−Removed: LEGAL PROCEEDINGS.
Carebourn Capital, L.P.
DarkPulse, Inc.
−Removed: On or about January 29, 2021, Carebourn Capital,
−Removed: (“ Carebourn ”) commenced an action against the Company in Minnesota State Court.
−Removed: Carebourn alleged that the Company
−Removed: was in breach of certain securities purchase agreements and convertible promissory notes sold to Carebourn on or about July 17, 2018 and
−Removed: July 24, 2018.
−Removed: On or about August 31, 2021, the Company answered
−Removed: Carebourn’s complaint and interposed affirmative defenses, including that Carebourn was an unregistered “dealer,” as
−Removed: such term is defined in the Securities Exchange Act of 1934 (“ Exchange Act ”) and, therefore, all contracts between
−Removed: the parties arising from or related to the securities purchase agreements and convertible promissory notes sold to Carebourn on or about
−Removed: July 17, 2018 and July 24, 2018 were void pursuant to the Exchange Act.
−Removed: The Company also asserted counterclaims against Carebourn under
−Removed: the Minnesota Securities Act.
−Removed: 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.
−Removed: On or about November 17, 2023, the State Court
−Removed: ruled in the Company’s favor on its motion for summary judgment on its Minnesota Securities Act counterclaims against Carebourn
−Removed: 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: As of the date hereof, the final judgment remains
−Removed: unsatisfied by Carebourn.
−Removed: DarkPulse intends to continue to exercise all legal rights and remedies available to it to collect the amounts
−Removed: awarded should Carebourn fail to voluntarily pay the same.
+Added: On or about January 29, 2021, Carebourn Capital, L.P.
+Added: (“ Carebourn ”)
+Added: commenced an action against the Company in Minnesota State Court.
+Added: Carebourn alleged that the Company was in breach of two convertible
+Added: promissory notes sold to Carebourn on or about July 17, 2018 and July 24, 2018.
+Added: Thereafter, the Company answered Carebourn’s complaint
+Added: and asserted counterclaims under the Minnesota Securities Act.
+Added: On or about November 17, 2023, the State Court ruled in
+Added: the Company’s favor on, among other things, its counterclaim for damages pursuant to Minnesota Securities Act and awarded the Company
+Added: damages in the amount of $124,012.91, attorney’s fees in the amount of $239,923.33 and costs in the amount of $23,757.24 (or a total
+Added: award in the amount of $387,693.48).
+Added: As of the date hereof, the final judgment remains unsatisfied
+Added: by Carebourn.
+Added: DarkPulse intends to continue to exercise all legal rights and remedies available to it to collect the amounts awarded should
+Added: Carebourn fail to voluntarily pay the same.
More Capital, LLC v.
DarkPulse, Inc.
−Removed: On or about June 29, 2021, More Capital, LLC (“ More ”)
−Removed: commenced an action against the Company in Minnesota State Court.
−Removed: More alleged that the Company was in breach of a certain securities
−Removed: purchase agreement and convertible promissory note sold to More on or about August 20, 2018.
−Removed: On or about September 3, 2021, the Company answered
−Removed: More’s complaint and interposed affirmative defenses, including that More was an unregistered “dealer,” as such term
−Removed: is defined in the Exchange Act and, therefore, all contracts between the parties arising from or related to the securities purchase agreement
−Removed: and convertible promissory note sold to More on or about August 20, 2018 were void pursuant to the Exchange Act.
−Removed: The Company also asserted
−Removed: counterclaims against More under the Minnesota Securities Act.
−Removed: 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: As of the date hereof, the final judgment remains
−Removed: unsatisfied by More.
−Removed: DarkPulse intends to continue to exercise all legal rights and remedies available to it to collect the amounts awarded
−Removed: should More fail to voluntarily pay the same.
+Added: On or about June 29, 2021, More Capital, LLC
+Added: (“ More ”) commenced an action against the Company in Minnesota State Court.
