback interface
. Duration
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Agreemenr 100,?015
Page 21 of46
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Rules & AIerLs:
Geo Fence - Acr:ess hotspot Aiert when target entered an important area Geo-fence alerts are based on a perimeter around a
certain location, where the operator defines the size
of
the perimeter.
Meeting detection Alert when two targets meet The alert occurs in two target are at the same perimeter
as defined by the user. The alert wifi take place
also if
targets visited the same location in different times.
Connectior detection Alert when a message is sent from/to a specific number Alert when target is corresponding ith a certain num ber
AS defined the user.
Alert when a phone call is performed from/to a specific Alert when target conducts/receives a phone call to/from
number
a certain number as defined bv the user.
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Exh$[4-2
List of Hardware Equi.pment and Software
The system Prorider shatl supply the fottowing
ha.dware equipment and software, or similar, to
enable the commissioning of the system.
Disclaimer: rhis List may change per Network\Regulation\System\country
feature support changes.
PowerEdge R7:0xd Server
Dell I R73oXI)
3.4GHa2 0M cache,e. Gr/s epr,rurbo, Hr,6 c/ I 2r
i;r;| ilr"# ii;iffi;, 60 (I3s w)
R730/xd PCIe Riser 2, Center
R730ixd PCIe Riser 1, Right
PowerEdge R730xd Shipping EMEA1
(English/French/German/Spani sh,/Russi anlFlebrew)
Bezel
Chassis with up to 24,2.5,, Hard Drives
DIMM Blanks for System with 2 processors
Performance Optimized
t;f
2133MT/s RDILIMs
! I8GB RDIlvIIvI,2133MT/s, Dual Rank, x8 Data Width
2 X Star-dard H:atsink for powerEdge R730/R730xd
Upgrade to Two Intel Xeon E5_Z6a{ fi 3.4GH2,20M
Cache,9.60GT/s
h
QPI,Turbo,HT,r'C/l 2T (1 3 5W)
Enterprise, integrated Dell Remote Access controrler, Enterprise
iD,RACS
2 X 300G8 t5K RpM SAS 6Gbps 2.5in Hot_plug '
Hard Orive,i:C
16 X 500c8 7.:,K R'M_NLSAS6Gbps 2.5in Hoi-plug Hard Orive,t:G
IE\C HT30Integrated RAID Controiter, lGB Cache
Performance BIOS Settings
Dual, Hot-plug, Redundant power Supply (1+l), 750W
2 X C13 to Ct4. pDU Style, t0 AMp;b.6m power
Cord
PowerEdge Server FIPS TpM C)
Inte Ethernet ii5rl
Intel Ethernet I] 5 0
QP Gb N etwork Daughter Card P
G b Server
\,
Agreement 100i2015
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Page 23 of 46
Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 90 of 111 g,.- -
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PorverEdge R730/R7 3Oxd Motherboard
No Media Required
No Operating Sysrem
OpenManage Essentials, Server Configuration
Management
Electronic System Documentation uriop"ntvtanage
DVD Kit, powerEdge R730/xd
OEM Order
Nor Selected in this Configuration
Asset Service - System & shipbox Label (Model,
Svc Tag, order krformation, Basic
Config Details)
|91$nals Sliding Rails With Cable Management Arm
RA'D 1+R{ID -5 f61H330/H730/H730p (2"t 3-22
HDDs or SSDs)
Base Warranfv
lYr Parts Only Warranty (Emerging Only)
iNFo lYr Prosupport and Nextbusin"rs buy on-Site Service (Emerging only)
3Yr ProSuppsrt and Next Business Day On_dite
Service (Emerging Only)
Consolidation Fee
EX-Works
PowerEdge R?30 Server
2.4GHz,r5M cache,8.00Gr/s Dell 2 R730
tro
ilfl il:J i#ffi};, epr,rurb o,Hr,6c/tzr(85w)
R730/xd PCIe Riser 2, Center *l*
R730 PCIe Riser 3, Left
R730/xd PCIe Riser 1, Right
PowerEdge R730 Shipping EMEA1
(English/French/German /Spanish.tRus sian /tlebrew
)
Bezel
Chassis with up io 8, 3.5" Hard Drives
Perform ance Crptim ize d
2.l33MT/s RDII{Ms
2 X 8Glf RD If\,[M, 2 J 3MT/s, Dual
Rank, x8 Data wi dth
2 Stancarc Heatsink for PowerEdge R 730/R73
0xd
U pgrade to T 'l\o Intel Xeon E5-2620 v3 2.4G
},lz, 5M Cache,8 .00G T/s O
V
l1
Turb 2T
V
t
Agreement 130/2015
Page24 of 46 ,.\
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iDTdA C8 Enterprise, integrated D
ell Remote Access Control ler, Enterprise
2 X J OC'GB OK RPM SAS 6Gbps
2 .5 in H,ot-plug I{ard Dri ve,3 .5 1n HYB CARR
PERC H?30 Integrated RAID Controller,
t GB Cache
Performalce BIO S Settings
DVD+/. RW, SAT,A, Intemal
Dual, Hot-plug, Redundant power Supply (1+l),
750W
Cl3 to C14, pDU Style, 10 AMp, 0.6m iower
cora
European Power Cord 220V
PowerEdge Server FIPS TpM
Intel Ethernet i350 ep 1Gb Network Daughter
Card
Intel Ethemet 1350 ep lGb Server adapti
PowerEdge R73 0/R73 Oxd Motherboard
No Media Required
No Oprating System
OpenManage Essentials, Server Configuration Management
