Request for Judgment in Thermo Communications Funding, Llc v. Vikram Grover| Trellis.Law

On April 29, 2024 a Exhibit,Appendix was filed involving a dispute between Thermo Communications Funding, Llc, and Vikram Grover, for Commercial - Contract in the District Court of Nassau County.

Preview
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

T11435?
25 February 2524
fk.42:10
GO-244011N

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA
CIVIL DIVISION

THERMO COMMUNICATIONS
FUNDING,LLC
GD 24-00110
Plaintiff,
COMPLAINT IN CONFESSION OF
JUDGMENT
v.

FOMO WORLDWIDE,INC., p/k/a FOMO
CORP.,SMARTSOLUTION
TECHNOLOGIES,INC.,
SMARTSOLUTION TECHNOLOGIES
L.P., ENERGY INTELLIGENCE
CENTER,LLC,IAQ TECHNOLOGIES
LLC AND DIAMOND TECHNOLOGY
SOLUTIONS LLC, AND VIKRAM
GROVER,

Defendants.
Filed on Behalf of Plaintiff,
THERMO COMMUNICATIONS FUNDING,
LLC

Counsel of Record for this Party:

JONATHAN R. McCLOSKEY,ESQUIRE
PA. I.D. #320574

MEYER,DARRAGH,BUCKLER,
BEBENEK & ECK,P.L.L.C.
Firm No. 198
U.S. Steel Tower,Suite 4850
600 Grant Street
Ai
IVO,-14nOn Pittsburgh, PA 15219-6194
033,1 yv. ^/0377
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4, 110•
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° Telephone No.: (412)261-6600
8p:2 • Fax No.: (412)471-2754
ki 9e83j Email: jmccloskev@mdbbe.com
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(P11391027.1) -

wa
MIMED FROM THE RECORD
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA
CIVIL DIVISION

THERMO COMMUNICATIONS
FUNDING,LLC
GD 24-
Plaintiff,
COMPLAINT IN CONFESSION OF
JUDGMENT

Defendants.

ACT 105 OF 2000 NOTICE

A JUDGMENT HAS BEEN ENTERED AGAINST YOU BY CONFESSION OF JUDGMENT.

PURSUANT TO 42 PA. C.S.A. §2737.1, IF YOU WERE INCORRECTLY IDENTIFIED AS A
DEFENDANT IN THE COMPLAINT IN CONFESSION OF JUDGMENT, YOU MAY BE
ENTITLED TO COSTS AND REASONABLE ATTORNEY FEES AS DETERMINED BY
THE COURT.

YOU MAY TAKE ACTION TO STRIKE THE JUDGMENT BY FOLLOWING THE
PROCEDURE IN RULE 2959 WHICH IS AS FOLLOWS:

I. Pennsylvania Rule of Civil Procedure 2959 — Striking Off Judgment.

(P1891027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

(a) (1)Relief From a judgment by confession shall be sought by petition. Except as provided
in subparagraph (2), all grounds for relief whether to strike off the judgment or to open it must be
asserted in a single petition. The petition may be filed in the county in which the judgment was
originally entered, in any county to which the judgment has been transferred or in any other
county in which the sheriff has received a writ of execution directed to the sheriff to enforce the
judgment.

(2) The ground that the waiver of the due process rights of notice and hearing was not
voluntary, intelligent and knowing shall be raised only

(i) in support of a further request for a stay of execution where the court has
stayed despite the timely filing of a petition for relief from the judgment and the presentation of
prima facie evidence of a defense; and

(ii) as provided by Pennsylvania Rule of Civil Procedure 2958.3 or Rule 2973.3.

(3) If written notice is served upon the petition pursuant to Rule 2956.1(c)(2) or Rule
2973.1(c), the petition shall be filed within thirty days after such service. Unless the defendant
can demonstrate that there were compelling reasons for the delay, a petition not timely filed shall
be denied.

(b) If the petition states prima facie grounds for relief the court shall issue a rule to show cause
and may grant a stay of proceedings. After being served with a copy of the petition the plaintiff
shall file an answer on or before the return day of the rule. The return day of the rule shall be
fixed by the court by local rule or special order.

