Evidence Record
Cm Arg V Cyberlux Durham Nc Cyberlux Answer 20250707
1. Defendant lacks knowledge or information sufficient to form a belief as to the truthfulness of the allegations in Paragraph 1 and, therefore, denies the same.
DISTIL analysis
DISTIL Run
Profile
Standard
Version
1
Doc Type
Legal Answer/Responsive Pleading
Total Nodes
18
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 Answer/Responsive Pleading Cyberlux Corporation (via Allen, Chesson & Grimes PLLC) Commercial Litigation - Contract Dispute 2022-02-28 to 2025-07-07
defensive_postureblanket_denialslimited_admissionsaffirmative_defense_asserted
Analytical Frame
Defense Response to Breach of Contract Claims
Analytical Summary
This is Cyberlux Corporation's Answer to a complaint filed by The ARG Group, LLC in Durham County Superior Court (Case 25-CV-004246-310). The document follows a standard defensive pleading structure, with Cyberlux admitting only minimal facts: its identity as a UAS/drone products manufacturer, and the existence of a February 28, 2022 Distributer Partner Agreement with ARG. The defendant systematically denies nearly all substantive allegations (paragraphs 11-57) without providing factual counter-narratives. Cyberlux asserts one affirmative defense under Rule 12(b)(6), arguing the complaint fails to state a claim. The defensive strategy is characterized by legal minimalism—offering no alternative factual account while challenging the legal sufficiency of plaintiff's claims.
Key Points
- Cyberlux admits entering a Distributer Partner Agreement with ARG on February 28, 2022
- Defendant systematically denies all substantive breach allegations without providing alternative facts
- Cyberlux asserts single affirmative defense: failure to state a claim under Rule 12(b)(6)
- No counterclaims filed against plaintiff
- Defense counsel requests jury trial and dismissal with prejudice
Stage 2
Core — Entities, Events, Claims
10 nodes
ENT-001
Entity
Cyberlux Corporation (Defendant)
Cyberlux Corporation, defendant in this action, described as a company that develops, manufactures, and sells UAS products including hardware and software solutions, drone hardware, software operating platforms, and related hardware.
Page 1 — Defendant Cyberlux Corporation ("Defendant") responds to Plaintiff's Complaint as follows... Defendant admits that it develops, manufactures, and sells UAS products including hardware and software solutions... Defendant admits that its products include certain drone hardware, software operating platforms, and related hardware.
ENT-002
Entity
The ARG Group, LLC (Plaintiff)
The ARG Group, LLC, plaintiff in this commercial litigation matter in Durham County Superior Court.
Page 1 — The ARG Group, LLC, Plaintiff, vs. Cyberlux Corporation, Defendant.
ENT-003
Entity
Allen, Chesson & Grimes PLLC
Law firm representing Cyberlux Corporation, with attorney J. Douglas Grimes (NC Bar #32699) serving as counsel. Located at 505 N. Church Street, Charlotte, North Carolina 28202.
Page 5 — ALLEN, CHESSON & GRIMES PLLC /s/ Doug Grimes J. Douglas Grimes, NC Bar #32699 505 N. Church Street Charlotte, North Carolina 28202 Telephone: 704.755.6010 dgrimes@allenchesson.com Counsel for Defendant
ENT-004
Entity
Anderson Jones, PLLC
Law firm representing plaintiff The ARG Group, LLC, with attorney Christian Lunghi serving as counsel. Located in Raleigh, North Carolina.
Page 6 — Christian Lunghi ANDERSON JONES, PLLC Post Office Box 60978 Raleigh, North Carolina 20248 Phone: (919) 277-2541 clunghi@andersonjones.com Attorneys for Plaintiff
ENT-005
Entity
Distributer Partner Agreement
A contract entered into between Cyberlux Corporation and The ARG Group, LLC on or about February 28, 2022, the specific terms of which are referenced but not detailed in this Answer.
Page 2 — Defendant admits that on or about February 28, 2022, Defendant and Plaintiff entered into a Distributer Partner Agreement, the contents of which speak for themselves.
EVT-001
Event
Execution of Distributer Partner Agreement
On or about February 28, 2022, Cyberlux Corporation and The ARG Group, LLC entered into a Distributer Partner Agreement governing their business relationship.
Page 2 — Defendant admits that on or about February 28, 2022, Defendant and Plaintiff entered into a Distributer Partner Agreement
EVT-002
Event
Filing of Answer
Cyberlux Corporation filed its Answer to plaintiff's Complaint on July 7, 2025 (though document internally references July 7, 2022, likely a typographical error given the case number 25-CV-004246-310).
Page 1, 5 — This the 7th day of July, 2022... Electronically Filed Date: 7/7/2025 2:23 PM Durham Superior Court County Clerk of Superior Court
CLM-001
Claim
Failure to State a Claim (12(b)(6) Defense)
Defendant asserts as its First Affirmative Defense that Plaintiff's Complaint fails to state a claim upon which relief may be granted, in whole or in part, and should be dismissed pursuant to North Carolina Rule of Civil Procedure 12(b)(6).