Electronic System Documentatio,
OEM Order -iop"r,lutanage DVD Ki! powerEdge R730/xd
Not Selected in this Configuration
Asset Service - System
Config Details)
& shipbox Labei (Model, Svc Tag, order Information,
Basic
F
L_.
|ea{Vna$ Sliding Raiis With Cabte Management Arm
RAID I for H3304I730/H730P (2 HDDs or"SSDs)
*{-
Base Warranty
lYr Pars Only Warranty (Emerging Only)
b
11, ProSupporr an{Ne1t-Au1n.r, buy
ry,Fg On_Sire Service (Emerging Only)
3Yr ProSupport and Next Business Day On_dite
Service (Emerging OnIy)
Consolidation Fee
EX-Works
PowerECge R730 Server
lntel Xeon E5-2650 v3 2-3GHz,25M cache,9.60GT/s Dell 2 R730
Max Mem 2133MHz
R730/xd PCIe Riser 2, Center
R730 PCIe Riser 3, Left
epl,Turbo,HT,l0c/20T (105w)
6
{.
R730/xd PCIe Riser I Ri
q
Agreement 100/2015
Page 25 of 46
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PowerEdge R730 Shipping EMEAI
(English/French./Germar/Spanish,rRussian[Iebrew) I
Bezel
Chassis with up ro 8, 3.5,, Hard Drives
Performance Optimized
2l33MTis RDIIvIMs
8 X 16GB RDIVIU,2133 MT/s, Dual Rank, x4 Data
Width
2 X Standard Heatsink for powerEdge R730/R730xd
upgrade to Two Intel Xeon E5-2650 v3 z.3GHz,25M cache,9.60GT/s
QPI,Turbo,HT, 1 0C/20T ( I 05W)
iDRACS Enterprise, integrated Deil Remote Access conboler, Enterprise
VFlastr, 8GB SD Card for iDRAC Enterprise
2 x 300cB 10K RPM sAS 6Gbps 2.5in Hor-plug
Hard Drive,3.5in HyB CARR
PERC HT30lntegrated RAID Controller, IGB Cache
Emulex LPE12002 Dual channel gGb pcle Host Bus Adapter,
Low profile
Performance BlOS Settings
DVD+/-RW. S.4"TA, Internal
Dual, Hot-plug. Redundant power Supply (l+l), 750W H
C13 to Cl4. PDU Sryle, 10 AMp,0.6m Fower Cord V\
PowerEdge Server FIPS TpM
Intel Ethernet i350 Qp tGb Network Daughter Card
Intel Ethernet 1350 eP 1Gb Server Adapter
PowerEd ge R7l 0/R73 Oxd Motherboard
-F
5-
No Media Required
No Operating System
Electronic system Documentation and openManage DVD Kit, powerEdge
R730ixd
OEM OrCer
Not SelecteJ in this Configuration
Asset Service - S.v*stem & Shipbox Label (Model, Svc Tag,
order Information, Basic
Config Details)
ReadyRails Sliding Rails With Cable Management Arm
RAID i for H330,tI730/H730p (2 HDDs oiSSOry
E
Base Warranty
\
lYr Parts Onl w On
!. ii
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Agreement 100/2015
Page 26 of 46
Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 93 of 111m m: r*::] (Xl (-: r:] _r-
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INFO lYr ProSupport and N ext Business Day On-Site Service (Emerging Only
Yr ProSupport ald Next Business Day On-Site
_1 )
Service (Emerging Only)
Consolidaticn F ee
EX-Works
PowerEdge K}'M lOglAD _ Port
Bi Keyboard/Video/lr4ouse Analog Switch, EUCEM
8x USB Sen.er Interface pod, includes 2 Deli I 1081AD
CAT 5 Cables, TAA
1U KMI.,{ (Touchpad, US/Intemational
Keyboard and Widescreen 1g.5,, LED) with
ReadyRails - Ki1 Deil I
NetApp 1 FAS8O2O
r<
L.\
-C 2
+
,-C 288 ?
0\
L
Agreemenr I00/20I5
Page?7 of46 J
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Digi PortServer TS l6 port rackmounlable RJ-45 Serial to Ethemet
Terminal Server Digium 2 TS I6
One (1) span digihl T1/Ei/JllpRI pCl-Express xl card Digium 2
Cisco 2921
Cisco 3 2921
Cisco 2921 Securit_v Bundle w/SEC license pAK
SMARTNET SX5XNBD Cisco 2921 Security
Four port 1 Oi 10011 000 Ethemet switch interface card
Cisco 2901-2921 IOS UNIVERSAL
Data Paper PAK for Cisco 2901-2951
Cisco 2921/2951 AC Power Supply
Console Cable 6ft with RJ45 and DBSF
Cisco Config Pro Express on Router Flash
lnsert Packout - PI-MSE
IP Base L.icense for Cisco 2gOl-ZgSl
Blank faceplate for HWIC slot on Cisco ISR !n
512M8 DRAM for Cisco ZgOt-Zg2t ISR (Default)
256M8 Cornpact Ftash for Cisco 1900 2900 3900 ISR \-
Secnrity License for Cisco ZgOl-2951
Blank facep_ate f.-:r DW slot on Cisco 2951 and,3925
Removable faceplate for SM slot on Cisco 290039004400 ISR
K
Cisco 3750X
Cisco 2 Cisco 3750X
Catalyst 3750X 48 Port Data Ip Base
SMARTNET SxsxNBD catalyst 3750x 4g port Data Ip Base for 36 Months
Catalyst 3K-X 350W AC Secondary power Supply
CAT 3750X IOS TINIVERSAL WITH WEB BASE DEV MGR
Cisco StackWise 50CM Stacking Cable
Catalyst 3750X and 3850 Stack power Cable 30 CM
Catalyst 3K-X 10G Network Module
Catalyst 3K-X 350W AC Power Supply D
Insert Packout - PI-MSE +
(-
-.\
Agreement _00/2015
Page 28 of46
i, . _..,, L-,*._J r.--.. -,.,; !......"....,.r .t,."..-.-! t-.".-*r L--.._..J L.*...,.,_,, 1..,,,,,.,",,j i
Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 95 of 111 t,