(d) The petition and the rule to show cause and the answer shall be served as provided in Rule
440(see text of Rule 440 reprinted below).

(e)The court shall dispose of the rule on petition and answer, and on any testimony, depositions,
admissions and other evidence. The court for cause shown may stay proceedings on the petition
insofar as it seeks to open the judgment pending disposition of the application to strike off the
judgment. If evidence is produced which a jury trial would require the issues to be submitted to
the jury the court shall open the judgment.

(f) The lien of the judgment or of any levy or attachment shall be preserved while the
proceedings to strike off or open the judgment is pending.

Rule 440. Service of Legal Papers other than Original Process

(a) (1)Copies of all legal papers other than original process filed in an action or served upon
any party to an action shall be served upon every other party to the action. Service shall be
made:

(P1891027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

(i) by handing or mailing a copy to or leaving a copy for each party at the address
of the party's attorney of record endorsed on an appearance or prior pleading of the party, or at
such other address as a party may agree, or

Note: Such other address as a party may agree might include a mailbox in the
prothonotary's office or an e-mail address. For electronic service by means other than
facsimile transmission, see Rule 205.4(g).

(ii) by transmitting a copy by facsimile to the party's attorney of record as
provided by subdivision (d).

(2) (i) If there is no attorney of record,service shall be made by handing a copy to the
party or by mailing a copy to or leaving a copy for the party at the address endorsed on an
appearance or prior pleading or the residence or place of business of the party, or by transmitting
a copy by facsimile as provided by subdivision (d).

(ii) If such service cannot be made, service shall be made by leaving a copy at or
mailing a copy to the last known address of the party to be served.

Note: This rule applies to the service upon a party of all legal papers other than original
process and includes, but is not limited to, all other pleadings as well as motions.
petitions, answers thereto, rules, notices, interrogatories and answers thereto. Original
process is served under Rule 400 et seq.

(b)Service by mail of legal papers other than original process is complete upon mailing.

(c) If service of legal papers other than original process is to be made by the sheriff, he shall
notify by ordinary mail the party requesting service to be made that service has or has not been
made upon a named party or person.

(P1891027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA
CIVIL DIVISION

THERMO COMMUNICATIONS
FUNDING,LLC
No GD 24-
Plaintiff,

v. COMPLAINT FOR CONFESSION
OF JUDGMENT

Defendants.

COMPLAINT IN CONFESSION OF JUDGMENT

Plaintiff, THERMO COMMUNICATIONS FUNDING,LLC,(hereinafter,"Plaintiff')
by and through Jonathan R. McCloskey and the law firm of Meyer, Darragh, Buckler, Bebenek,
& Eck, PLLC sues Defendants, FOMO CORP. ("FOMO"), SMARTSOLUTION
TECHNOLOGIES, INC. ("SMARTSOLUTION INC."), SMARTSOLUTION
TECHNOLOGIES LP, ("SMARTSOLUTION LP"), ENERGY INTELLIGENCE
CENTER, LLC, ("EIC"), IAQ TECHNOLOGIES LLC ("IAQ"), DIAMOND
TECHNOLOGY SOLUTIONS LLC ("DIAMOND), and VIKRAM GROVER
("GROVER")alleging herein:

1. Plaintiff is corporation duly organized under the laws of the State of Delaware

with an address of 101 W.Robert E. Lee Blvd., Suite 302, New Orleans, LA and authorized to

do business in the Commonwealth of Pennsylvania.

(P1891027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

2. FOMO is a Wyoming corporation with an address of 831 W North Ave.,

Pittsburgh, PA 15233.

3. Grover is the Chief Executive Officer and Manager of FOMO Corp.

4. Grover is an individual residing and domiciled with an address at 1 E. Erie Street,

Suite 525, Unit 2250, Chicago, IL 60611.

5. SMARTSolution Inc. is a Pennsylvania corporation with an address of 831 W.

North Ave., Pittsburgh, PA 15233.

