15 unchanged sentences
On or about April 21, 2023, the State Court ruled
−Removed: in the Company’s favor on its motion for partial summary judgment on its Exchange Act defense, holding that (i) Carebourn is
−Removed: a “dealer” under the Exchange Act in violation of the mandatory registration requirement imposed thereby, and (ii) all
−Removed: contracts between the parties are void.
+Added: in the Company’s favor on its motion for partial summary judgment on its Exchange Act defense, holding that (i) Carebourn is a “dealer”
+Added: under the Exchange Act in violation of the mandatory registration requirement imposed thereby, and (ii) all contracts between the parties
On or about November 17, 2023, the State Court
1 unchanged sentence
and awarded damages for Carebourn’s violation of Minn.
−Removed: § 80A.76(d) in the amount of $124,012.91, attorney’s
−Removed: fees in the amount of $239,923.33 and costs in the amount of $23,757.24 (or a total award in the amount of $387,693.48).
−Removed: On or about March 23, 2024, Carebourn appealed
−Removed: the final judgment entered by the State Court against Carebourn and in favor of the Company.
+Added: § 80A.76(d) in the amount of $124,012.91, attorney’s fees
+Added: in the amount of $239,923.33 and costs in the amount of $23,757.24 (or a total award in the amount of $387,693.48).
+Added: On or about March 23, 2024, Carebourn appealed the final judgment entered
+Added: by the State Court against Carebourn and in favor of the Company.
On or about March 25, 2024, the Minnesota Appellate
6 unchanged sentences
and (b) If the answer to (a) is yes, must this appeal be dismissed as untimely.
−Removed: On or about April 4, 2024, DarkPulse filed
−Removed: its informal briefing in response with the Appellate Court.
+Added: On or about April 4, 2024, DarkPulse filed its informal
+Added: briefing in response with the Appellate Court.
The Company is currently awaiting a decision from the Appellate Court.
−Removed: As of the date hereof, Carebourn has
−Removed: refused to voluntarily satisfy the final judgment.
−Removed: Accordingly, the Company intends to exercise all legal rights and remedies
−Removed: available to it to collect the amounts awarded.
+Added: As of the date hereof, Carebourn has refused to
+Added: voluntarily satisfy the final judgment.
+Added: Accordingly, the Company intends to exercise all legal rights and remedies available to it to
+Added: collect the amounts awarded.
DarkPulse intends to continue to exercise all
13 unchanged sentences
On or about December 11, 2023, the Minnesota State
−Removed: Court ruled in the Company’s favor on its motion for summary judgment on its (a) Exchange Act defense, holding that (1) More
−Removed: is a “dealer” under the Exchange Act in violation of the mandatory registration requirement imposed thereby, and (ii) all
−Removed: contracts between the parties are void, and (b) Minnesota Securities Act counterclaims against More and awarded damages for More’s
−Removed: violation of Minn.
−Removed: § 80A.76(d) in the amount of $300,809.39, attorney’s fees in the amount of $110,029.00 and costs
−Removed: in the amount of $210.25 (or a total award in the amount of $412,048.64).
−Removed: On or about March 23, 2024, More appealed the
−Removed: final judgment entered by the State Court against More and in favor of the Company.
+Added: Court ruled in the Company’s favor on its motion for summary judgment on its (a) Exchange Act defense, holding that (1) More is
+Added: a “dealer” under the Exchange Act in violation of the mandatory registration requirement imposed thereby, and (ii) all contracts
+Added: between the parties are void, and (b) Minnesota Securities Act counterclaims against More and awarded damages for More’s violation
+Added: § 80A.76(d) in the amount of $300,809.39, attorney’s fees in the amount of $110,029.00 and costs in the amount
+Added: of $210.25 (or a total award in the amount of $412,048.64).
+Added: On or about March 23, 2024, More appealed the final judgment entered
+Added: by the State Court against More and in favor of the Company.
On or about March 25, 2024, the Minnesota Appellate
6 unchanged sentences
and (b) If the answer to (a) is yes, must this appeal be dismissed as untimely.
−Removed: On or about April 4, 2024, DarkPulse filed
−Removed: its informal briefing in response with the Appellate Court.
+Added: On or about April 4, 2024, DarkPulse filed its informal
+Added: briefing in response with the Appellate Court.
The Company is currently awaiting a decision from the Appellate Court.
8 unchanged sentences
Carebourn Capital et al v.
−Removed: Standard Registrar
−Removed: and Transfer et al
+Added: Standard Registrar and Transfer et al
On or about May 20, 2022, Carebourn and More (together
9 unchanged sentences
Securities and Exchange Commission against Carebourn in the United States District Court for the District of Minnesota.
−Removed: On or about November 1, 2023, the Noteholders
−Removed: moved to dismiss the action.
−Removed: On or about November 2, 2023, the Company moved
−Removed: for sanctions against the Noteholders and their counsel of record.
