Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
observationobservation
ECF 155 filed 11 March 2026; document and service certificate dated 6 March; claim calculated through 15 April.
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1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
v.
CYBERLUX CORP.,et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
Case No. 3:25-cv-483
COMPLAINT IN INTERVENTION OF THE ARG GROUP, LLC
In accordance with Federal Rule of Civil Procedure 24 and its Motion to Intervene,
Intervenor The ARG Group, LLC (“ARG”), by and through its undersigned counsel of record,
respectfully submits this Complaint in Intervention, and states as follows:
PARTIES
1. Intervenor ARG is a Delaware limited liability company with its principal place of business
located in Tucson, Arizona.
2. Upon information and belief, the allegations regarding the parties as set forth in paragraphs 3
through 11 of Plaintiff HII Mission Technologies Corp.’s (“HII”) First Amended Complaint
for Interpleader (the “Amended Complaint”, ECF 41) accurately describe the parties named
in the Amended Complaint.
JURISDICTION AND VENUE
3. ARG accepts the allegations regarding jurisdiction and venue set forth in paragraphs 12
through 16 of HII’s Amended Complaint (ECF 41).
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 1 of 12 PageID# 2005
6
which party originated the transaction. This agreement recognized ARG’s foundational role
in enabling Cyberlux’s access to those business opportunities.
23. As a direct result of ARG’s efforts pursuant to the Contract, ARG was instrumental in
securing for Cyberlux the Subcontract between Cyberlux and HII for Cyberlux to supply K8
Unmanned Aircraft Systems, resulting in Cyberlux receiving $38,700,600 up front (the
“Initial Payment”) and $25,769,369.03 as final payment (the “Final Payment”) from HII. To
be clear, the K8 Drone was manufactured and sold pursuant to the Subcontract that is the
subject of HII’s Amended Complaint.SeeECF 41, ¶¶ 17-30.
The Amounts Owed ARG Under The Contract
24. Although Cyberlux received the Initial Payment from HII, it did not remit payment to ARG.
25. In accordance with the Contract, ARG is entitled to 20% of the $38,700,600 Initial Payment,
which is $7,740,120. ARG has not been paid its 20% of the Initial Payment for over 31
months (as of April 15, 2026). Prejudgment interest at 8% for 31 months on the $7,740,120
Initial Payment is $1,599,624.80 ($51,600.80/month). Therefore, through April 15, 2026,
ARG is owed $9,339,744.80 from the Initial Payment.
26. ARG also is entitled to 20% of the $25,769,369.03 Final Payment, which is $5,153,873.81,
plus prejudgment interest which cannot be calculated at this time.
27. In acknowledgment of ARG’s contributions and its obligations under the Contract, Cyberlux
has made $375,000 in partial payments to ARG and admitted that it owes ARG the amounts
claimed, but it has refused to pay the remaining amounts owed ARG.
28. After subtracting the $375,000 in partial payments made by Cyberlux, through April 15,
2026, in total, ARG is entitled to at least $14,118,618.61 from the Initial Payment and Final
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 6 of 12 PageID# 2010
observationobservation
Earlier asserted demand $15,272,447.30; later demand $14,118,618.61; unexplained difference $1,153,828.69.
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6
which party originated the transaction. This agreement recognized ARG’s foundational role
in enabling Cyberlux’s access to those business opportunities.
23. As a direct result of ARG’s efforts pursuant to the Contract, ARG was instrumental in
securing for Cyberlux the Subcontract between Cyberlux and HII for Cyberlux to supply K8
Unmanned Aircraft Systems, resulting in Cyberlux receiving $38,700,600 up front (the
“Initial Payment”) and $25,769,369.03 as final payment (the “Final Payment”) from HII. To
be clear, the K8 Drone was manufactured and sold pursuant to the Subcontract that is the
subject of HII’s Amended Complaint.SeeECF 41, ¶¶ 17-30.
The Amounts Owed ARG Under The Contract
24. Although Cyberlux received the Initial Payment from HII, it did not remit payment to ARG.
25. In accordance with the Contract, ARG is entitled to 20% of the $38,700,600 Initial Payment,
which is $7,740,120. ARG has not been paid its 20% of the Initial Payment for over 31
months (as of April 15, 2026). Prejudgment interest at 8% for 31 months on the $7,740,120
Initial Payment is $1,599,624.80 ($51,600.80/month). Therefore, through April 15, 2026,
ARG is owed $9,339,744.80 from the Initial Payment.
26. ARG also is entitled to 20% of the $25,769,369.03 Final Payment, which is $5,153,873.81,
plus prejudgment interest which cannot be calculated at this time.
27. In acknowledgment of ARG’s contributions and its obligations under the Contract, Cyberlux
has made $375,000 in partial payments to ARG and admitted that it owes ARG the amounts
claimed, but it has refused to pay the remaining amounts owed ARG.
28. After subtracting the $375,000 in partial payments made by Cyberlux, through April 15,
2026, in total, ARG is entitled to at least $14,118,618.61 from the Initial Payment and Final
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 6 of 12 PageID# 2010
claimallegation
The twelve-page complaint in intervention bears ECF 155 filing on 11 March 2026 in EDVA 3:25-cv-00483-JAG. Stephen J. Stine signs it with St
The twelve-page complaint in intervention bears ECF 155 filing on 11 March 2026 in EDVA 3:25-cv-00483-JAG. Stephen J. Stine signs it with Stephen L. Neal Jr. listed; the document date and CM/ECF service certificate say 6 March 2026. Those dates remain distinct; the filing does not itself establish intervention granted.
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
v.
CYBERLUX CORP.,et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
Case No. 3:25-cv-483
COMPLAINT IN INTERVENTION OF THE ARG GROUP, LLC
In accordance with Federal Rule of Civil Procedure 24 and its Motion to Intervene,
Intervenor The ARG Group, LLC (“ARG”), by and through its undersigned counsel of record,
respectfully submits this Complaint in Intervention, and states as follows:
PARTIES
1. Intervenor ARG is a Delaware limited liability company with its principal place of business
located in Tucson, Arizona.
2. Upon information and belief, the allegations regarding the parties as set forth in paragraphs 3
through 11 of Plaintiff HII Mission Technologies Corp.’s (“HII”) First Amended Complaint
for Interpleader (the “Amended Complaint”, ECF 41) accurately describe the parties named
in the Amended Complaint.
JURISDICTION AND VENUE
3. ARG accepts the allegations regarding jurisdiction and venue set forth in paragraphs 12
through 16 of HII’s Amended Complaint (ECF 41).
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 1 of 12 PageID# 2005
claimallegation
ARG describes 20 May 2025 letters to HII counsel Clark Belote and Charles Watts asserting a stakeholder claim, while quoting HII’s original
ARG describes 20 May 2025 letters to HII counsel Clark Belote and Charles Watts asserting a stakeholder claim, while quoting HII’s original complaint as referencing an ARG letter dated 28 April 2025. These are distinct cited dates, not silently interchangeable notices.
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33. On or about February 25, 2026, ARG and Cyberlux executed an “Amendment No. 1 to
Distributor Partner Agreement [the Contract]” (the “Amendment”), which permits ARG to
file its Motion to Intervene in this action. 1
ARG’s Proper Inclusion In The Original Complaint For Interpleader
34. On May 20, 2025, counsel for ARG sent a letter to Clark J. Belote, Esq., counsel for HII in
this action, which advised Mr. Belote of ARG’s “claims to funds held or to be held by HII on
behalf of or for the benefit of [Cyberlux]” pursuant to the Subcontract at issue in this action,
and further advised that “ARG 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
ARG, in whole or in part, under a valid and enforceable contract.” To support ARG’s
claims, ARG’s counsel attached,inter alia, the Contract and the complaint in the North
Carolina Action. That same day, ARG’s counsel also sent a letter to Charles Watts of
Cyberlux again demanding all amounts owed pursuant to the Contract and claimed in the
North Carolina Action.
35. On June 24, 2025, HII filed its original Complaint for Interpleader and properly named ARG
as an interpleader defendant/claimant because ARG has claimed a right or interest in the
interpleaded funds.SeeECF 1 at ¶¶ 1, 10. More specifically, the original Complaint alleges
that, “[b]y letter dated April 28, 2025 (attached as Exhibit 10), ARG Group asserted 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 ARG, in whole or in part, under a valid and
enforceable contract[.]’”.Id. at ¶ 67.
1 If the Court grants ARG’s Motion to Intervene, then ARG intends to move to stay and/or
voluntarily dismiss the North Carolina Action.
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 8 of 12 PageID# 2012
claimallegation
ARG argues HII’s inclusion of it in the original 24 June 2025 interpleader complaint recognised a legitimate claim, citing Thin Air Gear’s i
ARG argues HII’s inclusion of it in the original 24 June 2025 interpleader complaint recognised a legitimate claim, citing Thin Air Gear’s intervention ruling by analogy. That is ARG’s argument about party inclusion, not an admission that its debt or entitlement was allowed.
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33. On or about February 25, 2026, ARG and Cyberlux executed an “Amendment No. 1 to
Distributor Partner Agreement [the Contract]” (the “Amendment”), which permits ARG to
file its Motion to Intervene in this action. 1
ARG’s Proper Inclusion In The Original Complaint For Interpleader
34. On May 20, 2025, counsel for ARG sent a letter to Clark J. Belote, Esq., counsel for HII in
this action, which advised Mr. Belote of ARG’s “claims to funds held or to be held by HII on
behalf of or for the benefit of [Cyberlux]” pursuant to the Subcontract at issue in this action,
and further advised that “ARG 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
ARG, in whole or in part, under a valid and enforceable contract.” To support ARG’s
claims, ARG’s counsel attached,inter alia, the Contract and the complaint in the North
Carolina Action. That same day, ARG’s counsel also sent a letter to Charles Watts of
Cyberlux again demanding all amounts owed pursuant to the Contract and claimed in the
North Carolina Action.