6. SMARTSolution LP is a Pennsylvania limited partnership with an address of 831

W. North Ave., Pittsburgh, PA 15233.

7. EIC is a Wyoming limited liability company with an address of 831 W. North

Ave., Pittsburgh, PA 15233.

8. IAQ is a Pennsylvania limited liability company with an address of 831 W. North

Ave., Pittsburgh, PA 15233.

9. Diamond Technology Solutions LLC is a Pennsylvania limited liability company

with an address of 831 W. North Ave., Pittsburgh, PA 15233.

10. On or around February 28, 2022, Plaintiff and FOMO, SMARTSolution, Inc.,

SMARTSolution LP, EIC, and IAQ entered into a Loan and Security Agreement (the "Loan

Agreement"), pursuant to which Plaintiff agreed to issue credit to the above named Defendants.

A true and correct copy of the Loan Agreement is attached as Exhibit "A" and made a part

hereof.

11. The transactions contemplated by the loan documents appended hereto involved

significant business activities by the defendants in Allegheny County, Pennsylvania.

(P1891027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

12. In conjunction with and subject to the terms of the Loan Agreement,on or around

February 28, 2022, Plaintiff lent Defendants the sum of $1,000,000.00 and the loan was

memorialized in that certain Promissory Note of the same date (the "Note"). A true and correct

copy of the Note is attached as Exhibit B and is expressly incorporated and made a part of this

Complaint by reference.

13. To secure repayment of the debt evidenced by the Loan Agreement, on February

28, 2022, Grover executed a Limited Recourse Guaranty in favor of Plaintiff (the "Guaranty")

(the Loan Agreement, Note and Guaranty may hereafter be referred to collectively as the "Loan

Documents"). A true and correct copy of the Guaranty is attached as Exhibit C and is expressly

incorporated and made a part of this Complaint by reference.

14. The warrant of attorney in paragraph 12(1) of the Loan Agreement authorizes

Plaintiff to confess judgment in favor of Plaintiff for the full amount of the "Indebtedness" as

therein defined, which includes all obligations of Defendants to Plaintiff under the Loan

Documents, including all costs and expenses incurred by Plaintiff in connection with the

collection and administration of all or any part of such indebtedness.

15. Plaintiff and Defendants FOMO, SMARTSolution Inc., SMARTSolution L.P.,

EIC, Diamond, and Vikram Grover executed the Second Amendment to Loan and Security

Agreement and Promissory Note on or around July 16, 2023.(the "Second Amendment to Loan

Agreement")(A copy of the same is appended hereto, marked as Exhibit "D" and made a part

hereof).

16. Pursuant to section 2 of the Second Amendment to Loan Agreement, Diamond is

liable for all obligations set forth under the Loan Agreement and Note.

(P1891027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

17. Defendants defaulted under the Loan Agreement and Note by, inter alia, failing to

make payments when due.

18. Defendants misdirected and/or redirected payments required to be delivered into

the Lockbox Account in violation of section (d) of the Guaranty (on page 2 therein) and section

2(e) of the Loan Agreement. (A true and correct copy of the misdirected and/or redirected

payments evidencing deposits that went into accounts other than the required Lockbox Account

is appended hereto, marked as Exhibit"E" and made a part hereof).

19. SMARTSOLUTION L.P. changed the "remit to" addresses on numerous invoices

and misdirected and/or redirected payments away from the Lockbox Account and into other

accounts in violation of section (d) of the Guaranty (on page 2 therein) and section 2(e) of the

Loan Agreement.(True and correct copies of the foregoing invoices referenced in this paragraph

are appended hereto, marked as Exhibit"F'and made a part hereof).

20. The Defendants' and/or their principals, officers or employees acted with gross

negligence and/or willful misconduct (as described more fully above) which caused a loss to the

Plaintiff in violation of section (b) of the Guaranty (on page 2 therein) and section 2(e) of the

Loan Agreement.