. '...:,. l --l :-l -- --l .---l _-::l I
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Catalysr 296Cr-X 48 GigE 4 x SFp LAN Base
SMARTNET sx5xr{BD cat2960-x stk 24 GigE4xSFp Cisco 2 Cisco 2960-X
LAN Base (36 Months)
Insert Packout - PI-MSE
Cinterion MC-< 5i l'zlodem
Cinterion 9 MC55i
Optiplex 701D MT
' OptiPlex 7010 N{T: Mini-Tower Dell l5
'Windows 8
' 3rd Gen Intel core ii417a (euad core,
3.40GHz Turbo, gMB, w/ HD4000 Graphics
' 8cB (2X4cB I td00 MHz DDR3 Non_ECC
yIf!+ (QWERTY) Dell KB2I2-B euietKey USB Keyboard Btack
' lTB 3.5inch Serial ATA IiI (7.200 Rpm) I{ard Drive
' Dell optica- oiot wireress), Scroil use-1:
buttons scrolr) Brack
Mouse
' I6XDVD+/-RW Drive
Internal Dell Business Audio Speaker
3Yr ProSupp.rrt and Next Business Day On_Site Service (Emerging
Only)
Dell Professional p23 I 4H 5 g.4cm(23 ,') LED monitor vGA,DVI_D,Dp g20x t 0g0)
\^r
BlackUK
( 1 Dell 30
APc NetShelter SX 42u Deep Enclosure 1200x600 with Roof
and sides Black APC 2 AR3300 _p
Rack PDU 2G. Metered , ZerorJ,32A,23OV, (36) C13
& (6) Cl9 APC 4 AP8853
PDU cord Retention Kit for Full-Height & 4gu, Basic
& LCD-Metered pDU (l per APC 4 AP9569
PDU
Horizontal Cable Organizer lU w/brush strip
10 AR8429
CatT patch cord,0.5m,Blue
20
CatT patch ccrd,lm,Blue
40
;
0a
C
Agreement 100l?015
Page 29 of46
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CatT patch co:d,2m,Blue
60
Cat 7 patch cord,Sm,BLACK
20
Cat 7 patch cordl0m,Grey 10
48 port Cat 6 patch Panel HD Netkey
4
duplex patch cord,lOm - Patch cord Fiber OM3 LC LC 10m
10
Console Cable 6ft with RI45 and DBSF
2
Blank plate 1IJ(10 per pack total 4 packs)
40
Power Cord, Cl3 to Cl4, 5m 20
rE
Fower Cord, C13 to C14, 3m
40
APC Smart-LPS SRT 5000VA RM 230V APC 4 SRT5KRMXLI
APC Smar-LrPS SRT 5kVA Output FIW Kit APC 4 SRTOOl
SRT001 Kit installation APC 4
power cable j meters for ups + Sicon 32A APC 4
APC Smart-UPS SRT 192V 5kVA and 6kVA RM Batrerv pack APC 4 SRTI92RMBP
Office Pro Plus 2013 Microsoft 15
VPP L3 VMrvare vSphere 5 Enterprise for I processor Vmware 4 processors
Production Support/Subscription for VMware vSphere 5 Enterprise for 1 processor
C)
VPP L3 \\Iware vCenter Server 5 Standard for vSphere 5 (per Instance) Vmware
__C\
1 Instances
t,
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Agreement 100/2015 Page 30 of 46
Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page..--\, 97L-.\--)
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V eeam Backup &. Replication Enterpri SC for Vm ware and Hyper- per Socket License Veeam 6 Sockets
Microsoft windows Server 2012 R2 Standard Edition
2 Socket License Microsoft. 2
MS SQL 2014 Serrer Standard core 2 socket License
Microsoft 2
Nagios XI (Enterprise version with 100 Nodes
license) Nagios I
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Agreement 100/2015
Page 31 of46
Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 98 of 111 1\rBls? ,lt't *'1
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Eihihit E
Consi.Gerations
fi Gousi
ffir
d eratio li$ A}}toIfi ts.
fi i'System eonside ratloni' provision'of ttiq Licease, Systern ,&:00&060.(Siglt nil }ioq.
arid, Seryj.ees.,
fi
ti '!Support Feriod &ay,ore Suppor{ Period, , 22P/r olthe System
Go-nsid€ration'r Coidderafion.
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lr EdlrlicBt Tetiiil
I System Consideratiou
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I The System Cons.ideratinori strall be paid by the End-USe'r to the Co.mpany in, tlrqg Q) insullm-errtS- aS:
follows:
ll
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i
(a) 5070 of',*re Sptam Consideration,shzrli oe-paid o'y Janua4y-'2-8ur 2016 ({he "First Installment").
I
(b) 3"5910 of t'he S,ystern Considera,tion shall.bepaid uporr.the p. rnvision o,f the Hardware Eqrlipnrent to
the Erd-Uset'ssile.
il (c) l5o/o of lhe System Consicleration shall be paid upon the provisiori: of a writteu notice by the
ir
Company to the End.User confirrning thar the Deplotrnnent oF the Syptern at the End-Userrs site
rvas c gmpl eted (thel'iC om mlssi on ing No ti cen).
:
SUpporf qerjoi{ Considemtion
Thersupport P€fiod iconsidqrdtri:on sliall ba paid hi one.pa.vment, in advanc'e of each Support Period.
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Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 99 of 111 \t'r- : I: :i
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LJ Exhibit.C
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!--; i,.i Installation Requirements

