What changed in this filing

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Item 1. Legal Proceedings

2022-08-10 compared with 2022-05-16 · 66 added, 84 removed, 10 unchanged (94% of the section changed)

Legal Proceedings

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.

On July 11, 2022, the Court denied Carebourn’s

motion to compel DPLS to produce a privilege log.

On July 15, 2022, the Court denied Carebourn’s motion to disqualify or, in the

alternative, seek limited discovery of DPLS’ legal counsel, consisting of the Taft Stettinius & Hollister LLP and The Basile

Law Firm P.C.

On July 27, 2022, Carebourn paid $18,858.18 for attorneys’ fees awarded pursuant to the Court’s April 14, 2022

decision on the Company’s motion to compel Carebourn.

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.

More Capital, LLC

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.

On July 11, 2022, the

Court denied More’s motion for summary judgment against the Company and granted DarkPulse’s motion to compel More.

directed More to produce all responsive documents to certain requests for production served by DarkPulse within seven days thereof.

The Company remains committed

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

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.

FirstFire Global Opportunities Fund, LLC, and Eli Fireman (SDNY)

On May 26, 2022, the

FirstFire Parties filed their motion to dismiss the Company’s first amended complaint, filed on May 5, 2022, and opening memorandum

of law in support thereof.

On June 16, 2022, the Company filed its memorandum of law in opposition to the FirstFire Parties’ motion

to dismiss, and on June 30, 2022, the FirstFire Parties filed their memorandum of law in reply and further support of their motion to

As of the date hereof,

the FirstFire Parties’ motion to dismiss is fully submitted to the Court.

On May 26, 2022, the

FirstFire Parties requested oral arguments on their motion to dismiss.

As of the date hereof, oral arguments have not been scheduled and,

further, no decision has been rendered

on the FirstFire Parties’

motion to dismiss.

The Company remains committed

to actively litigating its claims for relief under the Securities Exchange Act of 1934 and the Racketeer Influenced and Corrupt Organizations

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.

On June 22, 2022, the

EMA Parties filed their motion to dismiss the Company’s first amended complaint, filed on March 28, 2022, and opening memorandum

of law in support thereof.

On July 13, 2022, the Company filed its memorandum of law in opposition to the EMA Parties’ motion to

dismiss, and on July 22, 2022, the EMA Parties filed their memorandum of law in reply and further support of their motion to dismiss.

As of the date hereof, no decision has been on the EMA Parties’ motion to dismiss.

The Company remains committed

to actively litigating its claims for relief under the Securities Exchange Act of 1934 and the Racketeer Influenced and Corrupt Organizations

Carebourn Capital

Standard Registrar and Transfer et al

On May 20, 2022, Carebourn

Capital, L.P.

(“Carebourn”) and More Capital, LLC (“More”) (Carebourn and More, together, the “MN Noteholders”)

commenced an action in the United States District Court for the District of Utah against (i) Standard Registrar and Transfer Co., Inc.

(“Standard”), (ii) Amy Merrill (“Merrill”) (Standard and Merrill, together, the “TA Defendants”),

(iii) DarkPulse, Inc., (iv) Dennis O’Leary (“O’Leary”), (v) Thomas Seifert (“Seifert”), (vi) Carl

Eckel (“Eckel”), (vii) Anthony Brown (“Brown”), and (viii) Faisal Farooqui (“Farooqui”) (DarkPulse,

O’Leary, Seifert, Eckel, Brown, and Farooqui, collectively, the “DPLS Defendants”).

The MN Noteholders’ complaint

alleges, among other things, that the TA Defendants and DPLS Defendants conspired together and acted in unison to preclude the MN Noteholders’

from receiving the benefits of the convertible note transactions between Carebourn, More, and DarkPulse.

On July 5, 2022, the

TA Defendants filed their motion to dismiss the MN Noteholders’ complaint.

Pursuant to the local rules of the U.S.

the District of Utah, the MN Noteholders must reply to the TA Defendants’ motion to dismiss on or before August 2, 2022.

date hereof, the DPLS Defendants have not been served and, thus, no deadline exists by which the DPLS Defendants must answer or otherwise

respond to the MN Noteholders’ complaint.

The Company intends to

vigorously defend itself against the MN Noteholders’ lawsuit.

DarkPulse, Inc.

/s/ Dennis O’Leary

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

(Principal Executive Officer and Principal

Financial Officer)

Brunson Chandler Jones et al

On July 8, 2022, the

Company commenced an action against the law firm of Brunson Chandler & Jones, PLLC and Lance B.

Brunson (“Chandler Defendants”)

in the United States District Court for the District of Utah.

The Company’s claims, consisting of professional negligence/malpractice

and breach of contract, arise from the legal services and relationship between DarkPulse and the Chandler Defendants and in connection

with the merger between DarkPulse, DarkPulse Technologies Inc., and Klever Marketing, Inc.

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