UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF NEW JERSEY 

HOV SERVICES, INC., and LASON INDIA 

PRIVATE LTD., 

 Plaintiffs, 

v. 

COGNIZANT TECHNOLOGY SOLUTIONS 

CORPORATION, 

 Defendant. 

 Civil Action No. 

 FIRST AMENDED COMPLAINT AND 

 JURY DEMAND 

 Plaintiffs HOV Services, Inc. (“HOV”), a Delaware corporation and Lason India Private 

Ltd., successor in interest to Vetri Software India Ltd., an Indian corporation authorized to do 

business in the State of New Jersey as HOV Services, Inc., f/k/a Lason Systems, Inc. (“Lason”) 

(together, “Plaintiffs”), as and for their First Amended Complaint against Defendant Cognizant 

Technology Solutions Corporation (“Defendant” or “CT”) state the following: 

NATURE OF THE ACTION

1. Plaintiffs bring this action in response to the persistent efforts by their direct 

competitor, Defendant CT, to cripple Plaintiffs’ business on a global scale and to destroy 

Plaintiffs’ competitive advantage by, among other things, systematically and wrongfully 

targeting and luring away in excess of 51 employees from Plaintiffs while simultaneously 

misappropriating and unlawfully using Plaintiffs’ confidential and proprietary business 

information. 

2. Upon information and belief, CT has directed its raid and illegal actions to acquire 

Plaintiffs’ confidential and proprietary business information from its corporate headquarters in 

Teaneck, New Jersey, where the proceeds of such activities ultimately flow as well. 

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3. CT has conducted its raid through personal off-premise meetings, telephone calls 

and emails with targeted employees with the design and intent to systematically induce HOV 

and/or Lason employees to terminate their employment with HOV and/or Lason and thereby 

cripple, irreparably harm and/or destroy Plaintiffs’ business. The HOV and/or Lason employees 

who defected have/are soliciting other HOV and/or Lason employees in Chennai, India in 

furtherance of Defendant’s scheme. Indeed, those individuals who conspired with Defendant are 

attempting to destroy Plaintiffs’ business including their employee base which Plaintiffs have 

spent an extraordinary amount of time and money training, developing and maintaining only to 

see them secretly contacted and solicited by Defendant. 

4. Defendant and certain of its agents have also induced current and former HOV 

and/or Lason employees to provide Defendant, in breach of their common law and contractual 

duties to HOV and/or Lason, vital confidential and proprietary information concerning 450 

employees of HOV and/or Lason including their names, detailed salary and bonus compensation 

data, working days, per day targets, number of documents produced per month, production 

efficiencies and various customer project names. This employee information is critical to the 

success and profitability of Plaintiffs in the highly competitive business process outsourcing 

industry and Defendant misappropriated this confidential and proprietary information for the 

improper and unlawful purpose of crippling, irreparably harming and/or destroying Plaintiffs’ 

business. 

5. Defendants’ raid against Plaintiffs’ operations is ongoing as, upon information 

and belief, Defendant CT continues to use Plaintiffs’ confidential information to solicit 

Plaintiffs’ employees and damage Plaintiffs’ business. Specifically, within the past month 

Defendant has improperly lured away and hired at least eight (8) more of HOV and/or Lason’s 

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employees. As a direct result, Plaintiffs face the imminent, irreparable crippling of their 

business, goodwill, reputation and customer relationships. 

6. Accordingly, this is an action seeking injunctive relief and damages arising out of 

Defendant’s unlawful solicitation of HOV and/or Lason’s employees for the purpose of disabling 

direct competition with Plaintiffs, conversion of Plaintiffs’ confidential and proprietary 

information, tortious interference with Plaintiffs’ prospective economic advantage and 

contractual relations with employees and clients, disclosure and use of confidential and 

proprietary information and the unlawful, willful, wanton and malicious corporate raid of 

Plaintiffs’ business operations. 