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1-: The End-User shall ensure that the following pre-requisites are ready 2 weeks prior to the System
-tr 1i installation (aligaed to SW version).
:
Disclaimer: This tist may change per Network\Regulation\Systerr feature support changes'
{
.t
I Internet Connection 2 symmetric A TM lines each 2 OMB (from

1
[2 lines a.e;;quired for
redundancy, The minimum
!
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ri different iSP's) with static IP' S of 8 external
lill addresses requirement might be even
lower - depends on the
: (-
number and type of end
fi stations.
]
li Cellular Reception Stable Cellular Reception --95 db

Air Condition 18 Degrees None
4 power socket -220Y Server room and
ij Electricity
operational room drawings
I are required to accuratelY
it specifl a1l wall outlets
il location. Power generator
and Faciliry environment
ll against hazard ddngers are
iitl ootional
Area needed for 5X5M, Height 2.5 M There are 2 48U racks with
seryer room the following dimensions:
i1 Height 2258.00 mm,
Width 600.00 mm, DePth
l Area needed for

operator room
l0Xl0M, Fleight2.5 M
1070.00 mm
Can be
S rooms
into
Patch panel Depends on the number of stationary stations.

.t Wires from the end stations to the patch panel in
the rack
SIMs 2 SIM cards for each network It is mandatory to use a 3rd
party to order the SIMs ,
il also use a account
Security Lockable doors
X named credit card with 4000$ balance It is recommended to use a
it Untraceable
payment method
1
1 X Passport scan on the same name as a credit 3rd party, The PassPort,
card credit card and utilitY bill
1 X Prepaid no name local SIM card should not be related to the
rl f X Utility bill with address on the same name as organization
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),) 1. Introduction
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-t jl This Service Level Agreement (the 'SLA') is an agreement between NSO Group Technologies
ilrl Ltd, (hereinafter the "Compatry") and Infralok Development Limited (hereinafter the
i
"Reseller").
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The purpose of this SLA is to specify the services and commitments with respect to the
i1
il software technical support, location support and/or hardware replacement services for the
-1 purchased products.
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1.1 Objecfives of the Service Level Agreement
ti
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-t To create an environment which is conducive to a co-operative and productive relationship
,
.ilil between the Company, t}te End User, and the Reseller to ensure effective support for the End
User.
To document the responsibilities of all the parties involved in the SLA'

t
i1
To ensure the Company provides high qualiry seryice to the Reseller and the End User,
i_)
iill To define the service to be delivered by the Company and the level of service whicb can be
it expected by the End User, thereby reducing the risk of misunderstandings'
:
il To institute a formal system of objective service level monitoring ensuring that reviews of the
{i SLA are based on factual data.
To provide a common understanding of service requirements/capabilities and of the principals
il involved in the measurement of service levels.
To provide for all parties to this SLA a single, easily referenced document, which caters for all
objectives as listed above.
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l-i Ilardware Replacement means a HW replacement service for the hardware products purchased
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by &e Reseller from the Company, whereby the Company delivers a replacement to the End
User's site before the End IJser retums the faulty hardware.
ll
11 All Hardware Replacements shall take effect after the Company receives relevant alerts and all
required information, and determines that the hardware issue is related to a malfunction of one of
U
itti the hardware components.
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fl Business Day means a normal working day in the time zone where the End User is located.
li il
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Device Number means a unique identifier of a hardware device, which can be located on a label
l.i on a Hardware product:
ll iiri r Media Access Control (MAC) Address,

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, Serial Number (SA{),
ti
f ' Service Tag Number (STN)
t
' Internationai Mobile Station Equipment Identity (IMEI)
tl Documentation means the User and Technical manrids provided by the Company for use with
the purchased software and hardware products.
il
i Enhancement means ali software changes, including new releases, new versions, product
t-
il improvements, system modifications, updates, upgrades and service packs.
tt
I Error means an error in one or more of the Company's products, which degrades the product
i: l'l functionality in accordance with the Severity defmitions, as compared to the product
(.. ll
functionality and performance specifications described in the official user guides provided by the
Company.
ii
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Hardware means a computing device md/or its component with a specific function and limited
configuration ability. The Hardware is sold by the Company to the Reseller for the sole purpose
!'li of executing the specific Sofrware producUs supplied with it.
t_ il Information means any idea, data and program, technical, business or other intangible
information, howeyer conveyed.
(
I
ir il Problem Resolufion means the use of reasonable commercial efforts to resolve the reported
problem. These methods may include, but are not limited to: configuration changes, patches that
I fix an issue, replacing a failed hardware component, reinstalling the software, etc.
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il Force Majeure has the meaning ascribed to it in the Agreement between the parties.
Response means addressing the initial request and commencement of work pertaining to the
i issue.
Response Time means the amount of time elapsed between the