+Added: More alleged that the Company was in breach
+Added: of a certain securities purchase agreement and convertible promissory note sold to More on or about August 20, 2018.
+Added: Thereafter, the
+Added: Company answered More’s complaint and asserted counterclaims under the Minnesota Securities Act.
+Added: On or about December 11, 2023, the Minnesota State Court
+Added: ruled in the Company’s favor on, among other things, its counterclaim for damages pursuant to Minnesota Securities Act and awarded
+Added: the Company damages in the amount of $300,809.39, attorney’s fees in the amount of $110,029.00 and costs in the amount of $210.25
+Added: (or a total award in the amount of $412,048.64).
+Added: As of the date hereof, the final judgment remains unsatisfied
+Added: DarkPulse intends to continue to exercise all legal rights and remedies available to it to collect the amounts awarded should
+Added: More fail to voluntarily pay the same.
Carebourn Capital et al v.
−Removed: Standard Registrar
−Removed: and Transfer et al
−Removed: On or about May 20, 2022, Carebourn and More (More,
−Removed: together with Carebourn, the “ Noteholders ”) commenced an action against the Company, certain members of the Company’s
−Removed: executive team and board of directors and Standard Registrar and Transfer Company, Inc., the Company’s transfer agent, in the United
−Removed: States District Court for the District of Utah.
−Removed: The Noteholders’ complaint alleged various causes of action arising from certain
−Removed: securities purchase agreements and convertible promissory notes the Company sold to the Noteholders.
−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.
−Removed: On or about December 4, 2023, the Court entered
−Removed: an order granting dismissal of the Noteholders’ claims with prejudice.
−Removed: The Court acknowledged that notwithstanding its dismissal
−Removed: of the Noteholders’ claims, the Court continues to retain jurisdiction over the Noteholders because of DarkPulse’s pending
−Removed: motion for sanctions against the Noteholders and their attorneys.
−Removed: On September 10, 2024, the Court entered an order
−Removed: granting in part the Company’s motion for sanctions against the Noteholders and their counsel of record.
−Removed: As of the date hereof, the Court has not yet rendered
−Removed: its decision on the amount sanctions that will be imposed against the Noteholders and their counsel of record and awarded to the Company.
+Added: Standard Registrar and Transfer et al
+Added: On or about May 20, 2022, the Carebourn Capital, L.P.
+Added: (“ Carebourn ”)
+Added: and More Capital, LLC (“ More ,” and together with Carebourn, the “ Noteholders ”) commenced an action
+Added: against the Company, certain members of the Company’s executive team and board of directors and Standard Registrar and Transfer
+Added: Company, Inc., the Company’s transfer agent, in the United States District Court for the District of Utah.
+Added: The Noteholders’
+Added: complaint alleged various causes of action arising from certain securities purchase agreements and convertible promissory notes the Company
+Added: sold to the Noteholders.
+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
+Added: against the Noteholders and their counsel of record.
+Added: On or about December 4, 2023, the Court entered an order
+Added: granting dismissal of the Noteholders’ claims with prejudice.
+Added: The Court acknowledged that notwithstanding its dismissal of the Noteholders’
+Added: claims, the Court continues to retain jurisdiction over the Noteholders because of DarkPulse’s pending motion for sanctions against
+Added: the Noteholders and their attorneys.
+Added: On September 10, 2024, the Court entered an order granting in part
+Added: the Company’s motion for sanctions against the Noteholders and their counsel of record.
+Added: On July 15, 2025, the Court entered an order ordering the
+Added: Noteholders and their counsel to pay the sum of $70,840 to the Company.
+Added: On September 30, 2025, the Court entered Final Judgment in this
+Added: As of the date hereof, the Noteholders and their
+Added: counsel have not paid the awarded amount to the Company.
+Added: DarkPulse intends to continue to exercise all legal rights and remedies available
+Added: to it to collect the amounts awarded.
