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MIND C.T.I. Ltd.

mndo · NASDAQ Technology
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Ticker mndo
Exchange NASDAQ
Sector Technology
Industry Software - Application
Employees 201-500
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FY2019 Annual Report · MIND C.T.I. Ltd.
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UNITED STATES 
SECURITIES AND EXCHANGE COMMISSION 
WASHINGTON, D.C.  20549 

FORM 20–F 

REGISTRATION STATEMENT PURSUANT TO SECTION 12(b) OR 12(g) OF THE 
SECURITIES EXCHANGE ACT OF 1934 

OR 

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES 
EXCHANGE ACT OF 1934 

For the fiscal year ended December 31, 2019  

OR 

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE 
SECURITIES EXCHANGE ACT OF 1934 

For the transition period from  

 to  

OR  

SHELL COMPANY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE 
SECURITIES EXCHANGE ACT OF 1934  

Date of event requiring this shell company report _____________  

Commission file number 000-31215  

MIND C.T.I. LTD. 
(Exact name of Registrant as specified in its charter 
and translation of Registrant’s name into English) 

ISRAEL 
(Jurisdiction of incorporation or organization) 

2 HaCarmel Street, Yoqneam, 2069202, Israel 
(Address of principal executive offices) 

 Shoham Shitrit 
c/o MIND C.T.I. Ltd. 

2 HaCarmel  Street 
Yoqneam, 2069202, Israel 
Tel:  +972-4-9936666 
investor@mindcti.com 
(Name, Telephone, E-mail and/or Facsimile number and Address of Company Contact Person) 

Securities registered or to be registered pursuant to Section 12(b) of the Act. 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
Title of each class 
Ordinary Shares,  
nominal value NIS 0.01 per share                             Nasdaq Global Market 

                        Name of each exchange on which registered 

Securities registered or to be registered pursuant to Section 12(g) of the Act. 

Securities for which there is a reporting obligation pursuant to Section 15(d) of the Act. 

None 
(Title of Class) 

None 
(Title of Class) 

Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as 
of the close of the period covered by the annual report. 

As of December 31, 2019, the Registrant had outstanding 19,896,326 Ordinary Shares, nominal value 
NIS 0.01 per share. 

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the 
Securities Act. 

Yes   No 

If this report is an annual or transition report, indicate by check mark if the registrant is not required to 
file reports pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934.   Yes   No 

Indicate by check mark whether the Registrant (1) has filed all reports required to be filed by Section 
13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such 
shorter period that the Registrant was required to file such reports), and (2) has been subject to such 
filing requirements for the past 90 days. 

Yes      No 

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate 
Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 
of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter 
  Yes  No 
period that the registrant was required to submit and post such files). 

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-
accelerated filer or an emerging growth company. See definition of “large accelerated filer,” 
“accelerated filer,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.  
Large accelerated filer 

 Emerging growth company 

 Non-accelerated filer 

 Accelerated filer 

If an emerging growth company that prepares its financial statements in accordance with U.S. GAAP, 
indicate by check mark if the registrant has elected not to use the extended transition period for 
complying with any new or revised financial accounting standards provided pursuant to Section 13(a) 
of the Exchange Act  

2 

 
 
 
  
 
 
 
 
The term “new or revised financial accounting standard” refers to any update issued by the Financial 
Accounting Standards Board to its Accounting Standards Codification after April 5, 2012. 

Indicate by check mark which basis of accounting the registrant has used to prepare the financial 
statements included in this filing: 
U.S. GAAP 

Other  

 International Financial Reporting Standards as issued 
by the International Accounting Standards Board 

If “Other” has been checked in response to the previous question, indicate by check mark which 
financial statement item the registrant has elected to follow. Item 17

   Item 18

If this is an annual report, indicate by check mark whether the registrant is a shell company (as defined 
in Rule 12b-2 of the Exchange Act). 

 Yes 

  No 

Unless the context requires otherwise, “MIND”, “us”, “we”, “our company”, “the company”, 

“the Company” and “our” refer to MIND C.T.I. Ltd. and its subsidiaries. 

FORWARD LOOKING STATEMENTS  

Statements in this Annual Report concerning our business outlook or future economic 
performance; anticipated revenues, expenses or other financial items; introductions and advancements 
in development of products, and plans and objectives related thereto; and statements concerning 
assumptions made or expectations as to any future events, conditions, performance or other matters, are 
“forward-looking statements” as that term is defined under the United States Federal Securities Laws. 
Forward-looking statements are subject to risks, uncertainties and other factors, which could cause 
actual results to differ materially from those stated in such statements. Factors that could cause or 
contribute to such differences include, but are not limited to, those set forth under “Risk Factors” in this 
Annual Report as well as those discussed elsewhere in this Annual Report and in our other filings with 
the Securities and Exchange Commission. 

PART I 

Item 1. 

Identity of Directors, Senior Management and Advisers 

Not applicable. 

Item 2. 

Offer Statistics and Expected Timetable 

Not applicable. 

Item 3. 

Key Information 

A. 

Selected Financial Data 

3 

 
 
 
 
 
 
 
 
 
 
 
 
Except as otherwise indicated, all financial statements and other financial information included 

in this annual report are presented solely under U.S. GAAP. 

The following table presents selected consolidated financial data as of and for each of the five 

years in the period ended December 31, 2019. The selected consolidated financial data presented below 
are derived from our audited consolidated financial statements for these periods and should be read in 
conjunction with these financial statements and the related notes thereto. Our audited consolidated 
balance sheets as of December 31, 2018 and 2019 and our audited consolidated statements of 
operations and cash flows for each of the three years ended December 31, 2019 and the related notes 
thereto are included elsewhere in this annual report. You should read the selected financial data in 
conjunction with Item 5 “Operating and Financial Review and Prospects.” 

2015 

Years Ended December 31, 
2018 

2017 

2016 

2019 

Consolidated Statements of 
Operations Data: 
Total revenues ...........................  
Gross profit ................................  
Operating income …….……… 
Financial income (expenses) – 

(dollars in thousands, except share and per share data) 

$ 20,928  $ 18,052 
11,221 
5,206 

12,298 
6,416 

$ 18,062 
11,029 
4,686 

$ 18,135 
11,989 
5,350 

$ 22,664 
12,538 
5,040 

net ...........................................  

(114) 

166 

630 

222 

483 

Net income …….…………….. 
Earnings per ordinary share: 

Basic .......................................  
………………………………
.. 
Diluted ....................................   
Weighted average number of 
ordinary shares used in 
computation of earnings per 
ordinary share – in 
thousands: 
Basic .......................................  
Diluted ....................................  

Consolidated Balance Sheet 
Data: 
Cash and cash equivalents .........  

$   5,018  $   4,203 

$   5,612 

$   5,134 

$ 5,065 

$ 0.26 

$ 0.22 

$ 0.29 

$ 0.27 

$ 0.26 

$ 0.26 

$ 0.22 

$ 0.29 

$ 0.27 

$ 0.25 

19,183 
19,283 

19,234 
19,307 

19,292 
19,559 

19,344 
19,561 

19,746 
19,962 

2015 

2016 

2018 

2019 

As of December 31, 
2017 
(dollars in thousands) 

$ 11,475 

$ 9,165 

$ 5,014 

$ 2,739 

$ 6,479 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Short-term and long-term bank 
deposits and marketable 
securities ....................................  

Working capital .........................  
Total assets................................. 
Share capital and additional 
paid-in capital ............................  
Treasury shares……………….. 
Total shareholders’ equity .........  

8,090 

10,649 

12,625 

13,269 

8,840 

14,734 
30,225 

15,217 
29,000 

14,921 
27,378 

15,272 
25,978 

12,779 
31,095 

25,916 
(1,692) 
$21,848 

26,052 
(1,607) 
$21,285 

26,234 
(1,554) 
$21,022 

26,458 
(1,515) 
$20,982 

27,104 
(1,204) 
$21,936 

B. 

Capitalization and Indebtedness 

Not applicable. 

C. 

Reasons for the Offer and Use of Proceeds  

Not applicable. 

D. 

Risk Factors 

We believe that the occurrence of any one or some combination of the following factors would 

have a material adverse effect on our business, financial condition and results of operations. 

Risks Relating to our Business and Industry  

If we are unable to compete effectively in the marketplace, we may suffer a decrease in market 
share, revenues and profitability. 

All the markets we operate in are significantly fragmented and highly competitive. The 

principal competitive factors in our market include completeness of offering, global reach, ease of 
integration, product features, platform scalability, reliability, security and performance, brand 
awareness and reputation, the strength of sales and marketing efforts, customer support, as well as the 
cost of deploying and using our products. 

Some of our competitors are larger and have greater name recognition, longer operating 

histories, more established customer relationships, larger budgets and significantly greater resources 
than we do. In addition, they have the operating flexibility to bundle competing products and services 
at little or no perceived incremental cost, including offering them at a lower price as part of a larger 
sales transaction. As a result, our competitors may be able to respond more quickly and effectively than 
we can to new or changing opportunities, technologies, standards or customer requirements. In 
addition, some competitors may offer products or services that address one or a limited number of 
functions at lower prices, with greater depth than our products or in different geographies. Our current 
and potential competitors may develop and market new products and services with comparable 
functionality to our products, and this could lead to us having to decrease prices in order to remain 
competitive. Customers utilize our products in many ways and use varying levels of functionality that 
our products offer or are capable of supporting or enabling within their applications. Customers that use 
many of the features of our products or use our products to support or enable core functionality for their 

5 

 
 
 
 
 
 
 
 
 
applications may have difficulty or find it impractical to replace our products with a competitor's 
products or services, while customers that use only limited functionality may be able to more easily 
replace our products with competitive offerings. Our customers also may choose to build some of the 
functionality our products provide, which may limit or eliminate their demand for our products. 

With the introduction of new products and services and new market entrants, we expect 
competition to intensify in the future. Moreover, as we expand the scope of our products, we may face 
additional competition. If one or more of our competitors were to merge or partner with another of our 
competitors, the change in the competitive landscape could also adversely affect our ability to compete 
effectively. In addition, some of our competitors have lower list prices than ours, which may be 
attractive to certain customers even if those products have different or lesser functionality. If we are 
unable to maintain our current pricing due to competitive pressures, our margins will be reduced and 
our business, results of operations and financial condition would be adversely affected. In addition, 
pricing pressures and increased competition generally could result in reduced revenue, reduced 
margins, increased losses or the failure of our products to achieve or maintain widespread market 
acceptance, any of which could harm our business, results of operations and financial condition. 

Our backlog, revenues and operating results may vary significantly from quarter to quarter.  

Our results of operations, including the levels of our revenues, cost of revenues, gross margins 

and operating expenses, have fluctuated from quarter to quarter in the past and may continue to vary 
significantly in the future. These fluctuations are a result of a variety of factors, many of which are 
outside of our control, may be difficult to predict and may or may not fully reflect the underlying 
performance of our business. Our operating results may vary significantly from quarter to quarter due 
to a number of factors, including the following: 

•  our ability to retain and increase revenue from existing customers and attract new 

customers;  

•  our ability to introduce new products and enhance existing products;  

•  competition and the actions of our competitors, including pricing changes and the 

introduction of new products, services and geographies;  

•  changes in network service provider fees that we pay in connection with the delivery of 

communication services on our messaging platforms;  

• 

reductions in pricing as a result of negotiations with our larger customers;  

•  change in the mix of products that our customers use;  

•  changes in laws, regulations or regulatory enforcement that impact our ability to market, 

sell or deliver our products;  

• 

the amount and timing of operating costs and capital expenditures related to the 
operations and expansion of our business, including investments in our international 
expansion;  

6 

 
 
•  significant security breaches of, technical difficulties with, or interruptions to, the 

delivery and use of our products on our platform;  

•  general economic conditions that may adversely affect a prospective customer's ability 
or willingness to adopt our products, delay a prospective customer's adoption decision, 
reduce the revenue that we generate from the use of our products or affect customer 
retention;  

•  changes in foreign currency exchange rates;  

•  sales tax and other tax determinations by authorities in the jurisdictions in which we 

conduct business;  

• 

the impact of new accounting pronouncements;  

•  expenses in connection with mergers, acquisitions or other strategic transactions; 

• 

the ability of our customers to expand their operations and increase their subscriber 
base, including their ability to obtain financing; 

•  potential termination of contracts by our customers due to lack of financing, internal 

changes, consolidation, competition or any other reason; and 

•  changes in our pricing policies. 

Due to all of the foregoing, we cannot predict revenues for any future quarter with any significant 
degree of accuracy. Accordingly, we believe that period-to-period comparisons of our operating results 
are not necessarily meaningful, and you should not rely upon them as indications of future 
performance. Accordingly, in the event of a revenue shortfall, we may not be able to mitigate the 
negative impact on our income (loss) and margins in the short term. If we fail to meet or exceed the 
expectations of investors, we could face costly lawsuits, including securities class action suits. 

In future quarters, our operating results may be below the expectations of public market 

analysts and investors, and as a result, the price of our ordinary shares may fall.  

We seek to expand our business through acquisitions, which could result in diversion of resources 
and extra expenses and which may involve other risks that could disrupt our business and harm 
our financial condition.  

It is part of our strategy to pursue acquisitions of business, products and technologies, or the 
establishment of joint venture arrangements in order to offer new products or services or otherwise 
enhance our market position or strategic strengths, and we are actively evaluating potential acquisition 
opportunities. The negotiation of potential acquisitions or joint ventures, as well as the integration of an 
acquired or jointly developed business, technology or product, could cause diversion of management’s 
attention from the day-to-day operation of our business. This could impair our relationships with our 
employees, customers, distributors, resellers and marketing allies. Future acquisitions could result in:  

•  potentially dilutive issuances of equity securities; 

7 

 
 
 
• 

the incurrence of debt and contingent liabilities;  

•  amortization of intangible assets; 

•  changes in our business model and margins; 

•  a strain in our ability to maintain reliable service levels for our customers; 

• 

research and development write-offs; and  

•  other acquisition-related expenses. 

In addition, we have limited experience with respect to negotiating an acquisition and operating 

an acquired business. Due to the multiple risks and difficulties associated with any acquisition, there 
can be no assurance that we will be successful in achieving our expected strategic, operating and 
financial goals for any such acquisition. If future acquisitions disrupt our operations, our business may 
suffer. 

We may not be successful in the integration of our acquisitions. 

We cannot assure you that we have identified, or will be able to identify, all material adverse 
issues related to the integration of our acquisitions, such as significant defects in the internal control 
policies of companies that we have acquired. In addition, our acquisitions could lead to difficulties in 
integrating acquired personnel and operations and in retaining and motivating key personnel from these 
businesses, while maintaining our corporate culture. In some instances, we may need to depend on the 
seller of an acquired business to provide us with certain transition services in order to meet the needs of 
our customers. Any failure to properly integrate and retain personnel, to recognize significant defects in 
the internal control policies of acquired companies  or to scale and adapt our internal control policies 
and our reporting systems and procedures, and any interruptions of transition services, may require a 
significant amount of time and resources to address and may harm our company.  

If we do not continually enhance our products and service offerings, introduce new products and 
features and adopt and monetize new technologies and methodologies in the marketplace, we 
may have difficulty retaining existing customers and attracting new customers.  

We believe that our future success will depend, to a significant extent, upon our ability to 

enhance our existing products and services, to introduce new products, services and features to meet 
the requirements of our customers, and to adopt to and leverage new technologies and methodologies 
such as cloud, microservices-based architecture, in a rapidly developing and evolving market. We 
devote significant resources to refining and expanding our base software modules and to developing 
our products, services and development methodologies and tools. In some instances, we rely on 
cooperative relationships with third parties to assist us in delivering certain products and services to our 
customers. Our present or future products, services and technology may not satisfy the evolving needs 
of the communications industry or of other industries that we serve. If we are unable to anticipate or 
respond adequately to such needs, due to resource, technological or other constraints, our business and 
results of operations could be harmed. 

8 

 
 
Our success depends on our ability to continually develop and market new and more 
technologically advanced products and enhancements.  

The market for our products and the services is characterized by: 

• 

rapid technological advances like the development of new standards for communications 
protocols; 

•  numerous introductions of new service providers, technological suppliers and other 

competitors; and 

•  changing customer needs. 

We believe that our future success will largely depend upon our ability to continue to enhance 

our existing products and successfully develop and market new products on a cost-effective and timely 
basis. We cannot assure you that we will be successful in developing and marketing new products that 
respond adequately to technological change. Our failure to do so would have a material adverse effect 
on our ability to market our own products.  

If our security measures for our software, hardware, services or cloud offerings are compromised 
and as a result, our data, our customers’ data or our IT systems are accessed improperly, made 
unavailable, or improperly modified, our products and services may be perceived as vulnerable, 
which may materially affect our business and result in potential legal liability. 

Our products and services, including our cloud offerings, store, retrieve, and manage our 
customers’ information and data, as well as our own data. We have a reputation for secure and reliable 
product offerings and related services, and we have invested a great deal of time and resources in 
protecting the integrity and security of our products, services and the internal and external data that we 
manage. Despite our efforts to implement network security measures, we cannot guarantee that our 
systems are fully protected from vulnerabilities related to IT-related viruses, worms and other 
malicious software programs, attacks, break-ins and similar disruptions from unauthorized tampering 
by computer hackers and others. Such cybersecurity incident could include an attempt to gain 
unauthorized access to digital systems for purposes of misappropriating assets or sensitive information, 
corrupting data, or causing operational disruption. Security measures in our products and services may 
be penetrated or bypassed by computer hackers and others who may gain unauthorized access to our or 
our customers’ or partners’ software, hardware, cloud offerings, networks, data or systems. They may 
use a wide variety of methods, which may include developing and deploying malicious software to 
attack our products third-party data, products or services incorporated into our own. Data may also be 
accessed or modified improperly as a result of customer, partner or employee error or malfeasance and 
third parties may attempt to fraudulently induce customers, partners, employees or suppliers into 
disclosing sensitive information such as user names, passwords or other information in order to gain 
access to our data or IT systems or our customers’ or partners’ data or IT systems. Any of the foregoing 
occurrences could create system disruptions and cause shutdowns or denials of service or compromise 
data, including personal or confidential information, of us, our partners or our customers. 

If a cyber-attack or other security incident (for example phishing, advanced persistent threats, or 

social engineering) were to result in unauthorized access to, or deletion of, and/or modification and/or 
exfiltration of our customers’ data, other external data or our own data or our IT systems or if the 
services we provide to our customers were disrupted, customers could lose confidence in the security 

9 

 
 
and reliability of our products and services, including our cloud offerings, and perceive them not to be 
secure. This in turn could lead to fewer customers using our products and services and result in reduced 
revenue and earnings. The costs we would incur to address and fix these security incidents would 
increase our expenses. These risks will increase as we continue to grow our cloud and network 
offerings and store and process increasingly large amounts of data, including personal information and 
our customers’ confidential information and data and other external data, and host or manage parts of 
our customers’ businesses in cloud-based IT environments.  

Any of the events described above could cause our customers to make claims against us for 

damages allegedly resulting from a security breach or service disruption, which could adversely affect 
our business, results of operation and financial condition. 

Our products and platform and our business are subject to a variety of European and 
international laws and regulations, including those regarding privacy, data protection and 
information security, and our customers may be subject to regulations related to the handling 
and transfer of certain types of sensitive and confidential information. Any failure of our 
products to comply with or enable our customers and channel partners to comply with applicable 
laws and regulations would harm our business, results of operations and financial condition. 

We and our customers that use our products may be subject to privacy and data protection-

related laws and regulations that impose obligations in connection with the collection, processing and 
use of personal data, financial data, health or other similar data. The U.S. federal and various state and 
foreign governments have adopted or proposed limitations on, or requirements regarding, the 
collection, distribution, use, security and storage of personally identifiable information of individuals. 
The U.S. Federal Trade Commission and numerous state attorneys general are applying federal and 
state consumer protection laws to impose standards on the online collection, use and dissemination of 
data, and to the security measures applied to such data. 

Similarly, many foreign countries and governmental bodies, including the European Union 

("EU") member states, have laws and regulations concerning the collection and use of personally 
identifiable information obtained from individuals located in the EU or by businesses operating within 
their jurisdiction, which are often more restrictive than those in the United States. Laws and regulations 
in these jurisdictions apply broadly to the collection, use, storage, disclosure and security of personally 
identifiable information that identifies or may be used to identify an individual, such as names, 
telephone numbers, email addresses and, in some jurisdictions, IP addresses and other online 
identifiers. 

For example, the General Data Protection Regulation ("GDPR") took effect in the European 

Union on May 25, 2018. The GDPR enhances data protection obligations for businesses and requires 
service providers (data processors) processing personal data on behalf of customers to cooperate with 
European data protection authorities, implement security measures and keep records of personal data 
processing activities. Noncompliance with the GDPR can trigger fines equal to or greater of €20 
million or 4% of global annual revenues. There are also additional EU laws and regulations (and 
member states implementations thereof) which govern the protection of consumers and of electronic 
communications. If our efforts to comply with GDPR or other applicable EU laws and regulations are 
not successful, we may be subject to penalties and fines that would adversely impact our business and 
results of operations, and our ability to conduct business in the EU could be significantly impaired. 

10 

 
 
As well, we continue to see jurisdictions imposing data localization laws, which require 
personal information, or certain subcategories of personal information to be stored in the jurisdiction of 
origin. These regulations may inhibit our ability to expand into those markets or prohibit us from 
continuing to offer services in those markets without significant additional costs. 

The uncertainty and changes in the requirements of multiple jurisdictions may increase the cost 

of compliance, delay or reduce demand for our services, restrict our ability to offer services in certain 
locations, impact our customers' ability to deploy our solutions in certain jurisdictions, or subject us to 
sanctions, by national data protection regulators, all of which could harm our business, financial 
condition and results of operations. 

Additionally, although we endeavor to have our products and platform comply with applicable 

laws and regulations, these and other obligations may be modified, they may be interpreted and applied 
in an inconsistent manner from one jurisdiction to another, and they may conflict with one another, 
other regulatory requirements, contractual commitments or our internal practices. 

We also may be bound by contractual obligations relating to our collection, use and disclosure 
of personal, financial and other data or may find it necessary or desirable to join industry or other self-
regulatory bodies or other privacy or data protection-related organizations that require compliance with 
their rules pertaining to privacy and data protection. 

We expect that there will continue to be new proposed laws, rules of self-regulatory bodies, 

regulations and industry standards concerning privacy, data protection and information security in the 
United States, the European Union and other jurisdictions, and we cannot yet determine the impact 
such future laws, rules, regulations and standards may have on our business. Moreover, existing U.S. 
federal and various state and foreign privacy and data protection-related laws and regulations are 
evolving and subject to potentially differing interpretations, and various legislative and regulatory 
bodies may expand current or enact new laws and regulations regarding privacy and data protection-
related matters. Because global laws, regulations and industry standards concerning privacy and data 
security have continued to develop and evolve rapidly, it is possible that we or our products or platform 
may not be, or may not have been, compliant with each such applicable law, regulation and industry 
standard and compliance with such new laws or to changes to existing laws may impact our business 
and practices, require us to expend significant resources to adapt to these changes, or to stop offering 
our products in certain countries. These developments could adversely affect our business, results of 
operations and financial condition. 

Any failure or perceived failure by us, our products or our platform to comply with new or 

existing U.S., EU or other foreign privacy or data security laws, regulations, policies, industry 
standards or legal obligations, or any security incident that results in the unauthorized access to, or 
acquisition, release or transfer of, personally identifiable information or other customer data may result 
in governmental investigations, inquiries, enforcement actions and prosecutions, private litigation, fines 
and penalties, adverse publicity or potential loss of business.  

If we fail to attract and retain qualified personnel, we will not be able to implement our business 
strategy or operate our business effectively. 

Our products require sophisticated software development, sales, professional services and 
technical customer support. Our success depends on our ability to attract, train, motivate and especially 

11 

 
 
retain highly skilled personnel within each of these areas of expertise. Qualified personnel in these 
areas are in great demand worldwide and are likely to remain a limited resource. We cannot assure you 
that we will be able to retain the skilled employees we require. In addition, the resources required to 
retain such personnel may adversely affect our operating margins. The failure to retain qualified 
personnel may harm our business.  In particular, we maintain a large engineering and support center in 
Iasi, Romania and have encountered many successful attempts from other technology companies to 
recruit our employees after we have trained them. If this phenomenon continues and increases, we may 
not be able to retain the highly skilled personnel and may be forced to significantly raise the salaries of 
our Romanian employees and our results of operations will be consequently harmed. 

Because our revenues are generated in numerous countries, our results of operations could suffer 
if we are unable to manage international operations effectively. 

Our sales are made in many countries, with different legislation and complex taxation rules and 

in many states in the United States. Managing our existing international operations and additional 
international markets requires significant management attention and financial resources. Our ability to 
penetrate some international markets may be limited due to different technical standards, protocols and 
requirements for our products in different markets. In addition, conducting our business internationally 
subjects us to a number of risks, including: 

• 

the burden of compliance with a wide variety of foreign laws and regulations;  

•  staffing and managing foreign operations; 

• 

increased risk of collection;  

•  potentially adverse tax consequences; 

•  burdens that may be imposed by tariffs and other trade barriers; and 

•  adverse effects of political and economic instability.  

We currently benefit from local tax benefits that may be discontinued or reduced.  

We have derived benefits from various programs, including Israeli tax benefits relating to our 

“Approved and Preferred Enterprise” programs, and starting in 2017, we have derived benefits relating 
to the “Preferred Technological Enterprise” program under the Israel Law for the Encouragement of 
Capital Investment, 1959. 

To be eligible for tax benefits as a “Preferred Technological Enterprise,” we must continue to 

meet certain conditions. Should it be determined that our Preferred Technological Enterprise programs 
have not met, or do not meet, the statutory conditions, our income taxes will increase.  

Additional tax liabilities could materially adversely affect our results of operations and financial 
condition.  

As a global corporation, we are subject to income and other taxes both in Israel and in various 

foreign jurisdictions. Our domestic and international tax liabilities are subject to the allocation of 
revenues and expenses in different jurisdictions and the timing of recognizing revenues and expenses. 

12 

 
 
Additionally, the amount of income taxes paid or accrued is subject to our interpretation of applicable 
laws in the jurisdictions in which we do business. From time to time, we are subject to income and 
other tax audits in various jurisdictions, the timings of which are unpredictable. While we believe we 
comply with applicable tax laws, there can be no assurance that a governing tax authority will not have 
a different interpretation of the law and assess us with additional taxes. Should we be assessed 
additional taxes, there could be a material adverse effect on our results of operations and financial 
condition.  

Our business may be negatively affected by exchange rate fluctuations.  