Page 4 — FIRST AFFIRMATIVE DEFENSE Plaintiff's Complaint fails to state a claim upon which relief may be granted, in whole or in part, and therefore should be dismissed pursuant to North Carolina Rule of Civil Procedure 12(b)(6).
CLM-002
Claim
Denial of Substantive Allegations
Defendant systematically denies all substantive allegations in paragraphs 11 through 57 of plaintiff's complaint without providing specific factual bases for the denials.
Page 2, 3, 4 — 11. Denied. 12. Denied. 13. Denied. 14. Denied. 15. Denied. 16. Denied. 17. Denied. 18. Denied. 19. Denied. 20. Denied... 22. Denied. 23. Denied. 24. Denied. 25. Denied. 26. Denied. 27. Denied. 28. Denied. 29. Denied. 30. Denied... 32. Denied. 33. Denied. 34. Denied. 35. Denied. 36. Denied. 37. Denied... 39. Denied. 40. Denied. 41. Denied. 42. Denied. 43. Denied. 44. Denied... 46. Denied. 47. Denied. 48. Denied. 49. Denied. 50. Denied. 51. Denied. 52. Denied. 53. Denied. 54. Denied. 55. Denied. 56. Denied. 57. Denied.
CLM-003
Claim
Request for Dismissal with Prejudice
Defendant requests that Plaintiff have and recover nothing, that Plaintiff's Complaint be dismissed with prejudice, that costs be taxed against Plaintiff, and that all issues of fact be tried before a jury.
Page 5 — WHEREFORE, Defendant respectfully requests that: 1. Plaintiff have and recover nothing from Defendant and that Plaintiff's Complaint be dismissed with prejudice; 2. That the costs of this action be taxed against Plaintiff; 3. That all issues of fact be tried before a jury; and 4. For all such other and further relief as the Court may deem just and proper.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
4 nodes
TEN-001
Tension
Date Discrepancy in Filing
The document contains inconsistent dates: the signature line states 'This the 7th day of July, 2022' while the electronic filing stamp shows '7/7/2025 2:23 PM' and the case number includes '25-CV' suggesting a 2025 filing.
Page 1, 5 — This the 7th day of July, 2022... Electronically Filed Date: 7/7/2025 2:23 PM Durham Superior Court County Clerk of Superior Court... 25-CV-004246-310
QST-001
Question
Nature of Plaintiff's Allegations
What specific breach of contract, damages, or misconduct does plaintiff allege in the 57 paragraphs that defendant systematically denies? The Answer provides no context for understanding the substantive claims.
Page 2, 3, 4 — 11. Denied. 12. Denied. 13. Denied. 14. Denied. 15. Denied. 16. Denied. 17. Denied. 18. Denied. 19. Denied. 20. Denied.
QST-002
Question
True Filing Date
Was this Answer actually filed on July 7, 2022 or July 7, 2025? The signature line and electronic filing stamp conflict, creating ambiguity about document timing relative to the 2022 contract execution.
Page 1, 5 — This the 7th day of July, 2022... Electronically Filed Date: 7/7/2025 2:23 PM
QST-003
Question
Basis for 12(b)(6) Defense
On what specific legal grounds does defendant assert the complaint fails to state a claim? No argument or supporting authority is provided for the Rule 12(b)(6) affirmative defense.
Page 4 — FIRST AFFIRMATIVE DEFENSE Plaintiff's Complaint fails to state a claim upon which relief may be granted, in whole or in part, and therefore should be dismissed pursuant to North Carolina Rule of Civil Procedure 12(b)(6).
Stage 4
Interpretive — Inferences, Omissions, Patterns
4 nodes
OMI-001
Omission
No Factual Counter-Narrative
Despite denying 47+ substantive allegations, defendant provides no alternative factual account of what occurred between the parties, leaving the actual events and contractual performance entirely unaddressed.
Page 2, 3, 4 — 11. Denied. 12. Denied. 13. Denied... [continuing through] 57. Denied.
OMI-002
Omission
No Counterclaims Asserted
Defendant files only defensive denials and one procedural affirmative defense, asserting no counterclaims for breach, damages, or other relief against plaintiff, suggesting either a purely defensive posture or strategic reservation of offensive claims.
Page 4, 5 — FIRST AFFIRMATIVE DEFENSE Plaintiff's Complaint fails to state a claim upon which relief may be granted, in whole or in part, and therefore should be dismissed pursuant to North Carolina Rule of Civil Procedure 12(b)(6).
INF-001
Inference
Minimal Defense Strategy
The defense strategy appears to be one of legal minimalism: admit only facts that are indisputable (corporate identity, contract existence), deny everything substantive without elaboration, assert a single procedural defense, and force plaintiff to prove every element at trial.