21. Because the Defendants have violated sections (b) and/or (d) as stated on page 2

of the Guaranty, Defendant Grover is jointly and severally liable for all of the defendants'

obligations under the Loan Agreement, together with attorney's fees, costs, and other expenses.

22. Plaintiff demanded payment, but Defendants failed or refused to pay after

demand.

23. Defendants jointly and severally owe Plaintiff the following amounts:

a. Principal: $ 1,043,461.25

(P1891027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

b. Interest through February 16, 2024: $ 25,814.90

c. Attorney's Fees: $ 5,000.00

Interest continues to accrue at the rate of $600.34 per day.

d. Total Owed:$1,074,276.15.

24. Plaintiff has accelerated the amounts due under the Note and Loan Agreement and

the unpaid principal, together with interest, attorneys' fees, and late fees, and costs is due and

payable in full.

25. There has been no assignment, release, or transfer of the Note.

26. Plaintiff is the owner and holder of the Note and is entitled to enforce the Note.

27. Under the Loan Documents, Defendants are obligated to pay Plaintiffs reasonable

attorneys' fees and costs incurred in enforcing Plaintiffs rights under the Loan Documents.

28. Judgment has not been entered on the Note in any other jurisdiction.

29. Plaintiff has retained the undersigned law firm to represent Plaintiff in this matter

and is obligated to pay the firm a reasonable fee for its services.

30. Paragraph 12(1) of the Loan Agreement contains a confession of judgment

provision authorizing the undersigned to confess judgment against Defendants and in favor of

the Plaintiff due to the default.

31. THE JUDGMENT REQUESTED HEREIN IS NOT BEING ENTERED BY

CONFESSION AGAINST A NATURAL PERSON IN CONNECTION WITH A

CONSUMER CREDIT TRANSACTION.

32. The Loan Agreement has not been assigned, and no judgment has been entered on

the Loan Documents in any jurisdiction.

(P1891027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

33. Plaintiff has and will continue to incur reasonable costs of collection, and record

costs will be determined upon completion of the collection process.

34. All conditions precedent to this cause of action have been performed, have

occurred, or have been waived.

WHEREFORE,Plaintiff respectfully requests a judgment against the Defendants,jointly and

severally, for damages, interest, attorneys' fees, costs, and such other relief as is appropriate

under the circumstances.

Respectfully submitted,

MEYER,DARRAGH,BUCKLER,
BEBENEK & ECK,P.L.L.C.

By:
ION 61A-NR ASKEY,ESQUIRE
Casfrfsel

(P1691027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA
CIVIL DIVISION

THERMO COMMUNICATIONS
FUNDING,LLC
No GD 24-
Plaintiff,

Defendant.

CONFESSION OF JUDGMENT

Pursuant to the authority contained in the warrant of attorney, the original or a copy of
which is attached to the complaint filed in this action, I appear for the Defendant(s) and confess
judgment in favor of Plaintiff and against Defendants,jointly and severally, as follows:

Principal: $ 1,043,461.25
Interest through February 16, 2024: $25,814.90
Attorneys' Fees: $5,000.00

Total: $1,074,276.15

Plus interest accruing after February 16, 2024 at the default rate, plus attorney fees, costs, and
expenses incurred by Plaintiff/Judgment Creditor.

Jonath .
Attorn y for plaintiff

(P1891027.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA

THERMO COMMUNICATIONS CIVIL DIVISION
FUNDING,LLC,
NO.:
Plaintiff,

Defendants.

CERTIFICATE OF RESIDENCE

I hereby certify that the precise address of the Plaintiff is:

Thermo Communications Funding, LLC
101 W. Robert E. Lee Blvd., Suite 302
New Orleans, LA 70124

and the last known addresses of the Defendants are:

FOMO Worldwide, Inc., p/k/a FOMO FOMO Worldwide, Inc., p/k/a
Corp. FOMO Corp.
1 E. Erie Street, Suite 525, Unit 2250 831 W. North Avenue
Chicago, IL 60611 Pittsburgh, PA 15233

Vikram Grover Vikram Grover
1 E. Erie Street, Suite 525, Unit 2250 831 W. North Avenue
Chicago, IL 60611 Pittsburgh, PA 15233

