Evidence Record

Exhibit 6

1. On June 28, 2023, a Virginia state court signed the Amended Final Order and Judgment against Cyberlux (and Mark D. Schmidt) in Case No. CL22-3882, in the Circuit Court of the City of...

Type
exhibit
Court
EDVA
Case
HII v. Cyberlux interpleader
Docket
3:25-cv-00483
Pages
5
Lines
142
SHA-256
878b97cfffef

DISTIL analysis

DISTIL Run
Profile
Standard
Version
1
Doc Type
legal_notice_letter
Total Nodes
34
Node Legend
Entity (ENT)
Event (EVT)
Claim (CLM)
Anchor (ANC)
Omission (OMI)
Tension (TEN)
Tell (TEL)
Inference (INF)
Hypothesis (HYP)
Stage 1
Index
Orientation · No nodes
Document Classification
legal_notice_letter Bell Nunnally law firm representing Atlantic Wave Holdings LLC commercial_litigation_debt_collection 2023-06-15 to 2025-04-24
multiple_creditor_claimsgarnishment_activeinterpleader_riskjudgment_enforcement
Analytical Frame
multi-party creditor dispute over subcontract payments
Analytical Summary
This letter from Atlantic Wave Holdings' counsel formally notifies Huntington Ingalls Industries that Atlantic Wave claims entitlement to funds HII holds for Cyberlux Corporation under a terminated subcontract. Atlantic Wave asserts a $912,000 minimum judgment from June 2023, perfected security interests via UCC filing, an active garnishment proceeding, and additional breach claims totaling over $7.7 million. The letter identifies at least four other creditors pursuing Cyberlux for debts exceeding $13.5 million collectively, including Legalist SPV III ($7.3M), RB Capital Partners ($5.7M), Thin Air Gear ($365K), and Aerotek ($204K). The notice requests HII withhold all funds pending resolution of competing claims, creating a classic interpleader scenario where multiple parties assert rights to the same pool of money.
Key Points
  • Atlantic Wave holds $912,000 judgment against Cyberlux domesticated in three states
  • UCC-1 financing statement filed July 2023 perfecting security interest in Cyberlux accounts receivable
  • Active garnishment proceeding with HII withholding payment pending court order
  • Atlantic Wave claims total exposure exceeds $7.7 million including breach damages
  • Four identified competing creditors claim over $13.5 million from Cyberlux
  • HII holds funds under terminated subcontract related to Prime Task Order 47QFCA22F0039
Stage 2
Core — Entities, Events, Claims
20 nodes
ENT-001
Entity
Atlantic Wave Holdings, LLC
Creditor entity holding judgment and security interests against Cyberlux Corporation, represented by David A. Walton of Bell Nunnally law firm
Page 2 — Atlantic Wave Holdings, LLC (Atlantic Wave)'s claims to funds held or to be held by HII on behalf of or for the benefit of Cyberlux Corporation
ENT-002
Entity
Cyberlux Corporation
Debtor entity subject to multiple creditor claims, judgment debtor to Atlantic Wave, party to terminated HII subcontract
Page 2 — Cyberlux Corporation (Cyberlux). Upon information and belief, 'Cyberlux has asserted entitlement to payment' from HII pursuant to Subcontract No. P000043846
ENT-003
Entity
Huntington Ingalls Industries / HII Mission Technologies
Prime contractor holding funds under terminated subcontract with Cyberlux, recipient of garnishment notice, party potentially facing interpleader situation
Page 2 — Huntington Ingalls Industries and HII Mission Technologies Corp. (collectively HII) as to Atlantic Wave Holdings, LLC (Atlantic Wave)'s claims to funds held or to be held by HII on behalf of or for the benefit of Cyberlux Corporation
ENT-004
Entity
Legalist SPV III, LP
Competing creditor claiming $7.3 million debt from Cyberlux under loan agreement with daily accruing fees
Page 4 — Legalist SPV III, LP filed a Petition in Intervention on February 7, 2025, alleging that Cyberlux is 'indebted to Legalist in the amount of $7,313,627.17 with fees accruing at a daily rate of $4,364.46 by virtue of their failure to satisfy their obligations under the Loan Agreement.'
ENT-005
Entity
RB Capital Partners
Competing creditor claiming approximately $5.7 million debt from Cyberlux in Southern District of California litigation
Page 4 — In Case No. 3:24-cv-01434-AJB-DTF, RB Capital Partners v. Cyberlux Corporation et al. (S.D.Cal.), filed on August 12, 2024, RB Capital Partners alleges that Cyberlux is indebted to RB Capital in the amount of $5,686,960, plus interest and attorney fees.
ENT-006
Entity
Thin Air Gear, LLC
Competing creditor claiming $365,049.42 debt from Cyberlux in Colorado federal litigation
Page 4 — In Case No. 1:25-cv-00805-GPG-MDB, Thin Air Gear, LLC, v. Cyberlux Corporation (D.Colo.), filed on March 12, 2025, Thin Air Gear, LLC, alleges that Cyberlux is indebted to Thin Air Gear in the amount of $365,049.42 as of November 18, 2024, including a 1.5% late fee per month on past due amounts.