7. This action also seeks damages arising out of Defendant’s wrongful and malicious 

use of HOV and/or Lason employees to access one or more HOV and/or Lason computers and 

databases in order to email to Defendant copies of employee lists and other confidential and 

proprietary information in violation of the Federal Computer Fraud and Abuse Act, 18 U.S.C. § 

1030, et seq. and the New Jersey Computer Related Offenses Act, N.J.S.A. 2A:38-1, et seq.

THE PARTIES

8. HOV is a Delaware corporation and parent of Lason India Private Ltd., successor 

in interest to Vetri Software India Ltd., an Indian corporation authorized to do business in the 

State of New Jersey as HOV, f/k/a Lason Systems, Inc. HOV maintains offices around the 

world, including in North America. Lason maintains an office in Chennai, India. 

9. Upon information and belief, Defendant CT is a corporation organized and 

existing under the laws of the State of Delaware with its principal place of business located at 

500 Frank W. Burr Boulevard, Suite 50, Teaneck, New Jersey 07666.

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10. Although not a named defendant herein, Arun S.P. (“Arun”) is a former member 

of Plaintiffs’ management group in Chennai, India and played an integral part in Defendant’s 

scheme to solicit HOV and/or Lason’s employees away from HOV and/or Lason to Defendant, 

its competitor, with the sole intention of causing an adverse impact on Plaintiffs. Arun had been 

employed with Plaintiffs for approximately six years and most recently as Deputy Senior 

Manager. 

11. Upon information and belief, Arun is currently employed by Defendant CT. 

JURISDICTION AND VENUE

12. This Court has jurisdiction pursuant to 28 U.S.C. § 1331 because of the claim 

asserted herein arising under the Federal Computer Fraud and Abuse Act, 18 U.S.C. § 1030, et

seq.

13. This Court can also exercise supplemental jurisdiction pursuant to 28 U.S.C. § 

1367(a) insofar as Plaintiffs’ state law claims derive from a common nucleus of operative facts 

as its federal law claims and form part of the same case or controversy. 

14. Venue is proper in this District pursuant to 28 U.S.C. § 1391(a)(1) because 

Defendant resides in and operates from its principal place of business in the State of New Jersey. 

FACTS COMMON TO ALL COUNTS

A. THE BUSINESS PROCESS OUTSOURCING INDUSTRY

15. Business process outsourcing involves the contracting of the operations and 

responsibilities of specific business functions or processes to a third-party service provider, 

which in many instances is located outside the country where the contracting company is 

headquartered. 

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16. Worldwide, business process outsourcing is a highly competitive, multi-billion 

dollar industry. 

17. In so far as business process outsourcing is a service based industry, the two most 

critical assets of any outsourcing company are its client relationships and its employees. 

18. Plaintiffs operate a business process outsourcing company that offers transaction 

management (e.g., accounts payable, accounts receivable management, payer/provider healthcare 

services), risk management (e.g., employee screening, construction services, collection 

management) and content management (e.g., document management) services to companies 

worldwide across key verticals such as financial, telecommunications, healthcare, insurance, 

construction, publishing, accounting and government. 

19. Defendant CT is a direct competitor of Plaintiffs providing similar global business 

process outsourcing services across various industries all over the world including banking and 

finance, communications and technology, energy and utilities, insurance, life sciences and 

manufacturing. 

B. DEFENDANT’S UNLAWFUL RAID OF HOV’S EMPLOYEES

20. Beginning in our about 2007, Defendant has instituted a clandestine operation to 

raid HOV and/or Lason’s employee bases in an effort to cripple Plaintiffs’ status as direct 

competitors and unfairly compete with Plaintiffs for the same client contracts. 

21. Upon information and belief, Defendant set its covert actions into motion by 

approaching Arun S.P. (“Arun”), a former member of Plaintiffs’ management group in Chennai, 

India. 