35. On June 24, 2025, HII filed its original Complaint for Interpleader and properly named ARG
as an interpleader defendant/claimant because ARG has claimed a right or interest in the
interpleaded funds.SeeECF 1 at ¶¶ 1, 10. More specifically, the original Complaint alleges
that, “[b]y letter dated April 28, 2025 (attached as Exhibit 10), ARG Group asserted 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 ARG, in whole or in part, under a valid and
enforceable contract[.]’”.Id. at ¶ 67.
1 If the Court grants ARG’s Motion to Intervene, then ARG intends to move to stay and/or
voluntarily dismiss the North Carolina Action.
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 8 of 12 PageID# 2012
claimallegation
ARG reports HII’s 14 July 2025 confirmation request with a 23 July deadline, its same-day response claiming $15,272,447.30, and exclusion fr
ARG reports HII’s 14 July 2025 confirmation request with a 23 July deadline, its same-day response claiming $15,272,447.30, and exclusion from the 4 August amended complaint. It quotes Belote’s distinction between a colourable interest in Disputed Funds and a general Cyberlux claim. ARG alleges inconsistency; the full correspondence and basis for the different claim amount remain separate dependencies.
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36. Thus, HII agreed that ARG had a legitimate claim to the interpleaded funds and was a proper
party to this action, otherwise it would not have included ARG as an interpleader
defendant/claimant in the original Complaint.SeeECF 132 at 1, n. 2 (In granting Thin Air
Gear, LLC’s (“TAG”) Motion to Intervene, the Court stated, “[n]otably, HII’s original
complaint named TAG as an interpleader creditor-defendant”).
HII’s Improper Exclusion Of ARG From The Amended Complaint For Interpleader
37. On July 14, 2025, Mr. Belote sent a letter to ARG’s counsel advising,inter alia, that HII
would be filing an Amended Complaint for Interpleader and requesting confirmation whether
ARG asserts an interest in, or claim to, the Payment Receivable (defined in this letter as
additional amounts held by HII that may otherwise be or become payable to Cyberlux under
the Subcontract or otherwise interpleaded in this case). Mr. Belote sought this confirmation
and supporting information by July 23, 2025.
38. As requested, on July 14, 2025, ARG’s counsel sent a letter to Mr. Belote that confirmed
ARG’s interest and entitlement to its portion of the Payment Receivable and provided
information and documents that supported ARG’s claim for $15,272,447.30 of the Payment
Receivable.
39. On August 4, 2025, HII filed the Amended Complaint, which did not include ARG as an
interpleader defendant/claimant.SeeECF 41.
40. In an August 4, 2025 email to ARG’s counsel, Mr. Belote confirmed that ARG “is no longer
a party to the case because, in HII’s view, it has not articulated a colorable legal basis to
claim an interest in the Disputed Funds (as defined therein), as opposed to holding a general
claim against Cyberlux”, which is directly contradicted by what HII alleged in the original
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 9 of 12 PageID# 2013
claimallegation
Under an interpleader count citing 28 USC 1335 and 2361, ARG requests payment of at least $14,118,618.61 from the fund, additional interest,
Under an interpleader count citing 28 USC 1335 and 2361, ARG requests payment of at least $14,118,618.61 from the fund, additional interest, fees, costs and further relief. This is requested distribution, not an entered allocation or current payable balance.
Read the anchor · page 10
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Complaint. In a subsequent email to HII’s counsel, ARG’s counsel advised HII’s counsel of
the contradiction in HII’s position, but HII’s counsel did not reconsider his position.
41. As of the date of this filing, HII and Cyberlux have not paid ARG the amounts owed
pursuant to the Contract, the North Carolina Action, or otherwise
COUNT I - JUDGMENT IN INTERPLEADER PURSUANT TO 28 U.S.C. § 1335 AND 28
U.S.C. § 2361
42. ARG re-alleges and incorporates by reference each allegation set forth above as if fully set
forth herein.
43. Pursuant to 28 U.S.C. § 1335 and 28 U.S.C. § 2361, the Court has authority to enter
judgment distributing the interpleaded funds as appropriate or as justice so demands.
44. Based upon the Statement of Facts alleged above, ARG is entitled to a judgment directing
that the Court pay ARG at least $14,118,618.61 from the Initial Payment and Final Payment,
including additional prejudgment interest on the Initial Payment as this case progresses and
all prejudgment interest on the Final Payment, plus applicable post-judgment interest and all
attorneys’ fees and costs incurred in the prosecution of this Complaint in Intervention from
the interpleaded funds.
PRAYER FOR RELIEF/AD DAMNUM
WHEREFORE, ARG requests that Judgment be entered in ARG’s favor as follows:
1. A Judgment directing that ARG is awarded at least $14,118,618.61 from the Initial Payment
and Final Payment, including additional prejudgment interest on the Initial Payment as this
case progresses and all prejudgment interest on the Final Payment from the interpleaded
funds;
2. All reasonable attorneys’ fees and costs (including expert witness fees and other costs of
litigation) incurred in the prosecution of this Complaint in Intervention;
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 10 of 12 PageID# 2014
claimallegation
ARG now describes itself as a Delaware LLC with principal place of business in Tucson, Arizona, and a Service-Disabled Veteran-Owned busines
ARG now describes itself as a Delaware LLC with principal place of business in Tucson, Arizona, and a Service-Disabled Veteran-Owned business. It adopts HII’s amended-complaint jurisdiction and other party descriptions on the stated basis, without reproducing those underlying allegations.
Read the anchor · page 1
1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
v.
CYBERLUX CORP.,et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
Case No. 3:25-cv-483
COMPLAINT IN INTERVENTION OF THE ARG GROUP, LLC
In accordance with Federal Rule of Civil Procedure 24 and its Motion to Intervene,
Intervenor The ARG Group, LLC (“ARG”), by and through its undersigned counsel of record,
respectfully submits this Complaint in Intervention, and states as follows:
PARTIES
1. Intervenor ARG is a Delaware limited liability company with its principal place of business
located in Tucson, Arizona.
2. Upon information and belief, the allegations regarding the parties as set forth in paragraphs 3
through 11 of Plaintiff HII Mission Technologies Corp.’s (“HII”) First Amended Complaint
for Interpleader (the “Amended Complaint”, ECF 41) accurately describe the parties named
in the Amended Complaint.
JURISDICTION AND VENUE
3. ARG accepts the allegations regarding jurisdiction and venue set forth in paragraphs 12
through 16 of HII’s Amended Complaint (ECF 41).
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 1 of 12 PageID# 2005
claimallegation
ARG alleges the 28 February 2022 agreement provides a 20% discount off GSA pricing and an 80/20 allocation under paragraph 4A. It further at
ARG alleges the 28 February 2022 agreement provides a 20% discount off GSA pricing and an 80/20 allocation under paragraph 4A. It further attributes to Schmidt written and Signal acknowledgements of 20% regardless of prime and 30% if Cyberlux sells directly without a prime. The actual agreement and messages are not embedded.
Read the anchor · page 3
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7. In February 2022, ARG initiated discussions with Cyberlux about ways it could support the
advancement and commercialization of Cyberlux’s Products, including the sale of drones.
8. On February 28, 2022, ARG and Cyberlux entered into a valid and binding “Cyberlux
Corporation and The ARG Group, LLC Distributor Partner Agreement” (the “Contract”).
9. Pursuant to the terms of the Contract, ARG agreed to secure customer orders and facilitate
the sale of Cyberlux’s Products and Cyberlux agreed to provide ARG with a 20% discount
off the GSA pricing for the Products.
10. In accordance with paragraph 4A of the Contract, ARG and Cyberlux also agreed that the
proceeds from sales of the Products would be allocated with 80% payable to Cyberlux and
20% payable to ARG.
11. ARG played an integral role in the growth and success of Cyberlux’s enterprise and
functioned, in effect, as a business partner.
12. As a result of ARG’s substantial assistance, and as confirmed by Cyberlux and ARG’s course
of performance and written communications, Cyberlux agreed to share profits with ARG on
sales of the Products regardless of whether ARG or Cyberlux originated the transaction.
Indeed, on multiple occasions, Cyberlux’s CEO Mark Schmidt expressly acknowledged, via
Signal messages and other forms of communication, that ARG was entitled to 20% of the
proceeds from sales of the Products (including drones) regardless of who the prime was on
the contract. Mr. Schmidt also confirmed in writing that if Cyberlux sold the Products
directly without a prime, ARG and Cyberlux would split the 20%, so ARG would receive
30% of the proceeds. This agreement recognized ARG’s foundational role in enabling
Cyberlux’s access to those business opportunities.
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 3 of 12 PageID# 2007
claimallegation
ARG claims introductions, test sites, technical specifications, cost data and firing-mechanism assistance, including a team with Army member
ARG claims introductions, test sites, technical specifications, cost data and firing-mechanism assistance, including a team with Army members. It says SOFIC Tampa contacts led to Fairwinds and Ferd Irizarry, and that ARG brought Cameron Holt in to advance FMS/FMF. These are ARG’s causal and performance allegations.
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ARG’s Performance Under The Contract
13. Following the commencement of the partnership and execution of the Contract, ARG quickly
became a critical driver of Cyberlux’s growth, actively contributing to business development,
expanding market reach, and accelerating the deployment of key product lines.
14. ARG’s efforts were critical to Cyberlux’s success by introducing Cyberlux to key business
contacts and purchasers of the Products and to individuals who could further support
Cyberlux’s business interests, providing comprehensive operational support, establishing test
sites, facilitating the integration of complex firing mechanisms, generating valuable business
leads, and advising on technical specifications and cost data, each of which was essential to
the effective functioning and growth of Cyberlux’s operations.
15. One of the primary Products Cyberlux and ARG planned to market and sell was the K8
Drone, which was manufactured and sold pursuant to the Subcontract (the “Subcontract”)
between Cyberlux and HII that is the subject of HII’s Amended Complaint.SeeECF 41, ¶¶
17-30.
16. To enhance the K8 Drone’s appeal and functionality, ARG assembled a specialized team,
including members of the U.S. Army, to help redesign its firing mechanism, with the goal of
boosting both sales and marketability for Cyberlux.