SMARTSolution Technologies, Inc. SMARTSolution Technologies LP
831 W.North Avenue 831 W. North Avenue
Pittsburgh, PA 15233 Pittsburgh, PA 15233

(P18138243.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

Energy Intelligence Center, LLC Energy Intelligence Center, LLC
1001 Conshohocken State Road 831 W. North Avenue
Suite 106 Pittsburgh, PA 15233
Conshohocken,PA 19428

IAQ Technologies LLC IAQ Technologies LLC
1001 Conshohocken State Road 831 W. North Avenue
Suite 106 Pittsburgh, PA 15233
Conshohocken,PA 19428

Diamond Technology Solutions LLC
831 W. North Avenue
Pittsburgh, PA 15233

JONA TIAN ESQUIRE
Co for P • • ,
Thermo Communications Funding, LLC

(P1888243.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA

THERMO COMMUNICATIONS CIVIL DIVISION
FUNDING,LLC,
NO.: G O - V1 -0021o8
Plaintiff,

Defendants.

To: IAQ Technologies LLC
831 W North Ave.
Pittsburgh, PA 15233

NOTICE OF ENTRY OF JUDGMENT

Please take notice that on 2024, a Judgment by

Confession of Judgment, was entered against you in the court and at docket term and number set

forth above.

The amount of the Judgment is $1,074,276.15 plus interest accruing after February 16,

2024 at the default rate, plus attorneys' fees and costs and expenses incurred by Plaintiff.

A copy of the Complaint is enclosed.

Department of Court Records, Allegheny County

(P1888190.11
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA

THERMO COMMUNICATIONS CIVIL DIVISION
FUNDING,LLC,
NO • Cb - 2q - 0 ‘
0-2-10C
Plaintiff,

FOMO WORLDWIDE,INC., p/k/a FOMO
CORP.,SMARTSOLUTION
TECHNOLOGIES,INC.,
SMARTSOLUTION TECHNOLOGIES
L.P., ENERGY INTELLIGENCE r>.) 0
CENTER,LLC,IAQ TECHNOLOGIES
LLC AND DIAMOND TECHNOLOGY
SOLUTIONS LLC, AND VIKRAM
GROVER,

Defendants.

To: Energy Intelligence Center, LLC
831 W North Ave.
Pittsburgh, PA 15233

NOTICE OF ENTRY OF JUDGMENT

Please take notice that on , 2024, a Judgment by

Confession of Judgment, was entered against you in the court and at docket term and number set

forth above.

The amount of the Judgment is $1,074,276,15 plus interest accruing after February 16,

2024 at the default rate, plus attorneys' fees and costs and expenses incurred by Plaintiff.

A copy of the Complaint is enclosed.

Department of Court Records, Allegheny County

(P1888190 1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA

THERMO COMMUNICATIONS CIVIL DIVISION
FUNDING, LLC,
NO.: 6- - CI " 00-2
Plaintiff,

FOMO WORLDWIDE,INC., pficia FOMO
CORP.,SMARTSOLUTION

Z9 833lillg
TECHNOLOGIES,INC., r-
•
SMARTSOLUTION TECHNOLOGIES CV!: C
L.P., ENERGY INTELLIGENCE
CENTER,LLC,IAQ TECHNOLOGIES
LLC AND DIAMOND TECHNOLOGY 0 --'

I Z Z: Wd
SOLUTIONS LLC, AND VIKRAM ;
v)
GROVER, r.
1:1

Defendants. rn

To: SMARTSolution Technologies LP
831 W. North Avenue
Pittsburgh, PA 15233

NOTICE OF ENTRY OF JUDGMENT

Please take notice that on 2024, a Judgment by

Confession of Judgment, was entered against you in the court and at docket term and number set

forth above.

The amount of the Judgment is $1,074,276.15 plus interest accruing after February 16,

2024 at the default rate, plus attorneys' fees and costs and expenses incurred by Plaintiff.

A copy of the Complaint is enclosed.

