ARG v Cyberlux — Durham complaint, 24 April 2025

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF DURHAM THE ARG GROUP, LLC, 25CV004246-310 Plaintiff, COMPLAINT CYBERLUX CORPORATION, Defendant. NOW COMES Plaintiff, THE ARG GROUP, LLC ("ARG" or "Plaintiff"), complaining of the Defendant, CYBERLUX CORPORATION ("'Cyberlux" or "Defendant") and alleges the following: PARTIES AND JURISDICTION 1. Plaintiff is limited liability company organized under the laws of the State of North Carolina and doing business in North Carolina, with registered agent and office located in North Carolina. 2. Plaintiff is Service-Disabled Veteran-Owned Small Business and HUBZone certified small business, is leading provider of sales and tactical distribution services of advanced technology equipment to the Department of Defense, Federal Law Enforcement Agencies and US Allies. Plaintiff has global reach across North and South America and Europe and is focused on delivering advanced technology solution to the warfighter, including drone capabilities and advanced technology products for special operators. Plaintiff serves the Special Operations Command, the U.S. Air Force, the National Guard Bureau, Homeland Security/Customs and Border Protection, and Federal Law Enforcement. 3. Upon information and belief, Defendant is corporation organized and existing under the laws of the State of Nevada and doing business in North Carolina, with registered Electronically Filed Date: 4/24/2025 1:50 PM Durham Superior Court County Clerk of Superior Court JG

office located at 160 Mine Lake Ct, Ste 200, Raleigh, North Carolina 27615, and principal office located at 800 Park Offices Dr, Suite 3209, Research Triangle Park, North Carolina 27709. 4. Defendant develops, manufactures, and sells Advanced Lighting Solutions ("ALS") for portable and fixed use, certain solar power solutions, and Unmanned Aircraft Systems ("UAS") products including UAS hardware and software solutions. 5. Defendant's products include, but are not limited to, the BrightEye and Watchdog Tactical Illumination Systems, other various LED and solar products, and the FlightEye UAS products including FlightEye drone hardware and the Flight GDN software operating platform and related product offerings (collectively, the "Products'"). 6. This Court has jurisdiction over the parties and subject matter of this action. 7. Venue is proper in this Court of Durham County pursuant to N.C. Gen. Stat. §§ 1- 79 and 1-82, and the forum selection clause contained in the Contract entered into between Plaintiff and Defendant governing this dispute. FIRST CAUSE OF ACTION Breach of Contract 8. The allegations contained in the preceding paragraphs are realleged and incorporated herein. 9. On February 28, 2022, Plaintiff and Defendant entered into valid and binding Cyberlux Corporation and The ARG Group, LLC Distributor Partner Agreement (the "Contract"). 10. Pursuant to the terms of the Contract, Defendant agreed to provide Plaintiff with twenty percent (20%) discount off the GSA pricing for the Products. In turn, Plaintiff was responsible for securing customer orders and facilitating the sale of the Products. 11. One of the principal Products sold was the K8 Drone, for which Plaintiff secured $79 million contract with the United States Department of Defense on behalf of Defendant to

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF DURHAM THE ARG GROUP, LLC, 25CV004246-310 Plaintiff, COMPLAINT CYBERLUX CORPORATION, Defendant. NOW COMES Plaintiff, THE ARG GROUP, LLC ("ARG" or "Plaintiff"), complaining of the Defendant, CYBERLUX CORPORATION ("'Cyberlux" or "Defendant") and alleges the following: PARTIES AND JURISDICTION 1. Plaintiff is limited liability company organized under the laws of the State of North Carolina and doing business in North Carolina, with registered agent and office located in North Carolina. 2. Plaintiff is Service-Disabled Veteran-Owned Small Business and HUBZone certified small business, is leading provider of sales and tactical distribution services of advanced technology equipment to the Department of Defense, Federal Law Enforcement Agencies and US Allies. Plaintiff has global reach across North and South America and Europe and is focused on delivering advanced technology solution to the warfighter, including drone capabilities and advanced technology products for special operators. Plaintiff serves the Special Operations Command, the U.S. Air Force, the National Guard Bureau, Homeland Security/Customs and Border Protection, and Federal Law Enforcement. 3. Upon information and belief, Defendant is corporation organized and existing under the laws of the State of Nevada and doing business in North Carolina, with registered Electronically Filed Date: 4/24/2025 1:50 PM Durham Superior Court County Clerk of Superior Court JG