17. To launch the K8 Drone into the marketplace, ARG facilitated Cyberlux’s participation in
key trade shows, creating valuable opportunities to generate exposure and drive sales. At one
particular trade show that ARG Group advised Cyberlux to attend (SOFIC in Tampa), ARG
brought its key contacts, including representatives from USASOC, Global Ordnance, the
Ukrainian Army, PRG, as well as Air Force and Navy EOD units. This strategic introduction
enabled Cyberlux to connect with critical military and defense stakeholders and ultimately
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 4 of 12 PageID# 2008
claimallegation
ARG identifies an eight-page Holt roadmap dated 7 August 2022, titled Accelerating FlightEye K8 FMS to Ukraine. It says Marty Moore joined C
ARG identifies an eight-page Holt roadmap dated 7 August 2022, titled Accelerating FlightEye K8 FMS to Ukraine. It says Marty Moore joined Cyberlux’s advisory board by November 2022 through Jeremy Shrock, and refers to hundreds of Signal pages including Larry Isely. None of those records is physically attached to this twelve-page pleading.
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led to a meeting with intervenor Fairwinds Technologies, LLC (“Fairwinds”). Through the
connection with Fairwinds, Cyberlux was introduced to Ferd Irizarry, who would join
Cyberlux’s Board of Advisors. The creation of the Board of Advisors was directly initiated
by ARG’s recommendation.
18. ARG also brought in Major General Cameron Holt to assist with developing a pathway to
secure a Foreign Military Sales (“FMS”) or Foreign Military Financing (“FMF”) deal.
19. On August 7, 2022, General Holt provided ARG with an eight-page roadmap titled
“Accelerating FlightEye K8 FMS to Ukraine”, which outlined the necessary steps,
requirements, and government offices involved in advancing the sale of the K8 drones.
20. By November 2022, Cyberlux added retired Army Sergeant Major Marty Moore to its Board
of Advisors. Sergeant Major Moore was a contact of Jeremy Shrock, whom ARG had
brought in specifically to assist with lead development and the design of the K8 Drone’s
firing mechanism. At that point, Cyberlux’s Board of Advisors included Major General Holt,
Sergeant Major Moore, and Brigadier General Irizarry, all of whom were introduced to
Cyberlux directly or indirectly through ARG’s efforts and network.
21. ARG possesses hundreds of pages of Signal app communications between itself and
Cyberlux, as well as separate group conversations including Larry Isely, which demonstrate
ARG’s involvement in guiding Cyberlux through key technical and operational matters.
These communications show that ARG played a central role in navigating the integration of
the K8 drone firing mechanism, developing specification sheets, and compiling cost data
necessary to advance the K8 drone project.
22. As a result of ARG’s substantial assistance, including establishing key business contacts and
facilitating operations, Cyberlux agreed to share profits with ARG on sales regardless of
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 5 of 12 PageID# 2009
claimallegation
ARG alleges its efforts secured the HII subcontract and characterises $38,700,600 as initial payment and $25,769,369.03 as final payment rec
ARG alleges its efforts secured the HII subcontract and characterises $38,700,600 as initial payment and $25,769,369.03 as final payment received by Cyberlux from HII. That alleged recipient and payment characterisation require the bank and interpleader record; the pleading itself is not a receipt.
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which party originated the transaction. This agreement recognized ARG’s foundational role
in enabling Cyberlux’s access to those business opportunities.
23. As a direct result of ARG’s efforts pursuant to the Contract, ARG was instrumental in
securing for Cyberlux the Subcontract between Cyberlux and HII for Cyberlux to supply K8
Unmanned Aircraft Systems, resulting in Cyberlux receiving $38,700,600 up front (the
“Initial Payment”) and $25,769,369.03 as final payment (the “Final Payment”) from HII. To
be clear, the K8 Drone was manufactured and sold pursuant to the Subcontract that is the
subject of HII’s Amended Complaint.SeeECF 41, ¶¶ 17-30.
The Amounts Owed ARG Under The Contract
24. Although Cyberlux received the Initial Payment from HII, it did not remit payment to ARG.
25. In accordance with the Contract, ARG is entitled to 20% of the $38,700,600 Initial Payment,
which is $7,740,120. ARG has not been paid its 20% of the Initial Payment for over 31
months (as of April 15, 2026). Prejudgment interest at 8% for 31 months on the $7,740,120
Initial Payment is $1,599,624.80 ($51,600.80/month). Therefore, through April 15, 2026,
ARG is owed $9,339,744.80 from the Initial Payment.
26. ARG also is entitled to 20% of the $25,769,369.03 Final Payment, which is $5,153,873.81,
plus prejudgment interest which cannot be calculated at this time.
27. In acknowledgment of ARG’s contributions and its obligations under the Contract, Cyberlux
has made $375,000 in partial payments to ARG and admitted that it owes ARG the amounts
claimed, but it has refused to pay the remaining amounts owed ARG.
28. After subtracting the $375,000 in partial payments made by Cyberlux, through April 15,
2026, in total, ARG is entitled to at least $14,118,618.61 from the Initial Payment and Final
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 6 of 12 PageID# 2010
claimallegation
The demand calculates 20% of the initial amount as $7,740,120, plus $1,599,624.80 interest at 8% for 31 months ($51,600.80 monthly), reachin
The demand calculates 20% of the initial amount as $7,740,120, plus $1,599,624.80 interest at 8% for 31 months ($51,600.80 monthly), reaching $9,339,744.80. It adds 20% of the final amount, $5,153,873.81, then subtracts $375,000 partial payments, giving $14,118,618.61. The stated calculation date is 15 April 2026, after both the 6 March document date and 11 March filing stamp; additional initial and all final-payment interest are reserved.
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6
which party originated the transaction. This agreement recognized ARG’s foundational role
in enabling Cyberlux’s access to those business opportunities.
23. As a direct result of ARG’s efforts pursuant to the Contract, ARG was instrumental in
securing for Cyberlux the Subcontract between Cyberlux and HII for Cyberlux to supply K8
Unmanned Aircraft Systems, resulting in Cyberlux receiving $38,700,600 up front (the
“Initial Payment”) and $25,769,369.03 as final payment (the “Final Payment”) from HII. To
be clear, the K8 Drone was manufactured and sold pursuant to the Subcontract that is the
subject of HII’s Amended Complaint.SeeECF 41, ¶¶ 17-30.
The Amounts Owed ARG Under The Contract
24. Although Cyberlux received the Initial Payment from HII, it did not remit payment to ARG.
25. In accordance with the Contract, ARG is entitled to 20% of the $38,700,600 Initial Payment,
which is $7,740,120. ARG has not been paid its 20% of the Initial Payment for over 31
months (as of April 15, 2026). Prejudgment interest at 8% for 31 months on the $7,740,120
Initial Payment is $1,599,624.80 ($51,600.80/month). Therefore, through April 15, 2026,
ARG is owed $9,339,744.80 from the Initial Payment.
26. ARG also is entitled to 20% of the $25,769,369.03 Final Payment, which is $5,153,873.81,
plus prejudgment interest which cannot be calculated at this time.
27. In acknowledgment of ARG’s contributions and its obligations under the Contract, Cyberlux
has made $375,000 in partial payments to ARG and admitted that it owes ARG the amounts
claimed, but it has refused to pay the remaining amounts owed ARG.
28. After subtracting the $375,000 in partial payments made by Cyberlux, through April 15,
2026, in total, ARG is entitled to at least $14,118,618.61 from the Initial Payment and Final
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 6 of 12 PageID# 2010
claimallegation
ARG alleges Cyberlux acknowledged the debt, made $375,000 partial payments, and otherwise failed to pay despite ARG’s full performance and n
ARG alleges Cyberlux acknowledged the debt, made $375,000 partial payments, and otherwise failed to pay despite ARG’s full performance and no offsets. Those are ARG’s representations; the alleged acknowledgements and payment ledger are not reproduced.
Read the anchor · page 6
6
which party originated the transaction. This agreement recognized ARG’s foundational role
in enabling Cyberlux’s access to those business opportunities.
23. As a direct result of ARG’s efforts pursuant to the Contract, ARG was instrumental in
securing for Cyberlux the Subcontract between Cyberlux and HII for Cyberlux to supply K8
Unmanned Aircraft Systems, resulting in Cyberlux receiving $38,700,600 up front (the
“Initial Payment”) and $25,769,369.03 as final payment (the “Final Payment”) from HII. To
be clear, the K8 Drone was manufactured and sold pursuant to the Subcontract that is the
subject of HII’s Amended Complaint.SeeECF 41, ¶¶ 17-30.
The Amounts Owed ARG Under The Contract
24. Although Cyberlux received the Initial Payment from HII, it did not remit payment to ARG.
25. In accordance with the Contract, ARG is entitled to 20% of the $38,700,600 Initial Payment,
which is $7,740,120. ARG has not been paid its 20% of the Initial Payment for over 31
months (as of April 15, 2026). Prejudgment interest at 8% for 31 months on the $7,740,120
Initial Payment is $1,599,624.80 ($51,600.80/month). Therefore, through April 15, 2026,
ARG is owed $9,339,744.80 from the Initial Payment.
26. ARG also is entitled to 20% of the $25,769,369.03 Final Payment, which is $5,153,873.81,
plus prejudgment interest which cannot be calculated at this time.
27. In acknowledgment of ARG’s contributions and its obligations under the Contract, Cyberlux
has made $375,000 in partial payments to ARG and admitted that it owes ARG the amounts
claimed, but it has refused to pay the remaining amounts owed ARG.
28. After subtracting the $375,000 in partial payments made by Cyberlux, through April 15,
2026, in total, ARG is entitled to at least $14,118,618.61 from the Initial Payment and Final
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 6 of 12 PageID# 2010
claimallegation
ARG describes its 24 April 2025 Durham action and Cyberlux’s answer, and now characterises the requested amount there as at least $14,118,61
ARG describes its 24 April 2025 Durham action and Cyberlux’s answer, and now characterises the requested amount there as at least $14,118,618.61 plus specified remedies. It alleges a 25 February 2026 Amendment No.1 permits intervention. It conditionally intends to seek a stay or voluntarily dismiss the state case if intervention is granted; neither amendment nor resulting disposition is attached.