22. As a member of Plaintiffs’ Management Group, Arun had access to and utilized 

Plaintiffs’ proprietary and confidential information, including its database of customers and 

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identified prospects, customer contact information, specific transaction details, pricing 

information as well as detailed, client-specific personnel information. 

23. To protect Plaintiffs’ confidential business information, Plaintiffs required Arun, 

as a condition of his continued employment, to sign a Non-Disclosure, Proprietary and 

Confidential Information and Inventions Policy (“NDA”), dated January 30, 2003. A true and 

complete copy of Arun’s NDA is attached hereto as Exhibit A. 

24. In his NDA, Arun agreed to certain post-employment covenants which prohibited 

him from disclosing Plaintiffs’ confidential information, interfering with Plaintiffs’ business and 

interfering with or recruiting HOV and/or Lason employees or agents. 

25. After Arun terminated his employment with Plaintiffs in 2007 and joined 

Defendant, he immediately began a persistent and systematic effort to lure away Plaintiffs’ 

employees from its Chennai, India headquarters. 

26. Through Arun, Defendant approached other HOV and/or Lason employees with 

offers of employment to poach them away from Plaintiffs and offer them jobs with Defendant’s 

Chennai, India office. Defendant orchestrated these efforts in order to cripple Plaintiffs’ 

business on a global scale and to destroy Plaintiffs’ competitive advantage by systematically and 

wrongfully targeting and luring away key employees from Plaintiffs. 

27. By December 2008, Defendant, with Arun’s assistance and cooperation, had 

successfully targeted and hired approximately 17 senior-level employees from HOV and/or 

Lason - many of whom had also executed NDAs with Plaintiffs. 

28. In 2009, the execution of the raid continued as Defendant lured away an 

additional 21 employees from HOV and/or Lason, including both senior-level and support 

employees. 

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29. As a result of Defendant’s persistent and systematic raids, Lason sent a letter to 

Defendant’s human resource center, located in Chennai, India, on August 19, 2009, notifying 

Defendant that certain former Lason employees (and currently employed with Defendant) had 

been contacting Lason’s current employees to lure them away from Lason to join Defendant. 

Lason’s letter further instructed that Lason had previously contacted and addressed with 

Defendant its employee poaching practices and advised, at that time and again therein, that such 

activity was an unethical business practice. 

30. Ignoring the directive in Lason’s August 19, 2009 letter, upon and information 

and belief, Arun and other former Lason employees at the direction of Defendant continued to 

contact current Lason employees to induce them to join Defendant. 

C. DEFENDANT INTENSIFIES ITS ATTACK AND UNLAWFULLY OBTAINS PLAINTIFFS’

CONFIDENTIAL AND PROPRIETARY INFORMATION 

31. In June 2010, Defendant CT intensified its clandestine attacks on Plaintiffs and 

unlawfully obtained Plaintiffs’ confidential and proprietary information. 

32. Specifically, in or about June 2010, Defendant induced and directed then-current 

HOV and/or Lason employees to transfer, through Plaintiffs’ email system, to Defendant vital 

confidential and proprietary information concerning 450 HOV and/or Lason employees 

including their names, detailed salary and bonus compensation data, working days, per day 

targets, number of documents produced per month, production efficiencies and various customer 

project names (“Plaintiffs’ Employee Data”). 

33. Plaintiffs’ Employee Data is maintained exclusively on Plaintiffs’ computer 

systems and is not readily accessible by other parties, nor can it be obtained from other sources 

or duplicated. 

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34. Plaintiffs’ Employee Data is essential to the operation of Plaintiffs’ business and 

constitutes valuable trade secrets and confidential and proprietary information acquired by 

Plaintiffs at great time, effort and expense. 

35. Plaintiffs’ analysis and review of the integrity of their computer systems is 

ongoing and Plaintiffs are uncertain at this time if Defendant has also unlawfully obtained other 

confidential and proprietary information in addition to Plaintiffs’ Employee Data. 

