Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
assumptionassumption
Any conclusion that the approval-dependent settlement provisions became operative assumes the required government approval/notice occurred;
Any conclusion that the approval-dependent settlement provisions became operative assumes the required government approval/notice occurred; this copy does not supply those events.
observationobservation
Modification 4, P000043846; effective 26 February 2025, signatures 26/27 February.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
observationobservation
Group C: 46 + 383 + 97 = 526; documentation categories are distinct.
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Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 2 of 8 PageID# 3840
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 3 of 9.
3. Description of CLINs 1001, 1002, 1003, and 1004.
CLIN 1001. Table columns: Categories | [middle heading redacted] | Description.
Drone Kits Delivered/Accepted Prior to SWO | [redacted] | [redacted]
[Category label redacted; description identifies Group A] | [redacted] | “Group A” refers to the 37 drone kits (K8-1 (12 kits); K8-2 (25 kits)) that Cyberlux has stated have passed HII-witnessed Flight Acceptance Testing (“FAT”) and were only awaiting Government acceptance and shipment when the SWO was issued on December 22, 2023.
Group B | [redacted] | “Group B” refers to the 745 drones (K8-1 (248 drones); K8-2 (497 drones)) that Cyberlux has stated have completed quality control (“QC”) and bench testing, but for which FAT has not occurred. The drones have not yet been placed into drone kit configuration.
Group C | [redacted] | “Group C” refers to the 526 Work in Progress drones that Cyberlux has stated had not undergone Cyberlux QC or bench testing. In addition, the drones have not undergone HII-witnessed FAT, nor have they yet been placed into drone kit configuration. Cyberlux stated that a number of these drones had been moved to a Tier 3 status between the issuance of the SWO (December 22, 2023) and the issuance of the Termination Notice (May 17, 2024). Group C has three subsets:
1. Subset 1: 46 drones (K8-1 (16 kits); K8-2 (30 kits)) for which Cyberlux has provided to HII documentation indicating that assembly of the drone was initiated prior [continues next page].
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
observationobservation
EDVA 180-2 overlays TXSD 1-2 and county-clerk unofficial-copy provenance.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
The eight-page redacted Modification No. 4 to subcontract P000043846 states an effective date of 26 February 2025 between HII Mission Techno
The eight-page redacted Modification No. 4 to subcontract P000043846 states an effective date of 26 February 2025 between HII Mission Technologies Corp., Delaware, and Cyberlux Corporation, Nevada. HII’s SVP Contracts signature is dated 27 February 2025 and Cyberlux CEO Mark Schmidt’s signature 26 February 2025. The HII printed-name field is blank; its handwritten surname is not confidently identified from this copy.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
The visible table records 60 training kits, each including two five-inch training drones plus listed control, repair, laptop and simulator e
The visible table records 60 training kits, each including two five-inch training drones plus listed control, repair, laptop and simulator equipment, delivered and accepted before stop-work; simulation software is likewise described as delivered/accepted. Training-course description and amounts are redacted. Insurance/trucking rows cite pre-stop-work shipments supported through Invoice 003 dated 9 August 2024; the initial-award-payment deduction references Invoice 20230829-HII001 dated 29 August 2023.
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Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 3 of 8 PageID# 3841
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 4 of 9.
Table columns: Categories | Amount | Description.
[Group C continuation, category cell blank] | [redacted] | to the SWO (December 22, 2023), consistent with Cyberlux's Group C categorization of July 24, 2024.
2. Subset 2: 383 drones for which Cyberlux has not supplied to HII documentation indicating assembly of the drone was initiated prior to the SWO, consistent with Cyberlux's Group C categorization of July 24, 2024.
3. Subset 3: 97 drones for which Cyberlux has provided to HII documentation indicating assembly of the drone was initiated after issuance of the SWO.
Group D | [redacted] | “Group D” refers to the components, parts and spares associated with 300 drone builds for which Cyberlux has stated that assembly had not been initiated prior to the SWO. Cyberlux provided an inventory of these components, parts and spares on September 13, 2024, as revised on September 20, 2024. Cyberlux has stated that these items are “not in any initial airframe assembly phase.”
Drone Training Kits | [redacted] | 60 drone training kits (each including two 5” Training Drones, Communications and control goggles and Controller, Replacement and Repair Parts, Laptop and a Mission Management Simulator unit) that were delivered and accepted prior to the SWO.
Simulation Software | [redacted] | Simulation software delivered and accepted prior to the SWO.
Training Course Delivered | [redacted] | [redacted]
Insurance costs | [redacted] | Related to shipments of drone kits prior to the SWO. Supported by provider invoice documented in Cyberlux Invoice 003 dated August 9, 2024.
Trucking costs | [redacted] | Related to shipments of drone kits prior to the SWO. Supported by provider invoice documented in Cyberlux Invoice 003 dated August 9, 2024.
Less initial payment made at award | [redacted] | Invoice 20230829-HII001 dated August 29, 2023.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Material amounts, CLIN totals and descriptions, most Group A/B/C delivery provisions and extensive later provisions are opaque redactions. P
Material amounts, CLIN totals and descriptions, most Group A/B/C delivery provisions and extensive later provisions are opaque redactions. Page 5’s substantive body is redacted. This copy cannot establish total settlement consideration, complete payment/title/indemnity terms or every delivery obligation; no concealed text is reconstructed.
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Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 3 of 9.
3. Description of CLINs 1001, 1002, 1003, and 1004.
CLIN 1001. Table columns: Categories | [middle heading redacted] | Description.
Drone Kits Delivered/Accepted Prior to SWO | [redacted] | [redacted]
[Category label redacted; description identifies Group A] | [redacted] | “Group A” refers to the 37 drone kits (K8-1 (12 kits); K8-2 (25 kits)) that Cyberlux has stated have passed HII-witnessed Flight Acceptance Testing (“FAT”) and were only awaiting Government acceptance and shipment when the SWO was issued on December 22, 2023.
Group B | [redacted] | “Group B” refers to the 745 drones (K8-1 (248 drones); K8-2 (497 drones)) that Cyberlux has stated have completed quality control (“QC”) and bench testing, but for which FAT has not occurred. The drones have not yet been placed into drone kit configuration.
Group C | [redacted] | “Group C” refers to the 526 Work in Progress drones that Cyberlux has stated had not undergone Cyberlux QC or bench testing. In addition, the drones have not undergone HII-witnessed FAT, nor have they yet been placed into drone kit configuration. Cyberlux stated that a number of these drones had been moved to a Tier 3 status between the issuance of the SWO (December 22, 2023) and the issuance of the Termination Notice (May 17, 2024). Group C has three subsets:
1. Subset 1: 46 drones (K8-1 (16 kits); K8-2 (30 kits)) for which Cyberlux has provided to HII documentation indicating that assembly of the drone was initiated prior [continues next page].
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
The visible section 4 delivery terms depend on government disposition instructions relayed by HII. For Group D, HII and government inventory
The visible section 4 delivery terms depend on government disposition instructions relayed by HII. For Group D, HII and government inventory a representative sample, then Cyberlux boxes, palletises and ships according to those instructions. This states a contractual sequence, not evidence that inspection or shipment occurred.
Read the anchor · page 4
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 4 of 8 PageID# 3842
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 5 of 9.
Table columns: Categories | Amount | Description.
CLIN 1001 Total | [redacted] | [redacted]
CLINs 1002, 1003, 1004. Columns: CLIN | [middle heading redacted] | Description. All substantive row labels, amounts and descriptions redacted.
4. Delivery. Subject to the Government's disposition instructions, the following delivery terms shall apply:
a. Upon notification from HII to Cyberlux of the Government's disposition instructions, Cyberlux shall take the following actions in accordance with such instructions:
i. For Groups A, B, and C: [redacted]
ii. For Group D:
1. HII and the Government take inventory of a representative sample of the Group D inventory.
2. Cyberlux boxes and palletizes Group D and then ships the items in accordance with the Government's disposition instructions.