ENT-007
Entity
Aerotek, Inc.
Competing creditor claiming $204,705.45 debt from Cyberlux for payroll expenses in North Carolina litigation
Page 4 — In Case No. 24CV034906-910, Aerotek, Inc. v. Cyberlux Corporation et al., In the General Court of Justice, Superior Court Division, State of North Carolina, filed on October 29, 2024, Aerotek alleges that Cyberlux is indebted to Aerotek for payroll expenses in the amount of $204,705.45, plus interest and attorney fees.
EVT-001
Event
Amended Final Order and Judgment Entry
Virginia state court entered Amended Final Order and Judgment against Cyberlux and Mark D. Schmidt on June 28, 2023 in Case No. CL22-3882, later domesticated in California (January 2024) and Texas (July 2024)
Page 2 — On June 28, 2023, a Virginia state court signed the Amended Final Order and Judgment against Cyberlux (and Mark D. Schmidt) in Case No. CL22-3882, in the Circuit Court of the City of Richmond, Virginia. The Amended Final Order and Judgment has since been domesticated in California state court in January of 2024 and in Texas state court in July of 2024.
EVT-002
Event
UCC-1 Financing Statement Filing
Atlantic Wave filed UCC Financing Statement with Virginia State Corporation Commission on July 6, 2023 to perfect security interest in Cyberlux collateral including accounts receivable
Page 3 — On July 6, 2023, Atlantic Wave filed a UCC Financing Statement (Form UCC1) with the Virginia State Corporation Commission, Office of the Clerk, to perfect Atlantic Wave's security interest in certain collateral of Cyberlux, including but not limited to 'money ... [and] accounts receivable and other rights to payment and performance.'
EVT-003
Event
HII Garnishment Answer Filing
HII filed Answer to writ of garnishment on October 24, 2024 stating it is withholding payment to Cyberlux pending court direction
Page 3 — On October 24, 2024, HII filed an Answer to writ of garnishment issued at the request of Atlantic Wave in Case No. CL22-3882-15, in the Circuit Court of the City of Richmond, Virginia, stating it 'is withholding any payment which is or may become due and owing to Cyberlux ... pending further order and/or direction of the Court.'
EVT-004
Event
Settlement Agreement Execution
Atlantic Wave and Cyberlux entered Settlement Agreement on June 15, 2023 including attorney fee provisions and stock compliance obligations with December 31, 2023 deadline
Page 3 — On June 15, 2023, Atlantic Wave and Cyberlux entered into a Settlement Agreement in Case No. CL22-3882, in the Circuit Court of the City of Richmond, Virginia, wherein Cyberlux agreed to be 'responsible for the payment of [Atlantic Wave's] attorneys' fees and costs in any action caused by the breach of this [Settlement] Agreement.'
EVT-005
Event
Subcontract Termination
HII and Cyberlux executed Modification No. 4 to Subcontract No. P000043846 effectuating termination settlement, effective February 26, 2025
Page 2 — HII pursuant to Subcontract No. P000043846, dated August 29, 2023, HII's Prime Task Order 47QFCA22F0039, and Technical Direction Letter 1-023
CLM-001
Claim
Atlantic Wave Judgment Claim: $912,000 minimum
Atlantic Wave asserts minimum $912,000 owed under Amended Final Order and Judgment after accounting for prior payments, credits, or offsets
Page 2 — The outstanding balance due and owed under the Amended Final Order and Judgment is, at minimum, $912,000, after accounting for any prior payments, credits, or offsets.
CLM-002
Claim
Atlantic Wave Attorney Fees Claim: $592,000+
Atlantic Wave claims attorney fees and costs exceeding $592,000 as of April 24, 2025 caused by Cyberlux's breach of Settlement Agreement, with ongoing accrual
Page 3 — As of April 24, 2025, the attorneys' fees and costs incurred by Atlantic Wave caused by Cyberlux's breach of the Settlement Agreement is well in excess of $592,000, and attorneys' fees and costs continue to accrue as a result of Cyberlux's wrongful conduct.
CLM-003
Claim
Atlantic Wave Stock Compliance Breach Damages: $6,017,250
Atlantic Wave claims damages exceeding $6 million for Cyberlux's failure to bring stock to Pink Current status and remedy caveat emptor classification by December 31, 2023 deadline
Page 3 — Pursuant to the Settlement Agreement, Cyberlux was contractually obligated, among other obligations, to bring its stock to Pink Current status and to remedy the caveat emptor classification on such stock by December 31, 2023, or be subject to additional liability and damages to Atlantic Wave. Cyberlux did not comply with its contractual obligation, which is now the subject of Case No. CL24-3910, in the Circuit Court of the City of Richmond, Virginia. The damages caused by Cyberlux's wrongful conduct is in excess of $6,017,250 (calculated based on a 20-day rolling average share price of $.0308577 for 195,000,000 shares).