Although the majority of our revenues are denominated in U.S. dollars, or dollars, or $, 

approximately 19% of our expenses are incurred in New Israeli Shekel, or NIS, and approximately 
62% of our expenses are denominated in Euro or linked to the Euro. As a result, we may be negatively 
affected by fluctuations in the exchange rates between the Euro or the NIS and the dollar. We cannot 
predict any future trends in the rate of devaluation or appreciation of the NIS or of the Euro against the 
dollar. If the dollar cost of our operations in Israel and/or Romania increases, our dollar-measured 
results of operations will be adversely affected. In addition, some of our revenues are denominated in 
Euro, some are denominated in Canadian dollar, or CAD and some are denominated in Great Britain 
Pound, or GBP. As a result, our dollar-measured results of operations will be adversely affected by 
devaluation in the GBP, CAD or Euro relative to the dollar. We may choose to limit these exposures by 
entering into hedging transactions. However, hedging transactions may not enable us to avoid 
exchange-related losses, and our business may be harmed by exchange rate fluctuations.  

We depend on a limited number of key personnel who would be difficult to replace. If we lose the 
services of these individuals, our business may be harmed. 

Because our markets are constantly changing, the success of our business depends in large part 

upon the continuing contributions of our senior management. Specifically, continued growth and 
success largely depend on the managerial and technical skills of our founder, President and Chief 
Executive Officer, Ms. Monica Iancu, and other members of our senior management. Because the 
demand for highly qualified senior personnel exceeds the supply of this type of personnel, it will be 
difficult to replace members of our management if one or more of them were to leave us. If either Ms. 
Iancu or other members of the senior management team are unable or unwilling to continue their 
employment with us, our business may be harmed. 

If we are unable to adequately protect our intellectual property or become subject to a claim of 
infringement, our business may be materially adversely affected. 

Our success and ability to compete depend substantially upon our internally developed or 

acquired technology. Any misappropriation of our technology could seriously harm our business. In 
order to protect our technology and products, we rely on a combination of trade secret, copyright and 
trademark law. Despite our efforts to protect our intellectual property rights, unauthorized parties may 
attempt to copy or otherwise obtain and use our software or technology or to develop software with the 
same functionality. Policing unauthorized use of our products is difficult and we cannot be certain that 
the steps we have taken will prevent misappropriation, particularly in foreign countries where the laws 
may not protect our intellectual property rights as fully as in the United States. 

If anyone asserts a claim against us relating to proprietary technology or information, we might 
seek to license his intellectual property or to develop non-infringing technology. We might not be able 

13 

 
 
to obtain a license on commercially reasonable terms or on any terms. Alternatively, our efforts to 
develop non-infringing technology could be unsuccessful. Our failure to obtain the necessary licenses 
or other right or to develop non-infringing technology could prevent us from selling our software and 
could therefore seriously harm our business. 

We use certain "open source" software tools that may be subject to intellectual property 
infringement claims or that may subject our derivative works or products to unintended 
consequences, possibly impairing our product development plans, interfering with our ability to 
support our clients or requiring us to allow access to the source code of our products or 
necessitating that we pay licensing fees.  

Certain of our products contain open source code and we may use more open source code in the 

future. In addition, certain third-party software that we embed in our products contains open source 
code. Open source code is code that is covered by a license agreement that permits the user to liberally 
use, copy, modify and distribute the software without cost, provided that users and modifiers abide by 
certain licensing requirements. The original developers of the open source code provide no warranties 
on such code.  

As a result of the use of open source software, we could be subject to suits by parties claiming 

ownership of what they believe to be their proprietary code or we may incur expenses in defending 
claims alleging non-compliance with certain open source code license terms. In addition, third-party 
licensors do not provide intellectual property protection with respect to the open source components of 
their products, and we may be unable to be indemnified by such third-party licensors in the event that 
we or our customers are held liable in respect of the open source software contained in such third-party 
software. If we are not successful in defending against any such claims that may arise, we may be 
subject to injunctions and/or monetary damages or be required to remove the open source code from 
our products. Such events could disrupt our operations and the sales of our products, which would 
negatively impact our revenues and cash flow.  

Moreover, under certain conditions, the use of open source code to create derivative code may 

obligate us to make the resulting derivative code available to others at no cost. The circumstances 
under which our use of open source code would compel us to offer derivative code at no cost are 
subject to varying interpretations. If we are required to publicly disclose the source code for such 
derivative products or to license our derivative products that use an open source license, our previously 
proprietary software products may be available to others without charge. If this happens, our customers 
and our competitors may have access to our products without cost to them, which could harm our 
business. Certain open source licenses require as a condition to use, modification or distribution of such 
open source that proprietary software incorporated into, derived from or distributed with such open 
source be disclosed or distributed in source code form, be licensed for the purpose of making derivative 
works or be redistributable at no charge. The foregoing may under certain conditions be interpreted to 
apply to our software, depending upon the use of the open source and the interpretation of the 
applicable open source licenses. 

We monitor our use of open source code to avoid subjecting our products to conditions we do 

not intend. The use of open source code, however, may ultimately subject some of our products to 
unintended conditions so that we are required to take remedial action that may divert resources away 
from our development efforts. 

14 

 
 
We are subject to ongoing costs and risks associated with being a public company, including 
potential lawsuits. 

As an Israeli company subject to U.S. federal securities laws, we spend a significant amount of 

management time and resources to comply with laws, regulations and standards relating to corporate 
governance and public disclosure, including the Sarbanes-Oxley Act of 2002, SEC regulations, Nasdaq 
listing rules and the Israeli Companies Law, 1999 (the “Companies Law”, or the “Israeli Companies 
Law”).  In connection with our compliance with Section 404 and the other applicable provisions of the 
Sarbanes-Oxley Act of 2002, our management and other personnel devote a substantial amount of time 
to assure that we continue to comply with these requirements. There is no guarantee that these efforts 
will result in management assurance that our internal control over financial reporting is adequate in 
future periods.  If our internal controls are found to be ineffective in future periods, it could harm our 
operations, financial reporting or financial results. 

Since we are a public company in the United States, the cost of our directors’ and officers’ 

liability insurance has significantly increased over recent years, as a result of which we have decided 
not to renew such insurance. Instead, our directors and officers rely on indemnification agreements 
provided by us. Accordingly, any lawsuits against our directors and officers could result in expensive 
legal expenses, settlements and judgments that we would be required to bear, which would harm our 
financial condition. 

Risks Relating to our Billing and Related Services Business  

System disruptions and failures may result in customer dissatisfaction, customer loss or both, 
which could materially and adversely affect our reputation and business. 

Our billing systems are an integral part of our customers’ business operations. The continued 

and uninterrupted performance of these systems for our customers is critical to our success. Customers 
may become dissatisfied by any system failure that interrupts our ability to provide services to them. 

Our ability to serve our customers depends on our ability to protect our systems and 
infrastructure against damages and unexpected adverse events. We also depend on various cloud 
providers and co-location datacenter providers which provide us environments, tools and applications 
on which we provide our products. Although we maintain insurance that we believe is appropriate for 
our business and industry, such coverage may not be sufficient to compensate for any significant losses 
that may occur as a result of any of these events. In addition, we have experienced systems outages and 
service interruptions in the past, none of which has had a material adverse effect on us. However, a 
prolonged system-wide outage or frequent outages could cause harm to our customers and to our 
reputation and reduce the attractiveness of our services significantly, which could result in decreased 
demand for our products and services and could cause our customers to make claims against us for 
damages allegedly resulting from an outage or interruption. Any damage or failure that interrupts or 
delays our operations could result in material harm to our business and expose us to material liabilities. 

The customer base for our wireline and wireless billing and customer care products is 
characterized by very small to medium size telephony carriers. If this market segment fails to 
grow, the demand for our billing and customer care software would diminish substantially. 

Our wireline and wireless billing and customer care products target very small to medium size 

carriers. Our growth in this field depends on continued growth of carriers of this size. We cannot be 

15 

 
 
certain that carriers of this size will be able to successfully compete with large telephony carriers in 
existing markets or will successfully develop in new and emerging markets. If this market segment fails 
to grow, the demand for our billing and customer care software would diminish substantially and our 
business would suffer. In addition, there may never be significant demand for new billing and customer 
care software by providers of telecom services. 

If we experience loss of one or more existing billing customers, we may suffer a decrease in 
revenues, reputation and profitability. 

A significant part of our revenues is derived from our existing customer base, maintenance 

agreements, customizations and additional professional services. Small service providers may be 
acquired by larger carriers and replace our solutions with the buyer’s existing billing platform, cease 
operations due to lack of funding, or terminate their relationship with us due to their financial 
condition, loss of market share and competitive pricing, as occurred with customers of ours over the 
years.  If one or more customers cease using our solutions or services due to replacements or any other 
reason, our business and results of operations would suffer. 

Because some of our billing customers require highly complex implementations and we sell fixed 
price projects, we may underestimate the effort and time required to implement such projects, 
resulting in a lower or negative profit margin for such projects and the incurrence of contractual 
penalties for late performance.  This could materially harm our results of operations. 

In 2019, we derived 60% of our revenues from the sale of software and related services to 

telecommunications service providers. As projects become more complex, the risk for on-time and on-
budget implementation increases. Each such contract may include penalties and potential liability for 
damages arising from late performance. These customers conduct a lengthy and complex approval and 
purchasing process, and the pricing for each project needs to be competitive in order to win. Our cost of 
sales increases as the length of the approval process increases because we need to support each 
opportunity during the time required for the customer to determine their specifications and the time 
required for the customer to receive internal approval to commit significant resources towards 
acquisition of the billing solution. The project implementation may be delayed due to customer related 
reasons such as lack of resources, delay in the build-up of the customer’s network infrastructure or 
deferral in making implementation scope related decisions. Our estimate for the cost includes the effort 
required to release new versions comprising enhanced functionality, the on-site professional services 
effort needed to perform migration of data from a customer’s existing platform and to develop, test and 
implement the customizations specifically requested by the customer.  

All the delays, either by us or by a third party, increase the cost of supplying the project and 
expose us to potential claims from customers and may decrease our revenues and could materially 
harm our profitability, business and results of operations. 

From time to time, our billing software and the systems into which it is integrated contain 
undetected errors. This may cause us to experience a significant decrease in market acceptance 
and use of our software products and we may be subject to warranty and other liability claims. 

From time to time, our billing software, as well as the systems into which it is integrated, 
contains undetected errors. Because of this integration, it can be difficult to determine the source of the 
errors. Also, from time to time, hardware systems we resell contain certain defects or errors. As a 

16 

 
 
result, and regardless of the source of the errors, we could experience one or more of the following 
adverse results: 

•  diversion of our resources and the attention of our personnel from our research and 

development efforts to address these errors; 

•  negative publicity and injury to our reputation that may result in loss of existing or 

future customers; and 

• 

loss of or delay in revenue and loss of market share. 

In addition, we may be subject to claims based on errors in our software or mistakes in 
performing our services. Our licenses and agreements generally contain provisions such as disclaimers 
of warranties and limitations on liability for special, consequential and incidental damages, designed to 
limit our exposure to potential claims. However, not all of our contracts contain these provisions and 
we cannot assure you that the provisions that exist will be enforceable. In addition, while we maintain 
product liability and professional indemnity insurance, we cannot assure you that this insurance will 
provide sufficient, or any, coverage for these claims. A product liability or professional indemnity 
claim, whether or not successful, could adversely affect our business by damaging our reputation, 
increasing our costs, and diverting the attention of our management team. 

Risks Relating to our Messaging Business 

Although we expect that the acquisitions of Message Mobile and GTX will result in synergies and 
other benefits to us, we may not realize those benefits because of difficulties related to 
integration, the achievement of synergies and other challenges. 

We entered the mobile messaging business in 2019 with the acquisitions of Message Mobile 

and GTX. Prior to the completion of the acquisitions, we, Message Mobile and GTX operated 
independently, and there can be no assurances that our businesses can be combined in a manner that 
allows for the achievement of substantial benefits. The integration process will require significant time 
and resources, and we may not be able to manage the process successfully. If we are not able to 
successfully integrate the businesses of Message Mobile and GTX with ours or pursue our customer 
and product strategy successfully, the anticipated benefits of the acquisitions may not be realized fully 
or may take longer than expected to be realized. Further, it is possible that there could be a loss of our 
pre-acquisition or new key employees and customers, disruption of our ongoing businesses, unexpected 
issues, higher than expected costs and an overall post-completion process that takes longer than 
originally anticipated. Specifically, the following issues, among others, must be addressed in 
combining the operations of Message Mobile and GTX with ours in order to realize the anticipated 
benefits of the acquisitions so the combined company performs as the parties hope: 

•  combining the companies' corporate functions; 

•  combining the businesses of Message Mobile and GTX with our business in a manner 
that permits us to achieve the synergies anticipated to result from the acquisitions, the 
failure of which would result in the anticipated benefits of the acquisitions not being 
realized in the time-frame currently anticipated or at all;  

17 

 
 
•  maintaining existing agreements with customers, distributors, providers, talent and 
vendors and avoiding delays in entering into new agreements with prospective 
customers, distributors, providers, talent and vendors; 

•  determining whether and how to address possible differences in corporate cultures and 

management philosophies; 

• 

integrating the companies' administrative and information technology infrastructure; 

•  developing products and technology that allow value to be unlocked in the future; 

•  evaluating and forecasting the financial impact of the acquisition transactions, including 

accounting charges; and  

•  effecting potential actions that may be required in connection with obtaining regulatory 

approvals. 

In addition, at times the attention of certain members of our management and resources may be 

focused on integration of the businesses of the companies and diverted from day-to-day business 
operations, which may disrupt our ongoing business and the business of the combined company. 

We have incurred, and may continue to incur, significant, non-recurring costs in connection 

with the acquisition and integration of Message Mobile and GTX, including costs to maintain 
employee morale and to retain key employees. We cannot ensure that the elimination of duplicative 
costs or the realization of other efficiencies will offset the transaction and integration costs in the near 
term or at all. 

Our messaging business depends on customers increasing their use of our messaging products, 
and any loss of customers or decline in their use of our products could materially and adversely 
affect our business, results of operations and financial condition. 

Our ability to grow our mobile messaging business and generate incremental revenue depends, 
in part, on our ability to maintain and grow our relationships with existing messaging customers and to 
have them increase their usage of our messaging platform. If our customers do not increase their use of 
our messaging products, then our revenue may decline and our results of operations may be harmed. 
Messaging customers are charged based on the usage of our products. Most of these customers do not 
have long-term contractual financial commitments to us and, therefore, they may reduce or cease their 
use of our products at any time without penalty or termination charges. Messaging customers may 
terminate or reduce their use of our products for any number of reasons, including if they are not 
satisfied with our products, the value proposition of our products or our ability to meet their needs and 
expectations. We cannot accurately predict customers' usage levels, and the loss of customers or 
reductions in their usage levels of our products may each have a negative impact on our business, 
results of operations and financial condition. If a significant number of messaging customers cease 
using, or reduce their usage of our products, it could harm our operations, financial reporting or 
financial results.   

If we are unable to attract new messaging customers in a cost-effective manner, then our 
business, results of operations and financial condition would be adversely affected. 

18 

 
 
In order to grow our messaging business, we must continue to attract new customers in a cost-

effective manner. We use a variety of marketing channels to promote our messaging products and 
platform, such as regional customer events and telemarketing campaigns. We will incur marketing 
expenses before we are able to recognize any revenue that the marketing initiatives may generate, and 
these expenses may not result in increased revenue or brand awareness. We may make significant 
expenditures and investments in new marketing campaigns, and we cannot guarantee that any such 
investments will lead to the cost-effective acquisition of additional customers. If we are unable to 
maintain effective marketing programs, then our ability to attract new customers could be materially 
and adversely affected, our marketing expenses could increase substantially and our results of 
operations may suffer. 

If we are unable to increase adoption of our messaging products by enterprises, our business, 
results of operations and financial condition may be adversely affected. 

Our ability to increase the customer base of our messaging business, especially among 
enterprises, and achieve broader market acceptance of our messaging products will depend, in part, on 
our ability to effectively organize, focus and train our sales and marketing personnel.  

As we seek to increase the adoption of our messaging products by enterprises, we expect to 

incur higher costs and longer sales cycles. In the enterprise market segment, the decision to adopt our 
products may require the approval of multiple technical and business decision makers, including 
security, compliance, procurement, operations and IT. In addition, while enterprise customers may 
quickly deploy our products on a limited basis before they will commit to deploying our products at 
scale, they often require extensive education about our products and significant customer support time, 
engage in protracted pricing negotiations and seek to secure readily available development resources. 
In addition, sales cycles for enterprises are inherently more complex and less predictable, and some 
enterprise customers may not use our products enough to generate revenue amounts that justify our cost 
to acquire such customers. In addition, these complex and resource intensive sales efforts could place 
additional strain on our product and engineering resources. Further, enterprises, including some of our 
customers, may choose to develop their own messaging solutions that do not include our products. 
They also may demand reductions in pricing as their usage of our products increases, which could have 
an adverse impact on our gross margin. As a result of our limited experience selling and marketing 
messaging products to enterprises, our efforts to sell to these potential customers may not be 
successful. If we are unable to increase the messaging revenue that we derive from enterprises, then our 
business, results of operations and financial condition may be adversely affected.  

To deliver our messaging products, we rely on network service providers for our messaging 
services. 

We currently interconnect with network service providers around the world to enable the use by 

our customers of our messaging products over their networks. We expect that we will continue to rely 
heavily on network service providers for these services going forward. Our reliance on network service 
providers has reduced our operating flexibility, ability to make timely service changes and control 
quality of service. In addition, the fees that we are charged by network service providers may change 
daily or weekly, while we do not typically change our customers' pricing as rapidly. 

Furthermore, many of these network service providers do not have long-term committed 

contracts with us and may terminate their agreements with us without notice or restriction. If a 

19 

 
 
significant portion of our network service providers stop providing us with access to their 
infrastructure, fail to provide these services to us on a cost-effective basis, cease operations or 
otherwise terminate these services, the delay caused by qualifying and switching to other network 
service providers could be time consuming and costly and could adversely affect our business, results 
of operations and financial condition. Further, if problems occur with our network service providers, it 
may cause errors or poor-quality communications with our products, and we could encounter difficulty 
identifying the source of the problem. The occurrence of errors or poor quality communications on our 
messaging products, whether caused by our platform or a network service provider, may result in the 
loss of our existing customers or the delay of adoption of our products by potential customers and may 
adversely affect our business, results of operations and financial condition. 

We may have to lower our prices for messaging products or change our pricing model from time 
to time. 

We charge our customers based on their use of our messaging products. We expect that we may 
need to change our pricing from time to time. In the past we have sometimes reduced our prices either 
for individual customers in connection with long-term agreements or for a particular product. One of 
the challenges to our pricing is that the fees that we pay to network service providers over whose 
networks we transmit communications can vary daily or weekly and are affected by volume and other 
factors that may be outside of our control and difficult to predict. This can result in us incurring 
increased costs that we may be unable or unwilling to pass through to our customers, which could 
adversely impact our business, results of operations and financial condition. 

Further, as competitors introduce new messaging products or services that compete with ours or 

reduce their prices, we may be unable to attract new customers or retain existing customers based on 
our historical pricing. As we expand internationally, we also must determine the appropriate price to 
enable us to compete effectively internationally. Moreover, enterprises, which are a primary focus for 
our direct sales efforts for our messaging products, may demand substantial price concessions. In 
addition, if the mix of products sold changes, including for a shift to IP-based products, then we may 
need to, or choose to, revise our pricing. As a result, in the future we may be required or choose to 
reduce our prices or change our pricing model, which could adversely affect our business, results of 
operations and financial condition. 

Defects or errors in our messaging products could diminish demand for these products, harm our 
business and results of operations and subject us to liability. 

Our customers use our messaging products for important aspects of their businesses, and any 
errors, defects or disruptions to our products and any other performance problems with our products 
could damage our customers' businesses and, in turn, hurt our brand and reputation. We provide regular 
updates to our messaging products, which may contain undetected errors, failures, vulnerabilities and 
bugs when first introduced or released. Real or perceived errors, failures or bugs in our products could 
result in negative publicity, loss of or delay in market acceptance of our messaging platform, loss of 
competitive position, lower customer retention or claims by customers for losses sustained by them. In 
such an event, we may be required, or may choose, for customer relations or other reasons, to expend 
additional resources in order to help correct the problem. In addition, we may not carry insurance 
sufficient to compensate us for any losses that may result from claims arising from defects or 
disruptions in our products. As a result, our reputation and our brand could be harmed, and our 
business, results of operations and financial condition may be adversely affected. 

20 

 
 
We face a risk of litigation resulting from customer misuse of our messaging software to send 
unauthorized messages in violation of applicable laws. 

The actual or perceived improper sending of messages with our messaging software may 

subject us to potential risks, including liabilities or claims relating to consumer protection laws. For 
example, the U.S. Telephone Consumer Protection Act of 1991 restricts telemarketing and the use of 
automatic SMS text messages without proper consent. The scope and interpretation of the laws that are 
or may be applicable to the delivery of messages are continually evolving and developing. If we do not 
comply with these laws or regulations or if we become liable under these laws or regulations due to the 
failure of our customers to comply with these laws by obtaining proper consent, we could face direct 
liability. 

In addition, if our customers’ use of our messaging products will not adhere to privacy 
regulations and messaging rules, they and us may be blocked from sending more messages through 
specific channels and may be fined for such conduct. Our failure to prevent such infringements could 
have a material adverse effect on our business. 

If we experience loss of one or more existing customers, we may suffer a decrease in revenues, 
reputation and profitability. 

A significant part of our messaging revenues is derived from servicing the messaging needs of 

the existing customer base of our messaging business. Customers of our messaging business may be 
acquired by other organizations and may replace our solutions with the buyer’s existing messaging 
provider services, cease operations due to lack of funding, or terminate their relationship with us due to 
their financial condition, loss of market share and competitive pricing, as occurred with customers of 
Message Mobile and GTX over the years.  If one or more customers cease using our messaging 
products or services due to replacements or any other reason, our business and results of operations 
would suffer. 

System disruptions and failures may result in customer dissatisfaction, customer loss or both, 
which could materially and adversely affect our reputation and business. 

We provide real time messaging services to our customers. The continued and uninterrupted 

performance of these services for our customers is critical to our success. Customers may become 
dissatisfied by any service failure that interrupts their business, which could lead them to stop using our 
messaging services. This could materially and adversely affect our reputation and business. 

Changes to regulations or technology vendor rules could materially and adversely affect our 
business. 

We use messaging technologies and products, such as SMS and WhatsApp, to deliver messages 

from our customers to consumers. Changes in rules and regulations may prevent us from using some 
services, which may block our ability to grow our services and have a material adverse effect on our 
business. 

Risks Relating to the Market of our Ordinary Shares  

Our share price has fluctuated and could continue to fluctuate significantly. 

The market for our ordinary shares, as well as the prices of shares of other technology 
companies, has been volatile. The price of our ordinary shares has fluctuated significantly over the 

21 

 
 
years. A number of factors, many of which are beyond our control, may cause the market price of our 
ordinary shares to fluctuate significantly, such as: 

•  sales of a substantial number of our ordinary shares; 

• 

fluctuations in our quarterly revenues and earnings and those of our publicly held 
competitors; 

•  public announcements concerning us or our competitors;  

•  market conditions in our industry; and 

• 

the general state of the securities market (particularly the technology sector). 

We do not control these matters and any of them may adversely affect our share price. In addition, 
trading in shares of companies listed on the Nasdaq Global Market in general and trading in shares of 
technology companies in particular has been subjected to extreme price and volume fluctuations that 
have been unrelated or disproportionate to operating performance. These broad market and industry 
factors may depress our share price, regardless of our actual operating results. Given the likely 
volatility that exists for our ordinary shares, sales of a substantial number of our ordinary shares could 
cause the market price of our ordinary shares to decline.  

If we are characterized as a passive foreign investment company, our U.S. shareholders will be 
subject to adverse tax consequences. 

If, for any taxable year, either, (i) 75% or more of our gross income is passive income; or (ii) 

50% or more of our assets, averaged over the year and generally determined based upon value, 
including cash (even if held as working capital), produce or are held to produce passive income, we 
may be characterized as a “passive foreign investment company”, or PFIC for United States federal 
income tax purposes. For this determination, passive income includes dividends, interest, royalties, 
rents, annuities and the excess of gain over losses from the disposition of assets that produce passive 
income. 

As a result of our cash position and the value of our assets, we may be deemed to be a PFIC for 

U.S. federal income tax purposes. 

If we are characterized as a PFIC, our shareholders who are residents of the United States will 
be subject to adverse U.S. tax consequences. Our treatment as a PFIC could result in a reduction in the 
after-tax return to shareholders resident in the United States and may cause a reduction in the value of 
our shares. If we were to be treated as a PFIC, our shareholders will be required, absent certain 
elections, to pay an interest charge together with tax calculated at the then prevailing highest tax rates 
on ordinary income on certain “excess distributions” including any gain on the sale of Ordinary Shares. 
The consequences of holding shares in a PFIC are described below under “Additional Information - 
United States Federal Income Tax Consequences - Passive Foreign Investment Companies.” 
Prospective investors should consult with their own tax advisors with respect to the tax consequences 
applicable to them of investing in our Ordinary Shares. 

Risks Relating to Our Location in Israel  

22 

 
 
Potential political, economic and military instability in Israel may harm our operating results. 

We are organized under the laws of the State of Israel and most of our senior management is 

located in Israel. Accordingly, our operating results are directly influenced by economic, political and 
military conditions in and relating to Israel. Since the establishment of Israel in 1948, a number of 
armed conflicts have taken place between Israel and its Arab neighbors, Hamas (an Islamist militia and 
political group in the Gaza Strip) and Hezbollah (an Islamist militia and political group in Lebanon). 
Recent political uprisings, social unrest and violence in various countries in the Middle East and North 
Africa, including Israel’s neighbor Syria, are affecting the political stability of those countries and have 
enabled the development of extremist groups. This instability may lead to deterioration of the political 
relationships that exist between Israel and these countries and has raised concerns regarding security in 
the region and the potential for armed conflict. In addition, Iran has threatened to attack Israel and is 
believed to be developing nuclear weapons. Iran is also believed to have a strong influence among 
parties hostile to Israel in areas that neighbor Israel, such as the Syrian government, Hamas in Gaza and 
Hezbollah in Lebanon. Any armed conflicts or political instability in the region could negatively affect 
business conditions and harm our results of operations. We cannot predict the effect on the region of 
the increase in the degree of violence between Israel and the Palestinians. Furthermore, several 
countries and trade groups restrict business with Israel and Israeli companies, and additional countries 
and trade groups may restrict doing business with Israel and Israeli companies for political reasons. 
These restrictive laws and policies may seriously harm our operating results, financial condition or the 
expansion of our business. In addition, the current situation in Israel could adversely affect our 
operations if our customers and/or strategic allies believe that instability in the region could affect our 
ability to fulfill our commitments.  

