Exhibit 15

P

Parker Poe

Catherine G. Clodfelter Partner t: 919.835.4036 f: 919.834.4564 catherineclodfelter@parkerpoe.com

Atlanta, GA Charleston, SC Charlotte, NC Columbia, SC Greenville, SC Raleigh, NC Spartanburg, SC Washington, DC

July 21, 2025

VIA EMAIL

Clark J. Belote

Kaufman & Canoles, P.C.

Suite 2100

Norfolk, VA 23510

clark.belote@kaufcan.com

Re:

HII Mission Technologies v. Cyberlux Corporation, et al.

Civil Action No. 3:25-cv-483

United States District Court for the Eastern District of Virginia

Request for Confirmation of Interest in Payment Receivable

Dear Mr. Belote,

Thank you for your letter and the opportunity to discuss our claim to the interpleaded amounts (the "Disputed Funds"). ANPC does claim that it has an interest in the Disputed Funds, as opposed to a general unsecured claim.

As an initial matter, ANPC filed a complaint (the "Complaint") against Cyberlux in North Carolina, to which Cyberlux did not answer or otherwise appear, and ANPC obtained a default judgment (the "Judgment"). We are including a copy of both the Complaint and Judgment with this letter.1 ANPC is domesticating the Judgment in Virginia and pursuing a garnishment. Those actions alone provide ANPC with a claim to the Disputed Funds beyond that of an unsecured creditor.

' ANPC is providing the Complaint and Judgment along with this letter. Because the parties have a confidentiality agreement which may include information set out in the Purchase Agreement, we will describe the provisions that are relevant and not confidential but will not provide you with a copy of the Purchase Agreement itself.

July 21, 2025

In addition, and to the extent necessary, ANPC will assert a lien on the Disputed Funds by asking the Federal Court in the Eastern District of Virginia to impose an equitable lien on the Disputed Funds. A brief outline of our contentions and supportive legal authority follows. Because the parties agreed in the Purchase Agreement that North Carolina law would govern any dispute, we are providing here the North Carolina and Fourth Circuit authority that supports ANPC's claim to the funds.

The Complaint stated a claim for money judgment based on Cyberlux's breach of a purchase agreement between the parties (the "Purchase Agreement"). ANPC contends that, by language in the Purchase Agreement, Cyberlux assigned certain funds to ANPC to be used as payment for assets and services that ANPC provided to produce the product that Cyberlux then sold to its customer. ANPC contends that the assignment is contained in the payment terms, which are in part as follows: "payment by BUYER to the Supplier shall be made within ten (10) Business Days following the date of BUYER's receipt of payment from BUYER's customer." To the extent necessary, ANPC will request in the interpleader action that the court create an equitable lien in favor of ANPC as a result of this language and the way that the funds, which were supposed to be paid to ANPC, were instead disbursed.

Under North Carolina law, an assignment occurs when a party intends to place a fund out of the owner's control for the benefit of another. Motz v. Stowe, 83 N.C. 434, 439 (1880) ("anything written, said, or done, in pursuance of an agreement and for valuable consideration, or in consideration of some pre-existing debt, to place a money right or fund out of the original owner's control, and to appropriate in favor of another person, amounts to an equitable assignment."). No particular writing is necessary for there to be an equitable assignment. Id. ("no writing or particular form of words is necessary, provided only a consideration be proved and the intention of the parties made apparent by suitable evidence.").

Equitable assignment will be allowed, even if the contract provides only a mere promise to pay from a specific fund, if considerations of unjust enrichment are implicated. See Embree Const. Grp., Inc. v. Rafcor, Inc., 330 N.C. 487, 497, 411 S.E.2d 916, 923 (1992). Where the assignee works to create a thing of value, and the sale of that thing of value allows the assignor to receive funds from which the assignee was to be paid, courts in North Carolina will impose an equitable assignment over the funds paid to the assignor so as to not allow the assignor to be unjustly enriched by the work of the assignee. Id.

July 21, 2025 Page 3

ANPC and Cyberlux acted jointly to fulfill the work and services request from Cyberlux's customer that was the subject of the Purchase Agreement.

Cyberlux promised to pay ANPC for its work out of the funds received from Cyberlux's customer in the Purchase Agreement. However, Cyberlux retained those funds instead, and, upon information and belief, used the funds to complete other work and serve other customers. Cyberlux was unjustly enriched in such a manner as to support a finding that there should be an equitable assignment in favor of ANPC over the funds received, not only from Cyberlux's customer in the Purchase Agreement, but over funds received from HII as well.

We have concluded from our research that in a federal interpleader filed under 28 U.S.C.A. § 1335, courts will allow and determine the contentions that ANPC raises in this letter. See Three Mountaineers, Inc. v. Ramsey, 143 F. Supp. 888, 889 (W.D.N.C. 1956).