Read the anchor · page 7
7
Payment, including additional prejudgment interest on the Initial Payment as this case
progresses and all prejudgment interest on the Final Payment.
29. ARG fully complied with its obligations under the Contract and there are no set-offs or
counterclaims against the amount owed to ARG.
30. ARG has repeatedly demanded that Cyberlux pay all amounts owed ARG, but Cyberlux has
failed and/or refused to do so.
The North Carolina Action
31. Because Cyberlux was in material breach of the Contract and engaged in other wrongful
conduct, on April 24, 2025, ARG brought a Complaint in the Superior Court for the County
of Durham, North Carolina, Case No. 25CV004246-310 (the “North Carolina Action”),
alleging claims for breach of contract, unjust enrichment/quantum meruit (in the alternative
to the breach of contract claim), breach of contract implied in fact, conversion, and unfair and
deceptive trade practices under N.C. Gen. Stat. § 75-1.1,et. seq. For relief, ARG seeks at
least $14,118,618.61 from the Initial Payment and Final Payment, including additional
prejudgment interest on the Initial Payment as the case progresses and all prejudgment
interest on the Final Payment, treble damages pursuant to N.C. Gen. Stat. § 75-16, all
attorneys’ fees and costs pursuant to the Contract, N.C. Gen. Stat. § 75-16.1, any other
applicable statute, and/or other equitable power of the Court, post-judgment interest, and
such other and further relief as the Court may deem appropriate.
32. In the North Carolina Action, Cyberlux filed an Answer and the case is at issue.
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 7 of 12 PageID# 2011
entityobservation
The ARG Group, LLC
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1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
v.
CYBERLUX CORP.,et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
Case No. 3:25-cv-483
COMPLAINT IN INTERVENTION OF THE ARG GROUP, LLC
In accordance with Federal Rule of Civil Procedure 24 and its Motion to Intervene,
Intervenor The ARG Group, LLC (“ARG”), by and through its undersigned counsel of record,
respectfully submits this Complaint in Intervention, and states as follows:
PARTIES
1. Intervenor ARG is a Delaware limited liability company with its principal place of business
located in Tucson, Arizona.
2. Upon information and belief, the allegations regarding the parties as set forth in paragraphs 3
through 11 of Plaintiff HII Mission Technologies Corp.’s (“HII”) First Amended Complaint
for Interpleader (the “Amended Complaint”, ECF 41) accurately describe the parties named
in the Amended Complaint.
JURISDICTION AND VENUE
3. ARG accepts the allegations regarding jurisdiction and venue set forth in paragraphs 12
through 16 of HII’s Amended Complaint (ECF 41).
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 1 of 12 PageID# 2005
entityobservation
Clark J. Belote
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8
33. On or about February 25, 2026, ARG and Cyberlux executed an “Amendment No. 1 to
Distributor Partner Agreement [the Contract]” (the “Amendment”), which permits ARG to
file its Motion to Intervene in this action. 1
ARG’s Proper Inclusion In The Original Complaint For Interpleader
34. On May 20, 2025, counsel for ARG sent a letter to Clark J. Belote, Esq., counsel for HII in
this action, which advised Mr. Belote of ARG’s “claims to funds held or to be held by HII on
behalf of or for the benefit of [Cyberlux]” pursuant to the Subcontract at issue in this action,
and further advised that “ARG 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
ARG, in whole or in part, under a valid and enforceable contract.” To support ARG’s
claims, ARG’s counsel attached,inter alia, the Contract and the complaint in the North
Carolina Action. That same day, ARG’s counsel also sent a letter to Charles Watts of
Cyberlux again demanding all amounts owed pursuant to the Contract and claimed in the
North Carolina Action.
35. On June 24, 2025, HII filed its original Complaint for Interpleader and properly named ARG
as an interpleader defendant/claimant because ARG has claimed a right or interest in the
interpleaded funds.SeeECF 1 at ¶¶ 1, 10. More specifically, the original Complaint alleges
that, “[b]y letter dated April 28, 2025 (attached as Exhibit 10), ARG Group asserted 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 ARG, in whole or in part, under a valid and
enforceable contract[.]’”.Id. at ¶ 67.
1 If the Court grants ARG’s Motion to Intervene, then ARG intends to move to stay and/or
voluntarily dismiss the North Carolina Action.
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 8 of 12 PageID# 2012
entityobservation
Charles Watts
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8
33. On or about February 25, 2026, ARG and Cyberlux executed an “Amendment No. 1 to
Distributor Partner Agreement [the Contract]” (the “Amendment”), which permits ARG to
file its Motion to Intervene in this action. 1
ARG’s Proper Inclusion In The Original Complaint For Interpleader
34. On May 20, 2025, counsel for ARG sent a letter to Clark J. Belote, Esq., counsel for HII in
this action, which advised Mr. Belote of ARG’s “claims to funds held or to be held by HII on
behalf of or for the benefit of [Cyberlux]” pursuant to the Subcontract at issue in this action,
and further advised that “ARG 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
ARG, in whole or in part, under a valid and enforceable contract.” To support ARG’s
claims, ARG’s counsel attached,inter alia, the Contract and the complaint in the North
Carolina Action. That same day, ARG’s counsel also sent a letter to Charles Watts of
Cyberlux again demanding all amounts owed pursuant to the Contract and claimed in the
North Carolina Action.
35. On June 24, 2025, HII filed its original Complaint for Interpleader and properly named ARG
as an interpleader defendant/claimant because ARG has claimed a right or interest in the
interpleaded funds.SeeECF 1 at ¶¶ 1, 10. More specifically, the original Complaint alleges
that, “[b]y letter dated April 28, 2025 (attached as Exhibit 10), ARG Group asserted 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 ARG, in whole or in part, under a valid and
enforceable contract[.]’”.Id. at ¶ 67.
1 If the Court grants ARG’s Motion to Intervene, then ARG intends to move to stay and/or
voluntarily dismiss the North Carolina Action.
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 8 of 12 PageID# 2012
entityobservation
Stephen J. Stine
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11
3. Post-judgment interest as permitted by law ; and
4. Such other and further relief as the Court deems just and proper.
Dated: March 6, 2026
Respectfully submitted,
/s/ Stephen J. Stine, Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
THE STINE LAW FIRM, PLLC
3900 Jermantown Rd., Suite 300
Fairfax, VA 22030-4900
Office Phone: 703.934-4647, Ext. 326
Cell Phone: (703) 501-5366
Fax: (703) 991-6559
Email: stine@stinelaw.com
sneal@stinelaw.com
Counsel for The ARG Group, LLC
CERTIFICATE OF SERVICE
I hereby certify that on this 6th day of March, 2026, a true and correct copy of the foregoing
was served via CM/ECF, upon all counsel of record.
Respectfully submitted,
/s/ Stephen J. Stine, Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
THE STINE LAW FIRM, PLLC
3900 Jermantown Rd., Suite 300
Fairfax, VA 22030-4900
Office Phone: 703.934-4647, Ext. 326
Cell Phone: (703) 501-5366
Fax: (703) 991-6559
Email: stine@stinelaw.com
sneal@stinelaw.com
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 11 of 12 PageID# 2015
entityobservation
Stephen L. Neal
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11
3. Post-judgment interest as permitted by law ; and
4. Such other and further relief as the Court deems just and proper.
Dated: March 6, 2026
Respectfully submitted,
/s/ Stephen J. Stine, Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
THE STINE LAW FIRM, PLLC
3900 Jermantown Rd., Suite 300
Fairfax, VA 22030-4900
Office Phone: 703.934-4647, Ext. 326
Cell Phone: (703) 501-5366
Fax: (703) 991-6559
Email: stine@stinelaw.com
sneal@stinelaw.com
Counsel for The ARG Group, LLC
CERTIFICATE OF SERVICE
I hereby certify that on this 6th day of March, 2026, a true and correct copy of the foregoing
was served via CM/ECF, upon all counsel of record.
Respectfully submitted,
/s/ Stephen J. Stine, Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
THE STINE LAW FIRM, PLLC
3900 Jermantown Rd., Suite 300
Fairfax, VA 22030-4900
Office Phone: 703.934-4647, Ext. 326
Cell Phone: (703) 501-5366
Fax: (703) 991-6559
Email: stine@stinelaw.com
sneal@stinelaw.com
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 11 of 12 PageID# 2015
entityobservation
Cyberlux
Read the anchor · page 3
3
7. In February 2022, ARG initiated discussions with Cyberlux about ways it could support the
advancement and commercialization of Cyberlux’s Products, including the sale of drones.
8. On February 28, 2022, ARG and Cyberlux entered into a valid and binding “Cyberlux
Corporation and The ARG Group, LLC Distributor Partner Agreement” (the “Contract”).
9. Pursuant to the terms of the Contract, ARG agreed to secure customer orders and facilitate
the sale of Cyberlux’s Products and Cyberlux agreed to provide ARG with a 20% discount
off the GSA pricing for the Products.
10. In accordance with paragraph 4A of the Contract, ARG and Cyberlux also agreed that the
proceeds from sales of the Products would be allocated with 80% payable to Cyberlux and
20% payable to ARG.
11. ARG played an integral role in the growth and success of Cyberlux’s enterprise and
functioned, in effect, as a business partner.
12. As a result of ARG’s substantial assistance, and as confirmed by Cyberlux and ARG’s course
of performance and written communications, Cyberlux agreed to share profits with ARG on
sales of the Products regardless of whether ARG or Cyberlux originated the transaction.
Indeed, on multiple occasions, Cyberlux’s CEO Mark Schmidt expressly acknowledged, via
Signal messages and other forms of communication, that ARG was entitled to 20% of the
proceeds from sales of the Products (including drones) regardless of who the prime was on
the contract. Mr. Schmidt also confirmed in writing that if Cyberlux sold the Products
directly without a prime, ARG and Cyberlux would split the 20%, so ARG would receive
30% of the proceeds. This agreement recognized ARG’s foundational role in enabling
Cyberlux’s access to those business opportunities.
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 3 of 12 PageID# 2007
entityobservation
HII MISSION TECHNOLOGIES
Read the anchor · page 1
1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
v.