Department of Court Records, Allegheny County

IP18813190 1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA

THERMO COMMUNICATIONS CIVIL DIVISION
FUNDING,LLC,
NO.: )
C-1 -7 0071o%
Plaintiff,

v.
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FOMO WORLDWIDE, INC., p/k/a FOMO ,
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CORP.,SMARTSOLUTION
TECHNOLOGIES,INC., "
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SMARTSOLUTION TECHNOLOGIES
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CENTER,LLC,IAQ TECHNOLOGIES
LLC AND DIAMOND TECHNOLOGY Nn
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SOLUTIONS LLC, AND VIKRAM 1"
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GROVER, cr)

Defendants.

To: SMARTSolution Technologies, Inc.
831 W.North Avenue
Pittsburgh, PA 15233

NOTICE OF ENTRY OF JUDGMENT

Please take notice that on , 2024, a Judgment by

Confession of Judgment, was entered against you in the court and at docket term and number set

forth above.

The amount of the Judgment is $1,074,276.15 plus interest accruing after February 16,

2024 at the default rate, plus attorneys' fees and costs and expenses incurred by Plaintiff.

A copy of the Complaint is enclosed.

Department of Court Records, Allegheny County

(P18881901)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA

THERMO COMMUNICATIONS CIVIL DIVISION
FUNDING,LLC,
NO.: a t'-7 LI- 60210
Plaintiff,

I Z Z: dN Z9 338 tag'
.
v 1. r.
1:

FOMO WORLDWIDE,INC., p/k/a FOMO 6)'.7.
CORP.,SMARTSOLUTION )• g-
;

TECHNOLOGIES,INC., •-8- c.
0
SMARTSOLUTION TECHNOLOGIES O p- ,
L.P., ENERGY INTELLIGENCE _
C —
CENTER,LLC,IAQ TECHNOLOGIES
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LLC AND DIAMOND TECHNOLOGY 70
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ti)
SOLUTIONS LLC, AND VIKRAM
GROVER,

Defendants.

To: Vikram Grover
831 W North Ave.
Pittsburgh, PA 15233

NOTICE OF ENTRY OF JUDGMENT

Please take notice that on , 2024, a Judgment by

Confession of Judgment, was entered against you in the court and at docket term and number set

forth above.

The amount of the Judgment is $1,074,276.15 plus interest accruing after February 16,

2024 at the default rate, plus attorneys' fees and costs and expenses incurred by Plaintiff.

A copy of the Complaint is enclosed.

Department of Court Records, Allegheny County

(P1888190.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,PENNSYLVANIA

THERMO COMMUNICATIONS CIVIL DIVISION
FUNDING,LLC,
NO.: G-0 -24-007(
Plaintiff,

Defendants.

To: FOMO Worldwide,Inc., p/k/a FOMO Corp.
831 W North Ave.
Pittsburgh, PA 15233

NOTICE OF ENTRY OF JUDGMENT

Please take notice that on , 2024, a Judgment by

Confession of Judgment, was entered against you in the court and at docket term and number set

forth above.

The amount of the Judgment is $1,074,276.15 plus interest accruing after February 16,

2024 at the default rate, plus attorneys' fees and costs and expenses incurred by Plaintiff.

A copy of the Complaint is enclosed.

Department of Court Records, Allegheny County

(P1888190.1)
FILED: NASSAU COUNTY CLERK 04/29/2024 05:56 PM INDEX NO. 607419/2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 04/29/2024

• j Z"'"_
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY.,aIWYLVANIA
CIVIL DIVISION
2024 FEB 26 PH
2: 20
d i ow
o•itru;
i;E,Tcy:o
THERMO COMMUNICATIONS curcH
FUNDING, LLC.,

vs -
CASE NUMBER GD-24-00Z( 0
FOMO WORLDWIDE,INC., p/k/a FOMO
CORP., SMARTSOLUTION

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Exhibit,Appendix: Thermo Communications Funding, Llc v. Vikram Grover

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Exhibit,Appendix: Thermo Communications Funding, Llc v. Vikram Grover

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