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF DURHAM THE ARG GROUP, LLC, 25CV004246-310 Plaintiff, COMPLAINT CYBERLUX CORPORATION, Defendant. NOW COMES Plaintiff, THE ARG GROUP, LLC ("ARG" or "Plaintiff"), complaining of the Defendant, CYBERLUX CORPORATION ("'Cyberlux" or "Defendant") and alleges the following: PARTIES AND JURISDICTION 1. Plaintiff is limited liability company organized under the laws of the State of North Carolina and doing business in North Carolina, with registered agent and office located in North Carolina. 2. Plaintiff is Service-Disabled Veteran-Owned Small Business and HUBZone certified small business, is leading provider of sales and tactical distribution services of advanced technology equipment to the Department of Defense, Federal Law Enforcement Agencies and US Allies. Plaintiff has global reach across North and South America and Europe and is focused on delivering advanced technology solution to the warfighter, including drone capabilities and advanced technology products for special operators. Plaintiff serves the Special Operations Command, the U.S. Air Force, the National Guard Bureau, Homeland Security/Customs and Border Protection, and Federal Law Enforcement. 3. Upon information and belief, Defendant is corporation organized and existing under the laws of the State of Nevada and doing business in North Carolina, with registered Electronically Filed Date: 4/24/2025 1:50 PM Durham Superior Court County Clerk of Superior Court JG

office located at 160 Mine Lake Ct, Ste 200, Raleigh, North Carolina 27615, and principal office located at 800 Park Offices Dr, Suite 3209, Research Triangle Park, North Carolina 27709. 4. Defendant develops, manufactures, and sells Advanced Lighting Solutions ("ALS") for portable and fixed use, certain solar power solutions, and Unmanned Aircraft Systems ("UAS") products including UAS hardware and software solutions. 5. Defendant's products include, but are not limited to, the BrightEye and Watchdog Tactical Illumination Systems, other various LED and solar products, and the FlightEye UAS products including FlightEye drone hardware and the Flight GDN software operating platform and related product offerings (collectively, the "Products'"). 6. This Court has jurisdiction over the parties and subject matter of this action. 7. Venue is proper in this Court of Durham County pursuant to N.C. Gen. Stat. §§ 1- 79 and 1-82, and the forum selection clause contained in the Contract entered into between Plaintiff and Defendant governing this dispute. FIRST CAUSE OF ACTION Breach of Contract 8. The allegations contained in the preceding paragraphs are realleged and incorporated herein. 9. On February 28, 2022, Plaintiff and Defendant entered into valid and binding Cyberlux Corporation and The ARG Group, LLC Distributor Partner Agreement (the "Contract"). 10. Pursuant to the terms of the Contract, Defendant agreed to provide Plaintiff with twenty percent (20%) discount off the GSA pricing for the Products. In turn, Plaintiff was responsible for securing customer orders and facilitating the sale of the Products. 11. One of the principal Products sold was the K8 Drone, for which Plaintiff secured $79 million contract with the United States Department of Defense on behalf of Defendant to

office located at 160 Mine Lake Ct, Ste 200, Raleigh, North Carolina 27615, and principal office located at 800 Park Offices Dr, Suite 3209, Research Triangle Park, North Carolina 27709. 4. Defendant develops, manufactures, and sells Advanced Lighting Solutions ("ALS") for portable and fixed use, certain solar power solutions, and Unmanned Aircraft Systems ("UAS") products including UAS hardware and software solutions. 5. Defendant's products include, but are not limited to, the BrightEye and Watchdog Tactical Illumination Systems, other various LED and solar products, and the FlightEye UAS products including FlightEye drone hardware and the Flight GDN software operating platform and related product offerings (collectively, the "Products'"). 6. This Court has jurisdiction over the parties and subject matter of this action. 7. Venue is proper in this Court of Durham County pursuant to N.C. Gen. Stat. §§ 1- 79 and 1-82, and the forum selection clause contained in the Contract entered into between Plaintiff and Defendant governing this dispute. FIRST CAUSE OF ACTION Breach of Contract 8. The allegations contained in the preceding paragraphs are realleged and incorporated herein. 9. On February 28, 2022, Plaintiff and Defendant entered into valid and binding Cyberlux Corporation and The ARG Group, LLC Distributor Partner Agreement (the "Contract"). 10. Pursuant to the terms of the Contract, Defendant agreed to provide Plaintiff with twenty percent (20%) discount off the GSA pricing for the Products. In turn, Plaintiff was responsible for securing customer orders and facilitating the sale of the Products. 11. One of the principal Products sold was the K8 Drone, for which Plaintiff secured $79 million contract with the United States Department of Defense on behalf of Defendant to