[Remaining lower-page provisions redacted.]
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Section 9 prohibits Cyberlux communications with Navy or GSA about subcontract performance or termination and makes HII the sole contact, in
Section 9 prohibits Cyberlux communications with Navy or GSA about subcontract performance or termination and makes HII the sole contact, including for contracting-officer review. The text’s subject-matter restriction is preserved; it is not expanded into a universal prohibition on any communication to government.
Read the anchor · page 6
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Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 7 of 9.
HII logo. Upper substantive body and headings redacted.
9. Communications. Cyberlux shall not communicate with the U.S. Navy or the General Services Administration regarding the performance or termination of the Subcontract. HII shall be the sole point of contact for such communications with the U.S. Navy or the General Services Administration, including but not limited to communications regarding the Government Contracting Officer's review of the Agreement.
10. Release. Upon notice that the Government Contracting Officer has approved the Agreement, and to the fullest extent permitted by law, each Party remises, releases, and discharges the other Party (including its predecessors and successors in interest, and all its affiliates and subsidiaries) and its officers, [continues next page].
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Section 10 conditions mutual stop-work/termination-related releases on notice of government contracting-officer approval, to the fullest law
Section 10 conditions mutual stop-work/termination-related releases on notice of government contracting-officer approval, to the fullest lawful extent. It covers described related persons/entities and known or unknown claims but expressly preserves rights under the agreement, including enforcement. No approval notice or fact of release effectiveness is attached.
Read the anchor · page 6
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Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 7 of 9.
HII logo. Upper substantive body and headings redacted.
9. Communications. Cyberlux shall not communicate with the U.S. Navy or the General Services Administration regarding the performance or termination of the Subcontract. HII shall be the sole point of contact for such communications with the U.S. Navy or the General Services Administration, including but not limited to communications regarding the Government Contracting Officer's review of the Agreement.
10. Release. Upon notice that the Government Contracting Officer has approved the Agreement, and to the fullest extent permitted by law, each Party remises, releases, and discharges the other Party (including its predecessors and successors in interest, and all its affiliates and subsidiaries) and its officers, [continues next page].
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Section 11 expressly binds successors and assigns, including a bankruptcy trustee/debtor-in-possession, assignment-for-creditors fiduciary a
Section 11 expressly binds successors and assigns, including a bankruptcy trustee/debtor-in-possession, assignment-for-creditors fiduciary and state/federal receiver, under applicable law. It does not itself establish a particular receiver’s appointment, ownership of property or compliance.
Read the anchor · page 7
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 7 of 8 PageID# 3845
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 8 of 9.
agents, and employees, of and from any and all liabilities, obligations, claims, losses, appeals, and demands that it now has or hereafter may have, whether known or unknown, administrative, judicial, legal, or equitable, arising out of or in any way related to the stop-work or termination of the Subcontract; provided, however, that this section shall not limit or diminish the rights of the Parties under the Agreement, including any right to enforce the provisions of this Agreement.
11. Binding Effect. The Agreement shall inure to the benefit of and be binding upon the respective successors and assigns of the Parties hereto, including any trustee or debtor-in-possession in bankruptcy, assignee for the benefit of creditors, state or federal receiver, or other fiduciary, successor, or assignor of a Party and/or its assets under applicable law.
12. Entire Agreement, Modification, Survival. The Parties hereby expressly agree that the Subcontract, as modified by this Agreement, constitutes the entire agreement between the Parties with respect to the subject matter hereof and supersedes and replaces any and all prior or contemporaneous negotiations, promises, understandings, and agreements, whether written or oral. To the extent any terms of this Agreement are inconsistent with the Subcontract's initial terms, including but not limited to the Subcontract's initial clauses concerning invoicing, payment, delivery, inspection/acceptance, warranty, and subcontractor closeout, this Agreement shall control. This Agreement may not be altered, amended, modified, revised, or otherwise changed except by a writing duly executed by both Parties. Sections 7-10 shall survive the termination of this Agreement.
13. Execution. This Agreement may be executed in counterparts, each of which will be deemed to be an original for the respective Parties, and all of which together shall be deemed to be one in the same agreement.
14. Authority. By their signatures below, the representative for each of the Parties represents that he or she has authority to enter into this Agreement on behalf of the respective Party, and the Party agrees to implement the terms and conditions set forth in this Agreement.
15. Severability. If any provision of this Agreement or the application thereof is held invalid or unenforceable, such invalidity or unenforceability shall not affect the other provisions herein, which shall be given full force and effect without the invalid or unenforceable provisions or applications. As such, the provisions of this Agreement are declared to be severable. In the event that any part, term, or provision of this Agreement is held void, illegal, unenforceable, or in conflict with any law or regulation, the Parties agree to negotiate in good faith for a replacement provision, construed to accomplish the Agreement's originally intended effect, that does not violate such law or regulation.
[signature page to follow]
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Section 12 makes the subcontract as modified the entire agreement, supersedes prior negotiations/promises on its subject and gives the modif
Section 12 makes the subcontract as modified the entire agreement, supersedes prior negotiations/promises on its subject and gives the modification control over inconsistent initial terms including invoicing, payment, delivery, inspection/acceptance, warranty and closeout. Changes require a writing executed by both parties; sections 7–10 survive termination. Redacted sections 7–8 cannot be evaluated from this copy.
Read the anchor · page 7
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 7 of 8 PageID# 3845
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 8 of 9.
agents, and employees, of and from any and all liabilities, obligations, claims, losses, appeals, and demands that it now has or hereafter may have, whether known or unknown, administrative, judicial, legal, or equitable, arising out of or in any way related to the stop-work or termination of the Subcontract; provided, however, that this section shall not limit or diminish the rights of the Parties under the Agreement, including any right to enforce the provisions of this Agreement.
11. Binding Effect. The Agreement shall inure to the benefit of and be binding upon the respective successors and assigns of the Parties hereto, including any trustee or debtor-in-possession in bankruptcy, assignee for the benefit of creditors, state or federal receiver, or other fiduciary, successor, or assignor of a Party and/or its assets under applicable law.
12. Entire Agreement, Modification, Survival. The Parties hereby expressly agree that the Subcontract, as modified by this Agreement, constitutes the entire agreement between the Parties with respect to the subject matter hereof and supersedes and replaces any and all prior or contemporaneous negotiations, promises, understandings, and agreements, whether written or oral. To the extent any terms of this Agreement are inconsistent with the Subcontract's initial terms, including but not limited to the Subcontract's initial clauses concerning invoicing, payment, delivery, inspection/acceptance, warranty, and subcontractor closeout, this Agreement shall control. This Agreement may not be altered, amended, modified, revised, or otherwise changed except by a writing duly executed by both Parties. Sections 7-10 shall survive the termination of this Agreement.
13. Execution. This Agreement may be executed in counterparts, each of which will be deemed to be an original for the respective Parties, and all of which together shall be deemed to be one in the same agreement.
14. Authority. By their signatures below, the representative for each of the Parties represents that he or she has authority to enter into this Agreement on behalf of the respective Party, and the Party agrees to implement the terms and conditions set forth in this Agreement.
15. Severability. If any provision of this Agreement or the application thereof is held invalid or unenforceable, such invalidity or unenforceability shall not affect the other provisions herein, which shall be given full force and effect without the invalid or unenforceable provisions or applications. As such, the provisions of this Agreement are declared to be severable. In the event that any part, term, or provision of this Agreement is held void, illegal, unenforceable, or in conflict with any law or regulation, the Parties agree to negotiate in good faith for a replacement provision, construed to accomplish the Agreement's originally intended effect, that does not violate such law or regulation.
[signature page to follow]
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Sections 13–15 permit counterparts, represent signatory authority, preserve enforceable provisions if another fails and require good-faith n
Sections 13–15 permit counterparts, represent signatory authority, preserve enforceable provisions if another fails and require good-faith negotiation of a lawful replacement provision reflecting intended effect. These are operative contract terms rather than proof of subsequent performance or an external authority investigation.