DarkPulse, Inc.
−Removed: FirstFire Global Opportunities
−Removed: Fund, LLC, and Eli Fireman
−Removed: On or about December 31, 2021, the Company commenced
−Removed: an action against FirstFire Global Opportunities Fund, LLC (“ FirstFire ”) and its control person, Eli Fireman (“ Fireman ,”
+Added: FirstFire Global Opportunities Fund, LLC, et
+Added: On or about December 31, 2021, the Company commenced an action against
+Added: FirstFire Global Opportunities Fund, LLC (“ FirstFire ”) and its control person, Eli Fireman (“ Fireman ,”
and together with FirstFire, the “ FirstFire Defendants ”), in the United States District Court for the Southern District
−Removed: On or about May 5, 2022, the Company amended its
−Removed: complaint against the FirstFire Defendants.
−Removed: The amended complaint alleges that the FirstFire Defendants were liable to the Company for
−Removed: rescission of certain convertible promissory notes and transitions effected thereunder and damages pursuant to the Racketeer Influenced
−Removed: and Corrupt Organizations Act (“ RICO ”).
−Removed: On or about January 17, 2023, the Court granted
−Removed: the FirstFire Defendants’ motion to dismiss the Company’s operative pleading.
−Removed: On the same day, the Company appealed the Court’s
−Removed: decision to the United States Court of Appeals for the Second Circuit (“ Second Circuit ”).
−Removed: On March 28, 2024, the Second Circuit issued its
−Removed: decision and found that the District Court (a) properly found that the Delaware forum-selection clause was enforceable but, thereafter,
−Removed: (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.
−Removed: On September 9, 2024, the FirstFire Defendants
−Removed: filed their opening memorandum of law in support of their motion to dismiss.
−Removed: Shortly thereafter, the Company opposed the FirstFire Defendants’
−Removed: motion and the FirstFire Defendants filed their reply in further support.
−Removed: As of the date hereof, the Court has not scheduled
−Removed: oral arguments on the FirstFire Defendants’ motion to dismiss or rendered its decision thereon.
−Removed: The Company remains committed to
−Removed: actively litigating its claims for relief against the FirstFire Defendants.
+Added: On or about May 5, 2022, the Company amended its complaint
+Added: against the FirstFire Defendants.
+Added: The amended complaint alleges that the FirstFire Defendants were liable to the Company for rescission
+Added: of certain convertible promissory notes and transitions effected thereunder and damages pursuant to the Securities Exchange Act of 1934
+Added: (“ Exchange Act ”) and Racketeer Influenced and Corrupt Organizations Act (“ RICO ”).
+Added: On or about January 17, 2023, the Court granted the FirstFire Defendants’
+Added: motion to dismiss the Company’s operative pleading.
+Added: Later during the same day, the Company appealed the Court’s decision to
+Added: the United States Court of Appeals for the Second Circuit (“ Second Circuit ”).
+Added: On March 28, 2024, the Second Circuit issued its decision and found
+Added: that the District Court
+Added: (a) properly found that the Delaware forum-selection
+Added: clause was enforceable but, thereafter,
+Added: (b) improperly made a ruling on the merits of
+Added: the Company’s claims for relief.
+Added: As a result, the Second Circuit affirmed the District Court’s decision in part, vacated in
+Added: part and remanded the case back to the District Court for transferring to the United States District Court for the District of Delaware.
+Added: On September 30, 2025, the Delaware Court granted
+Added: the FirstFire Defendants’ Motion to Dismiss.
+Added: On October 14, 2025, the Company filed a Motion for Reconsideration of the Delaware
+Added: Court’s September 30th decision.
+Added: As of the date hereof, the Delaware Court has not ruled on
+Added: DarkPulse’s Motion for Reconsideration.
+Added: The Company remains committed to actively litigating its claims for relief against the FirstFire
DarkPulse, Inc., et al v.