36. Evidence of Defendant’s computer raid and misappropriation of Plaintiffs’ 

Employee Data was so evident that certain former Lason employees confessed to sending 

Plaintiffs’ confidential and proprietary information to Defendant and, as a result, their Lason 

employment was terminated. 

37. By these acts, Defendant wrongfully and maliciously obtained Plaintiffs’ 

Employee Date for the improper and unlawful purpose of continuing its efforts to target and lure 

away select HOV and/or Lason employees who were extensively trained by HOV and/or Lason, 

at considerable time, effort and expense.

38. Through November 2010, and acting through Arun and other former HOV and/or 

Lason employees, Defendant has approached and successfully lured away 43 employees, most of 

whom were senior-level employees, from Lason’s Chennai, India headquarters. 

39. Defendant’s raid against Plaintiffs is ongoing and Defendant continues to 

unlawfully possess Plaintiffs’ confidential and proprietary information. 

40. Specifically, as a result of the foregoing, on November 16, 2010, counsel for 

Plaintiffs sent a letter to Gordon Coburn, the Chief Financial Officer for CT, located in Teaneck, 

New Jersey, requesting, inter alia, that CT cease its unlawful raid against Plaintiffs and purge its 

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database (corporate and personal) of Plaintiffs’ confidential information. A copy of the aforesaid 

letter is attached hereto as Exhibit B. 

41. Notwithstanding Plaintiffs’ written and verbal requests to date, CT has not 

confirmed (a) that it has purged its corporate (or the offending CT employees’ personal) 

databases of Plaintiffs’ confidential data; or (b) that CT’s agents and employees have been 

instructed to cease using Plaintiffs’ confidential data to compete unlawfully with Plaintiffs 

including the unlawful solicitation of Plaintiffs’ employees. 

42. In fact, during the week of January 3, 2011, CT hired at least eight (8) more of 

Plaintiffs’ employees immediately after each employee completed training provided by 

Plaintiffs, at Plaintiffs’ considerable time, effort and expense. 

FIRST CAUSE OF ACTION

(Violation of Federal Computer Fraud and Abuse Act) 

18 U.S.C. § 1030, et seq.

43. Plaintiffs reallege and incorporate by reference Paragraphs 1 through 42 of the 

Amended Complaint as if set forth herein. 

44. Plaintiffs’ computers on which Plaintiffs’ Employee Data is maintained are used 

in both interstate and foreign commerce and therefore are protected as defined by 18 U.S.C. § 

1030, et seq. 

45. Defendant directed and induced HOV and/or Lason employees to access one or 

more protected computers in violation of 18 U.S.C. § 1030, et seq. and, as a result, Defendant 

obtained confidential and proprietary information belonging to Plaintiffs without authorization 

and by exceeding the authorization that HOV and/or Lason granted to their employees for the 

purpose of causing harm to Plaintiffs. 

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46. Defendant took such actions knowingly and with the intent to recklessly cause 

damage to Plaintiffs and for the sole purpose of obtaining a commercial advantage and/or 

financial gain. 

47. As a direct and proximate result of Defendant’s aforesaid conduct, Plaintiffs have 

sustained damage or loss of not less than $5,000.00, within the meaning of 18 U.S.C. § 1030. 

48. As a direct and proximate result of Defendant’s conduct, Defendant intended to 

wrongfully obtain, and in fact, did obtain something of value that belonged to Plaintiffs and that 

has value well in excess of $5,000.00. 

49. As a further direct and proximate result of Defendant’s aforesaid conduct, 

Plaintiffs have suffered and will continue to suffer substantial additional losses well in excess of 

$5,000.00, including but not limited to losses sustained in responding to Defendant’s actions, 

investigating Defendant’s actions and taking remedial steps to prevent Defendant’s further 

offenses. 

50. Defendant’s misappropriation of Plaintiffs’ valuable trade secrets and confidential 

and proprietary information and continued unfair competition has caused Plaintiffs damages in 

an amount which may not be determinable, and as a result Plaintiffs have suffered and continue 

to suffer irreparable harm in the loss of employees and damage to their business. 