Read the anchor · page 7
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 7 of 8 PageID# 3845
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 8 of 9.
agents, and employees, of and from any and all liabilities, obligations, claims, losses, appeals, and demands that it now has or hereafter may have, whether known or unknown, administrative, judicial, legal, or equitable, arising out of or in any way related to the stop-work or termination of the Subcontract; provided, however, that this section shall not limit or diminish the rights of the Parties under the Agreement, including any right to enforce the provisions of this Agreement.
11. Binding Effect. The Agreement shall inure to the benefit of and be binding upon the respective successors and assigns of the Parties hereto, including any trustee or debtor-in-possession in bankruptcy, assignee for the benefit of creditors, state or federal receiver, or other fiduciary, successor, or assignor of a Party and/or its assets under applicable law.
12. Entire Agreement, Modification, Survival. The Parties hereby expressly agree that the Subcontract, as modified by this Agreement, constitutes the entire agreement between the Parties with respect to the subject matter hereof and supersedes and replaces any and all prior or contemporaneous negotiations, promises, understandings, and agreements, whether written or oral. To the extent any terms of this Agreement are inconsistent with the Subcontract's initial terms, including but not limited to the Subcontract's initial clauses concerning invoicing, payment, delivery, inspection/acceptance, warranty, and subcontractor closeout, this Agreement shall control. This Agreement may not be altered, amended, modified, revised, or otherwise changed except by a writing duly executed by both Parties. Sections 7-10 shall survive the termination of this Agreement.
13. Execution. This Agreement may be executed in counterparts, each of which will be deemed to be an original for the respective Parties, and all of which together shall be deemed to be one in the same agreement.
14. Authority. By their signatures below, the representative for each of the Parties represents that he or she has authority to enter into this Agreement on behalf of the respective Party, and the Party agrees to implement the terms and conditions set forth in this Agreement.
15. Severability. If any provision of this Agreement or the application thereof is held invalid or unenforceable, such invalidity or unenforceability shall not affect the other provisions herein, which shall be given full force and effect without the invalid or unenforceable provisions or applications. As such, the provisions of this Agreement are declared to be severable. In the event that any part, term, or provision of this Agreement is held void, illegal, unenforceable, or in conflict with any law or regulation, the Parties agree to negotiate in good faith for a replacement provision, construed to accomplish the Agreement's originally intended effect, that does not violate such law or regulation.
[signature page to follow]
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
The copy is filed as EDVA Document 180-2 on 15 April 2026, pages 1–8, PageIDs 3839–3846. It retains TXSD 4:25-cv-01689 Document 1-2 stamps f
The copy is filed as EDVA Document 180-2 on 15 April 2026, pages 1–8, PageIDs 3839–3846. It retains TXSD 4:25-cv-01689 Document 1-2 stamps from 11 April 2025, pages 2–9 of 9, and an Unofficial Copy Office of Marilyn Burgess District Clerk watermark. These are nested provenance markers, not three separate settlement events.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
The recitals identify the 29 August 2023 subcontract under prime task order 47QFCA22F0039 and TDL 1-023 supporting Navy and GSA/FEDSIM. They
The recitals identify the 29 August 2023 subcontract under prime task order 47QFCA22F0039 and TDL 1-023 supporting Navy and GSA/FEDSIM. They state government stop-work on 22 December 2023, HII’s consequent subcontract stop-work, government termination for convenience on 13 May 2024 and HII’s exercise of subcontract section 32.1 on 17 May 2024. These are recited chronology; original notices are not attached.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Section 1(a) makes sections 3–6 effective and enforceable only if and when the Government Contracting Officer approves the agreement. Sectio
Section 1(a) makes sections 3–6 effective and enforceable only if and when the Government Contracting Officer approves the agreement. Section 1(b) requires HII promptly to submit it and notify Cyberlux of approval, both parties to cooperate in good faith, and Cyberlux to provide access to subcontract books/records for government review. Signatures alone are not evidence that this approval occurred.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Section 2 bars money-damages action concerning the subcontract or termination during government review unless the proposing party first conf
Section 2 bars money-damages action concerning the subcontract or termination during government review unless the proposing party first confers in good faith about resolution. This is a qualified conference requirement, not an absolute permanent litigation prohibition.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
CLIN 1001 Group A describes 37 drone kits, 12 K8-1 and 25 K8-2, which Cyberlux stated had passed HII-witnessed flight acceptance testing and
CLIN 1001 Group A describes 37 drone kits, 12 K8-1 and 25 K8-2, which Cyberlux stated had passed HII-witnessed flight acceptance testing and awaited government acceptance/shipment when stop-work issued. Passing FAT and government acceptance are expressly different stages.
Read the anchor · page 2
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 2 of 8 PageID# 3840
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 3 of 9.
3. Description of CLINs 1001, 1002, 1003, and 1004.
CLIN 1001. Table columns: Categories | [middle heading redacted] | Description.
Drone Kits Delivered/Accepted Prior to SWO | [redacted] | [redacted]
[Category label redacted; description identifies Group A] | [redacted] | “Group A” refers to the 37 drone kits (K8-1 (12 kits); K8-2 (25 kits)) that Cyberlux has stated have passed HII-witnessed Flight Acceptance Testing (“FAT”) and were only awaiting Government acceptance and shipment when the SWO was issued on December 22, 2023.
Group B | [redacted] | “Group B” refers to the 745 drones (K8-1 (248 drones); K8-2 (497 drones)) that Cyberlux has stated have completed quality control (“QC”) and bench testing, but for which FAT has not occurred. The drones have not yet been placed into drone kit configuration.
Group C | [redacted] | “Group C” refers to the 526 Work in Progress drones that Cyberlux has stated had not undergone Cyberlux QC or bench testing. In addition, the drones have not undergone HII-witnessed FAT, nor have they yet been placed into drone kit configuration. Cyberlux stated that a number of these drones had been moved to a Tier 3 status between the issuance of the SWO (December 22, 2023) and the issuance of the Termination Notice (May 17, 2024). Group C has three subsets:
1. Subset 1: 46 drones (K8-1 (16 kits); K8-2 (30 kits)) for which Cyberlux has provided to HII documentation indicating that assembly of the drone was initiated prior [continues next page].
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Group B describes 745 drones, 248 K8-1 and 497 K8-2, which Cyberlux stated completed QC and bench testing but had not undergone FAT or been
Group B describes 745 drones, 248 K8-1 and 497 K8-2, which Cyberlux stated completed QC and bench testing but had not undergone FAT or been placed into kit configuration. The quantities are drones, unlike Group A’s kits.
Read the anchor · page 2
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 2 of 8 PageID# 3840
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 3 of 9.
3. Description of CLINs 1001, 1002, 1003, and 1004.
CLIN 1001. Table columns: Categories | [middle heading redacted] | Description.
Drone Kits Delivered/Accepted Prior to SWO | [redacted] | [redacted]
[Category label redacted; description identifies Group A] | [redacted] | “Group A” refers to the 37 drone kits (K8-1 (12 kits); K8-2 (25 kits)) that Cyberlux has stated have passed HII-witnessed Flight Acceptance Testing (“FAT”) and were only awaiting Government acceptance and shipment when the SWO was issued on December 22, 2023.
Group B | [redacted] | “Group B” refers to the 745 drones (K8-1 (248 drones); K8-2 (497 drones)) that Cyberlux has stated have completed quality control (“QC”) and bench testing, but for which FAT has not occurred. The drones have not yet been placed into drone kit configuration.