CYBERLUX CORP.,et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
Case No. 3:25-cv-483
COMPLAINT IN INTERVENTION OF THE ARG GROUP, LLC
In accordance with Federal Rule of Civil Procedure 24 and its Motion to Intervene,
Intervenor The ARG Group, LLC (“ARG”), by and through its undersigned counsel of record,
respectfully submits this Complaint in Intervention, and states as follows:
PARTIES
1. Intervenor ARG is a Delaware limited liability company with its principal place of business
located in Tucson, Arizona.
2. Upon information and belief, the allegations regarding the parties as set forth in paragraphs 3
through 11 of Plaintiff HII Mission Technologies Corp.’s (“HII”) First Amended Complaint
for Interpleader (the “Amended Complaint”, ECF 41) accurately describe the parties named
in the Amended Complaint.
JURISDICTION AND VENUE
3. ARG accepts the allegations regarding jurisdiction and venue set forth in paragraphs 12
through 16 of HII’s Amended Complaint (ECF 41).
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 1 of 12 PageID# 2005
entityobservation
Mark Schmidt
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3
7. In February 2022, ARG initiated discussions with Cyberlux about ways it could support the
advancement and commercialization of Cyberlux’s Products, including the sale of drones.
8. On February 28, 2022, ARG and Cyberlux entered into a valid and binding “Cyberlux
Corporation and The ARG Group, LLC Distributor Partner Agreement” (the “Contract”).
9. Pursuant to the terms of the Contract, ARG agreed to secure customer orders and facilitate
the sale of Cyberlux’s Products and Cyberlux agreed to provide ARG with a 20% discount
off the GSA pricing for the Products.
10. In accordance with paragraph 4A of the Contract, ARG and Cyberlux also agreed that the
proceeds from sales of the Products would be allocated with 80% payable to Cyberlux and
20% payable to ARG.
11. ARG played an integral role in the growth and success of Cyberlux’s enterprise and
functioned, in effect, as a business partner.
12. As a result of ARG’s substantial assistance, and as confirmed by Cyberlux and ARG’s course
of performance and written communications, Cyberlux agreed to share profits with ARG on
sales of the Products regardless of whether ARG or Cyberlux originated the transaction.
Indeed, on multiple occasions, Cyberlux’s CEO Mark Schmidt expressly acknowledged, via
Signal messages and other forms of communication, that ARG was entitled to 20% of the
proceeds from sales of the Products (including drones) regardless of who the prime was on
the contract. Mr. Schmidt also confirmed in writing that if Cyberlux sold the Products
directly without a prime, ARG and Cyberlux would split the 20%, so ARG would receive
30% of the proceeds. This agreement recognized ARG’s foundational role in enabling
Cyberlux’s access to those business opportunities.
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 3 of 12 PageID# 2007
entityobservation
Ferd Irizarry
Read the anchor · page 5
5
led to a meeting with intervenor Fairwinds Technologies, LLC (“Fairwinds”). Through the
connection with Fairwinds, Cyberlux was introduced to Ferd Irizarry, who would join
Cyberlux’s Board of Advisors. The creation of the Board of Advisors was directly initiated
by ARG’s recommendation.
18. ARG also brought in Major General Cameron Holt to assist with developing a pathway to
secure a Foreign Military Sales (“FMS”) or Foreign Military Financing (“FMF”) deal.
19. On August 7, 2022, General Holt provided ARG with an eight-page roadmap titled
“Accelerating FlightEye K8 FMS to Ukraine”, which outlined the necessary steps,
requirements, and government offices involved in advancing the sale of the K8 drones.
20. By November 2022, Cyberlux added retired Army Sergeant Major Marty Moore to its Board
of Advisors. Sergeant Major Moore was a contact of Jeremy Shrock, whom ARG had
brought in specifically to assist with lead development and the design of the K8 Drone’s
firing mechanism. At that point, Cyberlux’s Board of Advisors included Major General Holt,
Sergeant Major Moore, and Brigadier General Irizarry, all of whom were introduced to
Cyberlux directly or indirectly through ARG’s efforts and network.
21. ARG possesses hundreds of pages of Signal app communications between itself and
Cyberlux, as well as separate group conversations including Larry Isely, which demonstrate
ARG’s involvement in guiding Cyberlux through key technical and operational matters.
These communications show that ARG played a central role in navigating the integration of
the K8 drone firing mechanism, developing specification sheets, and compiling cost data
necessary to advance the K8 drone project.
22. As a result of ARG’s substantial assistance, including establishing key business contacts and
facilitating operations, Cyberlux agreed to share profits with ARG on sales regardless of
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 5 of 12 PageID# 2009
entityobservation
Cameron Holt
Read the anchor · page 5
5
led to a meeting with intervenor Fairwinds Technologies, LLC (“Fairwinds”). Through the
connection with Fairwinds, Cyberlux was introduced to Ferd Irizarry, who would join
Cyberlux’s Board of Advisors. The creation of the Board of Advisors was directly initiated
by ARG’s recommendation.
18. ARG also brought in Major General Cameron Holt to assist with developing a pathway to
secure a Foreign Military Sales (“FMS”) or Foreign Military Financing (“FMF”) deal.
19. On August 7, 2022, General Holt provided ARG with an eight-page roadmap titled
“Accelerating FlightEye K8 FMS to Ukraine”, which outlined the necessary steps,
requirements, and government offices involved in advancing the sale of the K8 drones.
20. By November 2022, Cyberlux added retired Army Sergeant Major Marty Moore to its Board
of Advisors. Sergeant Major Moore was a contact of Jeremy Shrock, whom ARG had
brought in specifically to assist with lead development and the design of the K8 Drone’s
firing mechanism. At that point, Cyberlux’s Board of Advisors included Major General Holt,
Sergeant Major Moore, and Brigadier General Irizarry, all of whom were introduced to
Cyberlux directly or indirectly through ARG’s efforts and network.
21. ARG possesses hundreds of pages of Signal app communications between itself and
Cyberlux, as well as separate group conversations including Larry Isely, which demonstrate
ARG’s involvement in guiding Cyberlux through key technical and operational matters.
These communications show that ARG played a central role in navigating the integration of
the K8 drone firing mechanism, developing specification sheets, and compiling cost data
necessary to advance the K8 drone project.
22. As a result of ARG’s substantial assistance, including establishing key business contacts and
facilitating operations, Cyberlux agreed to share profits with ARG on sales regardless of
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 5 of 12 PageID# 2009
entityobservation
Marty Moore
Read the anchor · page 5
5
led to a meeting with intervenor Fairwinds Technologies, LLC (“Fairwinds”). Through the
connection with Fairwinds, Cyberlux was introduced to Ferd Irizarry, who would join
Cyberlux’s Board of Advisors. The creation of the Board of Advisors was directly initiated
by ARG’s recommendation.
18. ARG also brought in Major General Cameron Holt to assist with developing a pathway to
secure a Foreign Military Sales (“FMS”) or Foreign Military Financing (“FMF”) deal.
19. On August 7, 2022, General Holt provided ARG with an eight-page roadmap titled
“Accelerating FlightEye K8 FMS to Ukraine”, which outlined the necessary steps,
requirements, and government offices involved in advancing the sale of the K8 drones.
20. By November 2022, Cyberlux added retired Army Sergeant Major Marty Moore to its Board
of Advisors. Sergeant Major Moore was a contact of Jeremy Shrock, whom ARG had
brought in specifically to assist with lead development and the design of the K8 Drone’s
firing mechanism. At that point, Cyberlux’s Board of Advisors included Major General Holt,
Sergeant Major Moore, and Brigadier General Irizarry, all of whom were introduced to
Cyberlux directly or indirectly through ARG’s efforts and network.
21. ARG possesses hundreds of pages of Signal app communications between itself and
Cyberlux, as well as separate group conversations including Larry Isely, which demonstrate
ARG’s involvement in guiding Cyberlux through key technical and operational matters.
These communications show that ARG played a central role in navigating the integration of
the K8 drone firing mechanism, developing specification sheets, and compiling cost data
necessary to advance the K8 drone project.
22. As a result of ARG’s substantial assistance, including establishing key business contacts and
facilitating operations, Cyberlux agreed to share profits with ARG on sales regardless of
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 5 of 12 PageID# 2009
entityobservation
Jeremy Shrock
Read the anchor · page 5
5
led to a meeting with intervenor Fairwinds Technologies, LLC (“Fairwinds”). Through the
connection with Fairwinds, Cyberlux was introduced to Ferd Irizarry, who would join
Cyberlux’s Board of Advisors. The creation of the Board of Advisors was directly initiated
by ARG’s recommendation.
18. ARG also brought in Major General Cameron Holt to assist with developing a pathway to
secure a Foreign Military Sales (“FMS”) or Foreign Military Financing (“FMF”) deal.
19. On August 7, 2022, General Holt provided ARG with an eight-page roadmap titled
“Accelerating FlightEye K8 FMS to Ukraine”, which outlined the necessary steps,
requirements, and government offices involved in advancing the sale of the K8 drones.
20. By November 2022, Cyberlux added retired Army Sergeant Major Marty Moore to its Board
of Advisors. Sergeant Major Moore was a contact of Jeremy Shrock, whom ARG had
brought in specifically to assist with lead development and the design of the K8 Drone’s
firing mechanism. At that point, Cyberlux’s Board of Advisors included Major General Holt,
Sergeant Major Moore, and Brigadier General Irizarry, all of whom were introduced to
Cyberlux directly or indirectly through ARG’s efforts and network.
21. ARG possesses hundreds of pages of Signal app communications between itself and
Cyberlux, as well as separate group conversations including Larry Isely, which demonstrate
ARG’s involvement in guiding Cyberlux through key technical and operational matters.
These communications show that ARG played a central role in navigating the integration of
the K8 drone firing mechanism, developing specification sheets, and compiling cost data
necessary to advance the K8 drone project.
22. As a result of ARG’s substantial assistance, including establishing key business contacts and
facilitating operations, Cyberlux agreed to share profits with ARG on sales regardless of
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 5 of 12 PageID# 2009
entityobservation
Larry Isely
Read the anchor · page 5
5
led to a meeting with intervenor Fairwinds Technologies, LLC (“Fairwinds”). Through the
connection with Fairwinds, Cyberlux was introduced to Ferd Irizarry, who would join
Cyberlux’s Board of Advisors. The creation of the Board of Advisors was directly initiated
by ARG’s recommendation.
