Item 3. Legal Proceedings
ITEM 3. LEGAL
PROCEEDINGS.
Carebourn Capital, L.P. v. DarkPulse, Inc.
On or about January 29, 2021, Carebourn Capital, L.P. (“ Carebourn ”)
commenced an action against the Company in Minnesota State Court. Carebourn alleged that the Company was in breach of two convertible
promissory notes sold to Carebourn on or about July 17, 2018 and July 24, 2018. Thereafter, the Company answered Carebourn’s complaint
and asserted counterclaims under the Minnesota Securities Act.
On or about November 17, 2023, the State Court ruled in
the Company’s favor on, among other things, its counterclaim for damages pursuant to Minnesota Securities Act and awarded the Company
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
award in the amount of $387,693.48).
As of the date hereof, the final judgment remains unsatisfied
by Carebourn. DarkPulse intends to continue to exercise all legal rights and remedies available to it to collect the amounts awarded should
Carebourn fail to voluntarily pay the same.
More Capital, LLC v. DarkPulse, Inc. et al
On or about June 29, 2021, More Capital, LLC
(“ More ”) commenced an action against the Company in Minnesota State Court. More alleged that the Company was in breach
of a certain securities purchase agreement and convertible promissory note sold to More on or about August 20, 2018. Thereafter, the
Company answered More’s complaint and asserted counterclaims under the Minnesota Securities Act.
On or about December 11, 2023, the Minnesota State Court
ruled in the Company’s favor on, among other things, its counterclaim for damages pursuant to Minnesota Securities Act and awarded
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
(or a total award in the amount of $412,048.64).
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As of the date hereof, the final judgment remains unsatisfied
by More. DarkPulse intends to continue to exercise all legal rights and remedies available to it to collect the amounts awarded should
More fail to voluntarily pay the same.
Carebourn Capital et al v. Standard Registrar and Transfer et al
On or about May 20, 2022, the Carebourn Capital, L.P. (“ Carebourn ”)
and More Capital, LLC (“ More ,” and together with Carebourn, the “ Noteholders ”) commenced an action
against the Company, certain members of the Company’s executive team and board of directors and Standard Registrar and Transfer
Company, Inc., the Company’s transfer agent, in the United States District Court for the District of Utah. The Noteholders’
complaint alleged various causes of action arising from certain securities purchase agreements and convertible promissory notes the Company
sold to the Noteholders.
On or about November 1, 2023, the Noteholders moved to dismiss the
action.
On or about November 2, 2023, the Company moved for sanctions
against the Noteholders and their counsel of record.
On or about December 4, 2023, the Court entered an order
granting dismissal of the Noteholders’ claims with prejudice. The Court acknowledged that notwithstanding its dismissal of the Noteholders’
claims, the Court continues to retain jurisdiction over the Noteholders because of DarkPulse’s pending motion for sanctions against
the Noteholders and their attorneys.
On September 10, 2024, the Court entered an order granting in part
the Company’s motion for sanctions against the Noteholders and their counsel of record.
On July 15, 2025, the Court entered an order ordering the
Noteholders and their counsel to pay the sum of $70,840 to the Company. On September 30, 2025, the Court entered Final Judgment in this
matter.
As of the date hereof, the Noteholders and their
counsel have not paid the awarded amount to the Company. DarkPulse intends to continue to exercise all legal rights and remedies available
to it to collect the amounts awarded.
DarkPulse, Inc. v. FirstFire Global Opportunities Fund, LLC, et
al
On or about December 31, 2021, the Company commenced an action against
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
of New York.
On or about May 5, 2022, the Company amended its complaint
against the FirstFire Defendants. The amended complaint alleges that the FirstFire Defendants were liable to the Company for rescission
of certain convertible promissory notes and transitions effected thereunder and damages pursuant to the Securities Exchange Act of 1934
(“ Exchange Act ”) and Racketeer Influenced and Corrupt Organizations Act (“ RICO ”).
On or about January 17, 2023, the Court granted the FirstFire Defendants’
motion to dismiss the Company’s operative pleading. Later during the same day, the Company appealed the Court’s decision to
the United States Court of Appeals for the Second Circuit (“ Second Circuit ”).
On March 28, 2024, the Second Circuit issued its decision and found
that the District Court
(a) properly found that the Delaware forum-selection
clause was enforceable but, thereafter,
(b) improperly made a ruling on the merits of
the Company’s claims for relief. As a result, the Second Circuit affirmed the District Court’s decision in part, vacated in
part and remanded the case back to the District Court for transferring to the United States District Court for the District of Delaware.
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On September 30, 2025, the Delaware Court granted
the FirstFire Defendants’ Motion to Dismiss. On October 14, 2025, the Company filed a Motion for Reconsideration of the Delaware
Court’s September 30th decision.
As of the date hereof, the Delaware Court has not ruled on
DarkPulse’s Motion for Reconsideration. The Company remains committed to actively litigating its claims for relief against the FirstFire
Defendants.
DarkPulse, Inc., et al v. Crown Bridge Partners, LLC, et al
On or about September 23, 2022, the Company, Social Life Network, Inc.
and Redhawk Holdings Corp. (together, the “ Crown Bridge Plaintiffs ”) commenced an action against Crown Bridge Partners,
LLC (“ Crown Bridge ”) and its control persons, Soheil Ahdoot and Sepas Ahdoot (collectively, the “ Crown Bridge
Defendants ”) in the United States District Court for the Southern District of New York. The complaint alleges that the Crown
Bridge Defendants are liable to each of the plaintiffs for damages pursuant to the Racketeer Influenced and Corrupt Organizations Act
(“ RICO ”).
On or about September 29, 2023, the Court granted the Crown Bridge
Defendants’ motion to dismiss the plaintiffs’ complaint.
On October 23, 2023, the plaintiffs appealed the Court’s
decision to the United States Court of Appeals for the Second Circuit (“ Second Circuit ”).
On August 19, 2024, the Second Circuit issued
its decision and found that the District Court erred when granting the Crown Bridge Defendants’ motion to dismiss. As a result,
the Second Circuit vacated the District Court’s decision and remanded the case back to the District Court for further proceedings
consistent with its decision.
On July 16, 2024, the parties submitted final briefing on their
respective motions for summary judgment and/or dismissal to the Court.
As of the date hereof, the Court has not issued
a ruling on the parties’ respective motions. The Company remains committed to actively litigating its claims for relief against
the Crown Bridge Defendants.
Unasserted Matters
We are unfamiliar with any unasserted claims held by the Company as
of December 31, 2025.
ITEM 4. MINE SAFETY DISCLOSURES.
Not applicable.
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PART II
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