It may be difficult to enforce a U.S. judgment against us, our officers and directors or to assert 
U.S. securities laws claims in Israel.  

We are incorporated in the State of Israel. Substantially most of our executive officers and 

directors are nonresidents of the United States, and a substantial portion of our assets and the assets of 
these persons are located outside the United States. Therefore, it may be difficult for a shareholder, or 
any other person or entity, to collect a judgment obtained in the United States against us or any of these 
persons, or to effect service of process upon these persons in the United States. 

We have been informed by our legal counsel in Israel that it may be difficult to bring original 

actions in Israel to enforce civil liabilities under the Securities Act and the Exchange Act. Israeli courts 
may refuse to hear a claim based on a violation of U.S. securities laws because Israel is not the most 
appropriate forum to bring such a claim. In addition, even if an Israeli court agrees to hear a claim, it 
may determine that Israeli law and not U.S. law is applicable to the claim. If U.S. law is found to be 
applicable, the content of applicable U.S. law must be proved as a fact, which can be a time-consuming 
and costly process. Certain matters of procedure will also be governed by Israeli law. There is little 
binding case law in Israel addressing these matters.  

Subject to specified time limitations and legal procedures, under the rules of private 
international law currently prevailing in Israel, Israeli courts may enforce a U.S. judgment in a civil 
matter, including judgments based upon the civil liability provisions of the U.S. securities laws and 
including a monetary or compensatory judgment in a non-civil matter, provided that the following key 
conditions are met: 

23 

 
 
• 

• 

• 

• 

subject to limited exceptions, the judgment is final and non-appealable; 

the judgment was given by a court competent under the laws of the state of the court and 
is otherwise enforceable in such state; 

the judgment was rendered by a court competent under the rules of private international 
law applicable in Israel;  

the laws of the state in which the judgment was given provide for the enforcement of 
judgments of Israeli courts; 

•  adequate service of process has been effected and the defendant has had a reasonable 

opportunity to present his arguments and evidence; 

• 

• 

the judgment and its enforcement are not contrary to the law, public policy, security or 
sovereignty of the State of Israel; 

the judgment was not obtained by fraud and does not conflict with any other valid 
judgment in the same matter between the same parties; and 

•  an action between the same parties in the same matter was not pending in any Israeli 

court at the time the lawsuit was instituted in the U.S. court. 

Provisions of Israeli law and our articles of association may delay, prevent or make difficult a 
change of control and therefore may depress the price of our stock. 

Some of the provisions of our articles of association and Israeli law could, together or 

separately:  

•  discourage potential acquisition proposals;  

•  delay or prevent a change in control; and 

• 

limit the price that investors might be willing to pay in the future for our ordinary 
shares. 

In particular, our articles of association provide that our board of directors will be divided into 

three classes that serve staggered three-year terms and authorize our board of directors to adopt 
protective measures to prevent or delay a coercive takeover, including without limitation the adoption of a 
“Shareholder Rights Plan.” In addition, Israeli corporate law regulates mergers and acquisitions of 
shares through tender offers, requires approvals for transactions involving significant shareholders and 
regulates other matters that may be relevant to these types of transactions. See Item 10.B 
“Memorandum and Articles of Associations - Mergers and Acquisitions under Israeli Law.” 
Furthermore, Israeli tax law treats stock-for-stock acquisitions between an Israeli company and a 
foreign company less favorably than does U.S. tax law. For example, Israeli tax law may subject a 
shareholder who exchanges his ordinary shares for shares in another corporation to taxation prior to the 
sale of the shares received in such stock-for stock swap. 

24 

 
 
Item 4. 

Information on the Company 

A. 

History and Development of the Company. 

General 

Our name is MIND C.T.I. Ltd. for both legal as well as commercial purposes. We were 
incorporated under the laws of the State of Israel on April 6, 1995 as a company with limited liability, 
and we are subject to the Israeli Companies Law and the regulations promulgated thereunder. Our 
principal executive offices are located at 2 HaCarmel Street, Yoqneam 20692, Israel. Our telephone 
number is +972 4 993 6666. Our agent in the United States is MIND Software, Inc. and its principal 
offices are located at 12520 Prosperity Drive, Suite 220, Silver Spring, MD 20904, USA. 

Principal Capital Expenditures 

During 2017, 2018 and 2019, the aggregate cash amount of our capital expenditures were $71 

thousand , $46 thousand and $52 thousand , respectively. These expenditures were mainly for the 
purchase of equipment and licenses for software tools to be used by our engineering teams. We 
currently have no material commitments for capital expenditures.  

B. Business Overview 

Overview 

We develop, manufacture, market and implement real-time and off-line convergent billing and 

customer care software solutions for communication service providers, including traditional wireline 
and wireless, voice over IP, or VoIP, broadband IP network operators, wireless internet service 
providers, or WISPs, LTE operators, cable operators and mobile virtual network operators, or MVNOs.  

Our convergent billing and customer care solution supports multiple services, including voice, 
data and content services as well as prepaid, postpaid and pay-in-advance payment models in a single 
platform. Prepaid subscribers can enjoy the full range of services offered by the provider, with their 
special bundles, rating plans and limits. The prepaid solution authorizes each service and controls each 
session in real time, taking care that the balance is not exceeded. Postpaid subscribers, including credit-
limited and non-limited, retail or business customers, represent the loyal and the higher average 
revenue per user (ARPU), market. All services used by a postpaid subscriber appear in a single bill, 
which includes all charges, including one-time, recurring and usage-related charges. Our billing 
solution (MINDBill) is truly convergent and it includes our own integrated real-time mediation 
platform that provides interfaces with IP, Intelligent Networks, or IN, and traditional 
telecommunication equipment, our own provisioning platform and our own online charging solution 
(OCS). 

Our billing and customer care solution includes a powerful workflow engine to support the 

implementation of business processes such as subscriber registration, order management, trouble ticket 
and debt collection. It also includes an integral point of sale (POS) solution that covers all dealer, store 
and cashier management and sales processes. We base our solution on a multi-layered architecture 
supporting real-time distributed processing, achieving performance, scalability and high availability. It 
uses an open architecture, including Service Oriented Architecture (SOA) and robust Application 
Programming Interfaces (APIs) thus enabling fast and seamless integration with other systems and 

25 

 
 
third-party applications. The MIND solution uses standardized best-of-breed object-oriented design 
concepts and development technologies such as Java, Angular, Spring, XML Web-services, REST 
APIs, and Micro-Services. It is JEE based and is powered by a commercial application server. 

MINDBill can be installed on-premises or in a cloud environment.  

We also provide professional services, primarily to our billing and customer care customers, 

consisting of installation, turnkey project implementation services, customer support, training and 
maintenance services, software and process customization and project management. Our professional 
services also include enhanced support options, known as managed services, which are mainly offered 
to customers in the United States and Europe and are performed from our offices. These managed 
services include performing day to day billing operational tasks. 

In addition to our billing and customer care solutions, we offer unified communications 
analytics solutions and call accounting systems, which we call PhonEX ONE. PhonEX ONE is used by 
organizations around the world for call accounting, telecom expense management, traffic analysis and 
fraud detection. PhonEX ONE delivers a full-management solution including real-time and historical 
data dashboards, providing in-depth analysis of every session type specific to unified communications 
as well as traditional/VoIP PBXs, for monitoring and optimizing telephony communication networks 
and unified communications platforms. The flexible and scalable architecture of PhonEX ONE meets 
the needs of large enterprises, supporting an unlimited number of extensions, users and sites, it 
provides full functionality through a web browser, based on Microsoft SQL database and the advanced 
ASP.NET technology.  

In addition, from 2019, following the acquisitions of Message Mobile and GTX, we offer 

enterprise messaging services, wholesale messaging services and mobile payment services.  

Our enterprise mobile messaging platform enables enterprises to easily communicate with 

clients and partners via text / SMS, instant messaging or voice. The software may be integrated with 
the customers' CRM or marketing automation platforms. The messaging services are used by 
businesses for direct communication with their customers for several reasons, such as customer care, 
notifications, appointments, OTPs (one-time passwords) and marketing.  

Our wholesale mobile messaging business offers wholesale messaging services and messaging 

termination services on our software platform. The software is designed to provide advanced routing 
functionality enabling us to offer competitive wholesale and termination prices to other aggregators and 
service providers. The payment for the wholesale and termination services is based on volume (number 
of messages) and is being calculated and paid every month. In most cases, there are long-term contracts 
with other aggregators for the wholesale and termination services, but the prices are being negotiated 
ad-hoc based on demand.  

Our mobile payment services to businesses are offered over a proprietary software platform. 

These services allow consumers (end users) to pay for their purchases via their mobile phone bill. The 
billing process is operated by us and is activated by the consumers either via a mobile message 
transaction (SMS) or via an online process (online billing).  

Our Market Opportunity 

26 

 
 
Billing and Customer Care Industry 

Billing and customer care are critical to telecommunications service providers as they enable 

them to manage customer relations, track and bill for usage, and launch, deploy and charge new 
services, marketing programs and rate plans. The need for comprehensive billing solutions is driven by 
the market trend that requires service providers to introduce new services, to be innovative in creating 
new product offerings and to optimize business processes for maximum efficiency. We provide tier 2 
and tier 3 service providers with flexible, easy to deploy, truly convergent and scalable billing 
solutions. 

From time to time, telecommunications service providers initiate searches for billing solutions 

to replace existing ones in order to offer additional services, reduce costs and improve service. In 
addition, our existing customers occasionally consider adding new modules that we developed to their 
existing platform, replacing other vendors or migrating to a newer version with up-to-date technology 
and enhanced functionality. 

Also, from time to time, new providers surface and introduce new offering to the market or try 

to attract a specific targeted customer base. They build new infrastructure or resell traffic and initiate 
searches for billing solutions. 

Convergence 

Implementation of convergent solutions has become a common demand and we encounter 
opportunities as carriers seek to replace multiple existing solutions with one convergent platform. 

The convergent billing solution in the telecommunications industry enables operators to manage 

efficiently, on one platform, all subscribers and all services. It includes convergence of payment 
methods like prepaid and postpaid, as well as services like fixed telephony, mobile telephony, 
broadband, cable and IPTV. 

Mobile Messaging 

The global messaging market, via SMS and IP messaging, is growing, with new use cases 

added every year and enterprises moving their operation and marketing activities from traditional mail 
and email channels to mobile messaging technologies. Application to person, or A2P, messaging 
continues to grow as the most effective way for businesses to engage with consumers and is also 
believed to be the most trusted form of communication. Businesses across the world increasingly 
recognize that the mobile phone offers an unmatched means to engage with their consumers in a way 
that is attractive, direct and personalized. Cloud communications make it possible for businesses to 
leverage this opportunity in a way that is scalable and cost-efficient. Our Communications Platform as 
a Service, or CPaaS, provides simple APIs with well-defined ways to easily integrate messaging into 
the enterprise’s legacy systems (such as CRM) or our own applications. Our platform helps our 
customers to reduce costly in-house development and the need to negotiate complex commercial 
agreements with service providers.  

 Our Billing and Customer Care Solution  

We develop, market and support real-time and off-line, scalable billing and customer care 
software, including mediation and rating, for providers of voice, data and content services that are 

27 

 
 
designed to meet their complex, mission-critical provisioning, authentication, authorization, accounting 
and reporting needs. Our billing and customer care software provides our customers with the following 
benefits: 

•  Real-Time Solution. Service providers require a system that enables authentication, 

authorization and accounting and, if needed, cut-off, all in real-time. We believe that the 
MIND solution is one of the few billing and customer care products that offers real-time 
functionality for both prepaid and postpaid billing plans, and that has a real-time rating 
engine able to support rating of voice, data and content services simultaneously;  

•  Mediation and Service Fulfillment. IP and traditional networks that can offer voice, data, 

video and content services are based on various network elements each of which 
generates billable information. We believe that the MIND solution is one of the few 
billing and customer care products that provide real-time collection and correlation of 
various events from multiple sources that relate to the same session and convert them 
into billable records. In addition, the MIND solution enables end-to-end automated flow 
for service creation and activation, meaning that from the order for service handled by 
the customer care representative until the service activation, the activities that need to be 
completed are automatically fulfilled by MIND;  

•  Scalability. Our billing solution (MINDBill) is designed to support millions of 
subscribers and at the same time it enables service providers to grow from 
accommodating a small number of subscribers to a large number of subscribers, 
primarily through the addition of hardware and licenses. Our solutions’ design allows a 
service provider to expand its infrastructure, business model and subscriber base without 
the need to replace its billing and customer care software; and 

• 

Improved Time to Market. MINDBill is modular, extensible software products, based on 
software architecture designed for easy adaptability and implementation. These features 
allow each of our customers to tailor our products to meet their individual needs in 
terms of the number of subscribers serviced and the variety of services provided. In 
addition, our products can be customized relatively quickly, enabling our customers to 
improve their time to market as they initially implement their networks and, later, as 
they add and modify the services they provide. 

Our Strategy 

Our objective is to be a leader in the market for convergent billing and customer care software 

for tier 2 and tier 3 service providers, to increase our presence in mobile messaging and to remain as 
profitable as possible in an increasingly competitive environment.  

 The key elements of our strategy to become a leader in the market for convergent billing and 

customer care software for tier 2 and tier 3 service providers include: 

•  Leverage our brand name recognition and technical expertise. We introduced our 

billing and customer care software in 1997. We believe that our early position in the 
market and our reputation for offering high quality, reliable billing and customer care 

28 

 
 
software has provided us with brand name recognition. We intend to leverage our 
reputation, brand name and recognition in the wireline and wireless markets; and 

•  Maintain and expand our technological expertise. We believe that our reputation in the 

market is due in large part to our technological expertise. We make significant 
investments in research and development to continually enhance our products to meet 
the changing needs in the telecom industry. We intend to continue our commitment to 
technology, both to enhance our existing products and to develop new products for 
growing markets. 

The key elements of our strategy to increase our presence in mobile messaging include: 

•  Expand through acquisitions. We believe that A2P messaging needs are increasing 

worldwide, be it in traditional text (SMS) or in IP messaging. This market is 
consolidating, as most of our competitors are very active and successful in executing 
their acquisition strategy.  We believe that there are many small service providers that 
may be willing to be acquired. We intend to continue targeting potential acquisitions 
that could benefit our growth; 

•  Provide multi-channel messaging solutions. We intend to continue to develop our 
platform to support multiple messaging channels such as SMS, WhatsApp, RCS, 
Telegram and others in order to provide to our customers multiple messaging options for 
personal mobile communication; and 

•  Partner with vendors of enterprise business support systems. We believe that enterprises 
are looking for pre-integrated holistic solutions, and we intend to continue to integrate 
our messaging platform with other enterprise software, such as CRM and Marketing 
Automation, in order to provide our messaging services as part of their solution.   

Billing and Customer Care Solutions  

The key functionalities of our billing and customer care solutions are as follows: 

•  Mediation. Providing real-time and batch event collection, interfacing with the voice, 

content, data, service delivery and routing network elements; 

•  Provisioning. Setting up the ability of a subscriber to use services, enabling features and 

quantitative limits on network elements and legacy billing solutions; 

•  Authentication & Authorization. Authenticate subscribers who connect to the network to 
use voice or data services, and authorize a particular usage by reviewing the type of 
service, the account balance, pre-rating the service and calculating the resulting cut-off 
parameters; 

•  Accounting. When each session is completed, the rating engine calculates the amount to 
be charged to the subscriber and updates the balance of the account in real-time. In 
addition, the usage detail records are stored for invoicing and reporting; 

29 

 
 
• 

Interconnect Billing. MINDBill generates reports that enable providers to bill for traffic 
and services that are being transported across their networks by other providers; 

•  Roaming. MINDBill provides the ability to define and manage the required roaming 

contract terms and the applicable tariff plan for each roaming partner;  

•  Virtual Providers. MINDBill allows carriers to have resellers of traffic under different 

brand names and manage them as Virtual Providers;  

•  Multiple Services and Products Support. MINDBill allows operators to provide 

advanced voice, data, content and video services. Our product catalog allows bundling 
of groups of services into tailor-made packages with special rates, discounts and 
promotions; 

•  Rating. MINDBill includes a flexible real-time rating engine that facilitates a wide 
variety of billing plans and tariff parameters. Our rating engine includes support for 
content-based rates, rates based on the day of the week, time of the day, call origin and 
destination and multi-currency rates for international services. It supports an unlimited 
number of free-unit and money-bundle, voucher-based payment models and much more; 

• 

Invoicing. MINDBill supports all stages of invoice generation, multiple billing cycles 
and invoice on demand. Invoices include usage details, monthly recurring charges, 
discounts and taxes. Invoices can be printed locally or exported to printing service 
bureaus, using a customizable invoice layout;  

•  Account Receivables (A/R). MINDBill manages all A/R activities, monitors the A/R 

status online and ensures a continuous cash flow. It supports multiple payment methods: 
cash, check, credit and debit cards, vouchers and more. It offers a flexible open 
application server programming interface (API) for payments interfaces to banks and 
credit card clearing houses and has pre-integrated interfaces with major financial 
institutions, banks, clearinghouses and credit bureaus. The A/R module supports 
deposits life cycle management, including payments and refunds, dispute management 
and resolution, resulting in the appropriate adjustments. MINDBill identifies the ageing 
debt for every open invoice according to the company classification policy (30-60-90 
days) and initiates the built-in debt collection process; 

•  Collection procedures. The MINDBill flexible collection facility defines the collection 

policy using different collection paths. The solution provides full monitoring and control 
of the collection treatment (dunning process). It identifies customers with past due debts 
and ensures that they are handled in accordance with the company policy; 

•  Subscriber Self-Care Web Interface. MINDBill includes a user-friendly subscriber web 
interface that allows subscribers to obtain real time information about their account, 
including invoice information, call details and payment history. Our solution also offers 
a set of APIs to facilitate seamless integration of an existing customer self-care 
application with our billing solution; 

30 

 
 
•  Customer Support Representative Web Interface. MINDBill includes a powerful and 
user-friendly customer support representative web interface that allows operators to 
perform customer care from any location; 

•  Point of Sale (POS). Our POS enables operators to offer their products and services in 
retail stores, selling services, equipment and accessories to new and existing customers 
and even to non-subscribers. POS integrates with external systems, such as credit card 
clearinghouses, external taxation engines, field service software, and address validation 
systems. POS main modules:  

•  Sales Module – a PC and Tablet-based cashier station that facilitates services, equipment 
and accessories sales, returns and repairs, through an easy to use interface on a single 
receipt. It enables cash, check and credit card payments and supports cash drawer, credit 
card swipe, barcode reader and ribbon printer; 

•  Resource Management Module – an inventory system that supports the operator’s 

warehouses and stores, automating the management and tracking of goods sold. It manages 
the equipment by serial number, status, and location, supporting the full goods life-cycle. 

•  Business Processes Workflow Environment. MINDBill includes an automated business 
processes workflow engine to implement our customers’ unique business rules, creating 
tailored business processes such as managing subscriptions, order management, trouble tickets 
and debt collection.  For example, a tailored account creation process may include account 
registration, package selection, provisioning and activation steps, it may involve different users 
from various departments, integration with external legacy systems and third-party services 
and more; 

•  Call Management and Traffic Analysis Reports (CMS). This module allows service providers 
to generate reports and graphic analysis of usage activity. Information such as peak hours, 
usage loads or duration of sessions enables operators to analyze subscriber behavior and 
improve their marketing and business development strategies. In addition, the traffic analysis 
reports assist service providers in planning the growth and development of their networks; and 

•  Monitoring. MINDBill includes a monitoring tool that enables 24x7 operational control, 

proactive monitoring and historical analysis of the behavior and well-being of our platform and 
the resources it is using, such as database and operating system.  This tool can forward 
monitoring information to external network managing systems using simple network 
management protocol (SNMP). 

Enterprise Software 

Our enterprise product, known as PhonEX ONE, is used by corporations for telecom expense 

management, call accounting, traffic analysis and fraud detection. PhonEX ONE is a call management 
system that collects, records and stores all call information and enables: 

• 

to generate near real-time reports on the enterprise’s communication use; 

31 

 
 
•  monitor quality of experience;  

• 

track agent’s performance in contact centers; 

•  produce sophisticated reports and graphics for easy and effective analysis of 

call activity; and 

•  allocate telephone expenses to specific departments, individual clients or 

projects. 

These functions allow organizations to more effectively manage their telecommunications 

resources. The system is easy to install and configure, user-friendly and compatible with any 
switchboard system, traditional or IP. The system performs call management and traffic analysis as 
well as fraud management in the same manner as our billing solutions. In addition, the system is multi-
lingual and multi-currency, which means that reports can be generated in any currency defined in the 
system, or in two currencies simultaneously. 

PhonEX ONE can be installed on-premises or in a cloud environment.  

PhonEX ONE, delivers one unified solution for management of all telecom expenses, including 

traditional voice, IP voice and data, and mobile telephony. The flexible and scalable architecture of 
PhonEX ONE meets the needs of large enterprises, supporting an unlimited number of extensions and 
sites. PhonEX ONE provides tools to monitor, budget and manage voice traffic in order to achieve 
maximum control over telecommunication expenses. Some of its major advantages are: 

•  Fully web-based solution. The PhonEX ONE fully web-based solution enables managers and 
users to conveniently access their telecom expenses management system anytime and from 
anywhere, using a web browser without decreasing their control over the traffic;  

•  Quality of Service (QoS) Monitoring. PhonEX ONE enables quantification of the user’s 
perceived audio call quality so the organization can ensure the relevant communication 
quality of experience of its contact centers, calls between branches, out-going calls, etc.; 

•  User centric. The PhonEX ONE user-centric architecture provides a consolidated solution for 
the collection, analysis, reporting, and managing of all the telecommunication and data traffic 
expenses; 

•  Dashboard. A visual representation of the most significant information regarding calls, a useful 
tool that helps administrators to get a quick and relevant image of the general system activity. 
The Dashboard can quickly provide - through its graphical and non-graphical monitors - a 
snapshot over the outgoing and incoming calls, traffic and exceptions as well as several top 
requested reports; 

•  Multi-site solution.  The PhonEX ONE scales to support large multi-site organizations using 

voice and data equipment from multiple vendors. PhonEX ONE supports complex hierarchies 
on which any employee can be associated to any branch of the organization and under a 
separate matrix to any corporate department; 

•  ASP.NET and MS-SQL database. PhonEX ONE is designed using the Microsoft .Net 

technology and has extensive configuration capabilities using XML files with server – client 
interaction; 

32 

 
 
•  Certification by IP switch vendors. PhonEX ONE is interoperable and certified on a timely 

manner with new releases of IP switch vendors, including Cisco and Microsoft; 

•  Enhanced security.  PhonEX ONE security management includes user authentication, security 
group restrictions, event log monitoring and encryption methodology of data base entries. This 
management tool enables a secure and easy control over the system;  

•  Modular architecture supporting high scalability. The PhonEX ONE’s scalable system 

architecture supports an unlimited number of sites and extensions; 

•  Guard and Alerter. The PhonEX ONE Guard and Alerter provide sophisticated tools for 
fraud prevention, alerting on phone misuse, budget surpass, possible toll fraud or other 
abnormal behaviors within the organization; and 

•  Multilingual and multicurrency. The built-in support of multiple languages and multiple 

currencies enables telecom expense management for multinational organizations. 

We intend to further develop and market these products as the market for Voice over IP systems 

for enterprises grows. 

Mobile Messaging  

Following the acquisition of Message Mobile, we offer messaging and payment solutions to 

enterprise customers. We plan to expand the range of services we offer and the technological vehicles 
used to deliver them to our customers, and to increase the rate of new customer acquisition by 
facilitating self-registration and on-boarding for new customers, and by offering competitive pricing 
and quality services.  

Professional Services 

We provide professional services to our customers, consisting primarily of project management, 

customization, installations, customer support, training and maintenance services. We also offer 
enhanced support options, called managed services, which are mainly offered to customers in the 
United States and are performed from our offices. The managed services include performing day to day 
billing operational tasks. The managed services contracts are usually for a term of three to five years 
and are paid on a monthly basis. We also have the ability to implement Software-as-a-Service (SaaS) 
models in a similar way. 

Technology 

Our software products are based on an open architecture, which was developed using industry 

standard API that enables it to readily integrate with other software applications. These application 
program interfaces create an object-oriented, multi-layered architecture that support a distributed 
environment. Our object-oriented technology enables the design and implementation of software 
utilizing reusable business objects rather than complex procedural codes. Our layered architecture 
organizes these business objects to optimize the interface between the user and the application. We 
implement our software in a distributed configuration. This allows various modules to be installed on 
different servers to support the system’s scalability and security. We utilize a business processes 
workflow environment that facilitates the implementation of tailored and automated business processes 
to fit our customers’ unique business rules. 

33 

 
 
We believe that our technology allows us to offer products with the following benefits: 

• 

fast integration and interoperability with telecommunications equipment of major 
manufacturers, legacy systems and external software; 

•  modular architecture that allows our products to be easily scalable and enables us to 

customize our software relatively quickly; 

• 

reliable products that support high availability of the service for mission-critical 
applications. Our automatic fail-over mechanism ensures minimal loss of service in case 
of a component failure; and 

•  security at all levels of the architecture. Each user of the system may be assigned to 
different security groups. Service providers are therefore able to determine and audit 
access to the system. In addition, firewalls can be installed to prevent unauthorized 
access to the system. 

Our software products are based on multiple-tier architecture, consisting of the following tiers: 

•  Client Application Tier: This is the top tier graphic user interface between the user and 
the application. It includes client applications for customer registration, sales, customer 
care and billing administration. In addition, it includes Web service and REST interfaces 
that enable external applications to interact with the business tier; 

•  Business Object Tier: This tier includes the business logic and rules of the system. This 
tier manages accounts, services, events and tariffs. It includes an object request broker 
that facilitates the transfer of information requested by the client application tier from 
the database tier; and 

•  Database Tier: This tier includes the Oracle database server and management software 

where the actual billing and customer care information is stored. 

Our messaging and payment services are based on our modern, cloud-based messaging 
platform developed by Message Mobile. All types of messages and payments are served by this 
single technology platform. 

Sales and Marketing 

Sales 

Billing and Customer Care Solutions  

We conduct our sales and marketing activities primarily directly. 