18. ARG also brought in Major General Cameron Holt to assist with developing a pathway to
secure a Foreign Military Sales (“FMS”) or Foreign Military Financing (“FMF”) deal.
19. On August 7, 2022, General Holt provided ARG with an eight-page roadmap titled
“Accelerating FlightEye K8 FMS to Ukraine”, which outlined the necessary steps,
requirements, and government offices involved in advancing the sale of the K8 drones.
20. By November 2022, Cyberlux added retired Army Sergeant Major Marty Moore to its Board
of Advisors. Sergeant Major Moore was a contact of Jeremy Shrock, whom ARG had
brought in specifically to assist with lead development and the design of the K8 Drone’s
firing mechanism. At that point, Cyberlux’s Board of Advisors included Major General Holt,
Sergeant Major Moore, and Brigadier General Irizarry, all of whom were introduced to
Cyberlux directly or indirectly through ARG’s efforts and network.
21. ARG possesses hundreds of pages of Signal app communications between itself and
Cyberlux, as well as separate group conversations including Larry Isely, which demonstrate
ARG’s involvement in guiding Cyberlux through key technical and operational matters.
These communications show that ARG played a central role in navigating the integration of
the K8 drone firing mechanism, developing specification sheets, and compiling cost data
necessary to advance the K8 drone project.
22. As a result of ARG’s substantial assistance, including establishing key business contacts and
facilitating operations, Cyberlux agreed to share profits with ARG on sales regardless of
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 5 of 12 PageID# 2009
eventattribution
ECF 155 bears 11 March 2026 filing.
Read the anchor · page 1
1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
v.
CYBERLUX CORP.,et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
Case No. 3:25-cv-483
COMPLAINT IN INTERVENTION OF THE ARG GROUP, LLC
In accordance with Federal Rule of Civil Procedure 24 and its Motion to Intervene,
Intervenor The ARG Group, LLC (“ARG”), by and through its undersigned counsel of record,
respectfully submits this Complaint in Intervention, and states as follows:
PARTIES
1. Intervenor ARG is a Delaware limited liability company with its principal place of business
located in Tucson, Arizona.
2. Upon information and belief, the allegations regarding the parties as set forth in paragraphs 3
through 11 of Plaintiff HII Mission Technologies Corp.’s (“HII”) First Amended Complaint
for Interpleader (the “Amended Complaint”, ECF 41) accurately describe the parties named
in the Amended Complaint.
JURISDICTION AND VENUE
3. ARG accepts the allegations regarding jurisdiction and venue set forth in paragraphs 12
through 16 of HII’s Amended Complaint (ECF 41).
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 1 of 12 PageID# 2005
eventattribution
Pleading and service certificate are dated 6 March 2026.
Read the anchor · page 11
11
3. Post-judgment interest as permitted by law ; and
4. Such other and further relief as the Court deems just and proper.
Dated: March 6, 2026
Respectfully submitted,
/s/ Stephen J. Stine, Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
THE STINE LAW FIRM, PLLC
3900 Jermantown Rd., Suite 300
Fairfax, VA 22030-4900
Office Phone: 703.934-4647, Ext. 326
Cell Phone: (703) 501-5366
Fax: (703) 991-6559
Email: stine@stinelaw.com
sneal@stinelaw.com
Counsel for The ARG Group, LLC
CERTIFICATE OF SERVICE
I hereby certify that on this 6th day of March, 2026, a true and correct copy of the foregoing
was served via CM/ECF, upon all counsel of record.
Respectfully submitted,
/s/ Stephen J. Stine, Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
THE STINE LAW FIRM, PLLC
3900 Jermantown Rd., Suite 300
Fairfax, VA 22030-4900
Office Phone: 703.934-4647, Ext. 326
Cell Phone: (703) 501-5366
Fax: (703) 991-6559
Email: stine@stinelaw.com
sneal@stinelaw.com
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 11 of 12 PageID# 2015
eventattribution
ARG projects the stated initial-payment interest calculation through 15 April 2026.
Read the anchor · page 6
6
which party originated the transaction. This agreement recognized ARG’s foundational role
in enabling Cyberlux’s access to those business opportunities.
23. As a direct result of ARG’s efforts pursuant to the Contract, ARG was instrumental in
securing for Cyberlux the Subcontract between Cyberlux and HII for Cyberlux to supply K8
Unmanned Aircraft Systems, resulting in Cyberlux receiving $38,700,600 up front (the
“Initial Payment”) and $25,769,369.03 as final payment (the “Final Payment”) from HII. To
be clear, the K8 Drone was manufactured and sold pursuant to the Subcontract that is the
subject of HII’s Amended Complaint.SeeECF 41, ¶¶ 17-30.
The Amounts Owed ARG Under The Contract
24. Although Cyberlux received the Initial Payment from HII, it did not remit payment to ARG.
25. In accordance with the Contract, ARG is entitled to 20% of the $38,700,600 Initial Payment,
which is $7,740,120. ARG has not been paid its 20% of the Initial Payment for over 31
months (as of April 15, 2026). Prejudgment interest at 8% for 31 months on the $7,740,120
Initial Payment is $1,599,624.80 ($51,600.80/month). Therefore, through April 15, 2026,
ARG is owed $9,339,744.80 from the Initial Payment.
26. ARG also is entitled to 20% of the $25,769,369.03 Final Payment, which is $5,153,873.81,
plus prejudgment interest which cannot be calculated at this time.
27. In acknowledgment of ARG’s contributions and its obligations under the Contract, Cyberlux
has made $375,000 in partial payments to ARG and admitted that it owes ARG the amounts
claimed, but it has refused to pay the remaining amounts owed ARG.
28. After subtracting the $375,000 in partial payments made by Cyberlux, through April 15,
2026, in total, ARG is entitled to at least $14,118,618.61 from the Initial Payment and Final
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 6 of 12 PageID# 2010
inferenceinference
The pleaded arithmetic reconciles to $14,118,618.61 after the $375,000 credit, but its future calculation date and additional reserved inter
The pleaded arithmetic reconciles to $14,118,618.61 after the $375,000 credit, but its future calculation date and additional reserved interest prevent treating it as a filing-day or current payoff.
inferenceinference
Naming ARG in an interpleader and recognising an asserted claim do not themselves adjudicate its ownership or priority in the fund; the comp
Naming ARG in an interpleader and recognising an asserted claim do not themselves adjudicate its ownership or priority in the fund; the complaint presents that inference as ARG’s argument.
inferenceinference
The earlier $15,272,447.30 asserted amount and the later $14,118,618.61 demand differ by $1,153,828.69. No reconciliation of that change is
The earlier $15,272,447.30 asserted amount and the later $14,118,618.61 demand differ by $1,153,828.69. No reconciliation of that change is supplied here.
otherattribution
Complete supplied 12-page source reviewed at SHA-256 0e6b94c719461c13191b9ba46401085446ba72845f1a7215a4331ad30e08b076. Source assertions, or
Complete supplied 12-page source reviewed at SHA-256 0e6b94c719461c13191b9ba46401085446ba72845f1a7215a4331ad30e08b076. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. No unexamined later court outcome is inferred.
Read the anchor · page 1
1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
v.
CYBERLUX CORP.,et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
Case No. 3:25-cv-483
COMPLAINT IN INTERVENTION OF THE ARG GROUP, LLC
In accordance with Federal Rule of Civil Procedure 24 and its Motion to Intervene,
Intervenor The ARG Group, LLC (“ARG”), by and through its undersigned counsel of record,
respectfully submits this Complaint in Intervention, and states as follows:
PARTIES
1. Intervenor ARG is a Delaware limited liability company with its principal place of business
located in Tucson, Arizona.
2. Upon information and belief, the allegations regarding the parties as set forth in paragraphs 3
through 11 of Plaintiff HII Mission Technologies Corp.’s (“HII”) First Amended Complaint
for Interpleader (the “Amended Complaint”, ECF 41) accurately describe the parties named
in the Amended Complaint.
JURISDICTION AND VENUE
3. ARG accepts the allegations regarding jurisdiction and venue set forth in paragraphs 12
through 16 of HII’s Amended Complaint (ECF 41).
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 1 of 12 PageID# 2005
questionquestion
What instruments and account history establish the applicable percentage base, the $375,000 credit, interest start date and change between t
What instruments and account history establish the applicable percentage base, the $375,000 credit, interest start date and change between the two demands?
questionquestion
Why does the 11 March filing calculate through 15 April, and what do the docket and original transmission records establish about the 6 Marc
Why does the 11 March filing calculate through 15 April, and what do the docket and original transmission records establish about the 6 March certificate?
questionquestion
Which agreement amendment, intervention order and state-court disposition establish the permitted forum and actual procedural outcome?
questionquestion
What native receipts and registry records distinguish funds paid to Cyberlux from funds held by HII or deposited in interpleader?
questionquestion
Which underlying messages, roadmap and operational records substantiate the claimed introductions, technical contribution and Schmidt acknow
Which underlying messages, roadmap and operational records substantiate the claimed introductions, technical contribution and Schmidt acknowledgements?
questionquestion
Is the $14,118,618.61 figure an awarded amount or filing-date balance?
eventattribution
ARG alleges Major General Holt supplied an FMS roadmap
ARG's filed intervention complaint alleges that on 7 August 2022 Major General Cameron Holt provided an eight-page roadmap titled 'Accelerating FlightEye K8 FMS to Ukraine'. The underlying roadmap is not present in the reviewed ARG folder. A later 28 November email independently documents Schmidt saying Holt and a USASAC official referred him to an Army contact and that Schmidt would coordinate a call around Holt's calendar.
Read the anchor · page 1
ERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
v.
