Two former employees of billionaire Patrick Soon-Shiong’s health care technology company NantHealth have alleged the firm and its Culver City holding company NantWorks had engaged in a multitude of fraudulent activities.

The former NantHealth executives, Stephanie Davidson and William Lynch, have alleged in a complaint filed in federal court in Panama City, Fla., that they warned the company of violations of the Health Insurance Portability and Accountability Act and other federal regulations. The plaintiffs, who are in a relationship, claim they were subsequently fired in retaliation for refusing to participate in the company’s fraudulent and illegal activities.

The company, in a statement, has denied the allegations.

In their filing, Davidson and Lynch claim that shortly after being hired last year, they became aware of these fraudulent activities which would, if known to the public, thwart NantHealth’s anticipated IPO.

Lynch, who was senior director of marketing, claims he warned NantHealth that its marketing materials and labeling contained false and misleading information in violation of Food and Drug Administration regulations. Davidson, who was senior vice president of professional services, claims she advised the company that its programs and platforms were lacking in mandated safety and security measures.

The pair’s complaint said an analysis of the company revealed that NantHealth’s clinical operating system as a platform is 10 years behind in technology capability… and that the “system runs on LUCK.”

In the filing, Davidson alleges that in addition to warning of potential HIPPA violations, she alerted the company of potential harm to patients through the use of NantHealth software, which she said may not properly communicate with medical equipment, causing false or inaccurate information or data to be reported.

Davidson and Lynch are requesting back pay, compensatory and punitive damages and a jury trial.

“This lawsuit was filed after Nant turned down a demand by Ms. Davidson and her boyfriend Mr. Lynch for $2 million with an accompanying threat that unless Nant paid, Ms. Davidson and Mr. Lynch would launch a smear campaign filled with false and damaging information,” said NantHealth Chief Operating Officer Steve Curd in a statement, calling the allegations false.

Curd noted Davidson was employed by NantHealth for less than three months, Lynch for less than nine months and both were terminated by the chief operating officer for improper behavior.

“When Ms. Davidson was fired she reached out to the CEO requesting that he reverse the COO’s decision to terminate her saying, ‘I love what we are doing and believe in the company,’” Curd’s statement said. “When this reversal was denied her lawyer sent repeated requests for a $2 million payment to avoid a smear campaign. Nant denied the payment request and the couple filed this baseless lawsuit filled with inaccuracies and false statements.”