3 supply Defendant K8 Unmanned Aircraft Systems, resulting in Defendant receiving $39 million in upfront payment upon execution of the contract, delivering $15 million in product during 2023, and retaining $23 million in advance payments as of December 31, 2023. 12. The parties agreed that proceeds from such sales would be allocated with eighty percent (80%) payable to Defendant and twenty percent (20%) payable to Plaintiff. 13. Following execution of the Contract, Plaintiff actively facilitated Defendant’s business operations by introducing Defendant to potential purchasers of the Products and to individuals who could further support Defendant’s business interests. Plaintiff played an integral role in the growth and success of Defendant’s enterprise and functioned, in effect, as a business partner. 14. As a result of Plaintiff’s substantial assistance—including establishing key business contacts and facilitating operations —Defendant agreed to share profits with Plaintiff on sales regardless of which party originated the transaction. This agreement recognized Plaintiff’s foundational role in enabling Defendant’s access to those business opportunities. 15. In acknowledgment of Plaintiff’s contributions, Defendant has made partial payments to Plaintiff in accordance with their agreement and has expressly admitted to owing Plaintiff additional sums. 16. Defendant continues to owe Plaintiff significant sums under the parties’ agreement, which remain due and unpaid. 17. As of the filing of this Complaint, Defendant has failed or refused to pay Plaintiff the outstanding amounts owed under the parties’ agreement, despite Plaintiff’s entitlement to such payment. 18. Defendant’s failure or refusal to remit payment to Plaintiff constitutes a material

3 supply Defendant K8 Unmanned Aircraft Systems, resulting in Defendant receiving $39 million in upfront payment upon execution of the contract, delivering $15 million in product during 2023, and retaining $23 million in advance payments as of December 31, 2023. 12. The parties agreed that proceeds from such sales would be allocated with eighty percent (80%) payable to Defendant and twenty percent (20%) payable to Plaintiff. 13. Following execution of the Contract, Plaintiff actively facilitated Defendant’s business operations by introducing Defendant to potential purchasers of the Products and to individuals who could further support Defendant’s business interests. Plaintiff played an integral role in the growth and success of Defendant’s enterprise and functioned, in effect, as a business partner. 14. As a result of Plaintiff’s substantial assistance—including establishing key business contacts and facilitating operations —Defendant agreed to share profits with Plaintiff on sales regardless of which party originated the transaction. This agreement recognized Plaintiff’s foundational role in enabling Defendant’s access to those business opportunities. 15. In acknowledgment of Plaintiff’s contributions, Defendant has made partial payments to Plaintiff in accordance with their agreement and has expressly admitted to owing Plaintiff additional sums. 16. Defendant continues to owe Plaintiff significant sums under the parties’ agreement, which remain due and unpaid. 17. As of the filing of this Complaint, Defendant has failed or refused to pay Plaintiff the outstanding amounts owed under the parties’ agreement, despite Plaintiff’s entitlement to such payment. 18. Defendant’s failure or refusal to remit payment to Plaintiff constitutes a material

Plaintiff, and Plaintiff's efforts directly enabled Defendant to generate revenue and grow its business operations. 35. At the time Plaintiff provided valuable goods and services to Defendant, based on the acts, statements, and conduct of the parties, there was clear understanding that Plaintiff was not providing said goods and services gratuitously, and that Defendant would be required to financially compensate Plaintiff for the same. 36. Defendant's failure to compensate Plaintiff for the goods and services provided constitutes material and substantial breach of contract implied in fact, for which Defendant is liable. 37. As aresult of Defendant's breach of the contract implied in fact, Plaintiff has been damaged and is entitled to recover from Defendant an amount well in excess of Twenty-Five Thousand Dollars ($25,000.00), the precise amount to be determined at trial, together with all costs, interest, and attorneys' fees recoverable under applicable North Carolina law. FOURTH CLAIM FOR RELIEF Conversion 38. The allegations contained in the preceding paragraphs are realleged and incorporated herein by reference. 39. Plaintiff performed all obligations under the terms of the agreement with Defendant, providing goods, services, and other benefits. 40. Defendant received and accepted the goods, services, and benefits provided by Plaintiff, generated substantial profits from the same, and retained those profits for its own use and gain. 41. Despite Plaintiff's performance and Defendant's acceptance of the goods, services, and benefits, Defendant has unlawfully retained possession of the property or funds rightfully