Group C | [redacted] | “Group C” refers to the 526 Work in Progress drones that Cyberlux has stated had not undergone Cyberlux QC or bench testing. In addition, the drones have not undergone HII-witnessed FAT, nor have they yet been placed into drone kit configuration. Cyberlux stated that a number of these drones had been moved to a Tier 3 status between the issuance of the SWO (December 22, 2023) and the issuance of the Termination Notice (May 17, 2024). Group C has three subsets:
1. Subset 1: 46 drones (K8-1 (16 kits); K8-2 (30 kits)) for which Cyberlux has provided to HII documentation indicating that assembly of the drone was initiated prior [continues next page].
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Group C describes 526 work-in-progress drones which Cyberlux stated lacked QC, bench testing, HII-witnessed FAT and kit configuration, with
Group C describes 526 work-in-progress drones which Cyberlux stated lacked QC, bench testing, HII-witnessed FAT and kit configuration, with some moved to Tier 3 between stop-work and termination. Its subsets are 46 with documentation indicating assembly before stop-work, 383 without supplied documentation showing a pre-stop-work start, and 97 with documentation indicating a post-stop-work start. The counts total 526; lack of supplied documentation for 383 is not proof that all 383 began after stop-work.
Read the anchor · page 2
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 2 of 8 PageID# 3840
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 3 of 9.
3. Description of CLINs 1001, 1002, 1003, and 1004.
CLIN 1001. Table columns: Categories | [middle heading redacted] | Description.
Drone Kits Delivered/Accepted Prior to SWO | [redacted] | [redacted]
[Category label redacted; description identifies Group A] | [redacted] | “Group A” refers to the 37 drone kits (K8-1 (12 kits); K8-2 (25 kits)) that Cyberlux has stated have passed HII-witnessed Flight Acceptance Testing (“FAT”) and were only awaiting Government acceptance and shipment when the SWO was issued on December 22, 2023.
Group B | [redacted] | “Group B” refers to the 745 drones (K8-1 (248 drones); K8-2 (497 drones)) that Cyberlux has stated have completed quality control (“QC”) and bench testing, but for which FAT has not occurred. The drones have not yet been placed into drone kit configuration.
Group C | [redacted] | “Group C” refers to the 526 Work in Progress drones that Cyberlux has stated had not undergone Cyberlux QC or bench testing. In addition, the drones have not undergone HII-witnessed FAT, nor have they yet been placed into drone kit configuration. Cyberlux stated that a number of these drones had been moved to a Tier 3 status between the issuance of the SWO (December 22, 2023) and the issuance of the Termination Notice (May 17, 2024). Group C has three subsets:
1. Subset 1: 46 drones (K8-1 (16 kits); K8-2 (30 kits)) for which Cyberlux has provided to HII documentation indicating that assembly of the drone was initiated prior [continues next page].
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
The Group C subset-1 text calls the total 46 drones but labels the 16 K8-1 and 30 K8-2 breakdown as kits. This literal unit inconsistency is
The Group C subset-1 text calls the total 46 drones but labels the 16 K8-1 and 30 K8-2 breakdown as kits. This literal unit inconsistency is retained; no kit-to-drone conversion or silent correction is imposed.
Read the anchor · page 2
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 2 of 8 PageID# 3840
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 3 of 9.
3. Description of CLINs 1001, 1002, 1003, and 1004.
CLIN 1001. Table columns: Categories | [middle heading redacted] | Description.
Drone Kits Delivered/Accepted Prior to SWO | [redacted] | [redacted]
[Category label redacted; description identifies Group A] | [redacted] | “Group A” refers to the 37 drone kits (K8-1 (12 kits); K8-2 (25 kits)) that Cyberlux has stated have passed HII-witnessed Flight Acceptance Testing (“FAT”) and were only awaiting Government acceptance and shipment when the SWO was issued on December 22, 2023.
Group B | [redacted] | “Group B” refers to the 745 drones (K8-1 (248 drones); K8-2 (497 drones)) that Cyberlux has stated have completed quality control (“QC”) and bench testing, but for which FAT has not occurred. The drones have not yet been placed into drone kit configuration.
Group C | [redacted] | “Group C” refers to the 526 Work in Progress drones that Cyberlux has stated had not undergone Cyberlux QC or bench testing. In addition, the drones have not undergone HII-witnessed FAT, nor have they yet been placed into drone kit configuration. Cyberlux stated that a number of these drones had been moved to a Tier 3 status between the issuance of the SWO (December 22, 2023) and the issuance of the Termination Notice (May 17, 2024). Group C has three subsets:
1. Subset 1: 46 drones (K8-1 (16 kits); K8-2 (30 kits)) for which Cyberlux has provided to HII documentation indicating that assembly of the drone was initiated prior [continues next page].
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
claimallegation
Group D describes components, parts and spares associated with 300 drone builds, for which Cyberlux stated assembly had not begun before sto
Group D describes components, parts and spares associated with 300 drone builds, for which Cyberlux stated assembly had not begun before stop-work and the items were not in an initial airframe assembly phase. It cites an inventory provided 13 September 2024 and revised 20 September 2024; the inventory itself is not attached.
Read the anchor · page 3
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 3 of 8 PageID# 3841
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 4 of 9.
Table columns: Categories | Amount | Description.
[Group C continuation, category cell blank] | [redacted] | to the SWO (December 22, 2023), consistent with Cyberlux's Group C categorization of July 24, 2024.
2. Subset 2: 383 drones for which Cyberlux has not supplied to HII documentation indicating assembly of the drone was initiated prior to the SWO, consistent with Cyberlux's Group C categorization of July 24, 2024.
3. Subset 3: 97 drones for which Cyberlux has provided to HII documentation indicating assembly of the drone was initiated after issuance of the SWO.
Group D | [redacted] | “Group D” refers to the components, parts and spares associated with 300 drone builds for which Cyberlux has stated that assembly had not been initiated prior to the SWO. Cyberlux provided an inventory of these components, parts and spares on September 13, 2024, as revised on September 20, 2024. Cyberlux has stated that these items are “not in any initial airframe assembly phase.”
Drone Training Kits | [redacted] | 60 drone training kits (each including two 5” Training Drones, Communications and control goggles and Controller, Replacement and Repair Parts, Laptop and a Mission Management Simulator unit) that were delivered and accepted prior to the SWO.
Simulation Software | [redacted] | Simulation software delivered and accepted prior to the SWO.
Training Course Delivered | [redacted] | [redacted]
Insurance costs | [redacted] | Related to shipments of drone kits prior to the SWO. Supported by provider invoice documented in Cyberlux Invoice 003 dated August 9, 2024.
Trucking costs | [redacted] | Related to shipments of drone kits prior to the SWO. Supported by provider invoice documented in Cyberlux Invoice 003 dated August 9, 2024.
Less initial payment made at award | [redacted] | Invoice 20230829-HII001 dated August 29, 2023.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
otherattribution
HII shall promptly submit the agreement and notify Cyberlux of government approval; both shall cooperate and Cyberlux shall provide relevant
HII shall promptly submit the agreement and notify Cyberlux of government approval; both shall cooperate and Cyberlux shall provide relevant records access.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
otherattribution
Cyberlux shall box, palletise and ship Group D according to government disposition instructions after the stated inventory step.
Read the anchor · page 4
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 4 of 8 PageID# 3842
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 5 of 9.
Table columns: Categories | Amount | Description.
CLIN 1001 Total | [redacted] | [redacted]
CLINs 1002, 1003, 1004. Columns: CLIN | [middle heading redacted] | Description. All substantive row labels, amounts and descriptions redacted.
4. Delivery. Subject to the Government's disposition instructions, the following delivery terms shall apply:
a. Upon notification from HII to Cyberlux of the Government's disposition instructions, Cyberlux shall take the following actions in accordance with such instructions:
i. For Groups A, B, and C: [redacted]
ii. For Group D:
1. HII and the Government take inventory of a representative sample of the Group D inventory.
2. Cyberlux boxes and palletizes Group D and then ships the items in accordance with the Government's disposition instructions.
[Remaining lower-page provisions redacted.]