Enterprise Software 

We conduct our sales and marketing activities primarily directly, as well as through appointed 
distributors and resellers throughout the world. We engage with our system integrators and equipment 
vendors for global marketing activities and responses to tenders.  

34 

 
 
Messaging 

We conduct our sales and marketing activities primarily directly.  

Our marketing programs are focused on creating awareness, interest and preference for our 

products and services. We engage in a variety of marketing activities, including: 

•  participating in industry trade shows and special events;  

•  conducting ongoing public and press relations programs; and 

•  conducting training seminars for vendors and system integrators. 

Principal Markets  

The following table shows our revenues for each of the past three years classified by type of 

revenue and geographic region. 

2017 

Years Ended December 31, 
2018 
(dollars in thousands) 
$ 13,130 

$ 12,995 

2019 

$ 12,030 

962 

1,032 

683 

12,033 
909 

12,098 
793 

11,347 
523 

202 
707 

212 
581 

168 
355 

3,181 

3,328 

8,839 

920 

709 

829 

2,261 

2,619 

8,010 

977 

357 

620 

884 

198 

686 

1,272 

618 

654 

18,062 

18,135 

22,664 

2,441 

2,151 

2,298 

The Americas (total)
 ....................................................................................  
      Sale of Licenses
 ....................................................................................  
      Services 
Asia Pacific and Africa (total)
 ....................................................................................  
      Sale of Licenses  
      Services
 ....................................................................................  
Europe (total)
 ....................................................................................  
      Sale of Licenses
 ....................................................................................  
      Services
 ....................................................................................  
Israel (total)
 ....................................................................................  
      Sale of Licenses
 ....................................................................................  
      Services
 ....................................................................................  
Total
 ....................................................................................  
     Sale of Licenses
 ....................................................................................  

35 

 
 
 
 
  
 
 
     Services
 ....................................................................................  

15,621 

15,984 

20,366 

Customers 

Billing and Customer Care Solutions  

Our billing and customer care solutions have been installed for a large base of customers 

worldwide, including:  

•  Traditional telephony providers that evolved into quad-play providers, offering wireless, 

wireline, cable, content and internet services, such as Moldtelecom, Belize Telemedia and 
Docomo Pacific; 

•  Wireless telephony providers, LTE operators and MVNO’s, such as KDDI America, Inc. and 

Chat Mobility; 

•  Cable providers that also offer voice services, such as EastLink; and 

•  Mobile Virtual Network Enablers (MVNEs), such as Pelephone Communications Ltd.  

Enterprise Software 

Our enterprise software products have been installed for a large base of customers worldwide, 

including international banking firms, global technology leaders, government agencies and other 
thousands of small to very large organizations.   

Messaging and Payment Services 

Our messaging and payment solutions are used by more than 100 enterprise customers, mostly 

in Germany.   

Competition 

Billing and Customer Care Solutions  

Competition in the market for billing and customer care software is intense and we expect 

competition to continue to be strong. We compete with many local companies and worldwide 
companies such as Amdocs, CSG and Optiva.   

We believe that our competitive advantage is based on: 

•  our ability to rapidly deploy a complete turn-key product-based solution;  

•  our truly convergent platform using one database and one product catalog for both prepaid and 

postpaid subscribers; 

•  our solutions’ functionality, which includes billing, customer care, point-of-sale, mediation, 

provisioning, online charging for multiple services and interconnect reporting; 

36 

 
 
 
 
 
 
•  our proven platform and our many years of wireless and IP experience to satisfy customer 

requirements; and 

•  our flexibility to meet customer requirements in a short time frame.  

Some of our competitors have greater financial, technical, sales, marketing and other resources 

and greater name recognition than we do. Some of our competitors have lower cost structure and 
compete with us on pricing. Current and potential competitors have established, and may establish in 
the future, cooperative relationships among themselves or with third parties to increase their ability to 
address the needs of prospective customers. Accordingly, new competitors or alliances among 
competitors may emerge and rapidly acquire significant market share and their solutions could achieve 
greater market acceptance than our solutions. 

Enterprise Software 

Our competitors in the market for enterprise software products are mainly local companies. To 
compete effectively, companies must be able to offer adequate technical support and ongoing product 
development. In addition, multinational companies prefer call accounting systems that can be installed 
at their various offices throughout the world, and therefore require call accounting products that are 
multilingual and support the local telecommunication requirements. The principal factors upon which 
we compete are scalability, ease of use, being certified by major IP switch vendors and the multi-
lingual and multi-currency nature of our system. 

Messaging and Payment 

Our competition in the messaging and payment market comes from a few international 
companies, such as Sinch AB and CM.com, and from many small, local service providers in Germany. 
Our competitive advantage is based on a combination of technology and service – our ability and will 
to tailor our services to the needs of enterprise customers. 

C. 

Organizational Structure  

Set forth below is a list of our significant subsidiaries: 

• 

• 

• 

• 

• 

• 

MIND Software Limited, a wholly owned subsidiary, incorporated in the United 
Kingdom; 

MIND Software, Inc., a wholly owned subsidiary, incorporated in the State of 
Delaware;  

MIND Software SRL., a wholly owned subsidiary of MIND Software Limited, 
incorporated in Romania. 

MIND CTI GmbH, a wholly owned subsidiary, incorporated in Germany; 

Message Mobile GmbH, a wholly owned subsidiary of MIND CTI GmbH, 
incorporated in Germany; and 

GTX GmbH, a wholly owned subsidiary of MIND CTI GmbH, incorporated in 
Germany. 

37 

 
 
In 2017, we sold Dirot Comp SRL, a wholly owned subsidiary of ours incorporated in Romania, 

for approximately $1.2 million, and we recorded a net one-time capital gain of $0.9 million. We sold 
this subsidiary because the sole asset owned by it was a plot of land in Romania on which we had 
planned to build our own office building, and we came to the conclusion that it would be preferable to 
rent office space instead. 

D. 

Property, Plant and Equipment 

Our headquarters are located in Yoqneam, Israel, approximately 50 miles north of Tel Aviv. We 

lease approximately 10,000 square feet at our Yoqneam headquarters. We also lease approximately 
15,550 square feet in Iasi, Romania and approximately 7,400 square feet in Suceava, Romania. The 
offices in Iasi and Suceava are used primarily for software development and for customer support.   

Item 4A. 

Unresolved Staff Comments 

Not applicable. 

Item 5. 

Operating and Financial Review and Prospects  

The following discussion and analysis of our financial condition and results of operations 

should be read together with our audited consolidated financial statements and the related notes 
included elsewhere in this annual report. The following discussion contains forward-looking statements 
that are based upon our current expectations and are subject to uncertainty and changes in certain 
circumstances. Actual results may differ materially from these expectations due to inaccurate 
assumptions and known or unknown risks and uncertainties, including those identified under 
“Cautionary Note Regarding Forward-Looking Statements” and under “Risk Factors” elsewhere in this 
annual report.  

Overview  

We were incorporated in Israel in 1995 and started providing our enterprise software products 

in that year. In 1997, we introduced our billing and customer care software for Voice over IP. We have 
enhanced our billing solutions since then to support multiple IP services, wireless and wireline carriers 
and triple play (voice, data and content) service providers. Following the acquisitions completed during 
2019 (see below), we, together with our subsidiaries, also provide enterprise messaging, 
communication and payment solutions. 

On March 25, 2019, we acquired Message Mobile GmbH, a leading provider of enterprise 

messaging, communication and payment solutions, based in Germany, with more than 15 years’ 
experience in the mobile industry. Its messaging platform enables enterprises to easily communicate 
with clients and partners via text / SMS, voice and instant messaging services like WhatsApp, 
Facebook Messenger and Telegram. Message Mobile also offers mobile payment solutions that use 
phone bill charging for a wide range of applications, such as mobile parking payment. 

On September 25, 2019, we acquired GTX GmbH, a company based in Germany offering 
global SMS services for B-2-B customers, providing business partners a robust and easy-to-use system 
to send SMS messages to end-users at the best possible quality and attractive pricing, acting as a one-

38 

 
 
stop-platform for clients aiming to extend their messaging activities on different channels, e.g., 
WhatsApp, Chatbot on Messenger and Rich Communication Services (RCS).  

In 2019, 60% of our total revenues were derived from providing our billing and customer care 

software, 27% of our total revenues were derived from enterprise messaging and payment solutions and 
13% of our total revenues were derived from providing our enterprise software. In 2019, license fees 
represented 10% of our total revenues and services represented 90% of our total revenues.  

In 2019, no customer accounted for more than 10% of our total revenues. In 2018, two 
customers accounted for approximately 15% and 12% of our total revenues. In 2017, two customers 
accounted for approximately 16% and 12% of our total revenues. We expect to continue to derive 
sizeable revenues from a small number of changing customers. 

Consolidation in the telecom markets was not favorable to us in the last years, and we closed 

fewer deals than in previous years. Accordingly, we expect challenges in maintaining our profitability 
levels in the near term.  

Our dividend policy is to declare a dividend distribution once per year, in the amount equal to 

our EBITDA for the preceding year plus financial income (expenses) minus taxes on income, subject to 
specific board approval and applicable law. Since 2003, our cash dividends amount to approximately 
$4.78 per share to (including the dividend declared in 2020 in respect of 2019). The amount per share 
that we distributed in 2018 and 2019 was $0.30 and $0.26, respectively, and a dividend of $0.24 per 
share was declared in March 2020. The board of directors’ decision to approve the annual distribution 
is based, among other factors, on our cash position at that time, potential acquisitions and future cash 
needs. Our board of directors may decide to discontinue the dividend distribution in whole or in part at 
any time. 

In previous reporting periods (until the year ended on December 31, 2018), we operated in one 

reportable segment (billing and related services). Following the acquisition of Message Mobile on 
March 25, 2019 (see above), management determined that we operate since that date in two reportable 
segments, the second one being messaging. 

Revenues. In the billing and related services segment, we are paid license fees by our customers 

for the right to use our products, based on (i) traffic volume, which is measured by factors such as 
number of subscribers, and (ii) the functionality of the system, based on application modules that are 
added to the software. In relation to our professional services, other than maintenance services and 
managed services, we mainly quote a fixed price based on the type of service offered, estimated direct 
labor costs and the expenses that we will incur to provide these services. We also provide Agile 
development teams that perform solution enhancements, each dedicated for a period of time to a 
specific customer, for a fixed cost per person per month. Fees for maintenance services are based on a 
percentage of the solution fee and are paid annually, quarterly or monthly. Fees for managed services 
are primarily based on the number of subscribers or customers business volume and are paid monthly.  

We primarily use two business models when we sell our solutions, the license model and the 
managed services model. In the license model, the customer pays a one-time implementation fee, a 
one-time license fee for a perpetual license limited by the traffic metrics chosen by the customer, and 
additional fees to expand the chosen traffic metrics limitation. In addition, we are paid maintenance 

39 

 
 
fees to renew periodically the maintenance agreement at the customer discretion. In the managed 
services model, the customer pays a one-time implementation fee, a monthly fee that includes a 
periodic license (right to use), maintenance and services fees, calculated by the metrics chosen by the 
customer (mainly, number of subscribers). 

In the messaging segment, revenues are derived mainly from usage-based fees earned from 

customers using our messaging software platform. Usage-based fees are recognized as revenues in the 
period in which the usage occurs.  

We also offer payment solutions where our customer can enable their customers (the end users) 
to pay for goods or services by charging their mobile phone account. For these services we are entitled 
to a share of the processed transactions/payment. Consequently, for the payment solutions transactions 
we recognize revenues on a “net basis” and only our share of the processed transactions are recognized 
as revenues. 

We provide a revenue breakdown for our billing and customer care software, our messaging 

and payment solutions and our enterprise call management software. We believe that this information 
provides a better understanding of our performance and allows investors to make a more informed 
judgment about our business. 

Cost of Revenues. In the billing and related services segment, the cost of revenues consists 

primarily of direct labor costs and overhead expenses related to software installation and maintenance. 
Cost of revenues also includes, among other things, software license fees to third parties, primarily 
Oracle, hardware, travel expenses, packaging and shipping costs. 

In the messaging segment, the cost of revenues consists primarily of fees paid to network 

providers. Our arrangements with the network service providers require us to pay fees based on the 
volume of text messages sent, as well as telephone numbers acquired by us to service our customers.  

Research and Development Expenses. Our research and development expenses consist 

primarily of compensation, overhead and related costs for research and development personnel and 
depreciation of testing and other equipment. Research and development costs related to software 
products are expensed as incurred until the “technological feasibility” of the product has been 
established. Because of the relatively short time period between “technological feasibility” and product 
release, no software development costs have been capitalized. We expect to continue to make 
investments in research and development.  

Selling and Marketing Expenses. Our selling and marketing expenses consist primarily of 

compensation, overhead and related costs, for sales and marketing personnel, the operation of 
international sales offices, sales commissions, marketing programs, public relations, promotional 
materials, travel expenses, trade shows and exhibition expenses. 

General and Administrative Expenses. Our general and administrative expenses consist 

primarily of compensation, overhead and related costs for executives and administrative personnel, 
professional fees, insurance, provisions for doubtful accounts and other general corporate expenses.  

Financial Income (Expenses), Net. Our financial income (expenses), net consists mainly of 

interest earned on bank deposits and short-term investments, gains and losses from the change in value 

40 

 
 
and realization of marketable securities, gains and losses from the conversion of monetary balance 
sheet items denominated in non-dollar currencies into dollars, net of financing costs, and bank charges.   

Taxes on Income.  See “Corporate Tax Rate” below.  

A. 

Operating Results  

The following discussion of our results of operations for the years ended December 31, 2018 

and 2019, including the percentage data in the following table, is based upon our statements of 
operations contained in our consolidated financial statements for those years, and the related notes 
thereto, included in Item 18:  

Revenues

Cost of revenues

Gross profit

Research and development expenses

Selling, general and administrative expenses: 

Selling and marketing
 ..........................................................................  
General and administrative
 ..........................................................................  

Years Ended 
December 31, 

2018 
2019 
(% of revenues) 

100.0% 

100.0% 

33.9 

44.7 

66.1 

20.7 

7.0 

8.9 

55.3 

18.5 

5.4 

9.2 

Operating income

29.5 

22.2 

Gain on disposal of a subsidiary………………… 
Financial income (expenses), net

Income before taxes on income 

Income tax expense ……….

- 
1.2 

30.7 

2.4 

- 
2.1 

24.3 

2.0 

Net income

28.3 % 

22.3% 

41 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Comparison of the Year Ended December 31, 2019 to the Year Ended December 31, 2018  

Revenues 

Years Ended December 31,

% Change 

License sales ..................................  
Professional services .....................  
Total revenues ...............................  

201
(  
 $ 

8
dollars
2.1
16.0
18.1

$ 

2019

in millions)

 $ 

32.
420.
7.22$ 

6.8 
27.4 
25.0 

Total revenues increased from $18.1 million in 2018 to $22.7 million in 2019, with the increase 

attributed to the acquisition of Message Mobile in March 2019 and GTX in September 2019, which 
generated revenues of $6.1 million during 2019, offset by a decrease in revenues from our existing 
lines of business. 

Revenues from our billing and customer care solutions for service providers decreased from 
$14.9 million in 2018 to $13.6 million in 2019. The decrease was primarily due to some customers 
under maintenance, or managed services, that decided to exit their business and fewer new customers, 
each of which provided lower initial proceeds. 

Revenues from our enterprise products decreased from $3.2 million in 2018 to $3.0 million in 

2019. The decrease was primarily due to the trend of market decrease and we expect this trend to 
continue. 

Revenues from licenses increased from $2.1 million in 2018 to $2.3 million in 2019. The 
increase was primarily attributed to an increase in the number of subscribers of our existing customers. 
The professional services significantly increased from $16.0 million in 2018 to $20.4 million in 2019, 
primarily as a result of the acquisition of Message Mobile in March 2019 and GTX in September 
2019, which generated revenues of $6.1 million in 2019.  

42 

 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
The following table presents the geographic distribution of our revenues: 

The Americas
 .....................................................................  
Asia Pacific and Africa
 ...........................................................................  
Europe
 ...........................................................................  
Israel
 ...........................................................................  
Total
 ...........................................................................  

Years Ended December 31, 

2018 

2019 

(% of revenues) 

72.4 

53.1  

4.4 

18.3 

4.9 

2.3 

39.0 

5.6 

100% 

100% 

Our revenues in the Americas decreased from $13.1 million in 2018 to $12.0 million in 2019. 

The decrease was primarily due to some customers under maintenance, or managed services 
agreements, that decided to terminate their contracts with us and to signing fewer new customers, each 
of which provided lower initial proceeds.  

Our revenues in Europe significantly increased from $3.3 million in 2018 to $8.8 million in 

2019. The increase was attributed to the inclusion of Message Mobile’s results of operations 
commencing from the second quarter of 2019 and GTX’s results of operations commencing from the 
fourth quarter of 2019, which together generated total revenues of $6.1 million in 2019, all in Europe, 
offset by lower revenues from existing customers in Europe. The percentage of total revenues in 
Europe significantly increased from 18.3% in 2018 to 39.0% in 2019, due to the same reason. Our 
revenues in Israel increased from $0.9 million in 2018 to $1.3 million in 2019, mainly due to the 
deployment of the new version of MINDBill to an existing customer in Israel, and as a percentage of 
total revenues increased from 4.9% in 2018 to 5.6% in 2019. 

Cost of Revenues  

Cost of sales of license ..................  
Cost of services .............................  
Total cost of revenues ...................  

Years Ended December 31,

% Change 

2018
(  

dollars
$ 
0.08
76.0
56.1$ 

2019

in millions)
140.$ 
99.9 

$ 

10.13

75.0 
64.6 
64.7 

Total cost of revenues in 2019 increased by $4.0 million, compared with 2018, mainly due to 

the inclusion of Message Mobile’s results of operations commencing from the second quarter of 2019 
and GTX’s results of operations commencing from the fourth quarter of 2019, which generated cost of 
revenues of $4.6 million in 2019. The cost of licenses increased by $0.6 million as a result of the 
increase of licenses revenues. 

43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Gross profit as a percentage of total revenues decreased from 66.1% in 2018 to 55.3% in 2019, 
mainly due to the inclusion of Message Mobile’s results of operations commencing from the second 
quarter of 2019 and GTX’s results of operations commencing from the fourth quarter of 2019. 

Operating Expenses 

Research and development ............  
Selling and marketing....................  
General and administrative............  
Total operating expenses ...............  

Years Ended December 31,

% Change 

2018
(  

dollars
3.7$ 
1.3
1.6
6.6$ 

2019

in 

millions)

2.4$ 
21.
1.2 
5.7$ 

11.7 
(3.4) 
28.5 
13.0 

Research and Development. The increase in our research and development expenses by 11.7% 

in 2019, compared to 2018, was primarily due to the inclusion of Message Mobile’s results of 
operations commencing from the second quarter of 2019 and GTX’s results of operations commencing 
from the fourth quarter of 2019. Research and development expenses as a percentage of total revenues 
decreased from 20.7% in 2018 to 18.5% in 2019, primarily due to the increase in total revenues 
attributed to the acquisitions of Message Mobile and GTX and the fact that research and development 
in the messaging segment represents a lower percentage of total revenues in comparison to our billing 
segment.  

Selling and Marketing Expenses. Selling and marketing expenses slightly decreased from $1.3 

million in 2018 to $1.2 million in 2019, mainly attributed to the decrease in sales commission expenses 
resulting from the lower revenues in our billing segment.  Selling and marketing expenses as a 
percentage of total revenues decreased from 7.0% in 2018 to 5.4 % in 2019, mainly due to the above-
mentioned increase in total revenues, while the selling and marketing expenses remained substantially 
the same. 

General and Administrative Expenses. General and administrative expenses increased from $1.6 

million in 2018 to $2.1 million in 2019, mainly due to the inclusion of Message Mobile’s results of 
operations commencing from the second quarter of 2019 and GTX’s results of operations commencing 
from the fourth quarter of 2019, which generated general and administrative expenses of $0.2 million 
in 2019 and also from the cost of professional services and amortization of intangible assets as a result 
of these acquisitions. General and administrative expenses as a percentage of revenues slightly 
increased from 8.9% in 2018 to 9.2% in 2019 due to the increase in expenses, offset by the increase in 
total revenues. 

Impairment of Goodwill. No impairment of goodwill was required following the impairment 

test performed during 2018 and 2019.  

Financial Income (Expenses), net. In 2019, financial income consisted of interest income on 

short-term bank deposits and marketable securities in the aggregate amount of $408 thousand and gains 
from currency exchange rate fluctuations in the aggregate amount of $89 thousand, offset by bank 
charges in the aggregate amount of $14 thousand. In 2018, financial income consisted of interest 

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
income incurred mainly on short-term bank deposits and marketable and available-for-sale securities of 
$340 thousand , offset by currency exchange rate fluctuations in the aggregate amount of $107 
thousand and bank charges in the aggregate amount of $11 thousand.  

 Income Tax Expense. Income tax expenses are comprised of current and deferred taxes. On a 
regular basis, we estimate our actual current tax exposures and assess temporary differences resulting 
from differing treatment of items for tax and accounting purposes. These differences result in deferred 
taxes, which are included on our consolidated balance sheet. In 2019, our income tax expenses in the 
amount of $458 thousand included mainly taxes on income in Israel in the amount of $316 thousand 
and a decrease in deferred taxes in the amount of $2 thousand. In 2018, our income tax expenses in the 
amount of $438 thousand included mainly taxes on income in Israel in the amount of $396 thousand 
and a decrease in deferred taxes in the amount of $2 taxes. 

For  a  comparison  of  the  year  ended  December  31,  2018  to  the  year  ended  December  31,  2017, 
please refer to Item 5 in our annual report on Form 20-F, filed with the SEC on March 21, 2019. 

Critical Accounting Policies 

Revenue Recognition. The majority of our revenues consist of revenues generated from 

software licensing, sales of professional services, including integration and implementation, 
maintenance services, managed services and mobile messaging services.  

We adopted ASC 606, “Revenue from Contracts with Customers”, on January 1, 2018, using 
the modified retrospective approach for all contracts not completed as of the date of adoption. Results 
for reporting periods beginning after January 1, 2018 are presented under ASC 606, while prior period 
amounts are not adjusted and continue to be reported in accordance with ASC 605, “Revenue 
Recognition”. ASC 606 requires an entity to evaluate revenue recognition by identifying a contract 
with a customer, identifying the performance obligations in the contract, determining the transaction 
price, allocating the transaction price to the performance obligations in the contract, and recognizing 
revenue when (or as) the entity satisfies a performance obligation. We apply the provisions of ASC 
606, “Revenue from Contracts with Customers”, as follows: 

i) Licenses: Revenue from perpetual licenses is classified as software license revenue. Software 
license revenue is recognized up front upon delivery of the licensed product and the utility that 
enables the customer to access authorization keys, provided that a signed contract has been 
received.  

ii) Services: Revenue from training, support and other services is recognized as the services are 

performed. For contracts in which the service consists of a single performance obligation, such 
as providing a training class to a customer, we recognize revenue upon completion of the 
performance obligation. For service contracts that are longer in duration and often include 
multiple performance obligations (for example, both training and consulting), we measure the 
progress toward completion of the obligations and recognizes revenue accordingly. In 
measuring progress towards the completion of performance obligations, we typically utilize 
output-based estimates for services with contractual billing arrangements that are not based on 
time and materials, and estimates output based on the total tasks completed as compared to the 
total tasks required for each work contract. Input-based estimates are utilized for services that 

45 

 
 
 
involve general consultations with contractual billing arrangements based on time and 
materials, utilizing direct labor as the input measure. 

Contracts may include a combination of our various products and services offerings, software, 
consulting services, and maintenance. For contracts with multiple performance obligations, we 
account for individual performance obligations separately if they are distinct. Significant 
judgment may be required to identify distinct obligations within a contract. The total transaction 
price is allocated to the individual performance obligations based on the ratio of the relative 
established standalone selling prices (SSP), or our best estimate of SSP, of each distinct product 
or service in the contract. Revenue is then recognized for each distinct performance obligation. 

iii) Managed Services: Revenues from managed services include a monthly fee for services and a 

right to access our software and are recorded as service revenues. We do not provide the 
customer with the contractual right to take possession of the software at any time during the 
period under these contracts.  The monthly fee is based mainly on the number of subscribers or 
customer’s business volume and the contracts include a minimum monthly charge. These 
revenues are recognized on a monthly basis when those services are satisfied. 

iv) Mobile Messaging Transactions: Certain of our subsidiaries provide mobile messaging 

services via text messages (SMS) and IP (Internet Protocol) messaging channels.  Revenues 
from mobile messaging services are recognized when the messaging service has been rendered, 
i.e., the messages are delivered to recipient. The revenue amount is based on the price specified 
in the contract, net of discounts. 

v) Mobile Payments Services: One of our subsidiaries offers payment solutions where the 

customer can enable their consumers (the end users) to pay for goods and services by charging 
their mobile phone account. For these services we are entitled to a share of the processed 
transaction/ payment. Consequently, only our share of the processed transactions is recognized 
as revenues. 

Impairment of Goodwill. Goodwill represents the excess of the aggregate purchase price paid 
over the fair value of the net assets acquired in our business combinations. Goodwill is not amortized 
and is tested for impairment at least annually or whenever events or changes in circumstances indicate 
that the carrying value may not be recoverable. Events or changes in circumstances that could trigger 
an impairment review include a significant adverse change in business climate, an adverse action or 
assessment by a regulator, unanticipated competition, a loss of key personnel, significant changes in the 
manner of our use of the acquired assets or the strategy for our overall business, significant negative 
industry or economic trends, or significant underperformance relative to expected historical or 
projected future results of operations. We have the option to first assess qualitative factors to determine 
whether the existence of events or circumstances leads to a determination that it is more likely than not 
that the fair value of a reporting unit is less than its carrying value, including goodwill. If, after 
assessing the totality of events or circumstances, we determine that it is not more likely than not that 
the fair value of a reporting unit is less than its carrying amount, additional impairment testing is not 
required. However, if we conclude otherwise, we are required to perform the first step of a two-step 
impairment test. Alternatively, we may elect to proceed directly to the first step of the two-step 
impairment test and bypass the qualitative assessment. The first step of the impairment test involves 

46 

 
 
 
 
 
 
 
comparing the estimated fair value of a reporting unit with its book value, including goodwill. If the 
estimated fair value exceeds book value, goodwill is considered not to be impaired and no additional 
steps are necessary. If, however, the fair value of the reporting unit is less than book value, the carrying 
amount of the goodwill is compared to its implied fair value. The estimate of implied fair value of 
goodwill may require valuations of certain internally generated and unrecognized intangible assets. If 
the carrying amount of goodwill exceeds the implied fair value of that goodwill, an impairment loss is 
recognized in an amount equal to the excess.  