51. To the extent that damages resulting from Defendant’s misappropriation of 

Plaintiffs’ valuable trade secrets and confidential and proprietary information and continued 

unfair competition are calculable, Plaintiffs seeks an award of such damages in an amount to be 

determined by the Court. 

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SECOND CAUSE OF ACTION

(Violation of New Jersey Computer Related Offenses Act) 

N.J.S.A. 2A:38-1, et seq.

52. Plaintiffs reallege and incorporate by reference Paragraphs 1 through 51 of the 

Amended Complaint as if set forth herein. 

53. HOV and Lason are both an “enterprise” as that term is used within the New 

Jersey Computer Related Offenses Act, N.J.S.A. 2A:38-1, et seq. (“the Act”). 

54. Defendant is an “actor” as that term is used within the Act. 

55. In violation of the Act, Defendant purposely or knowingly, and without 

authorization, accessed Plaintiffs’ computers without authorization, took all or a portion of 

Plaintiffs’ confidential and proprietary information, as more fully alleged above, and used the 

data to obtain a competitive advantage and compete unfairly with Plaintiffs. 

56. These violations of the Act have caused monetary and non-monetary harm to 

Plaintiffs.

57. Defendant’s misappropriation of Plaintiffs’ valuable trade secrets and confidential 

and proprietary information and continued unfair competition has caused Plaintiffs damages in 

an amount which may not be determinable, and as a result Plaintiffs have suffered and continue 

to suffer irreparable harm in the loss of employees and damage to their business. 

58. Accordingly, Plaintiffs are entitled to injunctive relief pursuant to Section 5 of the 

Act. 

59. To the extent that damages resulting from Defendant’s misappropriation of 

Plaintiffs’ valuable trade secrets and confidential and proprietary information and continued 

unfair competition are calculable, Plaintiffs seek an award of such damages in an amount to be 

determined by the Court. 

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THIRD CAUSE OF ACTION

(Unfair Competition) 

60. Plaintiffs reallege and incorporate by reference Paragraphs 1 through 59 of the 

Amended Complaint as if set forth herein. 

61. Defendant employed unlawful means to lure away HOV and/or Lason employees 

and used former senior-level and current HOV and/or Lason employees to assist Defendant CT 

in carrying out its unlawful corporate raid of Plaintiffs and illegal procurement of Plaintiffs’ 

valuable trade secrets and confidential and proprietary information. 

62. During their employment with HOV and/or Lason, Plaintiffs’ employees had 

access to vast amounts of proprietary and confidential information belonging exclusively to 

Plaintiffs, which information included valuable human resource information relating to 

confidential employee names, detailed salary and bonus compensation, working days, per day 

targets, number of documents produced per month, production efficiencies and various customer 

project names. 

63. That proprietary and confidential information was not known outside of Plaintiffs. 

Such information is of great value to Plaintiffs and would be of great value to Plaintiffs’ 

competitors. Plaintiffs went to great measures to protect that information. 

64. In order to protect its confidential and proprietary interests, Plaintiffs’ employees 

with access to Plaintiffs’ confidential information, including Arun, are required to execute NDAs 

which contain: (i) an express prohibition on the use or disclosure of any confidential or 

proprietary information either while employed or at any time thereafter; (ii) obligations of 

faithful and loyal service; and (iii) post-termination restrictive covenants (typically including a 

blanket prohibition on disclosing Plaintiffs’ confidential information). 

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65. At Defendant’s request and direction, Plaintiffs’ employees misappropriated and 

exploited Plaintiffs’ confidential and proprietary information by sharing it with Defendant to 

assist in its unlawful scheme to raid and destroy Plaintiffs’ business. Defendant knowingly 

obtained confidential and proprietary information with the intent to harm Plaintiffs by stealing its 

employees. 

