What changed in this filing

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Item 1. Legal Proceedings

2022-11-04 compared with 2022-08-10 · 51 added, 65 removed, 11 unchanged (91% 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.

On October 21, 2022, the Company filed a petition

against Twitter, Inc.

in the Supreme Court of the State of New York County of New York to compel disclosure of the owner(s) and operator(s)

of two certain Twitter accounts:

“Mike Wood” (@MIKEWOOD) and “Bull Meechum” (@BullMeechum3).

The petition seeks

disclosure of the owner(s) and operator(s) of the aforementioned accounts so the Company can commence an action against such individuals

for damages arising from false, misleading, and untrue statements made by the same.

On October 25, 2022, the court signed an order

to show cause directing Twitter to show cause on or before November 4, 2022 as to why an order compelling disclosure of the identities

of the owner(s) / operator(s) of the @MIKEWOOD and @BullMeechum3 Twitter accounts should not be made.

Carebourn Capital, L.P.

DarkPulse, Inc.

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.

As disclosed in greater detail in the Company’s

Form 10-Q, filed August 10, 2022, the Company remains in active litigation with Carebourn Capital, L.P.

(“Carebourn”) in Minnesota

There are no material updates to this litigation.

The Company remains committed to actively litigating

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

More Capital, LLC

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

More Capital, LLC v.

DarkPulse, Inc.

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.

As disclosed in greater detail in the Company’s

Form 10-Q, filed August 10, 2022, the Company remains in active litigation with More Capital, LLC (“More”) in Minnesota State

There are no material updates to this litigation.

The Company remains committed to actively litigating

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

Goodman et al.

DarkPulse, Inc.

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.

As disclosed in greater detail in the Company’s

Form 10-Q, filed November 15, 2021, on September 10, 2021, Stephen Goodman, Mark Banash, and David Singer (“Former Officers”)

commenced suit against the Company in Arizona Superior Court, Maricopa County.

As of the date hereof, the Company is engaged

in settlement negotiations with the Former Officers.

DarkPulse, Inc.

FirstFire Global Opportunities Fund, LLC, and

As disclosed in greater detail in the Company’s

Form 10-Q, filed August 10, 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”).

As previously disclosed therein, the FirstFire

Parties’ motion to dismiss the Company’s first amended complaint has been fully submitted to the Court.

On May 26, 2022, the

1 unchanged sentence

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

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.

DarkPulse, Inc.

EMA Financial, LLC et al

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.

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.

As disclosed in greater detail in the Company’s

Form 10-Q, filed August 10, 2022, the Company remains in active litigation with EMA Financial, LLC (“EMA”), EMA Group, Inc.

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

As of July 22, 2022, the EMA Parties’ motion

to dismiss the Company’s first amended complaint is fully submitted.

As of the date hereof, no decision has been rendered 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 Racketeer Influenced and Corrupt Organizations Act.

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