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
otherattribution
Cyberlux shall not communicate with Navy/GSA about subcontract performance or termination; HII is the sole contact for those subjects.
Read the anchor · page 6
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 6 of 8 PageID# 3844
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 7 of 9.
HII logo. Upper substantive body and headings redacted.
9. Communications. Cyberlux shall not communicate with the U.S. Navy or the General Services Administration regarding the performance or termination of the Subcontract. HII shall be the sole point of contact for such communications with the U.S. Navy or the General Services Administration, including but not limited to communications regarding the Government Contracting Officer's review of the Agreement.
10. Release. Upon notice that the Government Contracting Officer has approved the Agreement, and to the fullest extent permitted by law, each Party remises, releases, and discharges the other Party (including its predecessors and successors in interest, and all its affiliates and subsidiaries) and its officers, [continues next page].
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
entityobservation
HII Mission Technologies Corp.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
entityobservation
Cyberlux Corporation
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
entityobservation
Mark Schmidt
Read the anchor · page 8
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 8 of 8 PageID# 3846
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 9 of 9.
IN WITNESS WHEREOF, the Parties have caused this Agreement to be executed by their duly authorized representatives.
HII Mission Technologies Corp. Signature present, beginning Richard M.; handwritten surname not confidently transcribed. Printed Name: [blank]. Title: SVP Contracts. Date: 02/27/2025.
Cyberlux Corporation. Signature present. Printed Name: Mark Schmidt. Title: CEO. Date: 02/26/2025.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
entityobservation
General Services Administration
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
entityobservation
Department of the Navy
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
eventattribution
Agreement recites government and consequential HII stop-work.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
eventattribution
Agreement recites government termination for convenience.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
eventattribution
Agreement recites HII exercise of section 32.1.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
eventattribution
Stated effective date and Cyberlux signature date.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
eventattribution
HII SVP Contracts signature dated.
Read the anchor · page 8
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 8 of 8 PageID# 3846
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 9 of 9.
IN WITNESS WHEREOF, the Parties have caused this Agreement to be executed by their duly authorized representatives.
HII Mission Technologies Corp. Signature present, beginning Richard M.; handwritten surname not confidently transcribed. Printed Name: [blank]. Title: SVP Contracts. Date: 02/27/2025.
Cyberlux Corporation. Signature present. Printed Name: Mark Schmidt. Title: CEO. Date: 02/26/2025.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
inferenceinference
Execution, approval-dependent effectiveness and later fulfilment are separate gates. The signed modification establishes its visible terms,
Execution, approval-dependent effectiveness and later fulfilment are separate gates. The signed modification establishes its visible terms, while sections 3–6 and the release require specified approval events not evidenced here.
inferenceinference
Inventory is differentiated by physical units and testing/documentation stage. Combining kits, un-kitted drones and component builds into a
Inventory is differentiated by physical units and testing/documentation stage. Combining kits, un-kitted drones and component builds into a single delivered/accepted-drone total would erase those distinctions.
inferenceinference
The release preserves agreement enforcement and the communications clause has a specified subject. Neither should be widened into general im
The release preserves agreement enforcement and the communications clause has a specified subject. Neither should be widened into general immunity or a prohibition on all government contact.
otherattribution
Complete supplied 8-page source reviewed at SHA-256 98ac0c2af8d9af9e9b72a7345a628b33d93888a5216eb6f609dd2af71fa13ac0. Source assertions, ori
Complete supplied 8-page source reviewed at SHA-256 98ac0c2af8d9af9e9b72a7345a628b33d93888a5216eb6f609dd2af71fa13ac0. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. All eight source pages fully visually read, including redacted pages, table cells, signatures and nested stamps. Native extraction was court-stamp-only; source-fingerprinted manual structured transcription preserves every visible substantive clause and table row, explicit redactions and signature uncertainty. OCR used only as aid and corrected against own images; no hidden material recovered.
Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 180-2 Filed 04/15/26 Page 1 of 8 PageID# 3839
Prior embedded filing stamp: Case 4:25-cv-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9.
CONFIDENTIAL INFORMATION REDACTED. HII Mission Technologies. Exhibit 2.
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the “Agreement”), effective as of February 26, 2025, is made by and between HII Mission Technologies Corp. (“HII”), a Delaware company with offices located at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (“Cyberlux”) a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a “Party,” and collectively, “the Parties”).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the “Subcontract”), issued under HII's Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 (“TDL 23”) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the “Government”);
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the “SWO”);
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, pursuant to FAR 49.108-3, the Government expects HII to submit a subcontractor settlement to the Government Contracting Officer for review and approval. Accordingly, the Parties agree that Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement.
b. Following execution of the Agreement, HII will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereafter, HII will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith to obtain such approval. In furtherance of that effort, Cyberlux shall cooperate with any audit or other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract.
2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action.
[Visible repeated watermark: Unofficial Copy Office of Marilyn Burgess District Clerk. Visible standard footer where not redacted: A division of HII; Issued by: Mission Technologies Command Media; HII Proprietary. Redacted text is not reconstructed.]
questionquestion
Where are the contracting-officer approval and notice, and what do the complete authorised terms provide for title, payment, indemnity and d
Where are the contracting-officer approval and notice, and what do the complete authorised terms provide for title, payment, indemnity and delivery?
questionquestion
What original inventory/test records reconcile the unit inconsistency, the undocumented 383-drone subset and actual disposition of each grou
What original inventory/test records reconcile the unit inconsistency, the undocumented 383-drone subset and actual disposition of each group?
questionquestion
Does the executed redacted modification prove all drones were accepted or the full settlement terms and approval?
claimallegation
Cyberlux Payment Entitlement Assertion
Cyberlux asserted entitlement to payment under Subcontract Section 32.1 following the termination for convenience.
Read the anchor · page 1
Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement
claimallegation
Group B Drone Status
Cyberlux stated that 745 drones (K8-1: 248 drones; K8-2: 497 drones) designated as Group B had completed quality control and bench testing, but Flight Acceptance Testing had not occurred and the drones had not yet been placed into drone kit configuration.
Read the anchor · page 2
"Group B" refers to the 745 drones (K8-1 (248 drones); K8-2 (497 drones)) that Cyberlux has stated have completed quality control ("QC") and bench testing, but for which FAT has not occurred. The drones have not yet been placed into drone kit configuration.
claimallegation
Group D Components Status
Cyberlux stated that Group D refers to components, parts and spares associated with 300 drone builds for which assembly had not been initiated prior to the Stop-Work Order, providing inventory on September 13 and revised September 20, 2024, characterizing these items as not in any initial airframe assembly phase.
Read the anchor · page 3
'Group D" refers to the components, parts and spares associated with 300 drone builds for which Cyberlux has stated that assembly had not been initiated prior to the SWO. Cyberlux provided an inventory of these components, parts and spares on September 13, 2024, as revised on September 20, 2024. Cyberlux has stated that these items are "not in any initial airframe assembly phase."
claimallegation
Group A Drone Kits Status
Cyberlux stated that 37 drone kits (K8-1: 12 kits; K8-2: 25 kits) designated as Group A had passed HII-witnessed Flight Acceptance Testing and were only awaiting Government acceptance and shipment when the Stop-Work Order was issued on December 22, 2023.
Read the anchor · page 2
"Group A" refers to the 37 drone kit's (K8-1 (12 kits); K8-2 (25 kits)) that Cyberlux has stated have passed HII-witnessed Flight Acceptance Testing ("FAT") and were only awaiting Government acceptance and shipment when the SWO was issued on December 22, 2023.
claimallegation
Group C Work in Progress Drones
Cyberlux stated that 526 Work in Progress drones designated as Group C had not undergone Cyberlux QC or bench testing, HII-witnessed FAT, or placement into drone kit configuration, with a number moved to Tier 3 status between December 22, 2023 and May 17, 2024.
