What changed in this filing

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Item 1. Legal Proceedings

2021-11-15 compared with 2021-08-16 · 18 added, 38 removed, 10 unchanged (85% of the section changed)

Legal Proceedings

Carebourn Capital, L.P.

On January 29, 2021, Carebourn

Capital, L.P.

(“ Carebourn ”) commenced suit against the Company in the 4th Judicial District (Hennepin County District

Court, Minnesota), alleging the Company breached the terms and conditions of two convertible promissory notes and accompanying securities

purchase agreements Carebourn and the Company entered into on July 17, 2018 and July 24, 2018, respectively.

Also on January 29, 2021, Carebourn moved for

a temporary injunction to enjoin the Company from transferring any shares of its common stock to any third parties.

Following submission

of briefing by both parties and oral arguments on Carebourn’s motion, on March 17, 2021, the Court denied Carebourn’s motion

for a temporary injunction.

On April 14, 2021, Carebourn filed an amended

complaint and asserted new claims.

On May 13, 2021, the Company filed a motion to dismiss Carebourn’s amended complaint, arguing

that Carebourn is conducting itself as an unregistered dealer, in violation of Section 15(a) of the Securities and Exchange Act of 1934

(the “ Act ”), and, pursuant to Section 29(b) of the Act, the Company is entitled to have all contracts arising under

the unlawful securities transaction declared void ab initio and seek rescissionary damages for any unlawful securities transactions effected

by Carebourn.

As of the date hereof, a ruling has not been issued on the foregoing motions to dismiss filed by the Company and Standard

Registrar and Transfer Company, Inc., and the Company and Carebourn are conducting discovery.

The Company intends to defend itself against

the allegations asserted in Carebourn’s amended complaint and interpose the defenses provided under the Act, including but not

limited to asserting that Carebourn is an unregistered dealer acting in violation of Section 15(a) and, pursuant to Section 29(b), the

Company interposing its right to rescind the unlawful securities contracts in their entirety and, furthermore, seek rescissionary damages

for any unlawful securities transactions effected by Carebourn.

Former DarkPulse Officers

On June 10, 2021, Stephen Goodman, Mark Banash,

Former Officers

On September 10, 2021, Stephen Goodman, Mark Banash,

and David Singer (the “ Former Officers ”), all former officers and employees of the Company, commenced suit against

4 unchanged sentences

in the Former Officers’ complaint.

If the case progresses, then the Company

will file countersuits against all plaintiffs.

if the case progresses the Company will file countersuits against all plaintiffs.

More Capital, LLC

On June 29, 2021, More Capital,

LLC (“ More ”) commenced suit against the Company, et al., in the 4th Judicial District (Hennepin County District Court,

Minnesota), alleging the Company breached the terms and conditions of a convertible promissory note and accompanying securities purchase

agreement that More and the Company entered into on August 20, 2018.

On June 29, 2021, More Capital, LLC (“ More ”)

commenced suit against the Company, et al., in the 4th Judicial District (Hennepin County District Court) (Minnesota), alleging the Company

breached the terms and conditions of a convertible promissory note and accompanying securities purchase agreement More and the Company

entered into on August 20, 2018.

On July 20, 2021, the Company filed a motion to

dismiss More’s complaint, arguing that the claims asserted against the Company fail to state a claim upon which relief can be granted.

The Company intends to defend itself against the

allegations asserted in More’s complaint and interpose the defenses provided under the Act, including but not limited to asserting

that More is an unregistered dealer acting in violation of Section 15(a) of the Act and, pursuant to Section 29(b) of the Act, the Company

interposing its right to rescind the unlawful securities contracts in their entirety and, furthermore, seek rescissionary damages for

any unlawful securities transactions effected by More.

The Company intends to defend itself against

the allegations asserted in More’s complaint and interpose the defenses provided under the Exchange Act, including but not limited

to asserting that More is an unregistered dealer acting in violation of Section 15(a) of the Exchange Act and, pursuant to Section 29(b)

of the Exchange Act, the Company interposing its right to rescind the unlawful securities contracts in their entirety and, furthermore,

seek rescissionary damages for any unlawful securities transactions effected by More.

The Company contends that its arguments are brought

in good faith, particularly in light of recent SEC enforcement actions and the SEC’s ongoing investigation against More, among

other parties, for violations of federal securities laws, including violations of Section 15(a) of the Exchange Act.

and Exchange Commission v.

Carebourn Capital, LP et al, Case No.

1:20-cv-07162 (N.D.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-Q

Item 1. Legal Proceedings