CYBERLUX CORP.,et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
Case No. 3:25-cv-483
COMPLAINT IN INTERVENTION OF THE ARG GROUP, LLC
In accordance with Federal Rule of Civil Procedure 24 and its Motion to Intervene,
Intervenor The ARG Group, LLC (“ARG”), by and through its undersigned counsel of record,
respectfully submits this Complaint in Intervention, and states as follows:
PARTIES
1. Intervenor ARG is a Delaware limited liability company with its principal place of business
located in Tucson, Arizona.
2. Upo
eventattribution
HII amends interpleader complaint, removes ARG as party
HII filed amended interpleader complaint removing ARG, stating ARG had not articulated a colorable legal basis for claim to disputed funds.
Read the anchor · page 1
rmation and belief, the allegations regarding the parties as set forth in paragraphs 3
through 11 of Plaintiff HII Mission Technologies Corp.’s (“HII”) First Amended Complaint
for Interpleader (the “Amended Complaint”, ECF 41) accurately describe the parties named
in the Amended Complaint.
JURISDICTION AND VENUE
3. ARG accepts the allegations regarding jurisdiction and venue set forth in paragraphs 12
through 16 of HII’s Amended Complaint (ECF 41).
Case 3:25-cv-00483-JAG Document 155 Filed 03/11/26 Page 1 of 12 PageID# 2005
eventattribution
Additional EDVA filings refine claimant positions
The docket continues to develop after deposit, with filings narrowing the priority fight.
Read the anchor · page 2
interest in the interpleaded funds
and seeks a judgment and payment in the amount of at least $14,118,618.61 from the Initial
Payment and Final Payment (defined below), including additional prejudgment interest on
the Initial Payment as this case progresses and all prejudgment interest on the Final Payment,
in satisfaction of that interest.
ARG’s Contract With Cyberlux
5. ARG is a Service-Disabled Veteran-Owned Small Business and is a leading provider of sales
and tactical distribution services of advanced technology equipment to the Department of
Defense, Federal Law Enforcement Agencies, an
question
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
ARG filed complaint in Durham County Superior Court on April 24, 2025 alleging breach of contract, unjust enrichment, conversion, and unfair trade practices against Cyberlux.supports{"timeline_thread":"legal","timeline_thread_label":"Legal & recovery"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
The docket continues to develop after deposit, with filings narrowing the priority fight.supports{"timeline_thread":"programme","timeline_thread_label":"Procurement & programme"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
HII filed amended interpleader complaint removing ARG, stating ARG had not articulated a colorable legal basis for claim to disputed funds.supports{"timeline_thread":"legal","timeline_thread_label":"Legal & recovery"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
ARG's filed intervention complaint alleges that on 7 August 2022 Major General Cameron Holt provided an eight-page roadmap titled 'Accelerating FlightEye K8 FMS to Ukraine'. The underlying roadmap is not present in the reviewed ARG folder. A later 28 November email independently documents Schmidt saying Holt and a USASAC official referred him to an Army contact and that Schmidt would coordinate a call around Holt's calendar.supports{"timeline_thread":"communications","timeline_thread_label":"Communications & influence"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
{"timeline_thread":"programme","timeline_thread_label":"Procurement & programme"}relates to{"chapter":28,"exposure_lens":"The acquisition-chain inquiry locates the official owner of each technical, financial and contractual decision before drawing any conclusion from institutional involvement.","responsibility":"Requirement, contract vehicle, delegated authority, contracting decisions and settlement review.","sequence":328,"unit_key":"CH28"}
The controlling book publication map connects this dated event to Part III, Chapter 28. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"communications","timeline_thread_label":"Communications & influence"}relates to{"chapter":28,"exposure_lens":"The acquisition-chain inquiry locates the official owner of each technical, financial and contractual decision before drawing any conclusion from institutional involvement.","responsibility":"Requirement, contract vehicle, delegated authority, contracting decisions and settlement review.","sequence":328,"unit_key":"CH28"}
The controlling book publication map connects this dated event to Part III, Chapter 28. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"legal","timeline_thread_label":"Legal & recovery"}relates to{"chapter":28,"exposure_lens":"The acquisition-chain inquiry locates the official owner of each technical, financial and contractual decision before drawing any conclusion from institutional involvement.","responsibility":"Requirement, contract vehicle, delegated authority, contracting decisions and settlement review.","sequence":328,"unit_key":"CH28"}
The controlling book publication map connects this dated event to Part III, Chapter 28. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"legal","timeline_thread_label":"Legal & recovery"}relates to{"chapter":28,"exposure_lens":"The acquisition-chain inquiry locates the official owner of each technical, financial and contractual decision before drawing any conclusion from institutional involvement.","responsibility":"Requirement, contract vehicle, delegated authority, contracting decisions and settlement review.","sequence":328,"unit_key":"CH28"}
The controlling book publication map connects this dated event to Part III, Chapter 28. The connection follows stored event/source and publication identifiers.
AWH challenges ARG’s February 28, 2022 distributor agreement because it predates the alleged K8 development, Catalyst acquisition and Government contract, and because a product schedule allegedly lists no aircraft. It raises contingent-fee/disclosure/licensing/ITAR/anti-kickback objections and asserts unsecured status. These are disputed characterisations, not proof that no compensated services occurred or that a fee was unlawful.referencesARG alleges the 28 February 2022 agreement provides a 20% discount off GSA pricing and an 80/20 allocation under paragraph 4A. It further attributes to Schmidt written and Signal acknowledgements of 20% regardless of prime and 30% if Cyberlux sells directly without a prime. The actual agreement and messages are not embedded.
AWH challenges scope and timing while ARG asserts a broad compensation arrangement. Neither account substitutes for the agreement and exact messages.
Schmidt separates his management of the Matt/Fairwinds channel from Anthony’s PRG/Global work and discusses protecting distribution points and securing needed training expertise. Those assignments and dependencies support a developing channel-management structure. They do not establish that each channel was an independent customer or that quoted contacts had purchasing authority.referencesARG claims introductions, test sites, technical specifications, cost data and firing-mechanism assistance, including a team with Army members. It says SOFIC Tampa contacts led to Fairwinds and Ferd Irizarry, and that ARG brought Cameron Holt in to advance FMS/FMF. These are ARG’s causal and performance allegations.
Channel allocation and outreach are contemporary participant-origin evidence relevant to later performance allegations; shared ARG origin is retained and ultimate causal success remains unproved.
Schmidt identifies Matthew Jones of Fairwinds as a contact, attributes the introduction context to a possible sales channel, and says: We intend to have you involved of all the Model-Kx sales so we can manage any conflict. His description of Jones as well connected and of possible monthly volume is qualified prospect information. The message directly evidences the stated intention about Anthony’s involvement; it does not supply all commission terms or prove Fairwinds orders.referencesARG alleges the 28 February 2022 agreement provides a 20% discount off GSA pricing and an 80/20 allocation under paragraph 4A. It further attributes to Schmidt written and Signal acknowledgements of 20% regardless of prime and 30% if Cyberlux sells directly without a prime. The actual agreement and messages are not embedded.
The all-sales involvement statement supplies a contemporary message relevant to the pleading, but it does not state the entire alleged 20/30% agreement or prove its final terms.
ARG alleges its efforts secured the HII subcontract and characterises $38,700,600 as initial payment and $25,769,369.03 as final payment received by Cyberlux from HII. That alleged recipient and payment characterisation require the bank and interpleader record; the pleading itself is not a receipt.referencesThe visible 8 September entry is ACH DEPOSIT, HII TECHNICAL SO followed by redaction, for $38,700,600.00. It is evidence of the bank-recorded account credit, not by itself identification of contract terms, units accepted, earned revenue, restricted use or judgment-payoff entitlement. The visible originator fragment is not expanded beyond what is shown.
Compare the exact initial payment allegation against the separately reviewed bank record. The bank entry supports a receipt amount/date, not ARG’s contractual share.
AWH challenges ARG’s February 28, 2022 distributor agreement because it predates the alleged K8 development, Catalyst acquisition and Government contract, and because a product schedule allegedly lists no aircraft. It raises contingent-fee/disclosure/licensing/ITAR/anti-kickback objections and asserts unsecured status. These are disputed characterisations, not proof that no compensated services occurred or that a fee was unlawful.referencesARG claims introductions, test sites, technical specifications, cost data and firing-mechanism assistance, including a team with Army members. It says SOFIC Tampa contacts led to Fairwinds and Ferd Irizarry, and that ARG brought Cameron Holt in to advance FMS/FMF. These are ARG’s causal and performance allegations.
ARG asserts introductions and technical contributions; AWH disputes entitlement. Their competing assertions remain attributed and unresolved.
The twelve-page complaint in intervention bears ECF 155 filing on 11 March 2026 in EDVA 3:25-cv-00483-JAG. Stephen J. Stine signs it with Stephen L. Neal Jr. listed; the document date and CM/ECF service certificate say 6 March 2026. Those dates remain distinct; the filing does not itself establish intervention granted.supportsIs the $14,118,618.61 figure an awarded amount or filing-date balance?
Specifically named source propositions support the bounded distinction or question.
Under an interpleader count citing 28 USC 1335 and 2361, ARG requests payment of at least $14,118,618.61 from the fund, additional interest, fees, costs and further relief. This is requested distribution, not an entered allocation or current payable balance.supportsWhich agreement amendment, intervention order and state-court disposition establish the permitted forum and actual procedural outcome?
Specifically named source propositions support the bounded distinction or question.
ARG alleges the 28 February 2022 agreement provides a 20% discount off GSA pricing and an 80/20 allocation under paragraph 4A. It further attributes to Schmidt written and Signal acknowledgements of 20% regardless of prime and 30% if Cyberlux sells directly without a prime. The actual agreement and messages are not embedded.supportsWhat instruments and account history establish the applicable percentage base, the $375,000 credit, interest start date and change between the two demands?
Specifically named source propositions support the bounded distinction or question.
Under an interpleader count citing 28 USC 1335 and 2361, ARG requests payment of at least $14,118,618.61 from the fund, additional interest, fees, costs and further relief. This is requested distribution, not an entered allocation or current payable balance.supportsWhat native receipts and registry records distinguish funds paid to Cyberlux from funds held by HII or deposited in interpleader?
Specifically named source propositions support the bounded distinction or question.