CLM-004
Claim
Atlantic Wave Total Claim: $7,774,000+
Atlantic Wave contends total amount owed exceeds $7.774 million based on judgment, security interests, and breach claims
Page 3, 4 — Based on the foregoing judgment, security interest, and claims, among others, Atlantic Wave contends it is currently owed in excess of $7,774,000
CLM-005
Claim
Legalist Loan Default Claim: $7,313,627.17
Legalist claims $7.3 million debt with daily accruing fees of $4,364.46 for Cyberlux's failure to satisfy loan agreement obligations
Page 4 — Legalist SPV III, LP filed a Petition in Intervention on February 7, 2025, alleging that Cyberlux is 'indebted to Legalist in the amount of $7,313,627.17 with fees accruing at a daily rate of $4,364.46 by virtue of their failure to satisfy their obligations under the Loan Agreement.'
CLM-006
Claim
RB Capital Debt Claim: $5,686,960
RB Capital alleges Cyberlux owes $5.7 million plus interest and attorney fees
Page 4 — In Case No. 3:24-cv-01434-AJB-DTF, RB Capital Partners v. Cyberlux Corporation et al. (S.D.Cal.), filed on August 12, 2024, RB Capital Partners alleges that Cyberlux is indebted to RB Capital in the amount of $5,686,960, plus interest and attorney fees.
CLM-007
Claim
Thin Air Gear Debt Claim: $365,049.42
Thin Air Gear claims debt of $365,049.42 as of November 18, 2024 including 1.5% monthly late fees
Page 4 — In Case No. 1:25-cv-00805-GPG-MDB, Thin Air Gear, LLC, v. Cyberlux Corporation (D.Colo.), filed on March 12, 2025, Thin Air Gear, LLC, alleges that Cyberlux is indebted to Thin Air Gear in the amount of $365,049.42 as of November 18, 2024, including a 1.5% late fee per month on past due amounts.
CLM-008
Claim
Aerotek Payroll Claim: $204,705.45
Aerotek claims Cyberlux owes $204,705.45 for payroll expenses plus interest and attorney fees
Page 4 — In Case No. 24CV034906-910, Aerotek, Inc. v. Cyberlux Corporation et al., In the General Court of Justice, Superior Court Division, State of North Carolina, filed on October 29, 2024, Aerotek alleges that Cyberlux is indebted to Aerotek for payroll expenses in the amount of $204,705.45, plus interest and attorney fees.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
8 nodes
QUO-001
Quotation
Security interest language in judgment
Amended Final Order and Judgment contains agreed security interest provision favoring Atlantic Wave
Page 2, 3 — The Amended Final Order and Judgment, as agreed to by Cyberlux, also provides that 'the parties have agreed to a security interest and lien interest in all property of Defendants [Cyberlux and Mark D. Schmidt] in favor of Plaintiffs [Atlantic Wave and Secure Community, LLC] until all sums are paid, and such security interest may be further memorialized through the filing of appropriate UCC-1 forms and the filing of appropriate Liens.'
QUO-002
Quotation
HII withholding statement
HII's garnishment answer confirms funds are being held pending court direction
Page 3 — On October 24, 2024, HII filed an Answer to writ of garnishment issued at the request of Atlantic Wave in Case No. CL22-3882-15, in the Circuit Court of the City of Richmond, Virginia, stating it 'is withholding any payment which is or may become due and owing to Cyberlux ... pending further order and/or direction of the Court.'
QUO-003
Quotation
Attorney fee responsibility clause
Settlement Agreement placed attorney fee liability on Cyberlux for breach-related actions
Page 3 — On June 15, 2023, Atlantic Wave and Cyberlux entered into a Settlement Agreement in Case No. CL22-3882, in the Circuit Court of the City of Richmond, Virginia, wherein Cyberlux agreed to be 'responsible for the payment of [Atlantic Wave's] attorneys' fees and costs in any action caused by the breach of this [Settlement] Agreement.'
TEN-001
Tension
Competing priority claims to same fund
Multiple creditors assert rights to limited funds held by HII, with aggregate claims ($21M+) vastly exceeding likely available funds under terminated subcontract
Page 4 — On the face of those pleadings, Cyberlux is allegedly indebted to other creditors in an amount in excess of $13,500,000, not including the amount due and owed to Atlantic Wave. In addition, there is reason to believe that other creditors or stakeholders may exist that have a claim to funds held on behalf of or for the benefit of Cyberlux.
TEN-002
Tension
Secured vs unsecured creditor priority
Atlantic Wave claims perfected security interest via UCC filing and judgment lien, potentially giving priority over other creditors, but letter does not analyze other creditors' secured status