66. Defendant’s wrongful and fraudulent use of Plaintiffs’ confidential and 

proprietary information constitutes unfair competition, which has damaged and continues to 

damage Plaintiffs. 

67. Defendant’s unfair competition is ongoing and, unless enjoined, Defendant will 

continue to cause irreparable harm and injury for which Plaintiffs may have no adequate remedy 

at law. 

68. To the extent that damages resulting from Defendant’s continued unfair 

competition are calculable, Plaintiffs’ seek an award of such damages in an amount to be 

determined by the Court. 

FOURTH CAUSE OF ACTION

(Misappropriation and Misuse of Confidential & Proprietary Business Information) 

69. Plaintiffs reallege and incorporate by reference Paragraphs 1 through 68 of the 

Amended Complaint as if set forth herein. 

70. Defendant possesses confidential information that belongs exclusively to 

Plaintiffs and which is crucial to the successful operation of Plaintiffs’ business including, but 

not limited to, proprietary information relating to employee names, detailed salary and bonus 

compensation, working days, per day targets, number of documents produced per month, 

production efficiencies and various customer project names – Plaintiffs’ Employee Data. 

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71. Defendant obtained Plaintiffs’ confidential information through its improper 

solicitation of Plaintiffs’ employees including inducing then-current HOV and/or Lason 

employees to transfer, through email, to Defendant vital confidential and proprietary information 

concerning 450 HOV and/or Lason employees including their names, detailed salary and bonus 

compensation data, working days, per day targets, number of documents produced per month, 

production efficiencies and various customer project names.

72. Upon information and belief, Defendant misappropriated Plaintiffs’ confidential 

and proprietary information by providing economic incentives and rewards to certain of 

Plaintiffs’ employees to breach their common law and contractual duties to Plaintiffs. 

73. Defendant’s misappropriation of Plaintiffs’ trade secrets and confidential and 

proprietary information is ongoing and, unless enjoined, Defendant will continue to cause 

irreparable harm and injury for which Plaintiffs may have no adequate remedy at law. 

74. To the extent that damages resulting from Defendant’s misappropriation of 

Plaintiffs’ valuable trade secrets and confidential and proprietary information and continued 

unfair competition are calculable, Plaintiffs seek an award of such damages in an amount to be 

determined by the Court. 

FIFTH CAUSE OF ACTION

(Conversion) 

75. Plaintiffs reallege and incorporate by reference Paragraphs 1 through 74 of the 

Amended Complaint as if set forth herein. 

76. Defendant has wrongfully retained and used for its own purpose Plaintiffs’ 

confidential and proprietary business information without the consent of Plaintiffs. 

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77. Said conversion by Defendant was committed maliciously and for the sole 

purpose of inflicting harm on its competitor, Plaintiffs, and/or to benefit itself at the expense of 

Plaintiffs. 

78. As a direct and proximate result of Defendant’s conversion of their confidential 

and proprietary business information, Plaintiffs have suffered damages. 

SIXTH CAUSE OF ACTION

(Tortious Interference) 

79. Plaintiffs reallege and incorporate by reference Paragraphs 1 through 78 of the 

Amended Complaint as if set forth herein. 

80. Defendant has intentionally, maliciously and with blatant disregard for the rights 

of Plaintiffs, encouraged and solicited the services of HOV’s and/or Lason’s current and former 

employees and others so that they would reveal the confidential, proprietary and other business 

information that was obtained by them during their relationship with Plaintiffs and assist in 

Defendant’s business endeavors by unfairly and unlawfully competing with Plaintiffs. 

81. Additionally, Defendant has knowingly and intentionally interfered with the 

contractual relationships between Plaintiffs and their employees. This interference has included, 

but is not limited to, soliciting and inducing Plaintiffs’ employees to wrongfully and maliciously 

obtain Plaintiffs’ Employee Date for the improper and unlawful purpose of continuing its efforts 

to target and lure away select Plaintiffs’ employees who were extensively trained by Plaintiffs, at 

considerable time effort and expense.