In previous reporting periods (until the year ended on December 31, 2018), we operated in one 

reportable segment. Consequently, goodwill was evaluated for impairment based on an evaluation of 
the fair value of our company as a whole. Following the acquisition completed on March 25, 2019, 
management determined that we operate in two reportable segments. Therefore, for 2019, goodwill was 
tested for impairment at the reporting unit level.  

We perform annual testing for impairment of the goodwill during the third quarter of each year. 

As of September 30, 2019, the fair value of the reporting unit exceeded its carrying value. 

Recently Issued Accounting Pronouncements  

Effective January 1, 2019, we adopted ASC 842, “Leases”. In accordance with ASC 842, we 
first determine if an arrangement contains a lease and the classification of that lease, if applicable, at 
inception. ASC 842 requires the recognition of right-of-use assets and lease liabilities for our operating 
leases. We adopted ASC 842 using a modified retrospective transition method. Consequently, periods 
prior to January 1, 2019 were not restated.  

We elected to adopt the package of practical expedients permitted under ASC 842. Therefore, 
we are not required to reassess: (i) whether any expired or existing contracts are or contain leases; (ii) 
the classification of any expired or existing leases; and (iii) initial direct costs for any existing leases. 

As a result of adopting ASC 842, we recognized right-of-use assets and corresponding liabilities 

on our consolidated balance sheets, with no material impact to our consolidated statements of 
operations or consolidated statements of cash flows. Recently issued accounting pronouncements are 
described in Note 1(Significant Accounting Policies) and Note 4 (Leases) to our consolidated financial 
statements included in Item 18.  

Our Functional Currency 

The currency of the primary economic environment in which we operate is the U.S. dollar 
(“dollar”). In 2019, the majority of our revenues were denominated in dollars. In addition, the majority 
of our cash reserves and investments are denominated in dollars. Thus, the functional currency of the 
Company and certain subsidiaries is the dollar. 

The Company and certain subsidiaries’ transactions and balances denominated in dollars are 

presented at their original amounts. Non-dollar transactions and balances have been remeasured to 
dollars in accordance with Accounting Standards Codification (“ASC”) 830, “Foreign Currency 
Matters”. All transaction gains and losses from remeasurement of monetary balance sheet items 
denominated in non-dollar currencies are reflected in the statements of income as financial income or 
expenses, as appropriate. 

47 

 
 
For those subsidiaries whose functional currency has been determined to be a non-dollar 

currency, assets and liabilities are translated at year-end exchange rates, and statement of operation’s 
items are translated at average exchange rates prevailing during the year. Such translation adjustments 
are recorded as a separate component of accumulated other comprehensive income (loss) in 
shareholders’ equity.  

Impact of Foreign Currency Fluctuations on Results of Operations 

The dollar cost of our operations may be significantly influenced by currency fluctuations. 

The weakening of the dollar in global markets will have a negative effect on our profitability as 

we receive payment in dollars for most of our sales while we incur a significant portion of our 
expenses, principally salaries and related personnel expenses, in NIS and Euro.  

A devaluation of the NIS in relation to the dollar has the effect of reducing dollar amount of any 
of our expenses or liabilities which are payable in NIS, unless these expenses or payables are linked to 
the dollar. This devaluation also has the effect of decreasing the dollar value of any asset, which 
consists of NIS or receivables payable in NIS, unless the receivables are linked to the dollar.  

Any increase in the value of the NIS and/or Euro in relation to the dollar has the effect of 

increasing the dollar value of our expenses. Because exchange rates between the NIS and Euro to the 
dollar fluctuate continuously, exchange rate fluctuations and especially larger periodic devaluations 
will have an impact on our profitability and period-to-period comparisons of our results. The effects of 
foreign currency re-measurements are reported in our consolidated financial statements in current 
operations. 

B. 

Liquidity and Capital Resources  

Since our inception, we have financed our operations mainly through cash generated by 
operations. We supplemented this source by two private rounds of equity financing, the first in 1997 
(with a follow-on in 1999) and the second in 2000 and our initial public offering in 2000, which raised 
total net proceeds in the amount of $44.3 million.  

As of December 31, 2019, we had $6.5 million in cash and cash equivalents, and our working 
capital was $12.8 million. In our opinion, our working capital is sufficient for our requirements for the 
foreseeable future.  

The majority of our cash and cash equivalents and our deposits are denominated in dollars. 

Net Cash Provided by Operating Activities. Net cash provided by operating activities in 2019 

was $6.7 million, attributable to our net income of $5.1 million, non-cash related items, net, in the 
amount of $0.3 million, a net increase in operating assets and liabilities items in the amount of $1.3 
million. Net cash provided by operating activities in 2018 was $4.5 million, attributable to our net 
income of $5.1 million, non-cash related items, net, in the amount of $0.5 million, a net decrease in 
operating assets and liabilities items in the amount of $1.1 million.  

48 

 
 
 The increase in net cash provided by operating activities of $2.2 million from 2018 to 2019 

reflects mainly an increase of $1.3 million in operating assets and liabilities in 2019, compared with a 
decrease of $1.1 million in 2018.     

Net Operating Working Capital 

As of December 31, 2019, net operating working capital was $12.8 million, compared with 
$15.3 million as of December 31, 2018. The decrease of $2.5 million is mainly due to a decrease in 
cash and short-term investments used for the acquisitions of Message Mobile and GTX.  

Cash Deposits  

As of December 31, 2019, we had approximately $ 6.8 million in bank deposits with maturities 

of between three and twelve months. 

Marketable Securities 

As of December 31, 2019, we held marketable securities of $2.0 million. 

Net Cash Provided by/Used in Investing Activities. In 2019, we used cash of approximately $2.3 
million for the acquisition of subsidiaries, we decreased our investments in short-term bank deposits by 
$2.0 million, and we decreased our investments in marketable securities by $2.5 million. In 2018, we 
increased our investments in short-term bank deposits by $2.6 million, and we decreased our 
investments in marketable securities by $1.8 million.  

Net Cash Used in Financing Activities. In 2019, our financing activities used $5.1 million due 

to a cash dividend of $5.1 million. In 2018, our financing activities used $5.76 million due to a cash 
dividend of $5.8 million, offset by $0.04 million in proceeds from the exercise of employee stock 
options.  

Capital Expenditures. The aggregate cash amount of our capital expenditures was $52 thousand 

and $ 46 thousand in 2019 and 2018, respectively. These expenditures were principally for the 
purchase of equipment, mainly for our engineering teams. Although we have no material commitments 
for capital expenditures, we anticipate an increase in capital expenditures if we purchase or merge with 
companies or purchase assets in order to obtain complementary technology and to expand our product 
offerings, customer base and geographical presence.  

Cash Dividends.  Since 2003, we distributed aggregate cash dividends of $ 4.78 per share to our 

shareholders, including $0.30 per share in 2018, $0.26 per share in March 2019, and we declared a 
dividend of $0.24 per share in March 2020. For information about our dividend policy, please see Item 
8 “Financial Information - Dividend Policy.” 

C. 

Research and Development, Patents and Licenses, etc. 

We believe that investment in research and development is essential for maintaining and 
expanding our technological expertise in the market for billing and customer care software and to our 
strategy of being a leading provider of new and innovative convergent billing products. Our customers 
provide significant feedback for product development and innovation.  

49 

 
 
 
We have invested significant time and resources to create a structured process for undertaking 

research and product development. We believe that the method that we use for our product 
development and testing is well suited for identifying market needs, addressing the activities required 
to release new products, and bringing development projects to market successfully. Our product 
development activities also include the release of new versions of our products. Although we expect to 
develop new products internally, we may, based upon timing and cost considerations, acquire or license 
technologies or products from third parties. 

We invested in research and development $4.2 million (or 18.5% of total revenues) in 2019.and 
$3.7 million (or 20.7% of total revenues) in 2018. The increase in 2019 was mainly due to the inclusion 
of Message Mobile’s results of operations commencing from the second quarter of 2019 and GTX’s 
results of operations commencing from the fourth quarter of 2019.  Our engineering department 
comprised approximately 108 employees as of December 31, 2019. 

D. 

Trend Information  

Our billing and customer care solutions target tier 2 and tier 3 service providers. The trend that 
we believe is currently driving the market is replacing multiple obsolete products with one convergent 
real time billing solution. The need for comprehensive billing solutions is also driven by the market 
trend that requires service providers to introduce new services rapidly, to be innovative in creating new 
product offers and to optimize business processes for maximum efficiency. Many service providers 
seek solutions that are implemented upon a native cloud architecture. However, we have not developed 
native cloud-based solutions, and this has harmed our competitive position. 

The telecommunication market is undergoing consolidation and intensifying competition, and 
we have lost customers as a result of their exiting their business or consolidating their platform. Many 
operators that remain have very limited budgets. We expect that these trends will negatively impact our 
revenues, and more so our profitability, in 2020. 

Another trend that we expect will have an impact on our business is the growing acceptance of 
Software as a Service (SaaS) model, as both carriers and enterprises are looking at different options of 
leveraging cloud solutions to fulfill their business needs. SaaS deals typically generate lower initial 
proceeds than license deals, which has adversely impacted our revenues. We expect this trend to 
continue. 

Unified communications (UC) is an increasingly important investment for organizations 
looking to improve productivity and responsiveness while reducing their IT costs. The convergence of 
voice, video, and data communications around a shared IP-based infrastructure - allowing users to 
easily make a call, send a message, or join an audio or video conference - is bringing benefits to 
businesses of various sizes, industries and geography. 

The new business models include Unified Communications as a Service (UCaaS) or Billing as a 

Service (BaaS) along the Managed Services model we support already. 

Our goal is to develop marketing and sales relationships with the vendors of UCaaS under 
which our UC solutions (enterprise software) will be sold as part of these vendors’ offering. This 
requires us to develop new sales channels, and this process is time consuming and requires the 

50 

 
 
investment of some resources to conclude the necessary agreements and to certify and train these new 
channel partners. 

With increasing adoption, the trend we expect in the messaging business is companies turning 
to Application to Person (A2P) messaging to reach and engage with their target audience in a reliable, 
fast and secure way. Essentially, A2P messaging allows an application to send a message (typically 
SMS or IP Messaging). Examples of these types of messages include bank alerts, shipping notifications 
from online stores, appointment reminders, promotional and loyalty program notifications and two-
factor authentication one-time passcodes for account security.  

E. 

Off-balance Sheet Arrangements  

We do not have any off-balance sheet arrangements.  

F. 

Tabular Disclosure of Contractual Obligations 

Payment due by period 
($ in thousands) 

Contractual 
Obligations 

Total 

Less than 
1 year 

1-3 
years 

3-5 years 

Over 5 
years 

Operating Lease 
Obligations 

$1,368 

$312 

$702 

$289 

$65 

51 

 
 
 
 
 
 
Item 6. 

Directors, Senior Management and Employees 

A. 

Directors and Senior Management  

The following table sets forth certain information regarding our directors and executive officers 

as of the date of filing of this Annual Report: 

Name 

Age 

Position 

Monica Iancu 
Shoham Shitrit 
Gilad Parness 
Oren Tanhum 
Shoval Cohen Nissan 
Rani Ron 
Liviu Serea 
Danny Engle 
Mihail Rotenberg 
Meir Nissensohn 
Joseph Tenne  

President and Chief Executive Officer, Director 
Chief Financial Officer  
Vice President, Enterprise Solutions 
Vice President, Professional Services 

62  
40 
51 
49 
45   Vice President, Information Technology 
Vice President, Customer Solutions and Innovation 
48 
65 
General Manager, MIND Romania 
51   Vice President, Sales for North America 
Chairman of the Board of Directors 
68 
Director 
76 
Director 
64 

The background of each of our directors and executive officers is as follows:  

Monica Iancu. Ms. Iancu founded MIND and has been President and Chief Executive Officer of 
our company since inception and, until April 6, 2012, also served as the Chairperson. Ms. Iancu holds a 
B.Sc. degree in Computer Science and a Master’s degree in Telecommunications (with expertise in 
Voice and Data Integration over the Ethernet) from the Technion, Israel Institute of Technology. 

Shoham Shitrit.  Mr. Shitrit joined MIND in June 2019, bringing over ten years of experience in 

accounting and financial management in public companies. Before joining MIND, Shoham served as 
Company Controller of Elbit Systems Ltd. (NASDAQ: ESLT). Prior to that, he served for four years as 
Controller of Lumenis Ltd. (NASDAQ: LMNS). Prior thereto, Mr. Shitrit served for three years as a 
senior auditor at Ernst & Young (Israel). Mr. Shitrit holds a B.A. degree in Accounting and Economics 
from Bar- Ilan University and he is a Certified Public Accountant in Israel. 

Gilad Parness.  Mr. Parness joined MIND in 2004 as a team leader in MINDBill Support. He 
was promoted to Support Manager and later to Director of Professional Services leading the Sentori 
support team in 2007, and in 2009 joined our Sales and Account Management. Mr. Parness was 
promoted to Vice President of Enterprise Solutions in 2014 and leads the engineering, the support and 
the sales teams. Mr. Parness holds a Practical Engineer degree from Tel Chai College. 

Oren Tanhum.  Mr. Tanhum has served as our Vice President of Professional Services since 

2016. He joined MIND in July 1997 as a software engineer and was involved in the development of all 
versions of our billing platform. Throughout his almost 20 years with us, he has been promoted in the 
R&D organization, filling leadership roles at various levels. Mr. Tanhum holds a B.A. degree in 
Mathematics and Computer Science from Haifa University. 

52 

 
 
 
 
Shoval Cohen Nissan.  Mr. Cohen Nissan has served as our IT Manager since December 1998 

and was promoted to Vice President of IT in 2016. Mr. Cohen Nissan leads the planning and 
management of the supporting infrastructure company-wide and the implementation of network 
security at the corporate level. He also acts as Purchasing Manager for our internal needs and customer 
solutions. Mr. Cohen Nissan holds a Practical Engineering degree from Braude College. 

Rani Ron. Mr. Ron has served as our Vice President, Customer Solutions and Innovation since 

July 2019. He joined MIND in 1999 as a product manager and was promoted in 2004 to Product 
Management Group Leader and in 2006 to Director of Product Management. From 1996 to 1999, Mr. 
Ron worked as a software engineer at Intel Development Center in Haifa, Israel. He holds a B.Sc. in 
Computer Science from the Technion, Israel Institute of Technology.  

Liviu Serea. Mr. Serea has served as General Manager of our Romania office since January 

2001.  Before joining MIND, for over five years Mr. Serea managed a local company involved in 
hardware assembly, distribution and support. Mr. Serea holds a M.Sc. degree in Electronics and 
Telecommunications from the Politechnic Institute, Iasi, Romania.  

Danny Engle. Mr. Engle has served as the Vice President of North American Sales for MIND 

Software, Inc. (formerly Sentori, Inc.) since 2005. Mr. Engle joined Sentori in 2003 as Director of 
Sales, and we acquired Sentori in 2005. Mr. Engle is responsible for Sales, Customer Account 
Management and Partner Relationship Management. Prior to joining Sentori, Mr. Engle was District 
Manager at Siebel Systems, a leading CRM solutions provider. Mr. Engle holds a B.S. degree in 
Business Administration from the University of Texas. 

Mihail Rotenberg. Mr. Rotenberg has served as an independent director of our company since 

May 2008 and as our Chairman since May 2012. He is the founder of BreezeCOM Ltd., which merged 
to become Alvarion Ltd.  Mr. Rotenberg served as the CEO of BreezeCOM from 1993 to 2000. From 
2000 to 2005, Mr. Rotenberg served as President and CEO of Accessnet SA, a wireless internet service 
provider in Romania, which was sold in 2005 to Clearwire Inc. Mr. Rotenberg holds a Ph.D. degree 
from Polytechnic University, Bucharest, Romania.  

Meir Nissensohn. Mr. Nissensohn has served as an independent director of our company since 
August 2014. Mr. Nissensohn served as the Chairman of the Board of Directors and Chief Executive 
Officer of IBM Israel Ltd. from 1996 to 2012, having joined IBM Israel as a computer programmer in 
1969. Since his retirement from IBM, he is involved in various business initiatives with venture capital 
funds and serves as a director at several companies, including O.R.T. Technologies (TASE: ORTC) 
and Top Ramdor Systems (TASE: TOPS). Mr. Nissensohn holds a B.Sc. degree in Industrial 
Engineering from the Technion, Israeli Institute of Technology, and a post graduate degree in Business 
Administration (Finance) and an M.B.A. degree, both from Tel Aviv University. 

Joseph Tenne. Mr. Tenne has served as an independent director of our company since August 
2014. Since May 2017, Mr. Tenne served as a financial consultant to Itamar Medical Ltd. (NASDAQ 
and TASE: ITMR). Mr. Tenne serves as a director at AudioCodes Ltd., at OPC Energy Ltd., at Sapir 
Corp Ltd. and at Ratio Oil Explorations (Finance) Ltd. From 2014 to 2017, Mr. Tenne served as the 
CFO and VP Finance of Itamar Medical Ltd. From 2005 to 2013, Mr. Tenne served as the CFO of 
Ormat Technologies, Inc. (NYSE and TASE: ORA). From 1997 until 2003, Mr. Tenne was a partner in 
Kesselman & Kesselman, a member of PricewaterhouseCoopers International Limited (“PwC Israel”). 

53 

 
 
Mr. Tenne holds a B.A. degree in Accounting and Economics and an M.B.A. degree from Tel Aviv 
University. Mr. Tenne is also a Certified Public Accountant in Israel. 

 To the best of our knowledge, there are no family relationships between any of the directors or 

members of senior management named above. To the best of our knowledge, there is no arrangement 
or understanding with major shareholders, customers, suppliers or others, pursuant to which any person 
referred to above was selected as a director or member of senior management. 

B. 

Compensation of Directors and Executive Officers  

The aggregate direct remuneration paid to all persons who served in the capacity of director or 
executive officer during 2019 was $1.9 million, including $115,215 that was set aside for pension and 
retirement benefits. This does not include amounts expensed by us for automobiles made available to 
our officers or expenses, including business, travel, professional and business association dues and 
expenses, reimbursed to officers, and do not include equity-based compensation expenses.  

During 2019, we granted to our executive officers under our option plans options to purchase 

36,000 ordinary shares at exercise price of $0.003 per share. All these options expire in 2024. 

The table below outlines the compensation granted to our five most highly compensated office 

holders during or with respect to the year ended December 31, 2019. We refer to the five individuals 
for whom disclosure is provided herein as our “Covered Executives.” 

54 

 
 
 
 
 
 
Summary Compensation Table  

Name of 
Officer 

Position of 
Officer 

Salary   Cash Bonus / 
Commissions
(1) 

Equity-Based 
Compensation
(2) 

All Other 
Compensation(3) 

Total ($) 

Monica Iancu 

Shoham 
Shitrit  

Danny Engle 

President and 
Chief Executive 
Officer 
Chief Financial 
Officer (starting 
June 2019) 
Vice President 
of Sales, North 
America 

Gilad Parness  Vice President, 

Shoval Cohen 
Nisaan 

Enterprise 
Solutions 
Vice President, 
Information 
Technology 

$240,000 

$240,000 

$41,974 

$521,974 

$47,921 

$29,475 

$18,166 

$95,562 

$130,050 

$293,827 

$4,800 

$428,677 

$95,899 

$24,780 

$36,125 

$156,804 

$93,768 

$24,807 

$36,014 

$154,589 

__________________ 

(1)  Amounts reported in this column represent annual incentive bonuses granted to the Covered Executives or 
commissions based on performance-metric formulas set forth in their respective employment agreements. 

(2)  Amounts reported in this column represent the grant date fair value computed in accordance with accounting 

guidance for stock-based compensation.  

(3)  Amounts reported in this column include personal benefits and perquisites, including those mandated by applicable 
law. Such benefits and perquisites may include, to the extent applicable to the respective Covered Executive, 
payments, contributions and/or allocations for savings funds (e.g., Managers Life Insurance Policy), education 
funds (referred to in Hebrew as “keren hishtalmut”), pension, severance, vacation, car or car allowance, medical 
insurance and benefits, risk insurance (e.g., life insurance or disability insurance), convalescence or recreation pay, 
payments for social security, and other personal benefits and perquisites consistent with the Company’s guidelines. 
All amounts reported in this column represent incremental cost of the Company. 

On June 24, 2013, at our 2013 annual general meeting of shareholders, our shareholders 

approved a new compensation policy for directors and officers. In accordance with the Companies 
Law, the compensation terms of office holders of public companies are required to be determined in 
accordance with a compensation policy that is reviewed and approved at least one every three years. 
The compensation policy for directors and officers was updated and re-approved by our shareholders at 
our 2016, 2017, 2018 and 2019 annual general meetings. 

On May 4, 2017, our board of directors resolved that each of our external directors will be 

entitled to receive an annual fee of $13,200 and a participation fee of $680 per meeting. On August 9, 
2017, payment in the same amounts to each of our non-executive directors was approved by our 
shareholders. At the meeting our shareholders also approved that the remuneration of those of our 
external directors who our Board classifies as “expert external directors” (as such term is defined in the 
Israeli Companies Law) will be 20% more than the remuneration of non-expert external directors.  

C. 

Board Practices 

55 

 
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
Board of Directors 

Our board is divided into three classes of directors, denominated Class I, Class II and Class III. 

The term of Class I will expire in 2019, Class II in 2020 and Class III in 2021. Monica Iancu is a 
member of Class I, Mihail Rotenberg and Joseph Tenne are members of Class II and Meir Nissensohn 
is a member of Class III. At each annual general meeting of shareholders, directors will be elected by a 
simple majority of the votes cast for a three-year term to succeed the directors whose terms then expire. 
There is no legal limit on the number of terms that may be served by directors.  

Pursuant to regulations that took effect in April 2016, a Nasdaq-listed company that does not 

have a controlling shareholder is entitled to opt out of the provisions of the Companies Law requiring at 
least two external directors and certain related requirements, so long as the company complies with the 
SEC regulations and Nasdaq listing rules regarding independent directors and the composition of the 
audit and compensation committees.  In May 2016, our board of directors decided to adopt this relief, 
subject to the shareholder approval of related amendments to our articles of association, which occurred 
in August 2016.  

Under the Companies Law, our board of directors must determine the minimum number of 

directors having financial and accounting experience, as defined in the regulations, which our board of 
directors should have. In determining the number of directors required to have such expertise, the board 
of directors must consider, among other things, the type and size of the company and the scope and 
complexity of its operations. Our board of directors has determined that we require one director with the 
requisite financial and accounting expertise. 

Audit Committee 

 Under the Companies Law, our board of directors is required to appoint an audit committee, 

comprised of at least three directors. The members of the audit committee must satisfy certain 
independence standards under the Companies Law. Our audit committee consists of Mr. Joseph Tenne 
(Chairman of the audit committee), Mr. Mihail Rotenberg and Mr. Meir Nissensohn. 

Under the Companies Law, the roles of the audit committee include examining flaws in the 

management of the company’s business, in consultation with the internal auditor and the company’s 
independent accountants, suggesting remedial measures, approving specified related party transactions, 
establishing whistleblower procedures and assessing the company’s internal audit system and the 
performance of its internal auditor. The approval of the audit committee is required to effect specified 
actions and transactions with office holders, controlling shareholders and entities in which they have a 
personal interest.  

The Companies Law defines the term “office holder” of a company to include a director, the 

chief executive officer, the chief business manager, a vice president and any officer that reports directly 
to the chief executive officer. 

Under the Nasdaq rules, our audit committee assists the board in fulfilling its responsibility for 
oversight of the quality and integrity of our accounting, auditing and financial reporting practices and 
financial statements and the independence qualifications and performance of our independent auditors. 
Our audit committee also has the authority and responsibility to oversee our independent auditors, to 
recommend for shareholder approval the appointment and, where appropriate, replacement of our 

56 

 
 
independent auditors and to pre-approve audit engagement fees and all permitted non-audit services 
and fees. We have adopted an audit committee charter, which sets forth the qualifications, powers and 
responsibilities of our audit committee. 

Our audit committee also serves as (i) our compensation committee, as described below, and 

(ii) our nominations committee, authorized to recommend all director nominees for the selection of the 
board of directors, provided that no such recommendation is required in cases, if any, where the right to 
nominate a director legally belongs to a third party. In its capacity as our compensation committee, the 
audit committee is authorized to, among other things, review, approve and recommend to our board of 
directors base salaries, incentive bonuses, including the specific goals and amounts, stock option 
grants, employment agreements, and any other benefits, compensation or arrangements of our office 
holders. 

Under the Companies Law, at least once every three years our compensation committee is 

required to propose for shareholder approval by a special majority, a policy governing the 
compensation of office holders based on specified criteria, to review, from time to time, modifications 
to the compensation policy and examine its implementation and to approve the actual compensation 
terms of office holders prior to approval thereof by the board of directors.   

All the members of our audit committee are “independent directors” under the Nasdaq rules and 

meet the additional qualifications for membership on an audit committee and a compensation 
committee under applicable law.  

Internal Auditor 

Under the Companies Law, the board of directors must appoint an internal auditor proposed by 

the audit committee. The role of the internal auditor is to examine, among other things, whether the 
company’s actions comply with the law and orderly business procedure. The internal auditor must 
satisfy certain independence standards. Ms. Dana Gottesman-Erlich, C.P.A., partner of the accounting 
firm of BDO Israel, serves as our internal auditor. 

Fiduciary Duties of Office Holders 

The Companies Law imposes a duty of care and a duty of loyalty on all office holders of a 

company. The duty of care requires an office holder to act with the level of care with which a 
reasonable office holder in the same position would have acted under the same circumstances. The duty 
of care includes a duty to use reasonable means to obtain: 

•  information on the advisability of a given action brought for his approval or performed by 

him by virtue of his position; and  

•  all other important information pertaining to these actions. 

The duty of loyalty of an office holder includes a duty to: 

•  refrain from any conflict of interest between the performance of his duties in the company 

and the performance of his other duties or his personal affairs;  

57 

 
 
•  refrain from any activity that is competitive with the company; 

•  refrain from exploiting any business opportunity of the company to receive a personal gain 

for himself or others; and 

•  disclose to the company any information or documents relating to a company’s affairs 

which the office holder has received due to his position as an office holder. 