initial contact by the Reseller or
the End User with the Company's Technical Support Team and the returned response to the
Reseller or the End User by the Company's support staff.
it
Resolution Time means the amount of time elapsed between the initial contact by the Reseller
or the End User with the Company's Technical Support Team till the issue reported is resolyed
il wither by permanent fix or a workaround till a permanent fix would be available.
Security Code means a specific code dedicated to the End User's account in the Company's
'l'echnical Sr.rpport Center.'l'his code must be provided hy the EnrlTIser eaclr tirne the End User
T up;rruuchcri the Colrrpuny's support staff.
i
Support means the technical Support and Hardware replacement services provirlerl hy r.he
Company to the End User as set forth in this SLA.
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t--i Support case means a single issue opened in the Company's Case Management System. The
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case number identifies the Service Request.
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I1 Field Service Engineer means an engineer that provides the following onsite services:
Ii
Lf installation, field configuration, operates system to demonstrate equipment on test devices and to
i.
I analyze malfunctions, interprets rnaintenance manuals, schematics, and diagrams, and repairs
tt electronic equipment, such as computer, computing device or component, utilizing knowledge of
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electronics and using standard test instruments and hand tools.
System means the Hardware, Software and Documentation that have been provided to the
rI Reseller and/or the End User by the Company.
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i: Workaround means a change in the followed procedures or data to avoid error rvithout
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,j substantialiy impairing use of the product.
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Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 103 of 111 \\6 1,.
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3 Company's Obligations
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3.1. Maintenance and Support
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The Services shall include wuranty, support and maintenance of the System as further detailed
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below, via support center.
il
il The Company shall provide the End User with technical support for the System, consisting of:
r-i
ij (a) first level to fourth level ("Tierl to Tier4" as described in section 6.2) support via the
Company's support center, and (b) SW updates and SW upgrades of the System, which, for the
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avoidance of any doubt, shali not be specifically adjusted to comply with any End-User
Adjustments (as such term is defined in the Agreement which this SLA is attached to). The
ii Services shall only be provided to the End User
it i System support and maintenance covers both SW and HW provided by the company. In case of
i
i1 3rd party HW supplier, the company will contact the 3rd parly and ensure proper suppott
provided to the End User.
Maintenance will cover the following:
a. SW upgrades - periodical SW releases to add new features and bug fix'es. Installing
a new SW upgrade is communicated in advance to schedule the best time for the
l
il b.
end-user and minimize the system downtime
SW updates - special SW packages provided to fix specific critical bug outside the
1
I
periodical SW release. SW updates are also provided when a new OS version is
['J infroduced for a specific platform (e.g new iOS version).
c, MoUilqftng system - connected to our 2417 NOC room and monitored around the
clock. The monitoring system is configured to do the following:
il a. Connected to all the major HW components in the system, providing real-
time status of the system
b. Monitors SW components such as tunnels, VPS servers alerting when any
il component goes down
c. Checks for white accounts balances and alefts when it is below a predefined
threshold
i.l
For further details, see the enclosed "system monitoring capabilities and
I
i d.
requirements" appendix.
24/7 sapport - A dedicated NOC center is operated
can be submitted via phone call, dedicated website
to provide 24/7 support Tickets
or email. The NOC
representatives foilow our support procedures to ensure each ticket is being handled
it according to the SLA.
End user should report issues with the system, using an agreed form or tool specifuing ali
ri predefined data and providing all the required operational and technjcal information
The Company shall not be obligated to provide the Services in case of misuse, abuse, neglect,
alteration, modification, improper installation of the System, use of the System for purposes
il other than those authorizedby the Company, or repairs by anyone other than the Company or its
authorized representatives without the Cornpany prior written approval. The Company shall not
be ultligal,ed lo pnrvirle Llre Services irr corrrrecl,iorr rvil,lt [ltc l-']trd-lJser Adjustniettts.
il
3.2. Software Support
I For End Users covered under a valid Support offering, Software Support will be provided
pursuant to the terms of Section 6 "software Support Procedure". The scope of commitment
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in case ofSystem failure requiring a software repair or fix is to preserve the System at the fully
L ,\] functional condition as per the acceptance data ofthe System by the End User.
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r-1 Software fixes are generally delivered in a secure format, delivered by the Company or in
ti special occasions by the Reseller and/or the End User or third parfy partner if it is agreed for a
,i
Il particular case. In addition, permanent fixes are developed for known non-critical issues. These
i.l
are incorporated into service pack updates that are periodically distributed. The version updates
may include additional features, bug fixes and/ or services.
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The Company agrees to provide Suppor! where appropriate to the End User, which may
t.r
include but is not limited to, the following actions:
iili ,.1 (a) Provide the End User with access to product update releases and related Documentation,
t-l ilI'l upon general commercial release.
ti (b) Provide the End User with access to Technical Support Team representatives, who will
t1 work with the End User to diagrrose issues, ald provide Problem Resolutions, including
li
I
escalating the issue as needed.
?
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l. l 3.3. HardwareReplacement
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For End lJsers covered under a valid Support offering, the Company will use commercially
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reasonable efforts to provide Hardware replacement in accordance with the terms set forth in
Section 5 "Hardware Replacement Procedure". Provision of hardware Replacement is
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subject to the following limitations:
il (a) The Company will provide Hardware Replacement for up to three (3) years after hardware
llil
ii installation at the End User's Site or according to standard Hardware in case of a 3'o party
supplier.
:l (b) Hardware shall be repaired or replaced with same or similar products when needed, at the
lt Company's discretion.
it
il 3.4. On-site Hardware Support
il
For End Users covered under a valid Support offering, upon the End User's request, after the
i'l Company determines that the hardware issue is related to a malfunction of one of the hardware
i.l
|.l components, the Company will decide whether to dispatch a representative to the site'
i'i
il
it Provision of ou-site support is subject to the following limitations:
II
(a) On-site Hardware Support does not include on-site service for Software troubleshooting or
any Software or training related issues,
il (b) On-site Hardware Support service may not dispatch a representative on-site to perform
Hardware replacement outside of the End User's Site address for the Hardware,
it (c) On-site service response times may be dependent upon the End User's Site address for the
Hardware, the timely arrival of replacement parts at the End Uset's Site, and accessibility to the
Site.
it
it 3.5 On-site Software Support
On-site Sollware Support applies only in cases of Severity I issues rvhich can't be solved
Il remotely (based on the Company's customer support stat'f .iudgmcnt). After the Company
r:onfinns lhal lhe nral,ter is a Scvcrily I issue, tlte Contpatty and the End User will work
diligently, with highly skilled engineers to resolve the critisal situation artd to restore operation'
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Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 105 of 111 \t8 '-. i /\
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ln case the criticality of the issue remains or no progress is made, the Company will decide
whether to dispatch a representatiye to the End User's Site or use a partner Support
representative.
rp
ti 3.6. Exclusions
i.,
r.l Support does not include the following items or actions:
i,
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l.l (a) Step-by-step installation of Software or Service Packs.
i.i (b) On-site services (outside the ones described in this SLA), Professional Services, Managed
''l
1l Services, or Educational Services.
-i illi (c) Modification of software code, IT Network
li architecture changes, Security-policy
configuration, Audits, or Security design.
I The Company shall have no obligation to Support:
-)
il (a) An altered, damaged, or modified product or any portion of the product incorporated with or
into other software, hardware, or products not specifically approved in advance in writing by
the Company.
I
I
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(b) Product problems caused by the Resell6r's and,ior the End User's negligence, misuse,
i
misapplication, or use of the product in a way other than as specified in the System user
I
manual, or any other causes beyond the control of the Company.
I
? il (c) Product installed on any computer hardware that is not supported by the Company.
il r"l (d) Product not purchased from the Company.
l il (e) Products subjected to unusual physical or electrical stress, misuse, negligence or accident,
or used in ultra-hazardous activities,
-l
The Company shall have no obligation to Support the End User if:
l it
(a) Appropriate payment for Support has not been received by the Company and the Reseller
anilor the End User is unable to show reasonable proof of such payment; or
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il (b) The End User's annual Support term has expired without renewal.
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r 5, Hardware Replacement Procedure
The Company uses equipment from Ieading vendors, surveillance, network seryers and software
remedies. With each manufacturer, the Company has a contract for Service and Customer
tr ri technical support.
For End Users covered under a valid Suppori offering, the Company will provide the
f; i.t foll owing Hardware Support :
il
(a) The Company will atlempt to diagnose and resolve Hardware problems over tle phone or via
remote access. Upon determination that an issue is related to a malfirnction of one of the
il !iilil Hardware components, the Hardware Replacement process will be initiated by the Company.
(b) The Company will either issue a replacement for the faulty part or a full Hardware product
replacement.
tj t1 (c) The Company will send the required hardware to the End lJser's Site location within thirty
(30) business days of Hardware Replacement process initiation. The time to ship the required
I rF i
hardware is dependent also on the export procedures that the Company must comply with, as
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I
well as the import procedures on the End User's side.
'l
(d) The End User must ship back the faulty Hardware product (or replaceable unit) suitably
I iltl packaged, as specified by the Company in a letter shipped with the replacement, to a location
designated by the Company.
(e) Return shipment of the faulty Hardware should be made within five (5) business days of the
l
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II arival of the replacement. Transportation costs forreturn shipment shall be bome by the End
User.
(f)Transportation costs incurred in connection with the delivery of a repaired or replacement
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lt item to the End User by the Company shall be borne by the Company; provided, however. that
if the Company determines, in its sole discretion, that the allegedly defective item is not covered
by the terms and conditions of the Hardware Support described in this SLA or that a claim is
l il made after the Hardware Support period expired, tie cost of the repair or replacement by the
Company, including all shipping expsnses, shall be reimbursed by the End User.
(g) The Company shall have no obligation to Support and Replace Hardware not monitored by
I il Monitoring Client installed on the System and connected to the Company's Technical Support
Center.
!
itt1 The Company shall have no obligation to Support:

(a) An altered, damaged, or modified product or any portion of the product incorporated with or
i into other software, hardware, or products not specifically approved in writing by the Company.
(b) Product problems caused by the End User's negligence, misuse, misapplication, or use of the
product other than as specitied in the System user manual, or any other causes beyond the
T control of the Company.
rl (c) Products subjected to unusual physical or electrical stress, misuse, negligence or accident, or
used in ultra-hazardous activities.
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(d) Untrained personnel from the End User are operating the system.
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Case 3:19-cv-07123 Document 1-1 tu1 {1
Filed 10/29/19 Page 107 of 111
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6.' SoftwareSupportProcedure
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(a) Upon initiation of initial contact with the Company's Technical Support Center, the End User
-I I
must authenticate its identity by providing a valid Security Code. The Company shall have no
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ti obligation to provide Support if the End User does not provide the code.
ir
il (b) A Technical Support representative will validate the Security Code and start gathering
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details relevant to the question or issue. The Company shall have no obligation to provide
l
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Support services if the End User does not provide the relevant informarion.
(c) A unique Support Case number [Trouble Ticket] will be assigned and delivered to the End
-1
I User either verbally or via email. This nurnber will be used to track any given issue from initial
I tl contact to final Problem Resolution.
J
il (d) lf appropiate, an issue will be reproduced in the Company's labs. Additional testing and
I t"i
problem duptication may take place in a nelwork laboratory environment. Further investigation,
including additional troubleshooting or debugging activity may be required. Based on the results
{
il of the TestLab investigation, anissue may be resolved, or, if an anomaly is identifie4 elevated
to the appropriatc Company's Team for final Problem Resolution.
'1.
li
i (e) The Company agrees to use commercially reasonable efforts to work with the End User on
l-i Problem Resolution for an issue in accordance with the specifications bf this SLA. Timely
,i
efforts must be made by all parties involved. If communication from the End User ceases
l
)
without notice, after five (5) business days, the Company may, upon notice, close a Support Case
I
ii due to inactivity on the part of the End User.
(I) The End User agrees to grant access via dedicated secured VPN tunnel, upon receiving a
request from the Company for addressing issues reported by the End User. Thus, the Company
it
rl will have access to the System for a limited period of time in order to reach Problem Resolution.
The Cornpany shall haye no obligation to provide Support services if the End User does not
provide the VPN connection to the System.
I
J
ili1 (g) The End User agrees to grant access via dedicated secured VPN tunnel, upon the Company's
request, for the purpose of Software updates and upgrades or for fixing problems detected during
,-i the system operation. Thus, the Company will have access to the System for a limited period of
ii time in order to update/upgrade the System. The Company shall have no obligation to apply any
updates/upgrades if the End User does not provide the VPN connection to the System.
i-l (h) The Company shall have no obligation to provide Support services if Internet access / 3G
il issues occur at the End User's Site.
Exceptions:
I
i.
In some cases, the Company may not be able to resolve the issue until the access network is
stable (for example when the service provider installs firewalls over a period of time or there is a
poor 3G coverage or poor Intemet access). In these cases, the Problem Resolution period will be
paused until the nefwork is stable again.
il
Opening a support reeardins authentication of an inbound roamer identitv. wili require the
customer to provide a valid (activated) IMSI and MSISDN of the specific MNO from the
il specific country.
lVote.' System will present targets'information onJy if such information is available, based on
i-i global roaming agreements. SAI (Send Authentication Info) and MSISDN by IMSI, information
ll
may not be retrieved iftarget is hosted by an operator that blocks such queries or in lack of
roaming agreements with the telecom gateway,
il Technical Support Center:

!'or End Users covered under a valid Support offering, the Company will provide the following
t] Software Support:
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il Agreement 100/2015 Page 42 of 46 l,J I
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Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 108 of 111 lll kt,
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i support
(a) The company will provide the End user with access to the company's Technical
)i Center 24 hours a day,7 days a week, 365 days a year'
il (b) The company will provide the End user with assistance in operating, managing and
configuring the System as well as resolving any Software technical issues.
email, and
(c) The End User is able to submit an unlimited number of support cases by phone,
web (Case Management SYstem)'
,.1
ll 6.1 Support Levels and Support Level activities:
Tier 1 support - Technical support that is provided by an_Engineer trained by the company'
Support activitie, at this levei'should include basic software and hardware
installations'
il
!l upgrades, basic troubleshooting, configuration changes andlor operation
optimization'
l,
support
Tier 2 Support - Technical support level that is provided by a Field Service Engineer'
activities ut tfrls level should include all Tier 1 activities, customization management,
il configuration changes and diagnostics or advanced troubleshooting.
Specialist'
Tier 3 Support - Technical support level that is provided by a Technical Support
'ii Support activities at this .leve1 s'htuld include all Tier 1 and Tier
at R&D
2 activities,
level' This
in-dentl
level of
System
support
instructions, advanced diagnostics, and troubleshooting
shall be initiated by a request to the System Support Team'
i-l
il Activities:
(a) Providing initial client contact
lil (b) Establishing problem logs and tracking
(c) Providing "how to" support
a-t (d) Determining if an issue is documented
l:
ii (e) Maintaining confi guration knowledge
(f) Working with the End User to duplicate and reproduce problems
(g) Providing intemal problem determination and verification
(h) Performing remote diagnosis
Technical suppori level that is provided by an R&D Engineer'
Support
Tier 4 Support - and solutions, software R&D
activities at this level should inciude design level consultation
11
of software and hardware fixes and solutions' This level support
diagnostics, and high level
shall Ue initiated by a request to the Technical Support Team'
!i Activities:
(a) Isolating, tracking and fixing operational issues
(b) working with the End user to duplicate and reproduce problems
i-l
(c) Technical evaluation and allocation of defect reports within R&D
(d) Providing system fxes if and when deemed necessary
lt (e) Performing remote diagnosis
(f) System upgrades
n
ll 6.2. Severity Levels
Severity Level 1 - CriticalBusiness Impact: Complete System failure in which no field
n p.".a*. resolves the reported issue, A problem has made a critical application fitnction
unusable or unavailable and no workaround exists'
work, but is prodrrcing
scvcrity Lcvcl 2 - scrious Busincss Impact: The System is able to
l1 ,r*1r. *.ru., i1 uurtaitr t'uqucsl.s surrt. A problulrr Lus trtudu u uriticul upplication function
unusabie or unavailable but a workaround exists'
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Agreement 100/2015
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Case 3:19-cv-07123 Document 1-1 lbg
'L5Filed 10/29/19 Page 109 of 111 l))-
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\,, Severify Level 3 - Minor Busiress Impact: The system has problems, which do not affect its
ir main functions. A problem has diminished critical or important application functionality or
I]
L_; performance but the functionaliry still performs as specified in the user documentation.
,
il (a) For Severity Level 1: the Company's System Support Team and the End User agree to
tiLl dedicate fuil tirne and all t}le necessary resources to solve the case. Top prioriry is to
l'1
restore/improve service, not to debug the problem.
l
(b) For Severity Level 2 and 3: the Company's System Support Team and the End User agree
to use their technical resources in order to restore an acceptable level of service or bring
relevant information
I'
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iii. r
6.3. Contacting the Technical Support Center
J
Seryice Availability: The services of the helpdesk shall be available by way of CRM tool, email,
telephone at all times 24 hours a day,7 days a week.
I
I Report of System failure: The End User shall notify the Company in writing (via e-mail or
CRM tool) using the "Customer Support Ticket" form, or by telephone promptly following the
discovery of any verifiable and reproducibte failure of the System. Thjs SLAdoes not apply to
bug reports or feature requests that are cosmetic or do not otherwise impair the operation of the
lii.r System. Such bugs reports or feature requests are fypically prioritized for handling in some
future regularly scheduled product release.
Email Support
l
i-l
ii
The Company's Technical Support Center responds to all support requests sent via email. Generally, this
is used ai a backup in case the End User is unable to access the Case Management System. Email:
he lpdesk@slobalhel p.support
il
j-,l
tl Telephoue Support
il The Company's support engineers are available by telephone to receive support requests.
Phone: +.4440-36954\An
il
Skype
i'l NOC-HelpDesk
rl Contact Support via the web portal

The end user can also open a ticket to the Company's Technical Support Center via a dedicated web
portal that is connected to a CRM tool. Access is secured with a usemame and password which the
rl Company will provide.
il
6.4. Response Time and Resource Commitment
rl
Severity 1
(a) Response'I'ime: I hour

li (b) Commitrucnt - thc Company and the Und User lvill commit tho nccousury resources arouad the
clock for Probleur Resolution to obtain workaround or reducc thc scverity. Top priority is to
T
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it Agreement 100/2015 Page 44 of 46 ;'i
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Case 3:19-cv-07123 Document 1-1 Filed 10/29/19 Page 110 of 111 Jzr .,=
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t restore/improve service, not to debug the problem. If a workaround could not be provided, the
i-; )
i task wili be transferred to Supplier's R&D Tearn for further investigation.
I
Severify 2
il
t-J I I (a) Response Time - t hour
I i
l (b) Commitment - the Company and the End User will commit the necessary resources during
normal business hours for Problem Resolution to obtain workaround or reduce the severity.
tlti :.:i
,.I Top priority is to restore/improve service, not to debug the problem.
Severity 3
i (a) Response Time - 4 hours
IJ (b) Commitnent - the Company's Technical Support Team and the End User agree to use their
I
technical resources during normal business hours for Problem Resolution to obtain workaround
or reduce the severity. Top priority is to restore an acceptable level ofservice or bring relevant
il information.
NOTE: In case of Hardware problerns, the faulty parts will be shipped and time for shipment
[, will be defined for each specific case. In case of severe software problems, the time for
L, 1 L
resolution will be defined on a case-by-case basis. The Company will use commercially
reasonable efforts to provide Hardware replacement in accordance with the terms set forth in
ll Section 5 "Ifardware Replacement Procedure".
ill
i a'!
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6.5. Resolution Time and Resource Commitment
:ii Severity 1
(a) Resolution Time: 2 business days