belonging to Plaintiff. 42. Defendant's actions constitute an unauthorized exercise of dominion and control over Plaintiff's property, to the exclusion of Plaintiff's rights. 43. As direct and proximate result of Defendant's wrongful conduct, Plaintiff has been deprived of the use and enjoyment of the property or funds, and has suffered damages in an amount to be determined at trial. 44. Plaintiff seeks recovery of the full value of the property or funds unlawfully converted by Defendant, along with interest, costs, and reasonably attorney's fees permitted by law. FIFTH CLAIM FOR RELIEF Unfair and Deceptive Trade Practices, N.C. Gen. Stat. 75-1.1, et. seq. 45. The allegations contained in the preceding paragraphs are realleged and incorporated herein by reference. 46. The acts and/or omissions of Defendant as herein alleged constitute unfair or deceptive acts or practices. 47. Defendant made numerous explicit representations to Plaintiff regarding various business transactions, repeatedly assuring Plaintiff that it would be fairly compensated for its substantial efforts. 48. However, these assurances were mere pretexts, as Defendant never had any intention of honoring those promises. Instead, Plaintiff was intentionally misled into believing that compensation would be forthcoming, leading Plaintiff to rely on Defendant's false assurances to its detriment. 49. These actions exceed the scope of mere breach of contract and instead reflect deliberate, willful, and calculated scheme to exploit Plaintiff's substantial contributions.

8 50. Plaintiff’s efforts were critical to Defendant’s success, including, but not limited to, introducing Defendant to key business contacts, providing comprehensive operational support, establishing test sites, facilitating the integration of complex firing me chanisms, generating valuable business leads, and advising on technical specifications and cost data—each of which was essential to the effective functioning and growth of Defendant’s operations. 51. Defendant’s conduct reflects an intent to wrongfully benefit from Plaintiff’s intellectual and operational contributions without compensating Plaintiff for its significant efforts. 52. Defendant’s conduct was intended to deprive Plaintiff of the benefits of its work and goodwill. 53. The acts and/or omissions of Defendant as herein alleged were performed in or affecting commerce. 54. The acts and/or omissions of Defendant as herein alleged constitute violations of the North Carolina Unfair and Deceptive Trade Practices Act. 55. As a direct and proximate result of Defendant’s violations of the North Carolina Unfair and Deceptive Trade Practices Act, Plaintiff has suffered damages for which Defendant is liable. 56. Plaintiff is entitled to recover damages caused by Defendant’s violations of the North Carolina Unfair and Deceptive Trade Practices Act, in an amount to be proven at trial, and to have the same trebled pursuant to N.C. Gen. Stat. § 75-16. 57. Plaintiff is further entitled to recover its reasonable attorneys’ fees for the prosecution of Defendant’s violations of the North Carolina Unfair and Deceptive Trade Practices Act, pursuant to N.C. Gen. Stat. § 75-16.1.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF DURHAM THE ARG GROUP, LLC, 25CV004246-310 Plaintiff, COMPLAINT CYBERLUX CORPORATION, Defendant. NOW COMES Plaintiff, THE ARG GROUP, LLC ("ARG" or "Plaintiff"), complaining of the Defendant, CYBERLUX CORPORATION ("'Cyberlux" or "Defendant") and alleges the following: PARTIES AND JURISDICTION 1. Plaintiff is limited liability company organized under the laws of the State of North Carolina and doing business in North Carolina, with registered agent and office located in North Carolina. 2. Plaintiff is Service-Disabled Veteran-Owned Small Business and HUBZone certified small business, is leading provider of sales and tactical distribution services of advanced technology equipment to the Department of Defense, Federal Law Enforcement Agencies and US Allies. Plaintiff has global reach across North and South America and Europe and is focused on delivering advanced technology solution to the warfighter, including drone capabilities and advanced technology products for special operators. Plaintiff serves the Special Operations Command, the U.S. Air Force, the National Guard Bureau, Homeland Security/Customs and Border Protection, and Federal Law Enforcement. 3. Upon information and belief, Defendant is corporation organized and existing under the laws of the State of Nevada and doing business in North Carolina, with registered Electronically Filed Date: 4/24/2025 1:50 PM Durham Superior Court County Clerk of Superior Court JG