Page 3 — On July 6, 2023, Atlantic Wave filed a UCC Financing Statement (Form UCC1) with the Virginia State Corporation Commission, Office of the Clerk, to perfect Atlantic Wave's security interest in certain collateral of Cyberlux, including but not limited to 'money ... [and] accounts receivable and other rights to payment and performance.'
QST-001
Question
What is the actual value of funds HII holds?
Letter references funds held under terminated subcontract but does not specify dollar amount available, critical to understanding creditor recovery potential
Page 3, 4 — Atlantic Wave contends it is currently owed in excess of $7,774,000, and further contends that it is entitled to satisfy the amount owed by and through funds held by HII on behalf of or for the benefit of Cyberlux.
QST-002
Question
Do other creditors hold perfected security interests?
Letter identifies Legalist and RB Capital as major creditors but does not address whether they hold secured positions that might compete with Atlantic Wave's UCC filing
Page 4 — Legalist SPV III, LP filed a Petition in Intervention on February 7, 2025, alleging that Cyberlux is 'indebted to Legalist in the amount of $7,313,627.17 with fees accruing at a daily rate of $4,364.46 by virtue of their failure to satisfy their obligations under the Loan Agreement.'
QST-003
Question
What is the legal basis for the $6M stock compliance damages?
Atlantic Wave claims over $6 million in damages based on share price calculation for failure to achieve Pink Current status, but underlying contractual damage formula is not disclosed
Page 3 — The damages caused by Cyberlux's wrongful conduct is in excess of $6,017,250 (calculated based on a 20-day rolling average share price of $.0308577 for 195,000,000 shares).
Stage 4
Interpretive — Inferences, Omissions, Patterns
6 nodes
INF-001
Inference
Interpleader action likely
Letter structure and request for HII to withhold funds suggests Atlantic Wave anticipates or is preparing for interpleader proceeding where HII deposits funds with court for competing creditors to litigate priority
Page 4, 5 — We kindly request HII take all appropriate actions to protect such funds from disbursement to (or dissipation by) Cyberlux, until any and all conflicting claims to the affected funds may be resolved amongst the necessary parties or by a court of competent jurisdiction.
INF-002
Inference
Cyberlux facing insolvency
Aggregate creditor claims exceeding $21 million across multiple jurisdictions, terminated government subcontract, and inability to meet settlement obligations suggest Cyberlux is insolvent or near-insolvent
Page 4 — On the face of those pleadings, Cyberlux is allegedly indebted to other creditors in an amount in excess of $13,500,000, not including the amount due and owed to Atlantic Wave.
INF-003
Inference
Strategic timing of notice
Letter sent April 24, 2025, shortly after February 26, 2025 termination settlement effective date, suggests Atlantic Wave monitoring for payment trigger and acting preemptively to establish claim before other creditors
Page 2 — This letter serves as formal notice to Huntington Ingalls Industries and HII Mission Technologies Corp. (collectively HII) as to Atlantic Wave Holdings, LLC (Atlantic Wave)'s claims to funds held or to be held by HII on behalf of or for the benefit of Cyberlux Corporation.
OMI-001
Omission
No disclosure of HII fund amount
Letter does not state dollar value of funds held by HII under terminated subcontract, critical information for assessing creditor recovery potential and priority dispute stakes
Page 3, 4 — Atlantic Wave contends it is currently owed in excess of $7,774,000, and further contends that it is entitled to satisfy the amount owed by and through funds held by HII on behalf of or for the benefit of Cyberlux.
OMI-002
Omission
No analysis of competing security interests
While asserting its own perfected security interest, Atlantic Wave does not address whether Legalist, RB Capital, or other creditors hold competing secured positions that might affect priority
Page 3, 4 — Based on the foregoing judgment, security interest, and claims, among others, Atlantic Wave contends it is currently owed in excess of $7,774,000
OMI-003
Omission
Settlement Agreement substantive terms not disclosed
Letter references Settlement Agreement obligations including stock compliance requirements but does not provide full contractual terms, damage calculation methodology, or other material provisions
Page 3 — Pursuant to the Settlement Agreement, Cyberlux was contractually obligated, among other obligations, to bring its stock to Pink Current status and to remedy the caveat emptor classification on such stock by December 31, 2023