Read the anchor · page 2
"Group C" refers to the 526 Work in Progress drones that Cyberlux has stated had not undergone Cyberlux QC or bench testing. In addition, the drones have not undergone HII-witnessed FAT, nor have they yet been placed into drone kit configuration. Cyberlux stated that a number of these drones had been moved to a Tier 3 status between the issuance of the SWO (December 22, 2023) and the issuance of the Termination Notice (May 17, 2024).
eventattribution
Termination sequence
Modification 4 states that the Government terminated the relevant work for convenience on 13 May 2024 and HII exercised the subcontract termination provisions on 17 May 2024.
Read the anchor · page 2
of 8
Mission Technologies
A division of HII
Issued by: Mission Technologies Command Media
1
HII Proprietary
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the Agreement ), effective as of February 26,
2025, is made by and between HII Mission Technologies Corp. ( HII ), a Delaware company with offices located
at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation ( Cyberlux ), a Nevada company
with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a Party, and
collectively, the Parties ).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the Subcontract ),
issued under HII s Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 ( TDL 23 ) supporting
the Department of the Navy and the General Services Administration, Federal Systems Integration and
Management Center (each and collectively, the Government );
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII
in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the SWO );
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII
subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following
negotiation, the Parties now wish to resolve any disagreement and reach a settlement.
NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other
good and valuable consideration, the Parties agree as follows:
1. Review and Approval.
a. The Parties acknowledge that, purs
eventattribution
Stop-work sequence
Modification 4 states that the Government issued a stop-work order on 22 December 2023 and HII issued one to Cyberlux in turn.
Read the anchor · page 2
Page 1 of 8
Mission Technologies
A division of HII
Issued by: Mission Technologies Command Media
1
HII Proprietary
Modification No. 4 to Subcontract No. P000043846
To Effectuate a Termination Settlement
This Modification No. 4 to Effectuate a Termination Settlement (the Agreement ), effective as of February 26,
2025, is made by and between HII Mission Technologies Corp. ( HII ), a Delaware company with offices located
at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation ( Cyberlux ), a Nevada company
with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NC 27709 (each a Party, and
collectively, the Parties ).
WHEREAS, the Parties entered into Subcontract No. P000043846, dated August 29, 2023 (the Subcontract ),
issued under HII s Prime Task Order 47QFCA22F0039 and Technical Direction Letter 1-023 ( TDL 23 ) supporting
the Department of the Navy and the General Services Administration, Federal Systems Integration and
Management Center (each and collectively, the Government );
WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HII
in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the SWO );
WHEREAS, the Government terminated the TDL 23 work scope for convenience on May 13, 2024, and HII
subsequently exercised the termination provisions of Subcontract Section 32.1 on May 17, 2024; and
WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following
negot
attribution
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Modification 4 states that the Government issued a stop-work order on 22 December 2023 and HII issued one to Cyberlux in turn.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.
Modification 4 states an effective date of 26 February 2025.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.
Modification 4 states that the Government terminated the relevant work for convenience on 13 May 2024 and HII exercised the subcontract termination provisions on 17 May 2024.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.
cyberlux stated that 526 work in progress drones designated as group c had not undergone cyberlux qc or bench testing hii witnessed fat or placement into drone kit configuration with a number moved to tier 3 status between december 22 2023 and may 17 2024relates to{"chapter":26,"exposure_lens":"Potential contractual, civil, administrative or criminal exposure turns on the exact representation, the responsible actor, knowledge, materiality and the records that remain missing.","responsibility":"Product, performance, invoices, use of funds, public statements and corporate records.","sequence":326,"unit_key":"CH26"}
The controlling book database maps this allegation into Part II; the book's explicit control-to-exposure crosswalk places that responsibility in Part III, Chapter 26. This is an identifier-based publication link, not a name match.
cyberlux stated that 37 drone kits k8 1 12 kits k8 2 25 kits designated as group a had passed hii witnessed flight acceptance testing and were only awaiting government acceptance and shipment when the stop work order was issued on december 22 2023relates to{"chapter":31,"exposure_lens":"Money movement identifies a transaction. Exposure remains separate for each lender, bank, creditor and recipient and depends on its own authority, knowledge, benefit and defences.","responsibility":"Financing, account control, payment processing, creditor entitlement, value and recipient knowledge where legally relevant.","sequence":331,"unit_key":"CH31"}
The controlling book database maps this allegation into Part II; the book's explicit control-to-exposure crosswalk places that responsibility in Part III, Chapter 31. This is an identifier-based publication link, not a name match.
cyberlux stated that group d refers to components parts and spares associated with 300 drone builds for which assembly had not been initiated prior to the stop work order providing inventory on september 13 and revised september 20 2024 characterizing these items as not in any initial airframe assembly phaserelates to{"chapter":27,"exposure_lens":"The prime-contractor exposure inquiry asks what HII submitted or accepted, who knew what, and whether the procurement, payment and settlement files support the decision made.","responsibility":"Supplier selection, price, subcontract administration, advance controls, inspection, termination and Government submissions.","sequence":327,"unit_key":"CH27"}
The controlling book database maps this allegation into Part II; the book's explicit control-to-exposure crosswalk places that responsibility in Part III, Chapter 27. This is an identifier-based publication link, not a name match.
cyberlux stated that 745 drones k8 1 248 drones k8 2 497 drones designated as group b had completed quality control and bench testing but flight acceptance testing had not occurred and the drones had not yet been placed into drone kit configurationrelates to{"chapter":26,"exposure_lens":"Potential contractual, civil, administrative or criminal exposure turns on the exact representation, the responsible actor, knowledge, materiality and the records that remain missing.","responsibility":"Product, performance, invoices, use of funds, public statements and corporate records.","sequence":326,"unit_key":"CH26"}
The controlling book database maps this allegation into Part II; the book's explicit control-to-exposure crosswalk places that responsibility in Part III, Chapter 26. This is an identifier-based publication link, not a name match.
cyberlux asserted entitlement to payment under subcontract section 32 1 following the termination for conveniencerelates to{"chapter":27,"exposure_lens":"The prime-contractor exposure inquiry asks what HII submitted or accepted, who knew what, and whether the procurement, payment and settlement files support the decision made.","responsibility":"Supplier selection, price, subcontract administration, advance controls, inspection, termination and Government submissions.","sequence":327,"unit_key":"CH27"}
The controlling book database maps this allegation into Part II; the book's explicit control-to-exposure crosswalk places that responsibility in Part III, Chapter 27. This is an identifier-based publication link, not a name match.