ARG alleges its efforts secured the HII subcontract and characterises $38,700,600 as initial payment and $25,769,369.03 as final payment received by Cyberlux from HII. That alleged recipient and payment characterisation require the bank and interpleader record; the pleading itself is not a receipt.supportsWhat native receipts and registry records distinguish funds paid to Cyberlux from funds held by HII or deposited in interpleader?
Specifically named source propositions support the bounded distinction or question.
ARG alleges Cyberlux acknowledged the debt, made $375,000 partial payments, and otherwise failed to pay despite ARG’s full performance and no offsets. Those are ARG’s representations; the alleged acknowledgements and payment ledger are not reproduced.supportsWhat instruments and account history establish the applicable percentage base, the $375,000 credit, interest start date and change between the two demands?
Specifically named source propositions support the bounded distinction or question.
ARG reports HII’s 14 July 2025 confirmation request with a 23 July deadline, its same-day response claiming $15,272,447.30, and exclusion from the 4 August amended complaint. It quotes Belote’s distinction between a colourable interest in Disputed Funds and a general Cyberlux claim. ARG alleges inconsistency; the full correspondence and basis for the different claim amount remain separate dependencies.supportsWhat instruments and account history establish the applicable percentage base, the $375,000 credit, interest start date and change between the two demands?
Specifically named source propositions support the bounded distinction or question.
The demand calculates 20% of the initial amount as $7,740,120, plus $1,599,624.80 interest at 8% for 31 months ($51,600.80 monthly), reaching $9,339,744.80. It adds 20% of the final amount, $5,153,873.81, then subtracts $375,000 partial payments, giving $14,118,618.61. The stated calculation date is 15 April 2026, after both the 6 March document date and 11 March filing stamp; additional initial and all final-payment interest are reserved.supportsWhat instruments and account history establish the applicable percentage base, the $375,000 credit, interest start date and change between the two demands?
Specifically named source propositions support the bounded distinction or question.
The demand calculates 20% of the initial amount as $7,740,120, plus $1,599,624.80 interest at 8% for 31 months ($51,600.80 monthly), reaching $9,339,744.80. It adds 20% of the final amount, $5,153,873.81, then subtracts $375,000 partial payments, giving $14,118,618.61. The stated calculation date is 15 April 2026, after both the 6 March document date and 11 March filing stamp; additional initial and all final-payment interest are reserved.supportsThe earlier $15,272,447.30 asserted amount and the later $14,118,618.61 demand differ by $1,153,828.69. No reconciliation of that change is supplied here.
Specifically named source propositions support the bounded distinction or question.
ARG alleges Cyberlux acknowledged the debt, made $375,000 partial payments, and otherwise failed to pay despite ARG’s full performance and no offsets. Those are ARG’s representations; the alleged acknowledgements and payment ledger are not reproduced.supportsThe pleaded arithmetic reconciles to $14,118,618.61 after the $375,000 credit, but its future calculation date and additional reserved interest prevent treating it as a filing-day or current payoff.
Specifically named source propositions support the bounded distinction or question.
Under an interpleader count citing 28 USC 1335 and 2361, ARG requests payment of at least $14,118,618.61 from the fund, additional interest, fees, costs and further relief. This is requested distribution, not an entered allocation or current payable balance.supportsIs the $14,118,618.61 figure an awarded amount or filing-date balance?
Specifically named source propositions support the bounded distinction or question.
The demand calculates 20% of the initial amount as $7,740,120, plus $1,599,624.80 interest at 8% for 31 months ($51,600.80 monthly), reaching $9,339,744.80. It adds 20% of the final amount, $5,153,873.81, then subtracts $375,000 partial payments, giving $14,118,618.61. The stated calculation date is 15 April 2026, after both the 6 March document date and 11 March filing stamp; additional initial and all final-payment interest are reserved.supportsWhy does the 11 March filing calculate through 15 April, and what do the docket and original transmission records establish about the 6 March certificate?
Specifically named source propositions support the bounded distinction or question.
Under an interpleader count citing 28 USC 1335 and 2361, ARG requests payment of at least $14,118,618.61 from the fund, additional interest, fees, costs and further relief. This is requested distribution, not an entered allocation or current payable balance.supportsNaming ARG in an interpleader and recognising an asserted claim do not themselves adjudicate its ownership or priority in the fund; the complaint presents that inference as ARG’s argument.
Specifically named source propositions support the bounded distinction or question.
The twelve-page complaint in intervention bears ECF 155 filing on 11 March 2026 in EDVA 3:25-cv-00483-JAG. Stephen J. Stine signs it with Stephen L. Neal Jr. listed; the document date and CM/ECF service certificate say 6 March 2026. Those dates remain distinct; the filing does not itself establish intervention granted.supportsWhy does the 11 March filing calculate through 15 April, and what do the docket and original transmission records establish about the 6 March certificate?
Specifically named source propositions support the bounded distinction or question.
ARG reports HII’s 14 July 2025 confirmation request with a 23 July deadline, its same-day response claiming $15,272,447.30, and exclusion from the 4 August amended complaint. It quotes Belote’s distinction between a colourable interest in Disputed Funds and a general Cyberlux claim. ARG alleges inconsistency; the full correspondence and basis for the different claim amount remain separate dependencies.supportsThe earlier $15,272,447.30 asserted amount and the later $14,118,618.61 demand differ by $1,153,828.69. No reconciliation of that change is supplied here.
Specifically named source propositions support the bounded distinction or question.
The demand calculates 20% of the initial amount as $7,740,120, plus $1,599,624.80 interest at 8% for 31 months ($51,600.80 monthly), reaching $9,339,744.80. It adds 20% of the final amount, $5,153,873.81, then subtracts $375,000 partial payments, giving $14,118,618.61. The stated calculation date is 15 April 2026, after both the 6 March document date and 11 March filing stamp; additional initial and all final-payment interest are reserved.supportsIs the $14,118,618.61 figure an awarded amount or filing-date balance?
Specifically named source propositions support the bounded distinction or question.
ARG identifies an eight-page Holt roadmap dated 7 August 2022, titled Accelerating FlightEye K8 FMS to Ukraine. It says Marty Moore joined Cyberlux’s advisory board by November 2022 through Jeremy Shrock, and refers to hundreds of Signal pages including Larry Isely. None of those records is physically attached to this twelve-page pleading.supportsWhich underlying messages, roadmap and operational records substantiate the claimed introductions, technical contribution and Schmidt acknowledgements?
Specifically named source propositions support the bounded distinction or question.
The twelve-page complaint in intervention bears ECF 155 filing on 11 March 2026 in EDVA 3:25-cv-00483-JAG. Stephen J. Stine signs it with Stephen L. Neal Jr. listed; the document date and CM/ECF service certificate say 6 March 2026. Those dates remain distinct; the filing does not itself establish intervention granted.supportsThe pleaded arithmetic reconciles to $14,118,618.61 after the $375,000 credit, but its future calculation date and additional reserved interest prevent treating it as a filing-day or current payoff.
Specifically named source propositions support the bounded distinction or question.
ARG reports HII’s 14 July 2025 confirmation request with a 23 July deadline, its same-day response claiming $15,272,447.30, and exclusion from the 4 August amended complaint. It quotes Belote’s distinction between a colourable interest in Disputed Funds and a general Cyberlux claim. ARG alleges inconsistency; the full correspondence and basis for the different claim amount remain separate dependencies.supportsNaming ARG in an interpleader and recognising an asserted claim do not themselves adjudicate its ownership or priority in the fund; the complaint presents that inference as ARG’s argument.
Specifically named source propositions support the bounded distinction or question.
The demand calculates 20% of the initial amount as $7,740,120, plus $1,599,624.80 interest at 8% for 31 months ($51,600.80 monthly), reaching $9,339,744.80. It adds 20% of the final amount, $5,153,873.81, then subtracts $375,000 partial payments, giving $14,118,618.61. The stated calculation date is 15 April 2026, after both the 6 March document date and 11 March filing stamp; additional initial and all final-payment interest are reserved.supportsThe pleaded arithmetic reconciles to $14,118,618.61 after the $375,000 credit, but its future calculation date and additional reserved interest prevent treating it as a filing-day or current payoff.
Specifically named source propositions support the bounded distinction or question.
ARG claims introductions, test sites, technical specifications, cost data and firing-mechanism assistance, including a team with Army members. It says SOFIC Tampa contacts led to Fairwinds and Ferd Irizarry, and that ARG brought Cameron Holt in to advance FMS/FMF. These are ARG’s causal and performance allegations.supportsWhich underlying messages, roadmap and operational records substantiate the claimed introductions, technical contribution and Schmidt acknowledgements?
Specifically named source propositions support the bounded distinction or question.
ARG argues HII’s inclusion of it in the original 24 June 2025 interpleader complaint recognised a legitimate claim, citing Thin Air Gear’s intervention ruling by analogy. That is ARG’s argument about party inclusion, not an admission that its debt or entitlement was allowed.supportsNaming ARG in an interpleader and recognising an asserted claim do not themselves adjudicate its ownership or priority in the fund; the complaint presents that inference as ARG’s argument.
Specifically named source propositions support the bounded distinction or question.
ARG describes its 24 April 2025 Durham action and Cyberlux’s answer, and now characterises the requested amount there as at least $14,118,618.61 plus specified remedies. It alleges a 25 February 2026 Amendment No.1 permits intervention. It conditionally intends to seek a stay or voluntarily dismiss the state case if intervention is granted; neither amendment nor resulting disposition is attached.supportsWhich agreement amendment, intervention order and state-court disposition establish the permitted forum and actual procedural outcome?
Specifically named source propositions support the bounded distinction or question.
ARG alleges the 28 February 2022 agreement provides a 20% discount off GSA pricing and an 80/20 allocation under paragraph 4A. It further attributes to Schmidt written and Signal acknowledgements of 20% regardless of prime and 30% if Cyberlux sells directly without a prime. The actual agreement and messages are not embedded.supportsWhich underlying messages, roadmap and operational records substantiate the claimed introductions, technical contribution and Schmidt acknowledgements?
Specifically named source propositions support the bounded distinction or question.
WEIGH
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