Extracted text

5 pages · 7845 characters

Exhibit 6 — Formatted Extract

Type: exhibit
Court: EDVA
Matter: HII v. Cyberlux interpleader
Docket: 3:25-cv-00483
EXHIBIT 6

BN

BELLNUNNALLY ATTORNEYS & COUNSELORS

David A. Walton TEL: 214.740.1445 FAX: 214.740.5745 DWALTON@BELLNUNNALLY.COM

April 24, 2025

VIA EMAIL (clark.belote@kaufcan.com) Clark J. Belote Kaufman & Canoles, P.C. 150 W. Main Street, Suite 2100 Norfolk, VA 23510

RE: Claims to funds held or to be held on behalf of or for the benefit of Cyberlux Corporation.

Dear Mr. Belote:

This letter serves as formal notice to Huntington Ingalls Industries and HII Mission Technologies Corp. (collectively HII) as to Atlantic Wave Holdings, LLC (Atlantic Wave)'s claims to funds held or to be held by HII on behalf of or for the benefit of Cyberlux Corporation (Cyberlux). Upon information and belief, "Cyberlux has asserted entitlement to payment" from HII pursuant to Subcontract No. P000043846, dated August 29, 2023, HII's Prime Task Order 47QFCA22F0039, and Technical Direction Letter 1-023, as set forth in the Modification No. 4 to Subcontract No. P000043846 to Effectuate a Termination Settlement, effective as of February 26, 2025, by and between HII and Cyberlux. Atlantic Wave hereby asserts it is an interested stakeholder in any payment due and owed to Cyberlux by HII because Cyberlux has not satisfied debts due and owed to Atlantic Wave, in whole or in part, under a valid and enforceable judgment, writ of garnishment, or lien:

1.
On June 28, 2023, a Virginia state court signed the Amended Final Order and Judgment against Cyberlux (and Mark D. Schmidt) in Case No. CL22-3882, in the Circuit Court of the City of Richmond, Virginia. The Amended Final Order and Judgment has since been domesticated in California state court in January of 2024 and in Texas state court in July of 2024. The outstanding balance due and owed under the Amended Final Order and Judgment is, at minimum, $912,000, after accounting for any prior payments, credits, or offsets.
2.
The Amended Final Order and Judgment, as agreed to by Cyberlux, also provides that "the parties have agreed to a security interest and lien interest in all property of Defendants [Cyberlux and Mark D. Schmidt] in favor of

CLARK J. BELOTE KAUFMAN & CANOLES, P.C. APRIL 24, 2025

Plaintiffs [Atlantic Wave and Secure Community, LLC] until all sums are paid, and such security interest may be further memorialized through the filing of appropriate UCC-1 forms and the filing of appropriate Liens."