Disclosure of Personal Interest of an Office Holder 

The Companies Law requires that an office holder of a company disclose to the company any 

personal interest that he may have and all related material information known to him, in connection 
with any existing or proposed transaction by the company. The disclosure is required to be made 
promptly and in any event no later than the board of directors meeting in which the transaction is first 
discussed. If the transaction is an extraordinary transaction, the office holder must also disclose any 
personal interest held by:  

•  the office holder’s spouse, siblings, parents, grandparents, descendants, spouse’s 

descendants and the spouses of any of these people; or 

•  any corporation in which the office holder is a 5% or greater shareholder, director or general 
manager or in which he has the right to appoint at least one director or the general manager. 

Under Israeli law, an extraordinary transaction is a transaction:  

•  other than in the ordinary course of business;  

•  otherwise than on market terms; or 

•  that is likely to have a material impact on the company’s profitability, assets or liabilities. 

Approval of Related Party Transactions  

Once an office holder complies with the above disclosure requirement, the board of directors 

may approve a transaction between the company and an office holder, or a third party in which an 
office holder has a personal interest. A transaction that is adverse to the company’s interest may not be 
approved.  

If the transaction is an extraordinary transaction, approval of both the audit committee and the 

board of directors is required. Under specific circumstances, shareholder approval may also be 
required. 

Office Holder Compensation  

In general, all office holders’ terms of compensation – including fixed remuneration, bonuses, 
equity compensation, retirement or termination payments, indemnification, liability insurance and the 
grant of an exemption from liability – must comply with the company’s compensation policy. In 

58 

 
 
 
addition, the compensation terms of directors, the chief executive officer, and any employee or service 
provider who is considered a controlling shareholder generally must be approved separately by the 
compensation committee, the board of directors and the shareholders of the company, in that order. The 
compensation terms of other officers require the approval of the compensation committee and the board 
of directors.  

Disclosure of Personal Interests of a Controlling Shareholder 

Under the Companies Law, the disclosure requirements, which apply to an office holder, also 

apply to a controlling shareholder of a public company. For this purpose, a controlling shareholder is a 
shareholder who has the ability to direct the activities of a company, including a shareholder that owns 
25% or more of the voting rights if no other shareholder owns more than 50% of the voting rights, but 
excluding a shareholder whose power derives solely from his or her position on the board of directors 
or any other position with the company. Extraordinary transactions with a controlling shareholder or in 
which a controlling shareholder has a personal interest (other than compensation matters, which are 
discussed above under “Office Holder Compensation”), require the approval of the audit committee, 
the board of directors and the shareholders of the company, in that order. Except under specific 
circumstances, such a transaction needs to be re-approved in accordance with the foregoing procedure 
once in every three years. The shareholder approval must be by a majority of the shares voted on the 
matter, provided that either: 

•  at least a majority of the shares of shareholders who have no personal interest in the 

transaction and who vote on the matter vote in favor thereof; or 

•  the shareholders who have no personal interest in the transaction who vote against the 
transaction do not represent more than two percent of the voting rights in the company. 

Shareholders generally have the right to examine any document in the company’s possession 

pertaining to any matter that requires shareholder approval. If this information is made public in Israel 
or elsewhere, we will file the information with the Securities and Exchange Commission in the United 
States. 

For information concerning the direct and indirect personal interests of an office holder and 
principal shareholders in specified transactions with us, see Item 7.B “Related Party Transactions.” 

Executive Officers 

Our executive officers are appointed by our board of directors and serve at the discretion of our 

board of directors. We maintain written employment agreements with our executive officers. Each 
agreement terminates upon 30 days’ written notice and provides for standard terms and conditions of 
employment. All of our executive officers have agreed not to compete with us for 12 months (or 24 
months in the case of Monica Iancu) following the termination of their employment with us. Monica 
Iancu is entitled to severance pay upon termination of her employment by either her or us (other than 
by us for cause) and to receive, during each month of the six-month period following termination of her 
employment by us, or by her for cause, an amount of salary and benefits equal to her former monthly 
salary and other benefits. Under Israeli case law, the non-competition undertakings of employees may 
not be enforceable. 

59 

 
 
D. 

Employees 

The numbers and breakdowns of our employees as of the end of the past three years are set 

forth in the following table: 

As of December 31, 
2018 

2017 

2019 

Approximate numbers of employees by geographic location 

Israel 
Romania 
United States 
Germany 
   Total workforce 

Approximate numbers of employees by category of activity 

General and administration 
Research and development 
Professional services and customer support 
Sales and marketing  
   Total workforce 

41 
197 
2 
- 
240 

19 
151 
62 
8 
240 

34 
185 
2 
- 
221 

17 
144 
54 
6 
221 

25 
171 
2 
16 
214 

18 
138 
46 
12 
214 

We are subject to Israeli labor laws and regulations with respect to our Israeli employees. These 

laws principally concern matters such as paid annual vacation, paid sick days, length of the work day 
and work week, minimum wages, pay for overtime, insurance for work-related accidents, pension plans 
and severance payments upon the retirement or death of an employee or termination of employment 
under specified circumstances. The severance payments may be funded, in whole or in part, through 
Managers’ Insurance or a Pension Fund, as described below. The payments to the Managers’ Insurance 
fund or Pension Fund toward severance amount to 6% or 8.33% of base salaries. Furthermore, Israeli 
employees and employers are required to pay predetermined sums to the National Insurance Institute, 
which is similar to the U.S. Social Security Administration. Since January 1, 1995, these amounts also 
include payments for health insurance. The payments to the National Insurance Institute equal up to 
approximately 19.5% of base salaries, of which the employee contributes approximately two-thirds and 
the employer contributes approximately one-third. Our general practice in Israel is to contribute funds 
on behalf of all of our employees to Managers’ Insurance or a Pension Fund. Each employee who 
agrees to participate in the Managers’ Insurance plan contributes 6.0% of his or her base salary and we 
contribute 14.8% (and such contributions include contributions towards the severance component). 
Each employee who agrees to participate in the Pension Fund contributes 6.0% or 7.0% of his or her 
base salary and we contribute 14.8% or 15.8% (and such contributions include contributions towards 
the severance component). Another savings plan we offer some of our employees, although not legally 
required, is known as the Education Fund. Each employee who agrees to participate in the Advanced 
Studies fund contributes up to 2.5% of base salary and we contribute up to 7.5%.  

Furthermore, by order of the Israeli Ministry of Labor, Social Affairs and Social Services, all 
employers and employees are subject to provisions of collective bargaining agreements between the 
Histadrut, Federation of Labor, and the Coordination Bureau of Economic Organizations in Israel. 
These provisions principally concern cost of living increases, recreation pay, commuting expenses and 

60 

 
 
 
 
 
 
 
 
 
 
other conditions of employment. We provide our employees with benefits and working conditions 
above the required minimums. Our employees are not represented by a labor union. To date, we have 
not experienced any work stoppages and our relationships with our employees are good. 

E. 

Share Ownership 

As of March 1, 2020, Monica Iancu beneficially owned 3,316,265, or 16.67% of our ordinary 

shares. None of our other directors or members of senior management beneficially owns 1% or more of 
our ordinary shares.   

We have established stock option plans to provide for the issuance of options to our directors, 
officers and employees. Our most recent share incentive plan was adopted by our shareholders at our 
2011 annual general meeting (the “2011 Share Incentive Plan”). Under the 2011 Share Incentive Plan, 
our ordinary shares and/or options to purchase our ordinary shares may be issued from time to time to 
our directors, officers, employees, consultants and contractors at exercise prices and on other terms and 
conditions as determined by our board of directors. Our board of directors determines the exercise price 
and the vesting period of options granted. Unless otherwise is determined by our Board, any award 
granted under the 2011 Share Incentive Plan will have a four-year vesting schedule, such that 50% of 
the award will vest on the second anniversary of the commencement date and 25% of the award will 
vest on each of the third and fourth anniversaries of the commencement date. 

As of March 1, 2020, options to purchase 352,000 ordinary shares were outstanding and options 

for 2,107,290 ordinary shares had been exercised. The options vest over four years, primarily 
commencing on the date of grant. Generally, options not previously exercised will expire five years 
after they are granted. Our board of directors elected the capital gains treatment afforded under Section 
102 of the Israeli Income Tax Ordinance [New Version], 1961, or the Tax Ordinance, in respect of 
options and ordinary shares awarded to our Israeli employees under our option or share incentive plans 
after January 1, 2003. Accordingly, gains derived from options awarded to our Israeli employees and 
held by a trustee for two years from the date of grant, will generally be taxed as capital gains at a rate 
of 25%, and we will generally not be entitled to recognize an expense for the award of such options.  

On September 15, 2014, Ms. Iancu adopted a Rule 10b5-1 Sales Plan in order to establish a 

systematic program by which Oppenheimer & Co. Inc. is instructed to sell on Nasdaq up to 2,600,000 
ordinary shares held by her pursuant to the guidelines set forth therein. As of March 1, 2020, Ms. Iancu 
had sold 537,735 ordinary shares under the plan. The plan expired in September 2019. 

61 

 
 
 
 
 
Item 7. 

Major Shareholders and Related Party Transactions 

A.  Major Shareholders 

The following table sets forth certain information regarding the beneficial ownership of our 

ordinary shares as of March 1, 2020, unless otherwise specified, by each person who is known to own 
beneficially 5% or more of the outstanding ordinary shares. 

Name of 
Beneficial Owners 

Monica Iancu 
Invesco Ltd. and affiliates 
Morgan Stanley and affiliates 

Total Shares  
Beneficially Owned 
3,316,265(2) 
 1,200,000(3) 
 1,154,774(4) 

Percentage of  
Ordinary Shares (1) 
16.67% 
6.03% 
5.80% 

 _________________________ 
(1) 
(2) 
(3) 

Based on 19,896,326 ordinary shares outstanding on March 1, 2020. 
Based on a Schedule 13G/A filed with the SEC on March 5, 2015. 
Based on a Schedule 13G filed with the SEC on February 14, 2017, Invesco Advisers, Inc. is a subsidiary of 
Invesco Ltd. and advises the Invesco European Small Company Fund, which owns the foregoing shares. 
Based on a Schedule 13G filed with the SEC on February 13, 2020. 

(4) 

As of March 1, 2020, there were nine holders of record of our ordinary shares in the United 

States who collectively held less than 1% of our outstanding ordinary shares. In addition to this 
amount, there were also 16,956,919 shares held by the Depositary Trust Company in the United States. 
The number of record holders in the United States is not representative of the number of beneficial 
holders nor is it representative of where such beneficial holders are resident since many of these 
ordinary shares were held of record by brokers or other nominees.   

B. 

Related Party Transactions 

None. 

C. 

Interests of Experts and Counsel 

Not applicable. 

Item 8. 

Financial Information 

A. 

Consolidated Statements and Other Financial Information 

Financial Statements 

See Item 18. 

Export Sales 

We conduct our sales activities primarily directly, by our sales force located in the MIND 

offices in the United States and Israel. For information regarding our revenues by geographic market, 
see Item 5 — “Operating and Financial Review and Prospects.” 

62 

 
 
 
  
 
 
 
Legal Proceedings 

We are, or may be, from time to time named as a defendant in certain routine litigation 
incidental to our business. However, we are currently not a party to any legal proceedings which may 
have or have had in the recent past significant effects on our financial position or profitability.  

Dividend Policy 

Our dividend policy is distribute a cash dividend once in each calendar year, in the amount 

equal to our EBITDA plus financial income (expenses) minus taxes on income. Each dividend under 
the policy is subject to board approval and the requirements of applicable law. Our board of directors 
plans to declare the annual dividend when it approves the applicable year-end financial statements. 

B. 

Significant Changes   

Except as otherwise disclosed in this annual report, no significant change has occurred since 

December 31, 2019. 

Item 9. 

The Offer and Listing 

A. 

Offer and Listing Details 

Our ordinary shares have been listed on the Nasdaq Global Market under the symbol MNDO 

since August 8, 2000.  

B. 

Plan of Distribution 

Not applicable. 

C.  Markets 

Our ordinary shares are quoted on the Nasdaq Global Market under the symbol MNDO. 

D. 

Selling Shareholders 

Not applicable. 

E. 

Dilution 

Not applicable. 

F. 

Expenses of the Issue 

Not applicable. 

Item 10. 

Additional Information 

A. 

Share Capital 

63 

 
 
 
 
  
 
Not applicable. 

B.  Memorandum and Articles of Associations  

Objects and Purposes 

We were first registered under Israeli law on April 6, 1995 as a private company, and on August 

8, 2000 became a public company. Our registration number with the Israeli registrar of companies is 
51-213448-7. The full details of our objects and purposes can be found in Section 2 of our 
Memorandum of Association filed with the Israeli registrar of companies. Among the objects and 
purposes stipulated are the following: “to engage in any kind of commercial and/or productive business 
and to engage in any action or endeavor which the company’s managers consider to be beneficial to the 
company.” 

Transfer of Shares and Notices 

Fully paid ordinary shares are issued in registered form and may be freely transferred pursuant 

to our articles of association unless such transfer is restricted or prohibited by another instrument. 
Unless otherwise prescribed by law, we will provide at least 21 calendar days’ prior notice of any 
general shareholders meeting. 

Election of Directors 

The ordinary shares do not have cumulative voting rights in the election of directors. Thus, the 

holders of ordinary shares conferring more than 50% of the voting power have the power to elect all the 
directors, to the exclusion of the remaining shareholders. Our board of directors is divided into three 
classes of directors serving staggered three-year terms.   

Dividend and Liquidation Rights 

Dividends on our ordinary shares may be paid only out of profits and other surplus, as defined 

in the Companies Law, as of our most recent financial statements or as accrued over a period of two 
years, whichever is higher, unless otherwise approved by a court order. Our board of directors is 
authorized to declare dividends, provided that there is no reasonable concern that the dividend will 
prevent us from satisfying our existing and foreseeable obligations as they become due. In the event of 
our liquidation, after satisfaction of liabilities to creditors, our assets will be distributed to the holders 
of ordinary shares in proportion to their respective holdings. Dividend or liquidation right may be 
affected by the grant of preferential dividends or distribution rights to the holders of a class of shares 
with preferential rights that may be authorized in the future. 

Voting, Shareholders’ Meetings and Resolutions 

Holders of ordinary shares have one vote for each ordinary share held on all matters submitted 

to a vote of shareholders.  

These voting rights may be affected by the grant of any special voting rights to the holders of a 

class of shares with preferential rights that may be authorized in the future. 

We have two types of general shareholders meetings: the annual general meetings and 
extraordinary general meetings. These meetings may be held either in Israel or in any other place the 

64 

 
 
board of directors determines. An annual general meeting must be held in each calendar year, but not 
more than 15 months after the last annual general meeting. Our board of directors may convene an 
extraordinary meeting, from time to time, at its discretion and is required to do so upon the request of 
shareholders holding at least 5% of our ordinary shares. 

The quorum required for an ordinary meeting of shareholders consists of at least two 
shareholders present in person or by proxy who hold or represent between them at least 25% of the 
outstanding voting shares, unless otherwise required by applicable rules. Nasdaq generally requires a 
quorum of 33-1/3%, but we have an exemption from that requirement and instead follow the generally 
accepted business practice for companies in Israel. A meeting adjourned for lack of a quorum generally 
is adjourned to the same day in the following week at the same time and place or any time and place as 
the Chairman may designate with the consent of the shareholders voting on the matter adjourned. At 
such reconvened meeting, the required quorum consists of any two members present in person or by 
proxy, unless otherwise required by applicable rules. 

Under the Companies Law, unless otherwise provided in the articles of association or applicable 

law, all resolutions of the shareholders require a simple majority of the shares present, in person or by 
proxy, and voting on the matter. However, our articles of association require approval of 75% of the 
shares present and voting to remove directors or change the structure of our staggered board of 
directors.  

We file annual reports on Form 20-F electronically with the SEC and post a copy on our 

website. 

Duties of Shareholders 

Under the Companies Law, each and every shareholder has a duty to act in good faith in 
exercising his rights and fulfilling his obligations towards the company and other shareholders and to 
refrain from abusing his power in the company, such as in voting in the general meeting of 
shareholders on the following matters: 

•  any amendment to the articles of association; 

•  an increase of the company’s authorized share capital; 

•  a merger; or 

•  approval of certain actions and transactions which require shareholder approval. 

In addition, each and every shareholder has the general duty to refrain from depriving rights of 

other shareholders. Furthermore, any controlling shareholder, any shareholder who knows that it 
possesses the power to determine the outcome of a shareholder vote and any shareholder that, pursuant 
to the provisions of the articles of association, has the power to appoint or to prevent the appointment 
of an office holder in the company or any other power toward the company is under a duty to act in 
fairness towards the company. The Companies Law does not describe the substance of this duty of 
fairness. These various shareholder duties, which typically do not apply to shareholders of U.S. 

65 

 
 
companies, may restrict the ability of a shareholder to act in what the shareholder perceives to be its 
own best interests. 

Restrictions on Non-Israeli Residents 

The ownership or voting of our ordinary shares by non-residents of Israel, except with respect 

to citizens of countries which are in a state of war with Israel, is not restricted in any way by our 
memorandum of association or articles of association or by the laws of the State of Israel. 

Mergers and Acquisitions under Israeli Law 

The Companies Law includes provisions that allow a merger transaction and requires that each 

company that is party to a merger approve the transaction by its board of directors and a vote of the 
majority of its shares, voting on the proposed merger at a shareholders’ meeting. For purposes of the 
shareholder vote, unless a court rules otherwise, the merger will not be deemed approved if a majority 
of the shares held by parties other than the other party to the merger, or by any person who holds 25% 
or more of the shares or the right to appoint 25% or more of the directors of the other party, vote 
against the merger. Upon the request of a creditor of either party of the proposed merger, the court may 
delay or prevent the merger if it concludes that there exists a reasonable concern that as a result of the 
merger, the surviving company will be unable to satisfy the obligations of any of the parties to the 
merger. In addition, a merger may not be completed unless at least (i) 50 days have passed from the 
time that a proposal of the merger has been filed by each party with the Israeli Registrar of Companies 
and (ii) 30 days have passed since the merger was approved by the shareholders of each party. 

The Companies Law also provides that an acquisition of shares of public company must be 

made by means of tender offer if as a result of the acquisition the purchaser would become a 25% or 
more shareholder of the company and there is no 25% or more shareholder in the company. In addition, 
an acquisition of shares of a public company must be made by means of a tender offer if as a result of 
the acquisition the purchaser would become a 45% or more shareholder of the company and there is no 
45% or more shareholder in the company. These requirements do not apply if the acquisition (i) is 
made in a private placement that received shareholder approval, (ii) was from a 25% shareholder of the 
company and resulted in the acquirer becoming a 25% shareholder of the company or (iii) was from a 
45% shareholder of the company and resulted in the acquirer becoming a 45% shareholder of the 
company. The tender offer must be extended to all shareholders, but the offer or is not required to 
purchase more than 5% of the company’s outstanding shares, regardless of how many shares are 
tendered by shareholders. The tender offer may be consummated only if (i) at least 5% of the 
company’s outstanding shares will be acquired by the offer and (ii) the number of shares tendered in 
the offer exceeds the number of shares whose holders objected to the offer.   

If as a result of an acquisition of shares the acquirer will hold more than 90% of a company’s 

outstanding shares, the Companies Law requires that the acquisition be made by means of a tender 
offer for all of the outstanding shares. If as a result of a full tender offer the acquirer would own more 
than 95% of the outstanding shares, then all the shares that the acquirer offered to purchase will be 
transferred to it. The law provides for appraisal rights if any shareholder files a request in court within 
six months following the consummation of a full tender offer, although the acquirer may stipulate that 
any tendering shareholders forfeit their appraisal rights. If as a result of a full tender offer the acquirer 
would own 95% or less of the outstanding shares, then the acquirer may not acquire shares that will 
cause his shareholding to exceed 90% of the outstanding shares. 

66 

 
 
Finally, Israeli tax law treats stock-for-stock acquisitions between an Israeli company and a 

foreign company less favorably than does U.S. tax law. For example, Israeli tax law subjects a 
shareholder who exchanges his ordinary shares for shares in another corporation to taxation prior to the 
sale of the shares received in such stock-for-stock swap. 

Modification of Class Rights 

Our articles of association provide that the rights attached to any class (unless otherwise 
provided by the terms of such class), such as voting, rights to dividends and the like, may be varied by 
a shareholders resolution, subject to the approval of the holders of a majority of the issued shares of 
that class. 

Board of Directors 

According to the Companies Law and our articles of association, the oversight of the 

management of our business is vested in our board of directors. The board of directors may exercise all 
such powers and may take all such actions that are not specifically granted to our shareholders. As part 
of its powers, our board of directors may cause the company to borrow or secure payment of any sum 
or sums of money, at such times and upon such terms and conditions as it thinks fit, including the 
grants of security interests on all or any part of the property of the company.  

A resolution proposed at any meeting of the board of directors shall be deemed adopted if 

approved by a majority of the directors present and voting on the matter. For additional information, 
please see Item 6.C “Board Practices.”  

Exculpation of Office Holders 

Under the Companies Law, an Israeli company may not exempt an office holder from liability 
for a breach of his duty of loyalty, but may exempt in advance an office holder from his liability to the 
company, in whole or in part, for a breach of his duty of care (except in connection with distributions) 
provided the articles of association of the company allow it to do so. Our articles allow us to exempt 
our office holders to the fullest extent permitted by law. 

Insurance of Office Holders 

Our articles of association provide that, subject to the provisions of the Companies Law, we 

may enter into a contract for the insurance of the liability of any of our office holders, with respect to 
an act performed in the capacity of an office holder for:  

•  a breach of his duty of care to us or to another person; 

•  a breach of his duty of loyalty to us, provided that the office holder acted in good faith and 

had reasonable cause to assume that his act would not prejudice our interests; or  

•  a financial liability imposed upon him in favor of another person. 

Indemnification of Office Holders 

67 

 
 
Our articles of association provide that we may indemnify an office holder against the following 

obligations and expenses imposed on or incurred by the office holder with respect to an act performed 
in the capacity of an office holder: 

•  a financial obligation imposed on him in favor of another person by a court judgment, 

including a settlement or an arbitrator’s award approved by the court; such indemnification 
may be approved (i) after the liability has been incurred or (ii) in advance, provided that our 
undertaking to indemnify is limited to events that our board of directors believes are 
foreseeable in light of our actual operations at the time of providing the undertaking and to a 
sum or criterion that our board of directors determines to be reasonable under the 
circumstances;  

•  reasonable litigation expenses, including attorneys’ fees, expended by the office holder as a 
result of an investigation or proceeding instituted against him by a competent authority, 
provided that such investigation or proceeding concluded without the filing of an indictment 
against him and either (A) concluded without the imposition of any financial liability in lieu 
of criminal proceedings or (B) concluded with the imposition of a financial liability in lieu 
of criminal proceedings but relates to a criminal offense that does not require proof of 
criminal intent or in connection with a financial sanction;  

•  reasonable litigation expenses, including attorneys’ fees, expended by the office holder or 
charged to him by a court in connection with: (A) proceedings we institute against him or 
instituted on our behalf or by another person; or (B) a criminal charge from which he was 
acquitted; or (C) a criminal proceeding in which he was convicted of an offense that does 
not require proof of criminal intent; and 

•  a financial obligation imposed upon an office holder and reasonable litigation expenses, 
including attorney fees, expended by the office holder as a result of an administrative 
proceeding instituted against him. Without derogating from the generality of the foregoing, 
such obligation or expense will include a payment which the office holder is obligated to 
make to an injured party as set forth in Section 52(54)(a)(1)(a) of the Israeli Securities Law, 
1968 (the “Securities Law”) and expenses that the office holder incurred in connection with 
a proceeding under Chapters H’3, H’4 or I’1 of the Securities Law, including reasonable 
legal expenses, which term includes attorney fees. 

Limitations on Exculpation, Insurance and Indemnification 

The Companies Law provides that a company may not exculpate or indemnify an office holder, 

or enter into an insurance contract, which would provide coverage for any monetary liability incurred 
as a result of any of the following: 

•  a breach by the office holder of his duty of loyalty unless, with respect to indemnification or 
insurance coverage, the office holder acted in good faith and had a reasonable basis to 
believe that the act would not prejudice the company; 

•  a breach by the office holder of his duty of care if the breach was done intentionally or 

recklessly; 

68 

 
 
•  any act or omission done with the intent to derive an illegal personal benefit; or 

•  any fine levied against the office holder. 

In addition, under the Companies Law, indemnification of, and procurement of insurance 

coverage for, our office holders must be approved by our audit committee and our board of directors 
and, if the beneficiary is a director, by our shareholders. 

We have agreed to exempt from liability and indemnify our office holders to the fullest extent 

permitted under the Companies Law. We currently do not maintain directors and officers liability 
insurance for the benefit of our office holders.  

C.  Material Contracts 

None.  

D. 

Exchange Controls 

There are currently no Israeli currency control restrictions on payments of dividends or other 

distributions with respect to our ordinary shares or the proceeds from the sale of the shares, except for 
the obligation of Israeli residents to file reports with the Bank of Israel regarding certain transactions. 
However, legislation remains in effect, pursuant to which currency controls can be imposed by 
administrative action at any time. 

E. 

Taxation 

Israeli Tax Considerations  

The following is a summary of the current tax structure applicable to companies in Israel, with 
special reference to its effect on us. Note that this tax structure and any resulting benefit may not apply 
for any income derived by our foreign subsidiaries, which subsidiaries may be taxed according to tax 
laws applicable to their country of residence. The following also contains a discussion of the material 
Israeli tax consequences to persons purchasing our ordinary shares. To the extent that the discussion is 
based on tax legislation, which has not been subject to judicial or administrative interpretation, we 
cannot assure you that the tax authorities or courts will accept the views expressed in the discussion in 
question. 

Prospective purchasers of our ordinary shares should consult their own tax advisors as to the 

United States, Israeli or other tax consequences of the purchase, ownership and disposition of ordinary 
shares, including, in particular, the effect of any foreign, state or local taxes. 

General Corporate Tax Structure 

The general rate of corporate tax in Israel to which Israeli companies are subject is 23% for the 
2019 tax year and future years. The general rate of capital gains tax in Israel to which Israeli companies 
are subject is the corporate tax rate. However, the effective tax rate payable by a company which 
derives income from a “Preferred Enterprise” (as defined below) may be considerably less, as further 
discussed below. 

69 

 
 
Law for the Encouragement of Capital Investments, 1959 

General 

The Law for Encouragement of Capital Investments, 1959, or the Investments Law, as in effect 

until 2005, provided that upon application to the Investment Center of the Ministry of Industry and 
Trade of the State of Israel, a proposed capital investment in eligible facilities may be designated as an 
“Approved Enterprise.” Please see discussion below regarding a reform of the Investments Law that 
came into effect in 2011.   