Cyberlux asserted entitlement to payment under Subcontract Section 32.1 following the termination for convenience.supportscyberlux asserted entitlement to payment under subcontract section 32 1 following the termination for convenience
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
Cyberlux stated that 745 drones (K8-1: 248 drones; K8-2: 497 drones) designated as Group B had completed quality control and bench testing, but Flight Acceptance Testing had not occurred and the drones had not yet been placed into drone kit configuration.supportscyberlux stated that 745 drones k8 1 248 drones k8 2 497 drones designated as group b had completed quality control and bench testing but flight acceptance testing had not occurred and the drones had not yet been placed into drone kit configuration
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
Cyberlux stated that Group D refers to components, parts and spares associated with 300 drone builds for which assembly had not been initiated prior to the Stop-Work Order, providing inventory on September 13 and revised September 20, 2024, characterizing these items as not in any initial airframe assembly phase.supportscyberlux stated that group d refers to components parts and spares associated with 300 drone builds for which assembly had not been initiated prior to the stop work order providing inventory on september 13 and revised september 20 2024 characterizing these items as not in any initial airframe assembly phase
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
Cyberlux stated that 526 Work in Progress drones designated as Group C had not undergone Cyberlux QC or bench testing, HII-witnessed FAT, or placement into drone kit configuration, with a number moved to Tier 3 status between December 22, 2023 and May 17, 2024.supportscyberlux stated that 526 work in progress drones designated as group c had not undergone cyberlux qc or bench testing hii witnessed fat or placement into drone kit configuration with a number moved to tier 3 status between december 22 2023 and may 17 2024
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
Cyberlux stated that 37 drone kits (K8-1: 12 kits; K8-2: 25 kits) designated as Group A had passed HII-witnessed Flight Acceptance Testing and were only awaiting Government acceptance and shipment when the Stop-Work Order was issued on December 22, 2023.supportscyberlux stated that 37 drone kits k8 1 12 kits k8 2 25 kits designated as group a had passed hii witnessed flight acceptance testing and were only awaiting government acceptance and shipment when the stop work order was issued on december 22 2023
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
{"timeline_thread":"programme","timeline_thread_label":"Procurement & programme"}relates to{"chapter":27,"exposure_lens":"The prime-contractor exposure inquiry asks what HII submitted or accepted, who knew what, and whether the procurement, payment and settlement files support the decision made.","responsibility":"Supplier selection, price, subcontract administration, advance controls, inspection, termination and Government submissions.","sequence":327,"unit_key":"CH27"}
The controlling book publication map connects this dated event to Part III, Chapter 27. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"legal","timeline_thread_label":"Legal & recovery"}relates to{"chapter":27,"exposure_lens":"The prime-contractor exposure inquiry asks what HII submitted or accepted, who knew what, and whether the procurement, payment and settlement files support the decision made.","responsibility":"Supplier selection, price, subcontract administration, advance controls, inspection, termination and Government submissions.","sequence":327,"unit_key":"CH27"}
The controlling book publication map connects this dated event to Part III, Chapter 27. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"legal","timeline_thread_label":"Legal & recovery"}relates to{"chapter":27,"exposure_lens":"The prime-contractor exposure inquiry asks what HII submitted or accepted, who knew what, and whether the procurement, payment and settlement files support the decision made.","responsibility":"Supplier selection, price, subcontract administration, advance controls, inspection, termination and Government submissions.","sequence":327,"unit_key":"CH27"}
The controlling book publication map connects this dated event to Part III, Chapter 27. The connection follows stored event/source and publication identifiers.
Section 9 prohibits Cyberlux communications with Navy or GSA about subcontract performance or termination and makes HII the sole contact, including for contracting-officer review. The text’s subject-matter restriction is preserved; it is not expanded into a universal prohibition on any communication to government.supportsThe release preserves agreement enforcement and the communications clause has a specified subject. Neither should be widened into general immunity or a prohibition on all government contact.
Specifically named source propositions support the bounded distinction or question.
Section 1(a) makes sections 3–6 effective and enforceable only if and when the Government Contracting Officer approves the agreement. Section 1(b) requires HII promptly to submit it and notify Cyberlux of approval, both parties to cooperate in good faith, and Cyberlux to provide access to subcontract books/records for government review. Signatures alone are not evidence that this approval occurred.supportsWhere are the contracting-officer approval and notice, and what do the complete authorised terms provide for title, payment, indemnity and delivery?
Specifically named source propositions support the bounded distinction or question.
Material amounts, CLIN totals and descriptions, most Group A/B/C delivery provisions and extensive later provisions are opaque redactions. Page 5’s substantive body is redacted. This copy cannot establish total settlement consideration, complete payment/title/indemnity terms or every delivery obligation; no concealed text is reconstructed.supportsWhere are the contracting-officer approval and notice, and what do the complete authorised terms provide for title, payment, indemnity and delivery?
Specifically named source propositions support the bounded distinction or question.
Section 10 conditions mutual stop-work/termination-related releases on notice of government contracting-officer approval, to the fullest lawful extent. It covers described related persons/entities and known or unknown claims but expressly preserves rights under the agreement, including enforcement. No approval notice or fact of release effectiveness is attached.supportsAny conclusion that the approval-dependent settlement provisions became operative assumes the required government approval/notice occurred; this copy does not supply those events.
Specifically named source propositions support the bounded distinction or question.
Group B describes 745 drones, 248 K8-1 and 497 K8-2, which Cyberlux stated completed QC and bench testing but had not undergone FAT or been placed into kit configuration. The quantities are drones, unlike Group A’s kits.supportsWhat original inventory/test records reconcile the unit inconsistency, the undocumented 383-drone subset and actual disposition of each group?
Specifically named source propositions support the bounded distinction or question.
Section 1(a) makes sections 3–6 effective and enforceable only if and when the Government Contracting Officer approves the agreement. Section 1(b) requires HII promptly to submit it and notify Cyberlux of approval, both parties to cooperate in good faith, and Cyberlux to provide access to subcontract books/records for government review. Signatures alone are not evidence that this approval occurred.supportsDoes the executed redacted modification prove all drones were accepted or the full settlement terms and approval?
Specifically named source propositions support the bounded distinction or question.
The visible section 4 delivery terms depend on government disposition instructions relayed by HII. For Group D, HII and government inventory a representative sample, then Cyberlux boxes, palletises and ships according to those instructions. This states a contractual sequence, not evidence that inspection or shipment occurred.supportsExecution, approval-dependent effectiveness and later fulfilment are separate gates. The signed modification establishes its visible terms, while sections 3–6 and the release require specified approval events not evidenced here.
Specifically named source propositions support the bounded distinction or question.
Material amounts, CLIN totals and descriptions, most Group A/B/C delivery provisions and extensive later provisions are opaque redactions. Page 5’s substantive body is redacted. This copy cannot establish total settlement consideration, complete payment/title/indemnity terms or every delivery obligation; no concealed text is reconstructed.supportsDoes the executed redacted modification prove all drones were accepted or the full settlement terms and approval?
Specifically named source propositions support the bounded distinction or question.
Group C describes 526 work-in-progress drones which Cyberlux stated lacked QC, bench testing, HII-witnessed FAT and kit configuration, with some moved to Tier 3 between stop-work and termination. Its subsets are 46 with documentation indicating assembly before stop-work, 383 without supplied documentation showing a pre-stop-work start, and 97 with documentation indicating a post-stop-work start. The counts total 526; lack of supplied documentation for 383 is not proof that all 383 began after stop-work.supportsWhat original inventory/test records reconcile the unit inconsistency, the undocumented 383-drone subset and actual disposition of each group?
Specifically named source propositions support the bounded distinction or question.
Section 10 conditions mutual stop-work/termination-related releases on notice of government contracting-officer approval, to the fullest lawful extent. It covers described related persons/entities and known or unknown claims but expressly preserves rights under the agreement, including enforcement. No approval notice or fact of release effectiveness is attached.supportsExecution, approval-dependent effectiveness and later fulfilment are separate gates. The signed modification establishes its visible terms, while sections 3–6 and the release require specified approval events not evidenced here.
Specifically named source propositions support the bounded distinction or question.
The Group C subset-1 text calls the total 46 drones but labels the 16 K8-1 and 30 K8-2 breakdown as kits. This literal unit inconsistency is retained; no kit-to-drone conversion or silent correction is imposed.supportsInventory is differentiated by physical units and testing/documentation stage. Combining kits, un-kitted drones and component builds into a single delivered/accepted-drone total would erase those distinctions.
Specifically named source propositions support the bounded distinction or question.
Group B describes 745 drones, 248 K8-1 and 497 K8-2, which Cyberlux stated completed QC and bench testing but had not undergone FAT or been placed into kit configuration. The quantities are drones, unlike Group A’s kits.supportsDoes the executed redacted modification prove all drones were accepted or the full settlement terms and approval?
Specifically named source propositions support the bounded distinction or question.
Group C describes 526 work-in-progress drones which Cyberlux stated lacked QC, bench testing, HII-witnessed FAT and kit configuration, with some moved to Tier 3 between stop-work and termination. Its subsets are 46 with documentation indicating assembly before stop-work, 383 without supplied documentation showing a pre-stop-work start, and 97 with documentation indicating a post-stop-work start. The counts total 526; lack of supplied documentation for 383 is not proof that all 383 began after stop-work.supportsDoes the executed redacted modification prove all drones were accepted or the full settlement terms and approval?