82. By reason of the foregoing, Defendant has tortiously interfered with the 

contractual relationships of Plaintiffs and the prospective economic advantage Plaintiffs would 

have derived from those relationships. 

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83. As a direct and proximate result of Defendant’s tortuous interference with the 

contractual relationships of Plaintiffs and the prospective economic advantage Plaintiffs would 

have derived from those relationships, Plaintiffs have suffered damages. 

SEVENTH CAUSE OF ACTION

(Raiding) 

84. Plaintiffs reallege and incorporate by reference Paragraphs 1 through 83 of the 

Amended Complaint as if set forth herein. 

85. Defendant has targeted Plaintiffs for the raiding and pirating of their employees 

and, upon information and belief, has plans to engage in a further campaign against Plaintiffs 

using the wrongful and improper conduct described above in order to recruit a large number of 

Plaintiffs’ workforce from Plaintiffs over to Defendant for the improper purpose of injuring 

Plaintiffs and/or to benefit Defendant at the expense of Plaintiffs. 

86. Defendant was at all times aware that its use of current HOV and/or Lason 

employees in its raids was improper and would cause them to breach a number of legal duties 

(both common law duties and contractual obligations) owed to Plaintiffs. 

87. Defendant’s conduct amounted to an unlawful corporate raid of Plaintiffs’ 

business operations and its actions were willful, wanton and malicious. Defendant’s unlawful 

actions were intended to cripple and perhaps destroy the competitive advantage of Plaintiffs– a 

direct competitor in the business process outsourcing industry. 

88. Defendant’s raiding activities are ongoing and, unless enjoined, Defendant will 

continue to cause irreparable harm and injury for which Plaintiffs may have no adequate remedy 

at law. 

89. To the extent that damages resulting from Defendant’s unlawful raiding are 

calculable, Plaintiffs seek an award of such damages in an amount to be determined by the Court. 

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PRAYER FOR RELIEF

WHEREFORE, HOV Services, Inc. and Lason India Private Ltd., successor in interest 

to Vetri Software India Ltd., hereby demand judgment against Cognizant Technology Solutions 

Corporation for: 

A. The issuance of an Order enjoining Cognizant Technology Solutions Corporation 

as well as all persons and entities acting in concert or participation with it, from engaging in the 

systematic poaching of employees and misappropriation of Plaintiffs’ confidential and 

proprietary information and commanding it to return any and all databases, documents or lists in 

its possession or control that contain confidential and proprietary business information 

concerning the activities, personnel or affairs of HOV Services, Inc. and/or Lason India Private 

Ltd.; 

 B. An award of damages, in an amount to be determined at trial, incurred by HOV 

Services, Inc. and/or Lason India Private Ltd. as a result of Cognizant Technology Solutions 

Corporation’s unlawful actions; 

 C. Punitive damages against Cognizant Technology Solutions Corporation for its 

willful and malicious conduct; 

 D. An accounting and disgorgement of any profits earned by Cognizant Technology 

Solutions Corporation as a result of its unlawful actions; 

 E. All costs and disbursements, including reasonable attorneys’ fees and expenses, 

prejudgment interest and all other sums provided for under the law; and 

 F. Such other and further relief as this Court may deem just and proper. 

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JURY DEMAND

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure and Local Civil Rule 38.1, 

Plaintiffs HOV Services, Inc. and Lason India Private Ltd., successor in interest to Vetri 

Software India Ltd., hereby demand a trial by jury upon each of the causes of action so triable. 

Respectfully submitted, 

/s/ John P. Leonard______ 

 John P. Leonard, Esq. 

 McElroy, Deutsch, Mulvaney & Carpenter, LLP 

1300 Mount Kemble Ave. 

P.O. Box 2075 

Morristown, New Jersey 07962-2075 

Tel: (973) 993-8100 

Fax: (973) 425-0161 

Email: Jleonard@mdmc-law.com 

Date: January 13, 2012 

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