Our Approved and Preferred Enterprises 

During 2011, we decided to implement the new legislation amending the Investments Law, 

while waiving future benefits provided from the Approved Enterprise program under the Investments 
Law (see more details hereinafter).   

Further information with regard to our Approved and Preferred Enterprise programs can be 
found in Item 3, “Risk Factors” under the caption “We currently benefit from local tax benefits that 
may be discontinued or reduced” and in Note 8 of our Consolidated Financial Statements under the 
caption “Taxes on Income.”  

Reform of the Investments Law - 2011 

On December 29, 2010, the Israeli parliament approved an amendment to the Investments Law, 

effective as of January 1, 2011, which constitutes a reform of the incentives regime under such law. 
This amendment revises the objectives of the Investments Law to focus on achieving enhanced growth 
in the business sector, improving the Israeli industry’s competitiveness in international markets and 
creating employment and development opportunities in remote areas of Israel. The amendment allows 
enterprises meeting certain required criteria to enjoy grants as well as tax benefits. The amendment also 
introduces certain changes to the map of geographic development areas for purposes of the Investments 
Law, which will take effect in future years.  

The amendment generally abolishes the previous tax benefit routes that were afforded under the 

Investments Law, specifically the tax-exemption periods previously allowed, and introduces new tax 
benefits for industrial enterprises meeting the criteria of the law, which include the following: 

•  A reduced corporate tax rate for industrial enterprises, provided that more than 25% of their 
annual income is derived from export, which will apply to the enterprise’s entire preferred 
income the reduced tax rate in recent years is 9% for development area A and 16% for the 
rest of Israel. Under an amendment to the Investment Law enacted in December 2016, the 
reduced tax rate of 9% decreased to 7.5% for 2017 and thereafter. 

•  The reduced tax rates will no longer be contingent upon making a minimum qualifying 

investment in productive assets. 

70 

 
 
 
 
  
 
  
 
 
•  A definition of “preferred income” was introduced into the Investments Law to include 

certain types of income that are generated by the Israeli production activity of a Preferred 
Enterprise. 

•  A reduced dividend withholding tax rate of 15% will apply to dividends paid from preferred 
income to both Israeli and non-Israeli investors, with an exemption from such withholding 
tax applying to dividends paid to an Israeli company. Under a later amendment of the 
Investments Law, the dividend withholding tax rate of 15% was increased to 20% for 
dividends paid from preferred income that accrued from the tax year 2014 and onwards. 

The amendment will generally apply to preferred income produced or generated by a Preferred 

Company (as defined in the Investments Law) commencing from January 1, 2011. The amendment 
contains various transition provisions which allow, under certain circumstances, to apply the new 
regime to investment programs previously approved or elected under the Investments Law in its 
previous form.  Although this recent amendment took effect on January 1, 2011, the transitional 
provisions of its adoption also allow the company to defer its adoption to future years.   

The 2017 amendment ("Preferred Technological Enterprises") 

Amendment 73 to the Investments Law, which came into effect on January 1, 2017, provides a 

new tax incentive regime. Regulations have been promulgated to implement the “Nexus Principles,” 
based on OECD guidelines published as part of the Base Erosion and Profit Shifting (BEPS) project. 

The new incentive regime will apply to “Preferred Technological Enterprises” that meet certain 

conditions, including all of the following: 

•  The company’s average R&D expenses in the three years prior to the current tax year must be 
greater than or equal to 7% of its total revenue or exceed NIS 75 million (approximately $20 
million) per year; and 

•  The company must satisfy one of the following conditions:  

•  at least 20% of the workforce (or at least 200 employees) are employed in R&D; 
•  a venture capital investment in an amount approximately equivalent to at least NIS 8 
million was previously made in the company, and the company has not changed its 
business following such investment; or 

•  growth in sales or workforce by an average of 25% over the three years preceding the 
applicable tax year, and the company's total revenue was at least NIS 10 million or at 
least 50 employees are employed by the company over the three years preceding the 
applicate tax year. 

A Preferred Technological Enterprises will be subject to a corporate tax rate of 12% unless it is 
located in a specified development zone, in which case the rate will be 7.5% with respect to the portion 
of income derived from intellectual property developed in Israel. The withholding tax on dividends 
from such enterprises will be 4% for dividends paid to a foreign parent company holding at least 90% 
of the shares of the distributing company. For other dividend distributions, the withholding tax rate will 
be 20% (or a lower rate under a tax treaty, if applicable).  

71 

 
 
 
 
  
 
On February 18, 2018, the Israel Tax Authority issued a tax ruling granting us “Preferred 
Technological Enterprise” status, subject to the conditions and terms of the tax ruling. The grant of the 
status means that starting January 1, 2017 we are subject to a reduced Israeli corporate tax rate of 7.5% 
on any future taxable “technological income”. 

The tax ruling applies for five years until 2021 and may be extended for further periods subject 

to receipt of an additional ruling from the Israeli Tax Authority. 

Dividends Taxation 

When dividends are distributed from the Preferred Enterprise, they are generally considered to 
be attributable to the entire enterprise and their effective tax rate is a result of a weighted combination 
of the applicable tax rates. Further information with regard to taxation of dividends can be found in 
Note 8 of our Consolidated Financial Statements.   

We paid dividends to our shareholders in the amount of $6.2 million in 2017, $5.8 million in 
2018 and $5.1 million in 2019. In March 2020, we declared a dividend of approximately $4.8 million 
and withholding tax held at a rate of 20%. 

Law for the Encouragement of Industry (Taxes), 1969 

Under the Law for the Encouragement of Industry (Taxes), 1969, or the Industry 

Encouragement Law, a company qualifies as an “Industrial Company” if it is resident in Israel and at 
least 90% of its income in a given tax year, determined in NIS, exclusive of income from capital gains, 
interest and dividends, is derived from Industrial Enterprises owned by that company. An “Industrial 
Enterprise” is defined as an enterprise whose major activity in a particular tax year is industrial 
production activity. 

Industrial Companies qualify (based on tax regulations) for accelerated depreciation rates for 

machinery, equipment and buildings used by an Industrial Enterprise. An Industrial Company owning 
an Approved Enterprise, as described above, may choose between the above depreciation rates and the 
depreciation rates available to Approved Enterprises. 

Pursuant to the Industry Encouragement Law, an Industrial Company is also entitled to 
amortize the purchase price of know-how and patents over a period of eight years beginning with the 
year in which such rights were first used. 

In addition, an Industrial Company is entitled to deduct over a three-year period expenses 

involved with the issuance and listing of shares on a stock exchange and has the right, under certain 
conditions, to elect to file a consolidated tax return with related Israeli Industrial Companies that satisfy 
conditions set forth in the law.  

Eligibility for the benefits under the law is not subject to receipt of prior approval from any 
governmental authority. We believe that we currently qualify as an Industrial Company within the 
definition of the Industry Encouragement Law. However, the definition may be amended from time to 
time and the Israeli tax authorities, which reassess our qualifications annually, may determine that we 
no longer qualify as an Industrial Company. As a result of either of the foregoing, the benefits 
described above might not be available in the future.  

72 

 
 
 
Israeli Transfer Pricing Regulations  

On November 29, 2006, Income Tax Regulations (Determination of Market Terms), 2006, 

promulgated under Section 85A of the Tax Ordinance, came into force (the “Transfer Pricing 
Regulations”). Section 85A of the Tax Ordinance and the Transfer Pricing Regulations generally 
require that all cross-border transactions carried out between related parties will be conducted on an 
arm’s length principle basis and will be taxed accordingly. 

Capital Gains Tax on the Sale of our Ordinary Shares 

General 

Israeli law generally imposes a capital gains tax on the sale of any capital assets by residents of 
Israel, as defined for Israeli tax purposes, and on the sale of assets located in Israel, including shares in 
Israeli companies, by non-residents of Israel, unless a specific exemption is available or unless a tax 
treaty between Israel and the shareholder’s country of residence provides otherwise. The law 
distinguishes between real gain and inflationary surplus. The inflationary surplus is equal to the 
increase in the purchase price of the relevant asset attributable to the increase in the Israeli consumer 
price index or, in certain circumstances, a foreign currency exchange rate, between the date of purchase 
and the date of sale. The real gain is the excess of the total capital gain over the inflationary surplus. 

Israeli Residents 

Generally, the tax rate applicable to capital gains derived from the sale of shares, whether listed 
on a stock market or not, is 25% for Israeli individuals, unless such shareholder claims a deduction for 
financing expenses in connection with such shares, in which case the gain will generally be taxed at a 
rate of 30%. Additionally, if such shareholder is considered a “significant shareholder” at any time 
during the 12-month period preceding such sale, i.e., such shareholder holds directly or indirectly, 
including with others, at least 10% of any “means of control” in the company, the tax rate will be 30%. 
However, the foregoing tax rates will not apply to individuals: (i) who are dealers in securities; or (ii) 
who acquired their shares prior to an initial public offering (that may be subject to a different tax 
arrangement). Israeli companies are subject to the corporate tax rate on capital gains derived from the 
sale of listed shares. 

Shareholders that are individuals who have taxable income that exceeds NIS 640,000 in a tax 
year (linked to the CPI each year, which amounts to NIS 649,560in the 2019 tax year), will be subject 
to an additional tax, referred to as High Income Tax, at the rate of 3% on their taxable income for such 
tax year which is in excess of such threshold. For this purpose, taxable income will include taxable 
capital gains from the sale of our shares and taxable income from dividend distributions.  

Non-Residents of Israel 

Non-Israeli residents are exempt from Israeli capital gains tax on any gains derived from the 

sale of shares publicly traded on a recognized stock market outside of Israel, provided that such capital 
gains are not derived from a permanent establishment in Israel and that such shareholders did not 
acquire their shares prior to the issuer’s initial public offering. However, non-Israeli corporations will 
not be entitled to such exemption if Israeli residents (i) have a controlling interest of more than 25% in 

73 

 
 
 
such non-Israeli corporation, or (ii) are the beneficiaries of or are entitled to 25% or more of the 
revenues or profits of such non-Israeli corporation, whether directly or indirectly.  

In some instances where our shareholders may be liable to Israeli tax on the sale of their 
ordinary shares, the payment of the consideration may be subject to the withholding of Israeli tax at the 
source.  

Pursuant to the Convention between the Government of the United States of America and the 
Government of Israel with Respect to Taxes on Income, as amended (the “U.S.- Israel Tax Treaty”), 
the sale, exchange or disposition of our ordinary shares by a person who qualifies as a resident of the 
United States and is entitled to claim the benefits afforded to a resident, or a Treaty U.S. Resident, will 
not be subject to Israeli capital gains tax unless (i) the Treaty U.S. Resident held, directly or indirectly, 
shares representing 10% or more of our voting power during any part of the 12-month period preceding 
the sale, exchange or disposition, (ii) the capital gains from such sale can be allocated to a permanent 
establishment in Israel or (iii) such Treaty U.S. Resident is an individual and was present in Israel for 
183 days or more during the relevant taxable year. A sale, exchange or disposition of our ordinary 
shares by a Treaty U.S. Resident who does not meet the above conditions will be subject to Israeli 
capital gains tax, to the extent applicable. However, under the U.S.-Israel Tax Treaty, this Treaty U.S. 
Resident would be permitted to claim a credit for such taxes against U.S. federal income tax imposed 
with respect to such sale, exchange or disposition, subject to the limitations in U.S. laws applicable to 
foreign tax credits. The U.S.-Israel Tax Treaty does not relate to state or local taxes. 

A non-resident of Israel who receives dividend income or that realizes capital gains derived 

from the sale of our ordinary shares, from which tax was withheld at the source, is generally exempted 
from the duty to file tax returns in Israel with respect to such income, provided such income was not 
derived from a business conducted in Israel by the taxpayer and the taxpayer has no other taxable 
sources of income in Israel. 

Dividend Taxation 

Income Taxes on Dividends Distributed by the Company to Israeli Residents 

The distribution of dividend income to Israeli residents will generally be subject to income tax 

at a rate of 25% for individuals and will be exempt from income tax for corporations. The portion of 
dividends paid out of profits earned under a Preferred Enterprise tax status of the Company to 
individuals is subject to withholding tax at the rate of 20%. 

In addition, if an Individual Israeli shareholder is considered a “significant shareholder” at any 

time during the 12-month period preceding such distribution, i.e., such shareholder holds directly or 
indirectly, including with others, at least 10% of any means of control in the company, the tax rate on 
the dividend (not sourced from Preferred Enterprise income) will be 30%.  

74 

 
 
For information with respect to the applicability of High Income Tax on distribution of dividends, 

see “Capital Gains Tax on Sales of Our Ordinary Shares - Taxation of Israeli Residents.” 

Income Taxes on Dividends Distributed by the Company to Non-Israeli Residents 

Subject to the provisions of applicable tax treaties, dividend distributions from regular profits 

(non-Preferred Enterprise) by the Company to a non-resident shareholder are generally subject to 
withholding tax of 25%. The portion of dividends paid out of profits earned under a Preferred 
Enterprise tax status of the Company is subject to withholding tax at the rate of 20%.  

Generally, under the U.S-Israel Tax Treaty the maximum rate of withholding tax on dividends 
paid to a shareholder who is a resident of the United States (as defined in the U.S. – Israel Tax Treaty) 
will be 25%. However, when a U.S. tax resident corporation is the recipient of the dividend, the 
withholding tax rate on a dividend out of regular (non-Approved/Preferred Enterprise) profits may be 
reduced to 12.5% under the U.S-Israel Tax Treaty, where the following conditions are met: 

(a) 

(b) 

the recipient corporation owns at least 10% of the outstanding voting rights of the Company for 
all of the period preceding the dividend during the Company’s current and prior taxable year; and 

generally not more than 25% of the gross income of the paying corporation for its prior tax year 
consists of certain interest and dividend income. 

Otherwise, the usual rates apply. Dividends paid to such U.S. corporation from income derived during 
any period for which the Israeli company is entitled to the reduced tax rate applicable to an Approved 
or Preferred Enterprise will be subject to a 15% tax rate, provided that the conditions in clauses (a) and 
(b) above are met. 

U.S. Federal Income Taxation  

Subject to the limitations described in the next paragraph, the following discussion summarizes 

the material U.S. federal income tax consequences to a “U.S. Holder” arising from the purchase, 
ownership and sale of the Ordinary Shares. For this purpose, a “U.S. Holder” is a holder of Ordinary 
Shares that is: (1) an individual citizen or resident of the United States, including an alien individual 
who is a lawful permanent resident of the United States or meets the substantial presence residency test 
under U.S. federal income tax laws; (2) a corporation (or other entity treated as a corporation for U.S. 
federal income tax purposes) or a partnership (other than a partnership that is not treated as a U.S. 
person under any applicable U.S. Treasury Regulations) created or organized in or under the laws of 
the United States or the District of Columbia or any political subdivision thereof; (3) an estate, the 
income of which is subject to U.S. federal income tax regardless of source; (4) a trust if a court within 
the United States is able to exercise primary supervision over the administration of the trust and one or 
more U.S. persons have authority to control all substantial decisions of the trust; (5) a trust that has a 
valid election in effect to be treated as a U.S. person to the extent provided in U.S. Treasury 
regulations; or (6) any person otherwise subject to U.S. federal income tax on a net income basis in 
respect of the Ordinary Shares, if such status as a U.S. Holder is not overridden pursuant to the 
provisions of an applicable tax treaty. 

75 

 
 
 
 
 
This summary is for general information purposes only and does not purport to be a 

comprehensive description of all of the U.S. federal income tax considerations that may be relevant to a 
decision to purchase or hold our Ordinary Shares. This summary generally considers only U.S. Holders 
that will own our Ordinary Shares as capital assets. Except to the limited extent discussed below, this 
summary does not consider the U.S. federal tax consequences to a person that is not a U.S. Holder, nor 
does it describe the rules applicable to determine a taxpayer’s status as a U.S. Holder. This summary is 
based on the provisions of the Internal Revenue Code of 1986, as amended, or the Code, final, 
temporary and proposed U.S. Treasury Regulations promulgated thereunder, administrative and 
judicial interpretations thereof, and the U.S./Israel Income Tax Treaty, all as in effect as of the date 
hereof and all of which are subject to change, possibly on a retroactive basis, and all of which are open 
to differing interpretations. The Company will not seek a ruling from the U.S. Internal Revenue 
Service, or the IRS, with regard to the U.S. federal income tax treatment of an investment in our 
Ordinary Shares by U.S. Holders and, therefore, can provide no assurances that the IRS will agree with 
the conclusions set forth below. 

This discussion does not address all of the aspects of U.S. federal income taxation that may be 

relevant to a particular shareholder based on such shareholder’s particular circumstances and in 
particular does not discuss any estate, gift, generation-skipping, transfer, state, local or foreign tax 
considerations. In addition, this discussion does not address the U.S. federal income tax treatment of a 
U.S. Holder who is: (1) a bank, life insurance company, regulated investment company, or other 
financial institution or “financial services entity”; (2) a broker or dealer in securities or foreign 
currency; (3) a person who acquired our Ordinary Shares in connection with employment or other 
performance of services; (4) a U.S. Holder that is subject to the U.S. alternative minimum tax; (5) a 
U.S. Holder that holds our Ordinary Shares as a hedge or as part of a hedging, straddle, conversion or 
constructive sale transaction or other risk-reduction transaction for U.S. federal income tax purposes; 
(6) a tax-exempt entity; (7) real estate investment trusts; (8) a U.S. Holder that expatriates out of the 
United States or a former long-term resident of the United States; or (9) a person having a functional 
currency other than the dollar. This discussion does not address the U.S. federal income tax treatment 
of a U.S. Holder that owns, directly or constructively, at any time, Ordinary Shares representing 10% 
or more of our voting power. Additionally, the U.S. federal income tax treatment of persons who hold 
Ordinary Shares through a partnership or other pass-through entity are not considered. 

You are encouraged to consult your own tax advisor with respect to the specific U.S. federal 

and state income tax consequences to you of purchasing, holding or disposing of our Ordinary Shares, 
including the effects of applicable state, local, foreign or other tax laws and possible changes in the tax 
laws. 

Distributions on Ordinary Shares 

Subject to the discussion under the heading “Passive Foreign Investment Companies” below, a 

U.S. Holder will be required to include in gross income as ordinary income the amount of any 
distribution paid on Ordinary Shares (including the amount of any Israeli tax withheld on the date of 
the distribution), to the extent that such distribution does not exceed our current and accumulated 
earnings and profits, as determined for U.S. federal income tax purposes. The amount of a distribution 
which exceeds our earnings and profits will be treated first as a non-taxable return of capital, reducing 
the U.S. Holder’s tax basis for the Ordinary Shares to the extent thereof, and then capital gain. 
Corporate holders generally will not be allowed a deduction for dividends received. For noncorporate 

76 

 
 
U.S. Holders, to the extent that their total adjusted income does not exceed applicable thresholds, the 
maximum federal income tax rate for “qualified dividend income” and long-term capital gains is 
generally 15%. For those noncorporate U.S. Holders whose total adjusted income exceeds such income 
thresholds, the maximum federal income tax rate for “qualified dividend income” and long-term capital 
gains is generally 20%. For this purpose, “qualified dividend income” means, among other things, 
dividends received from a “qualified foreign corporation.” A “qualified foreign corporation” is a 
corporation that is entitled to the benefits of a comprehensive tax treaty with the United States which 
includes an exchange of information program. The IRS has stated that the Israel/U.S. Tax Treaty 
satisfies this requirement and we believe we are eligible for the benefits of that treaty. 

In addition, our dividends will be qualified dividend income if our Ordinary Shares are readily 

tradable on Nasdaq or another established securities market in the United States. Dividends will not 
qualify for the preferential rate if we are treated, in the year the dividend is paid or in the prior year, as 
a passive foreign investment company, or PFIC. A U.S. Holder will not be entitled to the preferential 
rate: (1) if the U.S. Holder has not held our Ordinary Shares or ADRs for at least 61 days of the 121-
day period beginning on the date which is 60 days before the ex-dividend date, or (2) to the extent the 
U.S. Holder is under an obligation to make related payments on substantially similar property. Any 
days during which the U.S. Holder has diminished its risk of loss on our Ordinary Shares are not 
counted towards meeting the 61-day holding period. Finally, U.S. Holders who elect to treat the 
dividend income as “investment income” pursuant to Code section 163(d)(4) will not be eligible for the 
preferential rate of taxation. 

The amount of a distribution with respect to our Ordinary Shares will be measured by the 

amount of the fair market value of any property distributed, and for U.S. federal income tax purposes, 
the amount of any Israeli taxes withheld therefrom. (See discussion above under “Israeli Tax 
Considerations - Dividend Taxation.”) Cash distributions paid by us in NIS will be included in the 
income of U.S. Holders at a dollar amount based upon the spot rate of exchange in effect on the date 
the dividend is includible in the income of the U.S. Holder, and U.S. Holders will have a tax basis in 
such NIS for U.S. federal income tax purposes equal to such dollar value. If the U.S. Holder 
subsequently converts the NIS, any subsequent gain or loss in respect of such NIS arising from 
exchange rate fluctuations will be U.S. source ordinary exchange gain or loss. 

Distributions paid by us will generally be foreign source income for U.S. foreign tax credit 

purposes. Subject to the limitations set forth in the Code, U.S. Holders may elect to claim a foreign tax 
credit against their U.S. income tax liability for Israeli income tax withheld from distributions received 
in respect of the Ordinary Shares. In general, these rules limit the amount allowable as a foreign tax 
credit in any year to the amount of regular U.S. tax for the year attributable to foreign source taxable 
income. This limitation on the use of foreign tax credits generally will not apply to an electing 
individual U.S. Holder whose creditable foreign taxes during the year do not exceed $300, or $600 for 
joint filers, if such individual’s gross income for the taxable year from non-U.S. sources consists solely 
of certain passive income. A U.S. Holder will be denied a foreign tax credit with respect to Israeli 
income tax withheld from dividends received with respect to the Ordinary Shares if such U.S. Holder 
has not held the Ordinary Shares for at least 16 days out of the 31-day period beginning on the date that 
is 15 days before the ex-dividend date or to the extent that such U.S. Holder is under an obligation to 
make certain related payments with respect to substantially similar or related property. Any day during 
which a U.S. Holder has substantially diminished his or her risk of loss with respect to the Ordinary 
Shares will not count toward meeting the 16-day holding period. A U.S. Holder will also be denied a 

77 

 
 
foreign tax credit if the U.S. Holder holds the Ordinary Shares in an arrangement in which the U.S. 
Holder’s reasonably expected economic profit is insubstantial compared to the foreign taxes expected 
to be paid or accrued. The rules relating to the determination of the U.S. foreign tax credit are complex, 
and U.S. Holders should consult with their own tax advisors to determine whether, and to what extent, 
they are entitled to such credit. U.S. Holders that do not elect to claim a foreign tax credit may instead 
claim a deduction for Israeli income taxes withheld, provided such U.S. Holders itemize their 
deductions. 

Disposition of Shares 

Except as provided under the PFIC rules described below, upon the sale, exchange or other 
disposition of our Ordinary Shares, a U.S. Holder will recognize capital gain or loss in an amount equal 
to the difference between such U.S. Holder’s tax basis in the sold Ordinary Shares and the amount 
realized on the disposition of such Ordinary Shares (or its dollar equivalent determined by reference to 
the spot rate of exchange on the date of disposition, if the amount realized is denominated in a foreign 
currency). The gain or loss realized on the sale or exchange or other disposition of Ordinary Shares will 
be long-term capital gain or loss if the U.S. Holder has a holding period of more than one year at the 
time of the disposition. 

In general, gain realized by a U.S. Holder on a sale, exchange or other disposition of Ordinary 

Shares will generally be treated as U.S. source income for U.S. foreign tax credit purposes. A loss 
realized by a U.S. Holder on the sale, exchange or other disposition of Ordinary Shares is generally 
allocated to U.S. source income. However, U.S. Treasury Regulations require such loss to be allocated 
to foreign source income to the extent specified dividends were received by the taxpayer within the 24-
month period preceding the date on which the taxpayer recognized the loss. The deductibility of a loss 
realized on the sale, exchange or other disposition of Ordinary Shares is subject to limitations. 

Tax on Net Investment Income 

U.S. Holders who are individuals, estates or trusts will generally be required to pay 3.8% tax on 
their net investment income (including dividends on and gains from the sale or other disposition of our 
Ordinary Shares), or in the case of estates and trusts on their net investment income that is not 
distributed. In each case, the 3.8% Medicare tax applies only to the extent the U.S. Holder’s total 
adjusted income exceeds applicable thresholds. 

Passive Foreign Investment Companies 

Special U.S. federal income tax laws apply to a U.S. Holder who owns shares of a corporation 
that was (at any time during the U.S. Holder’s holding period) a PFIC. We would be treated as a PFIC 
for U.S. federal income tax purposes for any tax year if, in such tax year, either: 

• 75% or more of our gross income (including our pro rata share of gross income for any 
company, U.S. or foreign, in which we are considered to own 25% or more of the shares by value), in a 
taxable year is passive (the “Income Test”); or  

• At least 50% of our assets, averaged over the year and generally determined based upon value 

(including our pro rata share of the assets of any company in which we are considered to own 25% or 

78 

 
 
 
  
more of the shares by value), in a taxable year are held for the production of, or produce, passive 
income (the “Asset Test”).   

For this purpose, passive income generally consists of dividends, interest, rents, royalties, 

annuities and income from certain commodities transactions and from notional principal contracts. 
Cash is treated as generating passive income. 

If we are or become a PFIC, each U.S. Holder who has not elected to treat us as a qualified 
electing fund by making a “QEF election”, or who has not elected to mark the shares to market (as 
discussed below), would, upon receipt of certain distributions by us and upon disposition of our 
Ordinary Shares at a gain, be liable to pay U.S. federal income tax at the then prevailing highest tax 
rates on ordinary income plus interest on such tax, as if the distribution or gain had been recognized 
ratably over the taxpayer’s holding period for the Ordinary Shares. In addition, when shares of a PFIC 
are acquired by reason of death from a decedent that was a U.S. Holder, the tax basis of such shares 
would not receive a step-up to fair market value as of the date of the decedent’s death, but instead 
would be equal to the decedent’s basis if lower, unless all gain were recognized by the decedent. 
Indirect investments in a PFIC may also be subject to special U.S. federal income tax rules. 