(b) Commitment - the Company and the End User will commit the necessary resources around the
ii clock for Problem Resolulion to obtain workaround or reduce the severity. Top priority is to
ti restore/improve service.
.;'] Severify 2
ij (a) Resolution Time - l0 business days
(b) Commitment - the Company and the End User will commit the necessary resources during
i'l normal business hours for Problem Resolution to obtain workaround or reduce the severity.
rl Top priority is to restore/improve service.
.,
Severity 3
(c) Resolution Time - the 2"d scheduled SW release
I
(d) Commitment - the Company's Technical Support Team and the End User aglee to use their
technical resources during normal business hours for Problem Resolution to resolve the issue in
il the next scheduled SW release. This will be communic ated by the Company to the End user.
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I Agreement 100/2015 Page 45 of 46
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\ l. Clarifications
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l i. r The System willextract target 3G keys only if such information is available, based on global
I
I roaming agreements. This information may not be rekieved if the target is hosted by an
I 'l operator that blocks such queries or in lack of roaming agreements with the telecom gateway
i
I I The System will not extuact targets 3G keys from and in specific countries such as the USA
;
l
I
and Israel.
t.
.
I
The installation of the system may involve the deployment of a dedicated SS7 telecom
i
1 I' gateway at one or more of the mobile operators in tie country. The End User shall be
I I
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responsible for providing access and permissions to the sites where the equipment is to be
f
installed, including the allocation of necessary space, power and ventilation required for the
jI
! installation of the equipment.
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. In case of a cloud-based implementation, i.e., no S57 gateway implemented at a local telecom
operator, billing records of targets may be affected and interception of incoming SMS will be
j t , restricted.
. Operating-wise, it is recommended that system queries be used with caution and on highty
:
j important cases, this in order to minimize risk of exceeding acceptable threshold in the
II foreign network for such activity.
The Company reserye the right to end the System's life upon a six months prior notice, with effect not
i il before the lapse of 5 (five) years of a sale of a license to the System to the Reseller and/or the End User,
Operation of the System during its life period is conditioned upon timely and fuli payment of
maintenance and support fees during the entire period.
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ii Agreement 10012015 Page 46 of 46
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WhatsApp Sues NSO Group For WhatsApp Hack

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Case 3:19-cv-07123 Document 1 Filed 10/29/19 Page 1 of 15

18 NSO GROUP TECHNOLOGIES LIMITED

3 (“Q Cyber”) (collectively, “Defendants”):

18 3. Plaintiff WhatsApp Inc. (“WhatsApp”) is a Delaware corporation with its principal

19 place of business in Menlo Park, California.

12 aided and abetted each other.

13 JURISDICTION AND VENUE

15 this Complaint pursuant to 28 U.S.C. § 1331.

18 operative fact as Plaintiffs’ federal claims.

10 users averaged 2.41 billion.

13 security for WhatsApp.

23 2. WhatsApp’s Terms of Service

25 Terms (available at https://www.whatsapp.com/legal?eea=0#terms-of-service).

28 authorized, and acceptable purposes.”

4 inappropriate;” [or] . . . (e) “involve sending illegal or impermissible communications.”

12 any impermissible or unauthorized manner.”

14 listed above, but also from assisting others in doing so.

15 C. Background on NSO Group and Pegasus

3 messages that could be detected and reported by the victims.

10 contacts from the device. Id.

21 through remote desktop software and a virtual private network. Id.

1 D. Defendants Agreed to the WhatsApp Terms

4 accepted and agreed to be bound by the Terms on behalf of Defendants.

7 E. Defendants Accessed and Used Plaintiffs’ Servers Without Authorization

8 and Infected Target Users’ Devices With Malware

19 malware—believed to be Pegasus or another remote access trojan developed by Defendants—from

21 2. Defendants Set Up Computer Infrastructure Used to Infect the Target

26 including Cyprus, Israel, Brazil, Indonesia, Sweden, and the Netherlands.

5 with subdomains used by Defendants.

6 3. Defendants’ Unauthorized Access of Plaintiff’s Servers

9 transmit malicious code—undetected—to Target Devices over WhatsApp servers. Defendants’

13 formatting rules that specify how data is packaged and transmitted.

19 use Plaintiffs’ servers in this manner.

21 without authorization, WhatsApp Signaling Servers, in an effort to compromise Target Devices. To

11 downloaded and installed Defendants’ malware from those servers.

14 including their communications.

18 dissidents, diplomats, and other senior foreign government officials.

2 identified a vulnerability involving the WhatsApp Service (CVE-2019-3568). WhatsApp and

7 news all over the world.”

11 Plaintiffs’ computer network.

15 FIRST CAUSE OF ACTION

16 (Computer Fraud and Abuse Act, 18 U.S.C. § 1030)

17 49. Plaintiffs reallege and incorporate by reference all preceding paragraphs.

20 authorization in an effort to compromise approximately 1,400 Target Devices.

22 “computers” as defined by 18 U.S.C. § 1030(e)(1).

25 or foreign commerce or communication.”

28 information and belief, obtained data from the Target Devices.

9 value of which exceeds $5,000.

11 violations alleged in the preceding paragraphs.

13 during a one-year period.

14 57. Defendants’ actions caused Plaintiffs to incur a loss as defined in 18 U.S.C.

17 other amount to be proven at trial.

18 SECOND CAUSE OF ACTION

19 (California Comprehensive Computer Data Access and Fraud Act,