+Added: On or about November 1, 2023, the Noteholders moved to dismiss the
+Added: On or about November 2, 2023, the Company moved for sanctions against
+Added: the Noteholders and their counsel of record.
On or about December 4, 2023, the Court entered
3 unchanged sentences
motion for sanctions against the Noteholders and their attorneys.
−Removed: On May 22, 2024, the Court scheduled oral arguments
−Removed: on the Company’s sanction motion on July 2, 2024.
+Added: On May 22, 2024, the Court scheduled oral arguments on the Company’s
+Added: sanction motion on July 2, 2024.
DarkPulse, Inc.
−Removed: FirstFire Global Opportunities
−Removed: Fund, LLC, and Eli Fireman
+Added: FirstFire Global Opportunities Fund, LLC, and
On or about December 31, 2021, the Company commenced
10 unchanged sentences
the Court’s decision to the United States Court of Appeals for the Second Circuit (“ Second Circuit ”).
−Removed: Oral arguments were held before the Second Circuit
−Removed: on the Company’s appeal on December 11, 2023.
+Added: Oral arguments were held before the Second Circuit on the Company’s
+Added: appeal on December 11, 2023.
On March 28, 2024, the Second Circuit issued its
1 unchanged sentence
(b) improperly made a ruling on the merits of the Company’s claims for relief.
−Removed: As a result, the Second Circuit affirmed the
−Removed: District Court’s decision in part, vacated in part and remanded the case back to the District Court for transferring to the United
−Removed: States District Court for the District of Delaware.
+Added: As a result, the Second Circuit affirmed the District
+Added: Court’s decision in part, vacated in part and remanded the case back to the District Court for transferring to the United States
+Added: District Court for the District of Delaware.
As of the date hereof, this action has not yet
2 unchanged sentences
DarkPulse, Inc., et al v.
−Removed: Partners, LLC, et al
+Added: Crown Bridge Partners, LLC, et al
On or about September 23, 2022, the Company, Social
6 unchanged sentences
of the plaintiffs for damages pursuant to RICO.
−Removed: On or about September 29, 2023, the Court granted
−Removed: the Crown Bridge Defendants’ motion to dismiss the plaintiffs’ complaint.
−Removed: On October 23, 2023, the plaintiffs appealed the
−Removed: Court’s decision to the Second Circuit.
+Added: On or about September 29, 2023, the Court granted the Crown Bridge
+Added: Defendants’ motion to dismiss the plaintiffs’ complaint.
+Added: On October 23, 2023, the plaintiffs appealed the Court’s decision
+Added: to the Second Circuit.
As of the date hereof, the appeal is fully briefed.
−Removed: The Company remains committed to actively litigating
−Removed: its claims for relief under RICO.
+Added: The Company remains committed to actively litigating its claims for
+Added: relief under RICO.
+Added: On July 24, 2024 The Company resolved
+Added: certain disputes with one of its lenders, GS Capital Partners LLC (“GS”), on terms mutually agreeable to both Darkpulse
+Added: Specifically, DarkPulse and GS compromised over $2,600,000 of debt owed to GS in return for issuing shares to GS, as
+Added: provided by the settlement agreement between the parties.
+Added: This settlement is expected to be approved by the District Court for
+Added: Clark County, Nevada,on or about August 15, 2024, and such approval will also resolve the collaborative proceeding initiated in such
+Added: court to obtain approval of the settlement under Section 3(A)(10) of the Securities Act.
+Added: Importantly, through this settlement,
+Added: DarkPulse was able to negotiate a strict leak-out clause concerning the shares issued to GS, which DarkPulse believes will allow it
+Added: to maintain its going concern value without the distraction of expensive and protracted litigation.
+Added: TJM West, Inc v Thomas J McCarthy Family Limited Partnership
+Added: On or about July 25,2023 TJM West filed an action in Maricopa court
+Added: against its landlord for illegal lockout from the company’s facilities.
+Added: On or about August 18,2023 TJM West’s motion for Temporary Restraining
+Added: Order was granted.
+Added: September 27, 2023 TJM West counsel motion to withdraw was accepted.
+Added: On or about October 6, 2923.
+Added: TJM West hired new counsel to assist with
+Added: a short deadline to file answers to landlords motion.
+Added: On or about November 6,2023 TJM West and its counsel mutually agreed
+Added: to a withdrawal.
+Added: On or about November 6,2023 TJM West engaged new counsel.
+Added: On or about May 8,2024 TJM West dropped its motion for Temporary Restraining
+Added: On or about May 24,2024 TJM West counsel filed motion to continue discovery.
+Added: On or about May 24,2024 TJM West’s counsel left the firm handling
+Added: the litigation it was determined in the best interest of the company to terminate its relationship with the law firm.
+Added: As of today the
+Added: company is interviewing new counsel and evaluating its claims against landlord to determine if it’s financially responsible to incur
+Added: additional fees related to exercising TJM’s right against the landlord for terminating the lease.
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.