Specifically named source propositions support the bounded distinction or question.
Section 1(a) makes sections 3–6 effective and enforceable only if and when the Government Contracting Officer approves the agreement. Section 1(b) requires HII promptly to submit it and notify Cyberlux of approval, both parties to cooperate in good faith, and Cyberlux to provide access to subcontract books/records for government review. Signatures alone are not evidence that this approval occurred.supportsExecution, approval-dependent effectiveness and later fulfilment are separate gates. The signed modification establishes its visible terms, while sections 3–6 and the release require specified approval events not evidenced here.
Specifically named source propositions support the bounded distinction or question.
Section 1(a) makes sections 3–6 effective and enforceable only if and when the Government Contracting Officer approves the agreement. Section 1(b) requires HII promptly to submit it and notify Cyberlux of approval, both parties to cooperate in good faith, and Cyberlux to provide access to subcontract books/records for government review. Signatures alone are not evidence that this approval occurred.supportsAny conclusion that the approval-dependent settlement provisions became operative assumes the required government approval/notice occurred; this copy does not supply those events.
Specifically named source propositions support the bounded distinction or question.
The eight-page redacted Modification No. 4 to subcontract P000043846 states an effective date of 26 February 2025 between HII Mission Technologies Corp., Delaware, and Cyberlux Corporation, Nevada. HII’s SVP Contracts signature is dated 27 February 2025 and Cyberlux CEO Mark Schmidt’s signature 26 February 2025. The HII printed-name field is blank; its handwritten surname is not confidently identified from this copy.supportsExecution, approval-dependent effectiveness and later fulfilment are separate gates. The signed modification establishes its visible terms, while sections 3–6 and the release require specified approval events not evidenced here.
Specifically named source propositions support the bounded distinction or question.
Section 10 conditions mutual stop-work/termination-related releases on notice of government contracting-officer approval, to the fullest lawful extent. It covers described related persons/entities and known or unknown claims but expressly preserves rights under the agreement, including enforcement. No approval notice or fact of release effectiveness is attached.supportsDoes the executed redacted modification prove all drones were accepted or the full settlement terms and approval?
Specifically named source propositions support the bounded distinction or question.
The visible section 4 delivery terms depend on government disposition instructions relayed by HII. For Group D, HII and government inventory a representative sample, then Cyberlux boxes, palletises and ships according to those instructions. This states a contractual sequence, not evidence that inspection or shipment occurred.supportsWhat original inventory/test records reconcile the unit inconsistency, the undocumented 383-drone subset and actual disposition of each group?
Specifically named source propositions support the bounded distinction or question.
Group D describes components, parts and spares associated with 300 drone builds, for which Cyberlux stated assembly had not begun before stop-work and the items were not in an initial airframe assembly phase. It cites an inventory provided 13 September 2024 and revised 20 September 2024; the inventory itself is not attached.supportsDoes the executed redacted modification prove all drones were accepted or the full settlement terms and approval?
Specifically named source propositions support the bounded distinction or question.
Group C describes 526 work-in-progress drones which Cyberlux stated lacked QC, bench testing, HII-witnessed FAT and kit configuration, with some moved to Tier 3 between stop-work and termination. Its subsets are 46 with documentation indicating assembly before stop-work, 383 without supplied documentation showing a pre-stop-work start, and 97 with documentation indicating a post-stop-work start. The counts total 526; lack of supplied documentation for 383 is not proof that all 383 began after stop-work.supportsInventory is differentiated by physical units and testing/documentation stage. Combining kits, un-kitted drones and component builds into a single delivered/accepted-drone total would erase those distinctions.
Specifically named source propositions support the bounded distinction or question.
Section 10 conditions mutual stop-work/termination-related releases on notice of government contracting-officer approval, to the fullest lawful extent. It covers described related persons/entities and known or unknown claims but expressly preserves rights under the agreement, including enforcement. No approval notice or fact of release effectiveness is attached.supportsWhere are the contracting-officer approval and notice, and what do the complete authorised terms provide for title, payment, indemnity and delivery?
Specifically named source propositions support the bounded distinction or question.
Group D describes components, parts and spares associated with 300 drone builds, for which Cyberlux stated assembly had not begun before stop-work and the items were not in an initial airframe assembly phase. It cites an inventory provided 13 September 2024 and revised 20 September 2024; the inventory itself is not attached.supportsInventory is differentiated by physical units and testing/documentation stage. Combining kits, un-kitted drones and component builds into a single delivered/accepted-drone total would erase those distinctions.
Specifically named source propositions support the bounded distinction or question.
Group B describes 745 drones, 248 K8-1 and 497 K8-2, which Cyberlux stated completed QC and bench testing but had not undergone FAT or been placed into kit configuration. The quantities are drones, unlike Group A’s kits.supportsInventory is differentiated by physical units and testing/documentation stage. Combining kits, un-kitted drones and component builds into a single delivered/accepted-drone total would erase those distinctions.
Specifically named source propositions support the bounded distinction or question.
The Group C subset-1 text calls the total 46 drones but labels the 16 K8-1 and 30 K8-2 breakdown as kits. This literal unit inconsistency is retained; no kit-to-drone conversion or silent correction is imposed.supportsWhat original inventory/test records reconcile the unit inconsistency, the undocumented 383-drone subset and actual disposition of each group?
Specifically named source propositions support the bounded distinction or question.
Group D describes components, parts and spares associated with 300 drone builds, for which Cyberlux stated assembly had not begun before stop-work and the items were not in an initial airframe assembly phase. It cites an inventory provided 13 September 2024 and revised 20 September 2024; the inventory itself is not attached.supportsWhat original inventory/test records reconcile the unit inconsistency, the undocumented 383-drone subset and actual disposition of each group?
Specifically named source propositions support the bounded distinction or question.
CLIN 1001 Group A describes 37 drone kits, 12 K8-1 and 25 K8-2, which Cyberlux stated had passed HII-witnessed flight acceptance testing and awaited government acceptance/shipment when stop-work issued. Passing FAT and government acceptance are expressly different stages.supportsDoes the executed redacted modification prove all drones were accepted or the full settlement terms and approval?
Specifically named source propositions support the bounded distinction or question.
CLIN 1001 Group A describes 37 drone kits, 12 K8-1 and 25 K8-2, which Cyberlux stated had passed HII-witnessed flight acceptance testing and awaited government acceptance/shipment when stop-work issued. Passing FAT and government acceptance are expressly different stages.supportsWhat original inventory/test records reconcile the unit inconsistency, the undocumented 383-drone subset and actual disposition of each group?
Specifically named source propositions support the bounded distinction or question.
Section 10 conditions mutual stop-work/termination-related releases on notice of government contracting-officer approval, to the fullest lawful extent. It covers described related persons/entities and known or unknown claims but expressly preserves rights under the agreement, including enforcement. No approval notice or fact of release effectiveness is attached.supportsThe release preserves agreement enforcement and the communications clause has a specified subject. Neither should be widened into general immunity or a prohibition on all government contact.
Specifically named source propositions support the bounded distinction or question.
CLIN 1001 Group A describes 37 drone kits, 12 K8-1 and 25 K8-2, which Cyberlux stated had passed HII-witnessed flight acceptance testing and awaited government acceptance/shipment when stop-work issued. Passing FAT and government acceptance are expressly different stages.supportsInventory is differentiated by physical units and testing/documentation stage. Combining kits, un-kitted drones and component builds into a single delivered/accepted-drone total would erase those distinctions.
Specifically named source propositions support the bounded distinction or question.
WEIGH
Explained weighting
A score appears only when its components and change threshold are published.
No published WEIGH run
The active Website Edition contains no applied score snapshot for this source or its connected objects. That means not assessed—not zero.