ANPC requests that any HII continue to include ANPC in the interpleader action and would appreciate the chance to speak further if you have any questions.

Sincerely, Cati Carpeta

Catherine G. Clodfelter

CGC

cc: Steven Naito Charles Raynal

STATE OF NORTH CAROLINA COUNTY OF DURHAM

FILED IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION

DATE: July 21, 2025 25-CVS-005686-310

TIME: 2:45:28 PM Advanced Navigation & Positioning DURHAM COUNTY Corporation

CLERK OF SUPERIOR COURT BY: Strickland, Lisa

Plaintiff, )

)

DEFAULT JUDGMENT

-V-

)

)

Cyberlux Corporation

)

) Defendant. )

)

THIS CAUSE coming before the undersigned, upon Motion of Advanced Navigation & Positioning Corporation ("ANPC") for Default Judgment against Cyberlux Corporation ("Defendant") on a breach of contract claim filed by Verified Complaint. Defendant has failed to plead or otherwise defend in this action and a default has been entered.

Therefore, it is ORDERED, ADJUDGED, and DECREED that:

This the 21 day of July 2025. Lisa P. Strickland

Clerk, Durham County Superior Court X Assistant Clerk

25CV005686-310

STATE OF NORTH CAROLINA COUNTY OF DURHAM

IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION 25-CVS-

Advanced Navigation & Positioning Corporation

) )

)

Plaintiff, )

)

) VERIFIED COMPLAINT -V- ) Cyberlux Corporation

)

)

Defendant.

) )

Plaintiff, complaining of the Defendant, alleges:

BACKGROUND

WHEREFORE, ANPC respectfully prays that the Court:

A. Enter judgment in favor of ANPC and against Cyberlux in the amount of $2,926,814.39, which includes: (1) $2,830,050.00 for the Final Invoice and (2) interest in the amount of $96,764.39.

B. Grant ANPC post-judgment interest as allowed by law.

C. Tax the costs of this action against Cyberlux.

D. Grant ANPC such other and further relief as the Court deems just and proper.

This the 5th day of June, 2025.

/s/ Catherine G. Clodfelter Catherine G. Clodfelter N.C. State Bar No. 47653 Charles E. Raynal IV N.C. State Bar No. 32310 PARKER POE ADAMS & BERNSTEIN LLP

P.O. Box 389 (27602-0389)

Raleigh, North Carolina 27601

Telephone:

Facsimile:

Email:

catherineclodfelter@parkerpoe.com

charlesraynal@parkerpoe.com

Counsel for Plaintiff ANPC

VERIFICATION

Tim Arbogast, being first duly sworn, deposes and says that he is the CFO of Advanced Navigation and Positioning Corporation, a Delaware corporation, and, as such, he is authorized to make this oath; that he has read the foregoing and attached Verified Complaint, and that the same is true of his own personal knowledge except those matters stated upon information and belief, which he believes to be true.

By: Tim Arbogast

CFO

STATE OF Oregon COUNTY OF Hood River

OFFICIAL STAMP Emily Joyce

NOTARY PUBLIC - OREGON

Personally appeared before me, Tim Arbogast, either being personally known to me or proven by satisfactory evidence (said evidence being ), and acknowledged that he signed the foregoing document.

This the 5 day of June 2025.

Enaly Joyce

OFFICIAL STAMP Emily Joyce NOTARY PUBLIC - OREGON COMMISSION NO. 1058184 MY COMMISSION EXPIRES MAY 13, 2029

Notary Public Emily Joyce (Type or Print Name)

My commission expires:

May 13, 2029

(Notary Seal)

Page:

ANPC Advanced Navigation & Positioning Corporation

+ Advanced Navigation & Positioning Corporation 489 N 8th Street Suite 203 Hood River, OR 97031 (800) 228-1857

Invoice

Invoice Number:

0000696-IN

Invoice Date:

12/20/2024

Order Number:

Order Date:

10/8/2024

Salesperson:

FRMB

Customer Number:

14-CYB001

Sold To:

Cyberlux Corporation

Research Triangle Park

Durham, NC 27709

Confirm To:

Ship To:

Cyberlux Corporation

Research Triangle Park

Durham, NC 27709

Customer P.O.

Ship VIA

F.O.B.

Terms

CCC Agreement 106703.105

Prepaid

Item Code

Unit

Ordered

Shipped

Back Ordered

Price

Amount

/4000-14

EACH

1.00

1.00

0.00

2,830,050.00

2,830,050.00

Revenue-International Milestone 4: 20% of contract due upon SAT

Prepared by: Tim Arbogast 2024.12.20 07:16:42-08'00' +

Net Invoice:

2,830,050.00

Less Discount:

0.00

Freight:

0.00

Sales Tax:

0.00

Invoice Total:

2,830,050.00

Ti Adoção