Page 2, 3, 4 — Defendant admits that on or about February 28, 2022, Defendant and Plaintiff entered into a Distributer Partner Agreement... 11. Denied. 12. Denied... FIRST AFFIRMATIVE DEFENSE Plaintiff's Complaint fails to state a claim upon which relief may be granted
INF-002
Inference
Contract Terms as Central Dispute
Defendant's repeated invocation that contract contents 'speak for themselves' suggests the interpretation and application of the February 2022 Distributer Partner Agreement will be the central factual and legal battleground.
Page 2 — Defendant admits that on or about February 28, 2022, Defendant and Plaintiff entered into a Distributer Partner Agreement, the contents of which speak for themselves... Defendant admits that the contents of contract speak for themselves.
Extracted text
6 pages · 4061 charactersFiling Header
STATE OF NORTH CAROLINA COUNTY OF DURHAM
IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION 25-CV-004246-310
The ARG Group, LLC, Plaintiff,
vs. Cyberlux Corporation,
Defendant.
ANSWER
Defendant Cyberlux Corporation ("Defendant") responds to Plaintiff's Complaint as follows:
1.
Defendant lacks knowledge or information sufficient to form a belief as to the truthfulness of the allegations in Paragraph 1 and, therefore, denies the same.
2.
Defendant lacks knowledge or information sufficient to form a belief as to the truthfulness of the allegations in Paragraph 1 and, therefore, denies the same.
3.
Admitted.
4.
Defendant admits that it develops, manufactures, and sells UAS products including hardware and software solutions. Except as admitted, Paragraph 4 is denied.
5.
Defendant admits that its products include certain drone hardware, software operating platforms, and related hardware. Except as admitted, Paragraph 5 is denied.
6.
. Paragraph 6 calls for a legal conclusion and, therefore, requires no response.
7.
Paragraph 7 calls for a legal conclusion and, therefore, requires no response.
8.
Defendant realleges and incorporates by reference its responses to the preceding paragraphs as though fully set forth herein.
9.
Defendant admits that on or about February 28, 2022, Defendant and Plaintiff entered into a Distributer Partner Agreement, the contents of which speak for themselves. Except as admitted, Paragraph 9 is denied.
10.
Defendant admits that the contents of contract speak for themselves. Except as admitted, and to the extent Paragraph 10 is inconsistent with said contractual terms, Paragraph 10 is denied.
11.
Denied.
12.
Denied.
13.
Denied.
14.
Denied.
15.
Denied.
16.
Denied.
17.
Denied.
18.
Denied.
19.
Denied.
20.
Denied.
1.
Defendant realleges and incorporates by reference its responses to the
preceding paragraphs as though fully set forth herein.
22.
Denied.
23.
Denied.
24.
Denied.
25.
Denied.
26.
Denied.
27.
Denied.
28.
Denied.
29.
Denied.
30.
Denied.
31.
Defendant realleges and incorporates by reference its responses to the preceding paragraphs as though fully set forth herein.
32.
Denied.
33.
Denied.
34.
Denied.
35.
Denied.
36.
Denied.
37.
Denied.
38.
Defendant realleges and incorporates by reference its responses to the preceding paragraphs as though fully set forth herein.
39.
Denied.
40.
Denied.
41.
Denied.
42.
Denied.
43.
Denied.
44.
Denied.
45.
Defendant realleges and incorporates by reference its responses to the preceding paragraphs as though fully set forth herein.
46.
Denied.
47.
Denied.
48.
Denied.
49.
Denied.
50.
Denied.
51.
Denied.
52.
Denied.
53.
Denied.
54.
Denied.
55.
Denied.
56.
Denied.
57.
Denied.
FIRST AFFIRMATIVE DEFENSE
Plaintiff's Complaint fails to state a claim upon which relief may be granted, in whole or in part, and therefore should be dismissed pursuant to North Carolina Rule of Civil Procedure 12(b)(6).
WHEREFORE, Defendant respectfully requests that:
1.
Plaintiff have and recover nothing from Defendant and that Plaintiff's Complaint be dismissed with prejudice;
2.
That the costs of this action be taxed against Plaintiff;
3.
That all issues of fact be tried before a jury; and
4.
For all such other and further relief as the Court may deem just and proper.
This the 7th day of July, 2022.
ALLEN, CHESSON & GRIMES PLLC
/s/ Doug Grimes J. Douglas Grimes, NC Bar #32699 505 N. Church Street Charlotte, North Carolina 28202 Telephone: 704.755.6010 dgrimes@allenchesson.com
Counsel for Defendant
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing document has been served by mailing a true copy thereof, through the United States Mail, first class, postage prepaid, on this the 7th day of July, 2025, properly addressed as follows:
Christian Lunghi ANDERSON JONES, PLLC Post Office Box 60978 Raleigh, North Carolina 20248
Phone: (919) 277-2541 clunghi@andersonjones.com
Attorneys for Plaintiff
/s/ Doug Grimes Doug Grimes
Original source file
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