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF DURHAM THE ARG GROUP, LLC, 25CV004246-310 Plaintiff, COMPLAINT CYBERLUX CORPORATION, Defendant. NOW COMES Plaintiff, THE ARG GROUP, LLC ("ARG" or "Plaintiff"), complaining of the Defendant, CYBERLUX CORPORATION ("'Cyberlux" or "Defendant") and alleges the following: PARTIES AND JURISDICTION 1. Plaintiff is limited liability company organized under the laws of the State of North Carolina and doing business in North Carolina, with registered agent and office located in North Carolina. 2. Plaintiff is Service-Disabled Veteran-Owned Small Business and HUBZone certified small business, is leading provider of sales and tactical distribution services of advanced technology equipment to the Department of Defense, Federal Law Enforcement Agencies and US Allies. Plaintiff has global reach across North and South America and Europe and is focused on delivering advanced technology solution to the warfighter, including drone capabilities and advanced technology products for special operators. Plaintiff serves the Special Operations Command, the U.S. Air Force, the National Guard Bureau, Homeland Security/Customs and Border Protection, and Federal Law Enforcement. 3. Upon information and belief, Defendant is corporation organized and existing under the laws of the State of Nevada and doing business in North Carolina, with registered Electronically Filed Date: 4/24/2025 1:50 PM Durham Superior Court County Clerk of Superior Court JG

7. That the costs of this action be taxed against Defendant; 8. For trial by jury on all issues so triable; and 9. That Plaintiff have and recover from Defendant such other and further relief as the Court may deem appropriate. This the 24" day of April 2025. 10 ANDERSON JONES, PLLC /s/ Christian Lunghi CHRISTIAN LUNGHI NCSB #60978 Post Office Box 20248 Raleigh, NC 27619 Phone: (919) 277-2541 Fax: (919) 277-2544 clunghi@andersonandjones.com Attorneyfor Plaintiff

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF DURHAM THE ARG GROUP, LLC, 25CV004246-310 Plaintiff, COMPLAINT CYBERLUX CORPORATION, Defendant. NOW COMES Plaintiff, THE ARG GROUP, LLC ("ARG" or "Plaintiff"), complaining of the Defendant, CYBERLUX CORPORATION ("'Cyberlux" or "Defendant") and alleges the following: PARTIES AND JURISDICTION 1. Plaintiff is limited liability company organized under the laws of the State of North Carolina and doing business in North Carolina, with registered agent and office located in North Carolina. 2. Plaintiff is Service-Disabled Veteran-Owned Small Business and HUBZone certified small business, is leading provider of sales and tactical distribution services of advanced technology equipment to the Department of Defense, Federal Law Enforcement Agencies and US Allies. Plaintiff has global reach across North and South America and Europe and is focused on delivering advanced technology solution to the warfighter, including drone capabilities and advanced technology products for special operators. Plaintiff serves the Special Operations Command, the U.S. Air Force, the National Guard Bureau, Homeland Security/Customs and Border Protection, and Federal Law Enforcement. 3. Upon information and belief, Defendant is corporation organized and existing under the laws of the State of Nevada and doing business in North Carolina, with registered Electronically Filed Date: 4/24/2025 1:50 PM Durham Superior Court County Clerk of Superior Court JG

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF DURHAM THE ARG GROUP, LLC, 25CV004246-310 Plaintiff, COMPLAINT CYBERLUX CORPORATION, Defendant. NOW COMES Plaintiff, THE ARG GROUP, LLC ("ARG" or "Plaintiff"), complaining of the Defendant, CYBERLUX CORPORATION ("'Cyberlux" or "Defendant") and alleges the following: PARTIES AND JURISDICTION 1. Plaintiff is limited liability company organized under the laws of the State of North Carolina and doing business in North Carolina, with registered agent and office located in North Carolina. 2. Plaintiff is Service-Disabled Veteran-Owned Small Business and HUBZone certified small business, is leading provider of sales and tactical distribution services of advanced technology equipment to the Department of Defense, Federal Law Enforcement Agencies and US Allies. Plaintiff has global reach across North and South America and Europe and is focused on delivering advanced technology solution to the warfighter, including drone capabilities and advanced technology products for special operators. Plaintiff serves the Special Operations Command, the U.S. Air Force, the National Guard Bureau, Homeland Security/Customs and Border Protection, and Federal Law Enforcement. 3. Upon information and belief, Defendant is corporation organized and existing under the laws of the State of Nevada and doing business in North Carolina, with registered Electronically Filed Date: 4/24/2025 1:50 PM Durham Superior Court County Clerk of Superior Court JG