3.
On July 6, 2023, Atlantic Wave filed a UCC Financing Statement (Form UCC1) with the Virginia State Corporation Commission, Office of the Clerk, to perfect Atlantic Wave's security interest in certain collateral of Cyberlux, including but not limited to "money ... [and] accounts receivable and other rights to payment and performance."
4.
On October 24, 2024, HII filed an Answer to writ of garnishment issued at the request of Atlantic Wave in Case No. CL22-3882-15, in the Circuit Court of the City of Richmond, Virginia, stating it "is withholding any payment which is or may become due and owing to Cyberlux ... pending further order and/or direction of the Court."
5.
On June 15, 2023, Atlantic Wave and Cyberlux entered into a Settlement Agreement in Case No. CL22-3882, in the Circuit Court of the City of Richmond, Virginia, wherein Cyberlux agreed to be "responsible for the payment of [Atlantic Wave's] attorneys' fees and costs in any action caused by the breach of this [Settlement] Agreement." As of April 24, 2025, the attorneys' fees and costs incurred by Atlantic Wave caused by Cyberlux's breach of the Settlement Agreement is well in excess of $592,000, and attorneys' fees and costs continue to accrue as a result of Cyberlux's wrongful conduct.
6.
Pursuant to the Settlement Agreement, Cyberlux was contractually obligated, among other obligations, to bring its stock to Pink Current status and to remedy the caveat emptor classification on such stock by December 31, 2023, or be subject to additional liability and damages to Atlantic Wave. Cyberlux did not comply with its contractual obligation, which is now the subject of Case No. CL24-3910, in the Circuit Court of the City of Richmond, Virginia. The damages caused by Cyberlux's wrongful conduct is in excess of $6,017,250 (calculated based on a 20-day rolling average share price of $.0308577 for 195,000,000 shares).

Based on the foregoing judgment, security interest, and claims, among others, Atlantic Wave contends it is currently owed in excess of $7,774,000, and further contends

CLARK J. BELOTE KAUFMAN & CANOLES, P.C. APRIL 24, 2025

that it is entitled to satisfy the amount owed by and through funds held by HII on behalf of or for the benefit of Cyberlux.

There are reasonable grounds to anticipate other rival claims to the same funds held by HII on behalf of or for the benefit of Cyberlux. Upon information and belief, Cyberlux is the subject of several other claims for monies due and owed by Cyberlux:

1.
In Case No. 1:25-cv-00805-GPG-MDB, Thin Air Gear, LLC, v. Cyberlux Corporation (D.Colo.), filed on March 12, 2025, Thin Air Gear, LLC, alleges that Cyberlux is indebted to Thin Air Gear in the amount of $365,049.42 as of November 18, 2024, including a 1.5% late fee per month on past due amounts.
2.
In Cause No. 2024-48085, Atlantic Wave Holdings, LLC, et al. v. Cyberlux Corporation, et al., 129th Judicial District Court, Harris County, Texas, Legalist SPV III, LP filed a Petition in Intervention on February 7, 2025, alleging that Cyberlux is "indebted to Legalist in the amount of $7,313,627.17 with fees accruing at a daily rate of $4,364.46 by virtue of their failure to satisfy their obligations under the Loan Agreement."
3.
In Case No. 24CV034906-910, Aerotek, Inc. v. Cyberlux Corporation et al., In the General Court of Justice, Superior Court Division, State of North Carolina, filed on October 29, 2024, Aerotek alleges that Cyberlux is indebted to Aerotek for payroll expenses in the amount of $204,705.45, plus interest and attorney fees.
4.
In Case No. 3:24-cv-01434-AJB-DTF, RB Capital Partners v. Cyberlux Corporation et al. (S.D.Cal.), filed on August 12, 2024, RB Capital Partners alleges that Cyberlux is indebted to RB Capital in the amount of $5,686,960, plus interest and attorney fees.

On the face of those pleadings, Cyberlux is allegedly indebted to other creditors in an amount in excess of $13,500,000, not including the amount due and owed to Atlantic Wave. In addition, there is reason to believe that other creditors or stakeholders may exist that have a claim to funds held on behalf of or for the benefit of Cyberlux.

Regardless of whether Cyberlux avers that it is not liable in whole or in part to any or all of the creditors or stakeholders, such averment is not ground for objection to HII taking appropriate actions to protect funds held by HII on behalf of or for the benefit of Cyberlux. We kindly request HII take all appropriate actions to protect such funds from

CLARK J. BELOTE KAUFMAN & CANOLES, P.C. APRIL 24, 2025

disbursement to (or dissipation by) Cyberlux, until any and all conflicting claims to the affected funds may be resolved amongst the necessary parties or by a court of competent jurisdiction.

We are glad to further discuss the foregoing matters with you and consider any resolution beneficial and fair to all affected parties. Please let us know your availability. Time is of the essence, and we appreciate in advance your prompt attention to this matter.

Very truly yours, Dank A. Walken

David A. Walton

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ip-hii-edva-00483-doc-0041-exhibit-6.pdf
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878b97cfffef0b69a130a569f7c0da605c9426f230cf4337690fc0bb7816e488