−Removed: Crown Bridge Partners,
−Removed: On or about September 23, 2022, the Company, Social
−Removed: Life Network, Inc.
+Added: Crown Bridge Partners, LLC, et al
+Added: On or about September 23, 2022, the Company, Social Life Network, Inc.
and Redhawk Holdings Corp.
−Removed: commenced an action against Crown Bridge Partners, LLC (“ Crown Bridge ”)
−Removed: and its control persons, Soheil Ahdoot and Sepas Ahdoot (collectively, the “ Crown Bridge Defendants ”) in the United
−Removed: States District Court for the Southern District of New York.
−Removed: The complaint alleges that the Crown Bridge Defendants are liable to each
−Removed: 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 United States Court of Appeals for the Second Circuit (“ Second Circuit ”).
+Added: (together, the “ Crown Bridge Plaintiffs ”) commenced an action against Crown Bridge Partners,
+Added: LLC (“ Crown Bridge ”) and its control persons, Soheil Ahdoot and Sepas Ahdoot (collectively, the “ Crown Bridge
+Added: Defendants ”) in the United States District Court for the Southern District of New York.
+Added: The complaint alleges that the Crown
+Added: Bridge Defendants are liable to each of the plaintiffs for damages pursuant to the Racketeer Influenced and Corrupt Organizations Act
+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
+Added: decision to the United States Court of Appeals for the Second Circuit (“ Second Circuit ”).
On August 19, 2024, the Second Circuit issued
2 unchanged sentences
consistent with its decision.
−Removed: On September 30, 2024, the District Court entered
−Removed: a scheduling order, setting forth deadlines for discovery and dispositive motion practice.
−Removed: The Company is actively litigating its claims
−Removed: for relief against the Crown Bridge Defendants.
−Removed: GS Capital Partners, LLC v.
−Removed: DarkPulse, Inc.
−Removed: On June 2, 2023, GS Capital Partners, LLC (“ GS
−Removed: Capital ”) commenced an action in the Supreme Court for New York County against the Company through the filing of motion for
−Removed: summary judgment in lieu of a complaint.
−Removed: The motion claims that the Company is in breach of a convertible promissory note, dated July
−Removed: 14, 2021, and accompanying securities purchase agreement, dated the same.
−Removed: The motion claims that GS Capital is entitled
−Removed: to an award of $2,407,671, plus prejudgment interest and attorney’s fees, costs and disbursements.
−Removed: On July 27, 2023, the Company moved to set aside
−Removed: the default judgment entered in favor of GS Capital and against the Company on July 25, 2023.
−Removed: GS Capital’s opposition thereto is
−Removed: due on or before August 31, 2023.
−Removed: Thereafter, DarkPulse’s reply is due on or before September 6, 2023.
−Removed: Oral arguments are currently
−Removed: not scheduled on the Company’s motion.
−Removed: On or about September 27, 2023, the Company and
−Removed: GS Capital confidentially settled the dispute.
−Removed: On or about October 3, 2023, the parties filed a stipulation with the court to vacate the
−Removed: judgment entered against the Company and in favor of GS Capital, vacate the motion filed by the Company, and discontinue the action.
−Removed: On or about October 9, 2023, the court vacated
−Removed: the judgment and the action was dismissed.
−Removed: The Company defaulted upon the settlement and,
−Removed: on July 24, 2024, the Company and GS Capital entered into a Settlement Agreement pursuant to which the Company entered into a confession
−Removed: of judgment in favor of GS Capital in the amount of $2,673,423.19 (the “ Balance ”).
−Removed: Upon approval of the court on August
−Removed: 19, 2024, the Company will issue to GS Capital free-trading and unrestricted shares of Common Stock pursuant to drawdown requests in the
−Removed: amounts determined by GS Capital, subject to a 4.99% beneficial ownership limitation.