The PFIC rules would not apply to a U.S. Holder who makes a QEF election for all taxable 

years that such U.S. Holder has held the Ordinary Shares while we are a PFIC, provided that we 
comply with specified reporting requirements. Instead, each U.S. Holder who has made such a QEF 
election is required for each taxable year that we are a PFIC to include in income such U.S. Holder’s 
pro rata share of our ordinary earnings as ordinary income and such U.S. Holder’s pro rata share of 
our net capital gains as long-term capital gain, regardless of whether we make any distributions of such 
earnings or gain. In general, a QEF election is effective only if we make available certain required 
information. The QEF election is made on a shareholder-by-shareholder basis and generally may be 
revoked only with the consent of the IRS. U.S. Holders should consult with their own tax advisors 
regarding eligibility, manner and advisability of making a QEF election if we are treated as a PFIC. 

A U.S. Holder of PFIC shares which are traded on qualifying public markets, including the 

Nasdaq, can elect to mark the shares to market annually, recognizing as ordinary income or loss each 
year an amount equal to the difference as of the close of the taxable year between the fair market value 
of the PFIC shares and the U.S. Holder’s adjusted tax basis in the PFIC shares. Losses are allowed only 
to the extent of net mark-to-market gain previously included income by the U.S. Holder under the 
election for prior taxable years. 

In light of the complexity of PFIC rules, we cannot assure you that we have not been or are not 
a PFIC or will avoid becoming a PFIC in the future. U.S. Holders who hold Ordinary Shares during a 
period when we are a PFIC will be subject to the foregoing rules, even if we cease to be a PFIC, subject 
to specified exceptions for U.S. Holders who made a QEF or mark-to-market election. U.S. Holders are 
strongly urged to consult their tax advisors about the PFIC rules, including tax return filing 
requirements and the eligibility, manner, and consequences to them of making a QEF or mark-to-
market election with respect to our Ordinary Shares in the event we that qualify as a PFIC. 

Information Reporting and Withholding 

79 

 
 
 
A U.S. Holder may be subject to backup withholding (at a rate of 24%) with respect to cash 
dividends and proceeds from a disposition of Ordinary Shares. In general, back-up withholding will 
apply only if a U.S. Holder fails to comply with specified identification procedures. Backup 
withholding will not apply with respect to payments made to designated exempt recipients, such as 
corporations and tax-exempt organizations. Backup withholding is not an additional tax and may be 
claimed as a credit against the U.S. federal income tax liability of a U.S. Holder, provided that the 
required information is timely furnished to the IRS. 

Under the Hiring Incentives to Restore Employment Act of 2010 (the “HIRE Act”), some 

payments made to “foreign financial institutions” in respect of accounts of U.S. stockholders at such 
financial institutions may be subject to withholding at a rate of 30%. U.S. Treasury Regulations provide 
that such withholding will only apply to distributions paid on or after January 1, 2014, and to other 
“withholdable payments” (including payments of gross proceeds from a sale or other disposition of our 
Ordinary Shares) made on or after January 1, 2017. U.S. Holders should consult their tax advisors 
regarding the effect, if any, of the HIRE Act on their ownership and disposition of our Ordinary Shares. 
See “Non-U.S. Holders of Ordinary Shares.” 

Non-U.S. Holders of Ordinary Shares 

Except as provided below, an individual, corporation, estate or trust that is not a U.S. Holder 

generally will not be subject to U.S. federal income or withholding tax on the payment of dividends on, 
and the proceeds from the disposition of, our Ordinary Shares. 

A non-U.S. Holder may be subject to U.S. federal income or withholding tax on a dividend paid 
on our Ordinary Shares or the proceeds from the disposition of our Ordinary Shares if: (1) such item is 
effectively connected with the conduct by the non-U.S. Holder of a trade or business in the United 
States or, in the case of a non-U.S. Holder that is a resident of a country which has an income tax treaty 
with the United States, such item is attributable to a permanent establishment or, in the case of gain 
realized by an individual non-U.S. Holder, a fixed place of business in the United States; (2) in the case 
of a disposition of our Ordinary Shares, the individual non-U.S. Holder is present in the United States 
for 183 days or more in the taxable year of the sale and other specified conditions are met; (3) the non-
U.S. Holder is subject to U.S. federal income tax pursuant to the provisions of the U.S. tax law 
applicable to U.S. expatriates. 

In general, non-U.S. Holders will not be subject to backup withholding with respect to the 
payment of dividends on our Ordinary Shares if payment is made through a paying agent, or office of a 
foreign broker outside the United States. However, if payment is made in the United States or by a U.S. 
related person, non-U.S. Holders may be subject to backup withholding, unless the non-U.S. Holder 
provides on an applicable Form W-8 (or a substantially similar form) a taxpayer identification number, 
certifies to its foreign status, or otherwise establishes an exemption. A U.S. related person for these 
purposes is a person with one or more current relationships with the United States. 

The amount of any backup withholding from a payment to a non-U.S. Holder will be allowed as 

a credit against such holder’s U.S. federal income tax liability and may entitle such holder to a refund, 
provided that the required information is timely furnished to the IRS. 

80 

 
 
The HIRE Act may impose withholding taxes on some types of payments made to “foreign 
financial institutions” and some other non-U.S. entities. Under the HIRE Act, the failure to comply 
with additional certification, information reporting and other specified requirements could result in 
withholding tax being imposed on payments of dividends and sales proceeds to U.S. Holders that own 
Ordinary Shares through foreign accounts or foreign intermediaries and specified non-U.S. Holders. 
The HIRE Act imposes a 30% withholding tax on dividends on, and gross proceeds from the sale or 
other disposition of, Ordinary Shares paid from the United States to a foreign financial institution or to 
a foreign nonfinancial entity, unless (1) the foreign financial institution undertakes specified diligence 
and reporting obligations or (2) the foreign nonfinancial entity either certifies it does not have any 
substantial U.S. owners or furnishes identifying information regarding each substantial U.S. owner. In 
addition, if the payee is a foreign financial institution, it generally must enter into an agreement with 
the U.S. Treasury that requires, among other things, that it undertake to identify accounts held by 
specified U.S. persons or U.S.-owned foreign entities, annually report certain information about such 
accounts, and withhold 30% on payments to other specified account holders. U.S. Treasury Regulations 
provide that such withholding will only apply to distributions paid on or after January 1, 2014, and to 
other “withholdable payments” (including payments of gross proceeds from a sale or other disposition 
of our Ordinary Shares) made on or after January 1, 2017. You should consult your tax advisor 
regarding the HIRE Act. 

F. 

Dividends and paying agents 

Not applicable. 

G. 

Statement by Experts  

Not applicable. 

H. 

Documents on Display 

We are subject to certain of the information reporting requirements of the Securities Exchange 

Act of 1934, or the Exchange Act. As a foreign private issuer, we are exempt from the rules and 
regulations under the Exchange Act prescribing the content of proxy statements, and our officers, 
directors and principal shareholders are exempt from the reporting and “short-swing” profit recovery 
provisions contained in Section 16 of the Exchange Act, with respect to their purchase and sale of our 
shares. In addition, we are not required to file reports and financial statements with the SEC as 
frequently or as promptly as U.S. companies whose securities are registered under the Exchange Act. 
However, we are required to file with the SEC, within four months after the end of each fiscal year, an 
annual report on Form 20-F containing financial statements audited by an independent accounting firm. 
We publish unaudited interim financial information after the end of each quarter. We furnish this 
quarterly financial information to the SEC under cover of a Form 6-K. 

We are subject to the informational requirements of the Securities Exchange Act of 1934, as 

amended, applicable to foreign private issuers and fulfill the obligations with respect to such 
requirements by filing reports with the Securities and Exchange Commission, or SEC. You may read 
and copy any document we file, including any exhibits, with the SEC without charge at the SEC’s 
public reference room at 100 F Street, N.E., Washington, D.C. 20549.Copies of such material may be 
obtained by mail from the Public Reference Branch of the SEC at such address, at prescribed rates. 

81 

 
 
Please call the SEC at 1-800-SEC-0330 for further information on the public reference room. Certain of 
our SEC filings are also available to the public at the SEC’s website at http://www.sec.gov, and on our 
website at http://www.mindcti.com. 

 You may request a copy of our SEC filings, at no cost, by e-mailing to investor@mindcti.com 

and upon said request copies will be sent by e-mail. A copy of each report submitted in accordance 
with applicable U.S. law is available for review at our principal executive offices. 

I.  

Subsidiary Information 

Not applicable. 

Item 11. 

Quantitative and Qualitative Disclosures about Market Risk  

Market risk represents the risk of changes in the value of our financial instruments as a result of 

fluctuations in foreign currency exchange rates.  

The following table sets forth our consolidated balance sheet exposure with respect to change in 

foreign currency exchange rates as of December 31, 2019. 

Currency 

NIS ....................................................................................................  
EURO ................................................................................................  
Romanian RON .................................................................................  
Other non-dollar currencies ...............................................................  

Current  
Monetary Assets  
(Liabilities)-Net 
(dollars in thousands) 
$365 
416 
217
(
170 
$734 

)

Our annual expenses paid in NIS are approximately $ 34.

 million. Accordingly, we estimate that 

a hypothetical increase of the value of the NIS against the dollar by 1% would result in an increase in 
our operating expenses by approximately $ 34  thousand for the year ended December 31, 2019. 

We are exposed to changes in prices of various securities in which we invest. As of December 

31, 2019, we held short term investments (mainly highly rated municipal bonds) of $2.0 million, which 
are held for trading and presented in the balance sheet as marketable securities. These debt securities 
are exposed to potential loss in market value due to a decline in debt securities prices. The potential 
loss in fair value resulting from a 10% adverse change in debt securities prices would be approximately 
$0.2 million. 

As of December 31, 2019, we did not hold any derivative financial instruments for either 

trading or non-trading purposes.  

Item 12. 

Description of Securities Other Than Equity Securities 

None. 

82 

 
 
 
 
 
PART II 

Item 13. 

Defaults, Dividend Arrearages and Delinquencies 

Not applicable. 

Item 14. 

Material Modifications to the Rights of Security Holders and Use of Proceeds   

None. 

Item 15. 

Controls and Procedures 

Disclosure Controls and Procedures 

We performed an evaluation of the effectiveness of the design and operation of our disclosure 

controls and procedures (as defined in Rule 13a-15(e) and 15d-15(e) under the Securities Exchange Act 
of 1934) as of December 31, 2019. The evaluation was performed with the participation of our senior 
management and under the supervision and with the participation of our chief executive officer and 
chief financial officer. Based on this evaluation, our chief executive officer and chief financial officer 
have concluded that our disclosure controls and procedures were effective as of December 31, 2019.  

Management’s Annual Report on Internal Control over Financial Reporting  

Our management, including our chief executive officer and chief financial officer, is 
responsible for establishing and maintaining adequate internal control over our financial reporting, as 
such term is defined in Rule 13a-15(f) under the Securities Exchange Act. Our internal control system 
was designed to provide reasonable assurance to our management and our board of directors regarding 
the reliability of financial reporting and the preparation and fair presentation of published financial 
statements for external purposes in accordance with generally accepted accounting principles. All 
internal control systems, no matter how well designed, have inherent limitations. Therefore, even those 
systems determined to be effective can provide only reasonable assurances with respect to financial 
statement preparation and presentation. Also, projections of any evaluation of effectiveness to future 
periods are subject to the risk that controls may become inadequate because of changes in conditions, 
or that the degree of compliance with the policies or procedures may decline. 

Our management (with the participation of our chief executive officer and chief financial officer) 
conducted  an  evaluation,  pursuant  to  Rule  13a-15(c)  under  the  Securities  Exchange  Act,  of  the 
effectiveness, as of the end of the period covered by this Annual Report, of our internal  control over 
financial reporting based on the criteria set forth in the Internal Control-Integrated Framework (2103 
framework) issued by the Committee of Sponsoring Organizations of the Treadway Commission. Based 
on  the  results  of  this  evaluation,  management  assessed  the  effectiveness  of  our  internal  control  over 
financial  reporting  as  at  December 31,  2019  and  concluded  that  our  internal  control  over  financial 
reporting was effective as of December 31, 2019.  

 Attestation Report of the Registered Public Accounting Firm 

83 

 
 
 
  
Not applicable.  

Changes in Financial Control over Financial Reporting 

There were no changes in our internal control over financial reporting that occurred during 2019 
that have materially affected, or that are reasonably likely to materially affect, our internal control over 
financial reporting.  

Item 16A. 

Audit Committee Financial Expert 

Our board of directors has designated Mr. Joseph Tenne as our “audit committee financial 

expert”, as defined by the SEC rules. 

Item 16B. 

Code of Ethics 

We have adopted a Code of Ethics that applies to all of our directors, officers and employees, 

including our principal executive and financial officers. The Code of Ethics is publicly available on our 
website at www.mindcti.com. If we make any substantive amendments to the Code of Ethics or grant 
any waiver from a provision of this code to our chief executive officer, principal financial officer, 
principal accounting officer or controller, we will either disclose the nature of such amendment or 
waiver on our website or in our annual report on Form 20-F. 

Item 16C. 

Principal Accountant Fees and Services 

At the annual meeting held on May 26, 2019, our shareholders re-appointed Brightman 
Almagor Zohar & Co., certified public accountants in Israel and a firm in the Deloitte Global Network, 
as our independent auditor until the close of the following year’s annual general meeting. Brightman 
Almagor Zohar has served as our independent auditor since 2009.  

Brightman Almagor Zohar billed the following fees to us for professional services in each of 

the last two fiscal years: 

Audit Fees 
Audit-Related Fees 
Tax Fees 
Total 

Years Ended December 31, 

2018 

2019 

$80,261 
- 
- 
$80,261 

$84,163 
- 
- 
$84,163 

Our audit committee’s policy is to approve each audit and non-audit service to be performed by 

our independent accountant before the accountant is engaged. 

Item 16D. 

Exemptions from the Listing Standards for Audit Committees 

Not applicable. 

84 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Item 16E. 

Purchases of Equity Securities by the Issuer and Affiliated Purchasers 

 None.  

Item 16F. 

Change in Registrant’s Certifying Accountant  

Not applicable. 

Item 16G. 

Corporate Governance 

We follow the Israeli Companies Law, the relevant provisions of which are summarized 
in this annual report, rather than comply with the Nasdaq requirement relating to the quorum for 
shareholder meetings, as described in Item 10.B “Additional Information – Memorandum and 
Articles of Association – Voting, Shareholders’ Meetings and Resolutions”, and rather than 
comply with the Nasdaq requirements relating to compensation committees (other than the due 
composition thereof), our audit committee (in its capacity as our compensation committee) 
fulfills the duties of a compensation committee in accordance with the Companies Law, as 
described in Item 6 “Directors, Senior Management and Employees - Board Practices.”  In 
addition, we are exempt from Nasdaq’s requirement to send an annual report to shareholders 
prior to our annual general meetings. Instead, we file annual reports on Form 20-F electronically 
with the SEC and post a copy on our website. 

Item 16H. Mine Safety Disclosure 

Not applicable. 

Item 17. 

Financial Statements 

Not applicable. 

Item 18. 

Financial Statements 

PART III 

See pages F-1 through F-29 of this annual report attached hereto.  

85 

 
 
 
 
 
 
 
Item 19. 

Exhibits   

The following exhibits are filed as part of this Annual Report: 

Exhibit No.  Exhibit 

1.1* 

1.2** 

2(d) 

4.1*** 

4.2*** 

4.3**** 

4.4***** 

8 

11**** 

12.1 

12.2 

13.1 

13.2 

15.1  

101 

Memorandum of Association, as amended  

Articles of Association, as amended 

Description of Ordinary Shares 

MIND 1998 Share Option Plan 

MIND 2000 Share Option Plan 

MIND 2011 Share Incentive Plan  

Compensation Policy of Directors and Officers, dated May 26, 2019 

List of Subsidiaries 

Code of Ethics and Business Conduct 

Certification of Principal Executive Officer pursuant to 17 CFR 240.13a-14(a), as 
adopted pursuant to §302 of the Sarbanes-Oxley Act 

Certification of Principal Financial Officer pursuant to 17 CFR 240.13a-14(a), as 
adopted pursuant to §302 of the Sarbanes-Oxley Act 

Certification of Principal Executive Officer pursuant to 18 U.S.C. § 1350, as 
adopted pursuant to § 906 of the Sarbanes-Oxley Act 

Certification of Principal Financial Officer pursuant to 18 U.S.C. § 1350, as 
adopted pursuant to § 906 of the Sarbanes-Oxley Act  

Consent of Brightman Almagor Zohar & Co., a firm in the Deloitte Global 
Network 

The following financial information from MIND C.T.I. Ltd.’s Annual Report on 
Form 20-F for the year ended December 31, 2019, formatted in XBRL (eXtensible 
Business Reporting Language):  

(i) 
(ii) 

Consolidated Balance Sheets at December 31, 2019 and 2018; 
Consolidated Statements of Operations for the years ended December 
31, 2019, 2018 and 2017; 

(iii)  Consolidated Comprehensive Income for the years ended December 

31, 2019, 2018 and 2017; 

(iv)  Consolidated Statements of Changes in Shareholders’ Equity for the 

years ended December 31, 2019, 2018 and 2017; 
 Consolidated Statements of Cash Flows for the years ended December 
31, 2019, 2018 and 2017; and 
 Notes to Consolidated Financial Statements, tagged as blocks of text 

(v) 

(vi) 

86 

 
 
 
 
* 

** 

*** 

**** 

***** 

Incorporated by reference to MIND C.T.I. Ltd.’s Annual Report on Form 20-F for the fiscal 
year ended December 31, 2002.  

Incorporated by reference to MIND C.T.I. Ltd.’s Annual Report on Form 20-F for the fiscal 
year ended December 31, 2016.  

Incorporated by reference to MIND C.T.I. Ltd.’s Annual Report on Form 20-F for the fiscal 
year ended December 31, 2003.  

Incorporated by reference to MIND C.T.I. Ltd.’s Annual Report on Form 20-F for the fiscal 
year ended December 31, 2011.  

Incorporated by reference to MIND C.T.I. Ltd.’s Annual Report on Form 20-F for the fiscal 
year ended December 31, 2013.  

The Registrant hereby certifies that it meets all of the requirements for filing on Form 20-F and 

has duly caused and authorized the undersigned to sign this annual report on its behalf. 

SIGNATURES 

MIND CTI LTD. 

/s/ Monica Iancu 

By: Monica Iancu 
Title: President & CEO 
Date: March 18, 2020   

87 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Exhibit 8 

LIST OF SUBSIDIARIES 

Name of Subsidiary 

MIND Software SRL 

MIND Software, Inc. 

Jurisdiction of Incorporation 

Romania 

Delaware 

MIND Software Limited 

United Kingdom 

MIND CTI GmbH 

Message Mobile GmbH 

GTX Messaging GmbH 

Germany 

Germany 

Germany 

88 

 
 
 
 
 
 
Exhibit 12.1 

Certification of Principal Executive Officer pursuant to 17 CFR 240.13a-14(a), 
as adopted pursuant to §302 of the Sarbanes-Oxley Act 

I, Monica Iancu, certify that: 

1.  I have reviewed this annual report on Form 20-F of MIND C.T.I. Ltd.; 

2.  Based on my knowledge, this report does not contain any untrue statement of a material fact or 
omit to state a material fact necessary to make the statements made, in light of the circumstances 
under which such statements were made, not misleading with respect to the period covered by 
this report; 

3.  Based on my knowledge, the financial statements, and other financial information included in 
this report, fairly present in all material respects the financial condition, results of operations and 
cash flows of the company as of, and for, the periods presented in this report; 

4.  The  company’s  other  certifying  officer  and  I  are  responsible  for  establishing  and  maintaining 
disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) 
and internal  control over financial reporting (as defined in Exchange Act  Rules 13a-15(f) and 
15d-15(f)) for the company and have: 

a.  designed such disclosure controls and procedures, or caused such disclosure controls and 
procedures  to  be  designed  under  my  supervision,  to  ensure  that  material  information 
relating to the company, including its consolidated subsidiaries, is made known to us by 
others within those entities, particularly during the period in which this report is being 
prepared; 

b.  designed such internal  control over financial reporting, or caused such internal  control 
over  financial  reporting  to  be  designed  under  our  supervision,  to  provide  reasonable 
assurance regarding the reliability of financial reporting and the preparation of financial 
statements  for  external  purposes  in  accordance  with  generally  accepted  accounting 
principles; 

c.  evaluated  the  effectiveness  of  the  company’s  disclosure  controls  and  procedures  and 
presented in this report my conclusions about the effectiveness of the disclosure controls 
and  procedures,  as  of  the  end  of  the  period  covered  by  this  report  based  on  such 
evaluation; and 

d.  disclosed  in  this  report  any  change  in  the  company’s  internal  control  over  financial 
reporting that occurred during the period covered by the annual report that has materially 
affected, or is reasonably likely to materially affect, the company’s internal control over 
financial reporting; and 

5.  The company’s other certifying officer and I have disclosed, based on our most recent evaluation 
of internal control over financial reporting, to the company’s auditors and the audit committee of 
the company’s board of directors (or persons performing the equivalent functions): 

a.  all significant deficiencies and material weaknesses in the design or operation of internal 
control  over  financial  reporting  which  are  reasonably  likely  to  adversely  affect  the 
company’s ability to record, process, summarize and report financial information; and 

89 

 
 
 
 
b.  any fraud, whether or not material, that involves management or other employees who 

have a significant role in the company’s internal control over financial reporting. 

Date: March 18, 2020  

/s/ Monica Iancu 
—————————————— 
Monica Iancu 
President and Chief Executive Officer  
(Principal Executive Officer) 

90 

 
 
 
 
Exhibit 12.2 

Certification of Principal Financial Officer pursuant to 17 CFR 240.13a-14(a), 
as adopted pursuant to §302 of the Sarbanes-Oxley Act 

I, Shoham Shitrit, certify that: 

1.  I have reviewed this annual report on Form 20-F of MIND C.T.I. Ltd.; 

2.  Based on my knowledge, this report does not contain any untrue statement of a material fact or 
omit to state a material fact necessary to make the statements made, in light of the circumstances 
under which such statements were made, not misleading with respect to the period covered by 
this report; 

3.  Based on my knowledge, the financial statements, and other financial information included in 
this report, fairly present in all material respects the financial condition, results of operations and 
cash flows of the company as of, and for, the periods presented in this report; 

4.  The  company’s  other  certifying  officer  and  I  are  responsible  for  establishing  and  maintaining 
disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) 
and internal control over financial reporting (as defined in Exchange Act  Rules 13a-15(f) and 
15d-15(f)) for the company and have: 

a.  designed such disclosure controls and procedures, or caused such disclosure controls and 
procedures  to  be  designed  under  my  supervision,  to  ensure  that  material  information 
relating to the company, including its consolidated subsidiaries, is made known to us by 
others within those entities, particularly during the period in which this report is being 
prepared; 

b.  designed such  internal  control over financial reporting, or caused such internal  control 
over  financial  reporting  to  be  designed  under  our  supervision,  to  provide  reasonable 
assurance regarding the reliability of financial reporting and the preparation of financial 
statements  for  external  purposes  in  accordance  with  generally  accepted  accounting 
principles; 

c.  evaluated  the  effectiveness  of  the  company’s  disclosure  controls  and  procedures  and 
presented in this report my conclusions about the effectiveness of the disclosure controls 
and  procedures,  as  of  the  end  of  the  period  covered  by  this  report  based  on  such 
evaluation; and 

d.  disclosed  in  this  report  any  change  in  the  company’s  internal  control  over  financial 
reporting that occurred during the period covered by the annual report that has materially 
affected, or is reasonably likely to materially affect, the company’s internal control over 
financial reporting; and 

91 

 
 
 
 
5. 

The company’s other certifying officer and I have disclosed, based on our most recent 
evaluation of internal control over financial reporting, to the company’s auditors and the 
audit  committee  of  the  company’s  board  of  directors  (or  persons  performing  the 
equivalent functions): 

a.  all significant deficiencies and material weaknesses in the design or operation of internal 
control  over  financial  reporting  which  are  reasonably  likely  to  adversely  affect  the 
company’s ability to record, process, summarize and report financial information; and 

b.  any fraud, whether or not material, that involves management or other employees who 

have a significant role in the company’s internal control over financial reporting. 

Date: March 18, 2020 

/s/ Shoham Shitrit 
—————————————— 
Shoham Shitrit 
Chief Financial Officer  
(Principal Financial Officer) 

92 

 
 
 
 
 
 
Exhibit 13.1 

Certification of Principal Executive Officer pursuant to 18 U.S.C. § 1350, 
as adopted pursuant to § 906 of the Sarbanes-Oxley Act 

In connection with the annual report on Form 20-F for the fiscal year ended December 31, 2019 of MIND 
C.T.I.  Ltd.  (the  “Company”)  as  filed  with  the  U.S.  Securities  and  Exchange  Commission  (the 
“Commission”) on the date hereof (the “Report”) and pursuant to 18 U.S.C. Section 1350, as adopted 
pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, I, Monica Iancu, certify that:  

• 

• 

the Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities 
• 
Exchange Act of 1934, as amended; and  

the information contained in the Report fairly presents, in all material respects, the financial 
• 
condition and results of operations of the Company.  

Date: March 18, 2020  
/s/ Monica Iancu  
Monica Iancu 
President and Chief Executive Officer  
(Principal Executive Officer)  

93 

 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 13.2 

Certification of Principal Financial Officer pursuant to 18 U.S.C. § 1350, 
as adopted pursuant to § 906 of the Sarbanes-Oxley Act 

In connection with the annual report on Form 20-F for the fiscal year ended December 31, 2019 of MIND 
C.T.I.  Ltd.  (the  “Company”)  as  filed  with  the  U.S.  Securities  and  Exchange  Commission  (the 
“Commission”) on the date hereof (the “Report”) and pursuant to 18 U.S.C. Section 1350, as adopted 
pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, I, Shoham Shitrit, certify that: 

• 

• 

 The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities 
• 
Exchange Act of 1934, as amended; and 

 The information contained in the Report fairly presents, in all material respects, the financial 
• 
condition and results of operations of the Company. 

Date: March 18, 2020  
/s/ Shoham Shitrit 
Shoham Shitrit 
Chief Financial Officer 
(Principal Financial Officer) 

94 

 
 
 
 
 
 
 
 
 
Exhibit 15.1 

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM 

We consent to the incorporation by reference in the Registration Statements on Form S-8 (Registration 
No. 333-181383; No. 333-117054; No. 333-100804 and No. 333-54632) of our report dated March 18, 
2020 relating to the consolidated financial statements of MIND C.T.I. Ltd. (the “Company”) appearing 
in the Annual Report on Form 20-F of the Company for the year ended December 31, 2019. 

/s/ Brightman Almagor Zohar & Co.  
Certified Public Accountants  
A firm in the Deloitte Global Network Tel Aviv, Israel  
March 18, 2020 

95