ANPC July 21 letter and default judgment — debt award, asserted equitable claim to HII funds

EXHIBIT 15 Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 1 of 13 PageID# 636

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 PPAB 12597398v1 Parker Poe Adams & Bernstein LLP PNC Plaza 301 Fayetteville Street Suite 1400 Raleigh, NC 27602-0389 t 919.828.0564 f 919.834.4564 www.parkerpoe.com July 21, 2025 VIA EMAIL Clark J. Belote Kaufman & Canoles, P.C. 150 West Main Street 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 interplead ed 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. 1 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. Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 2 of 13 PageID# 637

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 PPAB 12597398v1 Parker Poe Adams & Bernstein LLP PNC Plaza 301 Fayetteville Street Suite 1400 Raleigh, NC 27602-0389 t 919.828.0564 f 919.834.4564 www.parkerpoe.com July 21, 2025 VIA EMAIL Clark J. Belote Kaufman & Canoles, P.C. 150 West Main Street 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 interplead ed 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. 1 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. Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 2 of 13 PageID# 637

Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 5 of 13 PagelD# 640 STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE FILED SUPERIOR COURT DIVISION COUNTY OF DURHAM 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: The Motion is GRANTED; and Judgment in favor of ANPC and against Cyberlux in the amount of $2,926,814.39, as set out in the Verified Complaint, which includes: (1) $2,830,050.00 for the Final Invoice and (2) interest accruing at the legal rate of 8% on the principal amount until the judgment is satisfied, which is $96,764.39 as of July 15, 2025; and 3. This Judgment shall accrue post-judgment interest as allowed by law. This the 21 day of July → 2025. Lisa P. Strickland Clerk, Durham County Superior Court X Assistant Clerk

Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 6 of 13 PagelD# 641 25CV005686-310 STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF DURHAM 25-CVS- Advanced Navigation & Positioning Corporation Plaintiff, -V- VERIFIED COMPLAINT Cyberlux Corporation Defendant. Plaintiff, complaining of the Defendant, alleges: PARTIES The Plaintiff Advanced Navigation & Positioning Corporation, ('Plaintiff or "ANPC") is a Delaware corporation in good standing with a legal existence and the capacity to sue, with its principal place of business located at 489 North gih Street, Suite 203, Hood River, Oregon, 97031. 2. Upon information and belief, Cyberlux Corporation ("Defendant or "Cyberlux') is a Nevada corporation with its principal place of business in Durham County located at 800 Park Offices Drive, Suite 3209 Research Triangle, North Carolina, 27709 and can be served with process upon its registered agent, CT Corporation System, located at 160 Mine Lake Ct Ste 200, Raleigh, North Carolina 27615. This Court has jurisdiction over the parties to this action pursuant to N.C. General Statute §1-75.4 and other applicable bases for jurisdiction. 4. Venue is proper pursuant to N.C. General Statute §1-82 and other applicable bases for venue. PR Electronically Filed Date: 6/5/2025 4:37 PM Durham Superior Court County Clerk of Superior Court

Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 8 of 13 PagelD# 643 14. Pursuant to the Purchase Agreement, Cyberlux was required to pay the Final Invoice within ten days business days of Cyberlux's receipt of payment from Cyberlux's customer. 15. Upon information and belief, Cyberlux had received payment from Cyberlux's customer as of December 20, 2024 sufficient to pay the Final Invoice by December 30, 2024. 16. Cyberlux breached the Purchase Agreement when it failed to make a payment on the Final Invoice on or before December 30, 2024. 17. According to the Purchase Agreement, all disputes arising under the Purchase Agreement must be initially referred to the parties' senior management for resolution. The parties agreed to wait fourteen calendar days following referral to senior management before bringing to court any action arising out of or related to the Purchase Agreement. 18. Upon Cyberlux's failure to pay the Final Invoice in a timely manner, ANPC, by and through its attorney, gave notice to the Buyer's CEO of Cyberlux's failure to make timely payments on May 15, 2025 (the "Payment Dispute Letter"). 19. The Payment Dispute Letter was sent to Cyberlux's CEO via Federal Express and email. 20. As of the date of this Verified Complaint, Cyberlux has not responded to the Payment Dispute Letter. 21. It has been more than fourteen days since ANPC sent the Payment Dispute Letter to Cyberlux. CLAIM FOR RELIEF (Breach of Contract-Purchase Agreement) 22. ANPC incorporates the prior allegations of the Complaint by reference. 23. The Purchase Agreement is a valid and enforceable contract. 24. ANPC has performed all of its obligations under the Purchase Agreement. 3

Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 11 of 13 PagelD# 646 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. Advanced Navigation and Positioning Corporation OFFICIAL STAMP Emily Joyce NOTARY PUBLIC - OREGON By: Tim Arbogast — CFO STATE OF COUNTY OF HoOd RIDer 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. OFFICIAL STAMP Notary Public Emily Joyce (Type or Print Name) NOTARY PUBLIC - OREGON COMMISSION NO. 1058184 MY COMMISSION EXPIRES MAY 13, 2029 My commission expires:. May 13, 2029 (Notary Seal) [Visual notarisation supplement: State of Oregon, County of Hood River; June5,2025; Tim Arbogast and Emily Joyce signatures present. Alternative wording beginning or proven by satisfactory evidence is crossed out, leaving personal knowledge.]

ExhibitA Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 12 of 13 PageID# 647

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 PPAB 12597398v1 Parker Poe Adams & Bernstein LLP PNC Plaza 301 Fayetteville Street Suite 1400 Raleigh, NC 27602-0389 t 919.828.0564 f 919.834.4564 www.parkerpoe.com July 21, 2025 VIA EMAIL Clark J. Belote Kaufman & Canoles, P.C. 150 West Main Street 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 interplead ed 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. 1 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. Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 2 of 13 PageID# 637

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 PPAB 12597398v1 Parker Poe Adams & Bernstein LLP PNC Plaza 301 Fayetteville Street Suite 1400 Raleigh, NC 27602-0389 t 919.828.0564 f 919.834.4564 www.parkerpoe.com July 21, 2025 VIA EMAIL Clark J. Belote Kaufman & Canoles, P.C. 150 West Main Street 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 interplead ed 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. 1 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. Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 2 of 13 PageID# 637

Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 5 of 13 PagelD# 640 STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE FILED SUPERIOR COURT DIVISION COUNTY OF DURHAM 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: The Motion is GRANTED; and Judgment in favor of ANPC and against Cyberlux in the amount of $2,926,814.39, as set out in the Verified Complaint, which includes: (1) $2,830,050.00 for the Final Invoice and (2) interest accruing at the legal rate of 8% on the principal amount until the judgment is satisfied, which is $96,764.39 as of July 15, 2025; and 3. This Judgment shall accrue post-judgment interest as allowed by law. This the 21 day of July → 2025. Lisa P. Strickland Clerk, Durham County Superior Court X Assistant Clerk

Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 5 of 13 PagelD# 640 STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE FILED SUPERIOR COURT DIVISION COUNTY OF DURHAM 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: The Motion is GRANTED; and Judgment in favor of ANPC and against Cyberlux in the amount of $2,926,814.39, as set out in the Verified Complaint, which includes: (1) $2,830,050.00 for the Final Invoice and (2) interest accruing at the legal rate of 8% on the principal amount until the judgment is satisfied, which is $96,764.39 as of July 15, 2025; and 3. This Judgment shall accrue post-judgment interest as allowed by law. This the 21 day of July → 2025. Lisa P. Strickland Clerk, Durham County Superior Court X Assistant Clerk

Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 11 of 13 PagelD# 646 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. Advanced Navigation and Positioning Corporation OFFICIAL STAMP Emily Joyce NOTARY PUBLIC - OREGON By: Tim Arbogast — CFO STATE OF COUNTY OF HoOd RIDer 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. OFFICIAL STAMP Notary Public Emily Joyce (Type or Print Name) NOTARY PUBLIC - OREGON COMMISSION NO. 1058184 MY COMMISSION EXPIRES MAY 13, 2029 My commission expires:. May 13, 2029 (Notary Seal) [Visual notarisation supplement: State of Oregon, County of Hood River; June5,2025; Tim Arbogast and Emily Joyce signatures present. Alternative wording beginning or proven by satisfactory evidence is crossed out, leaving personal knowledge.]

EXHIBIT 15 Case 3:25-cv-00483-JAG Document 41-15 Filed 08/04/25 Page 1 of 13 PageID# 636