−Removed: The shares will be issued a price per share equal
−Removed: to the average of the three lowest VWAPs for the five prior trading days.
−Removed: GS Capital will be allowed to sell, the greater of (1) in one
−Removed: week, no more than 1% of the total outstanding shares of the Company on a non-cumulative basis at the “ask” price, and (2)
−Removed: 15% of the daily trading volume of the Common Stock on any single trading day.
−Removed: Each drawdown will reduce the Balance.
−Removed: The Company is required
−Removed: to reserve 2,500,000,000 shares of Common Stock.
−Removed: TJM West, Inc v Thomas J McCarthy Family
−Removed: Limited Partnership
−Removed: On or about July 25, 2023, TJM West filed an action
−Removed: in Maricopa court against its landlord for illegal lockout from the company’s facilities.
−Removed: On or about August 18, 2023, TJM West’s
−Removed: motion for Temporary Restraining Order was granted.
−Removed: September 27, 2023, TJM West counsel motion to
−Removed: withdraw was accepted.
−Removed: On or about October 6, 2923, TJM West hired new
−Removed: counsel to assist with a short deadline to file answers to landlords motion.
−Removed: On or about November 6, 2023, TJM West and its
−Removed: counsel mutually agreed to a withdrawal.
−Removed: On or about November 6, 2023, TJM West engaged
−Removed: On or about May 8, 2024, TJM West dropped its
−Removed: motion for Temporary Restraining Order.
−Removed: On or about May 24, 2024, TJM West counsel filed
−Removed: motion to continue discovery.
−Removed: On or about May 24, 2024, TJM West’s counsel
−Removed: left the firm handling the litigation it was determined in the best interest of the company to terminate its relationship with the law
−Removed: As of the date hereof, the Company is interviewing new counsel and evaluating its claims against landlord to determine if it’s
−Removed: financially responsible to incur additional fees related to exercising TJM’s rights against the landlord for terminating the lease.
−Removed: On or about June 28, 2024, the Company discussed
−Removed: with possible new counsel the feasibility of recovering its damages utilizing the courts.
−Removed: At that time, it appeared the cost of recovery
−Removed: would exceed the recoverable amount should the Company be successful in its litigation.
−Removed: TJM West is awaiting updates from the court in
−Removed: Maricopa County as to the status of the case.
−Removed: The facilities in question had served as TJM West’s
−Removed: manufacturing facility and is located at 2640 W Medtronic Way Tempe, AZ 85281.
−Removed: Currently, we do
−Removed: not have access to the facility nor have we signed a new lease signed with the landlord.
−Removed: In addition to the foregoing Legal Proceedings,
−Removed: we are also actively investigating potential legal claims, including but not limited to stock fraud, market manipulation, and/or defamation,
−Removed: against certain Twitter accounts, websites, and social media channels.
−Removed: The investigation is ongoing and should potential claims be identified,
−Removed: we will evaluate commencing formal litigation proceedings.
−Removed: From time to time, we may become involved in litigation
−Removed: relating to claims arising out of our operations in the normal course of business.
−Removed: We are not currently involved in any pending legal
−Removed: proceeding or litigation and, to the best of our knowledge, no governmental authority is contemplating any proceeding to which we are
−Removed: a party or to which any of our properties is subject, which would reasonably be likely to have a material adverse effect on our business,
−Removed: financial condition and operating results.
+Added: On July 16, 2024, the parties submitted final briefing on their
+Added: respective motions for summary judgment and/or dismissal to the Court.
+Added: As of the date hereof, the Court has not issued
+Added: a ruling on the parties’ respective motions.
+Added: The Company remains committed to actively litigating its claims for relief against
+Added: the Crown Bridge Defendants.
+Added: Unasserted Matters
+Added: We are unfamiliar with any unasserted claims held by the Company as
+Added: of December 31, 2025.
MINE SAFETY DISCLOSURES.
1 unchanged sentence
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.