What changed in this filing

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Item 1. Legal Proceedings

2022-05-16 compared with 2021-11-15 · 93 added, 27 removed, 1 unchanged (99% of the section changed)

Legal Proceedings

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

the Company in Arizona Superior Court, Maricopa County.

The complaint alleges the Company breached the rights of the Former Officers in

connection with Series D preferred stock issued to the Former Officers.

The Company intends to defend itself against the allegations asserted

in the Former Officers’ complaint.

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 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 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.

DarkPulse, Inc.

Twitter, Inc.

As disclosed in greater detail in the Company’s

Form 10-K, filed April 15, 2022, the Company’s investigation of the Investor News matter remains ongoing.

Carebourn Capital, L.P.

DarkPulse, Inc.

As disclosed in greater detail in the Company’s

Form 10-K, filed April 15, 2022, the Company remains in active litigation with Carebourn Capital, L.P.

(“ Carebourn ”).

The remainder of this disclosure will address all material updates since the aforementioned Form 10-K.

On April 11, 2022, the Court held a hearing on

Carebourn’s Motion to Compel DarkPulse.

As of the date hereof, no decision has been rendered on Carebourn’s motion.

14, 2022, the Court granted the Company’s Motion to Enforce the Protective Order, and simultaneously denied Carebourn’s request

for reconsideration of Carebourn’s Motion for Dispositive Relief.

On April 27, 2022, the Court awarded the Company $18,858.18 in

attorneys’ fees from Carebourn in connection with the Court’s April 14, 2022 decision on the Company’s Motion to Compel

Carebourn has been ordered to pay the $18,858.18 on or before July 26, 2022.

The Company remains committed to actively litigating

its claims for relief under the Securities Exchange Act of 1934.

More Capital, LLC v.

DarkPulse, Inc.

As disclosed in greater detail in the Company’s

Form 10-K, filed April 15, 2022, the Company remains in active litigation with More Capital, LLC (“ More ”).

The remainder

of this disclosure will address all material updates since the aforementioned Form 10-K.

On April 11, 2014, the Court held a hearing on

the Company’s Motion to Compel More and More’s Motion for Summary Judgment.

As of the date hereof, no decision has been rendered

on either of the aforesaid motions.

The Company remains committed to actively litigating

its claims for relief under the Securities Exchange Act of 1934.

Goodman et al.

DarkPulse, Inc.

As disclosed in greater detail in the Company’s

Form 10-K, filed April 15, 2022, the Company remains in active litigation with Stephen Goodman (“ Goodman ”), Mark Banash

(“ Banash ”), and David Singer (“ Singer ”) (Goodman, Banash, and Singer together, the “ Series

D Plaintiffs ”).

As of April 15, 2022, there has been no material updates to this litigation.

The Company remains committed to actively litigating

its claims and defenses against the Series D Plaintiffs.

DarkPulse, Inc.

FirstFire Global Opportunities

Fund, LLC, and Eli Fireman (SDNY)

As disclosed in greater detail in the Company’s

Form 10-K, filed April 15, 2022, the Company remains in active litigation with FirstFire Global Opportunities Fund, LLC (“ FirstFire ”),

and Eli Fireman (“ Fireman ”) (FirstFire and Fireman together, the “ FirstFire Parties ”).

The remainder

of this disclosure will address all material updates since the aforementioned Form 10-K.

On May 5, 2022, the Company filed its amended

complaint (“ FirstFire Amended Complaint ”).

Accordingly, the FirstFire Parties’ answer or motion in response to

the FirstFire Amended Complaint is due on or before May 19, 2022.

FirstFire Global Opportunities Fund, LLC v.

DarkPulse, Inc.

Chancery Court)

As disclosed in greater detail in the Company’s

Form 10-K, filed April 15, 2022, there are no material updates to this litigation and the Company maintains its view that the FirstFire

Delaware Chancery matter is fully disclosed.

Absent any future material developments, no further disclosures will be made about the FirstFire

Delaware Chancery matter.

DarkPulse, Inc.

EMA Financial, LLC et al

As disclosed in greater detail in the Company’s

Form 10-K, filed April 15, 2022, the Company remains in active litigation with EMA Financial, LLC (“ EMA ”), EMA Group,

(“ EMA Group ”), and Felicia Preston (“ Preston ”) (EMA, EMA Group, and Preston together, the “ EMA

The remainder of this disclosure will address all material updates since the aforementioned Form 10-K.

On March 28, 2022, the Company filed its first

amended complaint against the EMA Parties (the “ EMA Amended Complaint ”).

On April 22, 2022, the Company and the EMA

Parties entered into a Stipulation, which the Court so ordered on May 3, 2022, and established the EMA Parties were required to file and

serve their answer and/or pre-motion letter for a motion under Rule 12 to the EMA Amended Complaint on or before June 21, 2022.

The Company remains committed to actively litigating

its claims for relief under the Securities Exchange Act of 1934.

Title of Document

Rule 13a-14(a) Certification by Principal Executive and Financial Officer

Section 1350 Certification of Principal Executive and Financial Officer

Inline XBRL Instance Document (the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document)

Inline XBRL Taxonomy Extension Schema Document

Inline XBRL Taxonomy Extension Calculation Linkbase Document

Inline XBRL Taxonomy Extension Definition Linkbase Document

Inline XBRL Taxonomy Extension Label Linkbase Document

Inline XBRL Taxonomy Extension Presentation Linkbase Document

Cover Page Interactive Data File (formatted in inline XBRL, and included in exhibit 101).

*Filed with this Report.

**Furnished with this Report.

Pursuant to the requirements of the Securities

Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.

DarkPulse, Inc.

/s/ Dennis O’Leary

Dennis O’Leary, Chairman, Chief Executive Officer, President, Chief Financial Officer

(Principal Executive Officer and Principal

Financial Officer)

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