⚠️ Material Issues & Legal Liabilities

Overview: The Project Condor asset acquisition presents multiple material legal issues that may render the transaction void or voidable under Delaware law. This section analyzes potential liabilities arising from disclosure deficiencies, vote manipulation, fiduciary breaches, and contested asset ownership.
Core Legal Problem: A Delaware corporation's sale of substantially all assets requires valid stockholder approval under 8 Del. C. §271. If the stockholder vote was procured through undisclosed inducements, material omissions, or vote buying, the transaction may be rescinded, with all assets reverting to original stockholders and potentially exposing parties to liability for securities fraud.

1. Invalid Stockholder Vote Under Delaware Law (8 Del. C. §271)

Delaware General Corporation Law Section 271 requires that the sale of "all or substantially all" of a corporation's assets be approved by a majority of outstanding shares entitled to vote. The Project Condor transaction raises serious questions about whether valid stockholder approval was obtained.

Critical Vote Validity Issues
Delaware Chancery Court Case Pending: C.A. No. 2024-1296-SEM is a books and records action (8 Del. C. §220) seeking documents to establish vote manipulation and breach of fiduciary duty. If successful, this may lead to a derivative or direct action to rescind the transaction.
Legal Consequences of Invalid Vote
Rescission Risk: If the stockholder vote is deemed invalid, the entire transaction may be subject to rescission. This would require:

2. Vote Taint and Inducement Schemes

Delaware law strictly prohibits vote buying and the use of undisclosed inducements to secure stockholder approval. Multiple pieces of evidence suggest a systematic scheme to manipulate the stockholder vote through selective financial incentives.

A. The $800,000 Sravan Puttagunta Inducement Offer
Evidence of Vote Buying: Sravan Puttagunta (44% Common Stock holder) was offered $800,000 in exchange for providing a proxy vote approving the asset sale. Puttagunta REFUSED this offer and documented it.

This offer is significant for several reasons:

Critical Question: Who else was offered money for their vote? This is a central focus of the Delaware §220 books and records demand.
B. Management Employment Inducements

Three members of Solfice management received employment offers from Luminar Technologies as part of the transaction. This created a structural conflict of interest where management's economic incentives were aligned with the buyer rather than with Solfice stockholders.

Name Role at Solfice Stockholdings Inducement Received
Scott Harvey Director/Officer 660,000 Common shares = $0 value Luminar employment + undisclosed compensation
Stefan Safko CEO Unknown Common holdings Luminar employment + undisclosed compensation
Satyanarayan Vakkaleri COO Unknown Common holdings Luminar employment + undisclosed compensation
The Conflict: Scott Harvey held 660,000 shares of Common Stock with a liquidation value of $0, yet voted YES to approve the transaction. His economic incentive was employment with the buyer, NOT maximizing stockholder value. This violates DGCL §144 (Interested Director Transactions).
C. Management Total Compensation (Undisclosed)

The total value of management's compensation packages with Luminar has NEVER been disclosed to stockholders or in any SEC filing. This includes:

Completely Undisclosed Management Compensation: All amounts remain undisclosed despite closing condition requirement in APA §7.2(e)

Stockholders were never informed of the total compensation management would receive from the buyer, making it impossible to evaluate the full cost of the transaction or assess management's conflicts of interest.

3. Disclosure Deficiencies and Material Omissions

Delaware law requires complete and accurate disclosure to stockholders when seeking their approval for a material transaction. The Project Condor stockholder materials contained multiple material omissions that rendered the vote invalid.

What Was NOT Disclosed to Stockholders
Management Compensation

COMPLETELY UNDISCLOSED:

Management Conflicts

Management's financial interests in transaction never disclosed to stockholders

Impossible to assess conflicts of interest without compensation disclosure

Selective Disclosure

Only Scott Harvey and Fabien Chraim (~20% of Common Stock) voted in favor despite receiving $0 in the transaction

No evidence Common stockholders received full APA or compensation schedules

Vote Buying Evidence

$800,000 inducement offer to Puttagunta never disclosed to other stockholders

Unknown how many others received similar offers

Delaware Legal Standard: Complete and Accurate Disclosure

The omission of management's employment contract values and the failure to disclose the $800K vote buying attempt constitute material omissions under Delaware law. A reasonable stockholder would want to know:

Legal Impact: A stockholder vote procured through materially incomplete disclosure is invalid and provides no cleansing effect under Corwin v. KKR Financial Holdings LLC, 125 A.3d 304 (Del. 2015).

4. Fiduciary Duty Breaches

Delaware corporate law imposes fiduciary duties of loyalty and care on directors and officers. When directors have a financial interest in a transaction, they must navigate heightened disclosure obligations and procedural safeguards.

A. Breach of Duty of Loyalty
Self-Dealing Transaction: Management negotiated their own compensation packages while controlling the board that approved the transaction. This creates a classic conflict of interest requiring entire fairness review.

Evidence of loyalty breach:

B. Entire Fairness Standard Applies

When §144's procedural protections are not satisfied (as here, due to lack of disclosure and interested board approval), Delaware courts apply the "entire fairness" standard. Under this standard, defendants must prove both:

C. Self-Dealing and the "Double-Dip" Problem

Management's compensation structure created a "double-dip" scenario that is facially unfair:

Step 1: Management votes to approve sale of company assets for $10.595M
Step 2: Management receives undisclosed compensation/severance from transaction
Step 3: Management immediately joins Luminar with undisclosed employment contracts
Step 4: Investors distributed proceeds (many taking substantial losses)
Result: Management's total compensation remains undisclosed while stockholders took massive losses
D. Failure to Maximize Stockholder Value

There is no evidence that management attempted to:

Revlon Duties: When a Delaware corporation is being sold, directors have enhanced duties under Revlon, Inc. v. MacAndrews & Forbes Holdings, Inc., 506 A.2d 173 (Del. 1986) to seek the best available transaction for stockholders. Management's self-interested conduct suggests they prioritized their own employment over stockholder value.

5. Asset Title Disputes and Ownership Claims

If the underlying stockholder vote and transaction are found to be invalid, Luminar Technologies may not have valid legal title to the Solfice Research intellectual property and software assets.

Equitable Remedies Available
Contested Ownership: Former Solfice stockholders have asserted equitable claims to the Project Condor assets, arguing that Luminar's title is "tainted" by the invalid stockholder vote and fiduciary breaches.

Legal theories supporting contested ownership:

Impact on Future Transactions
Disclosure Obligations: Luminar must disclose the disputed title status to any prospective acquirers. Failure to disclose contested ownership constitutes:

Any sale, transfer, or assignment of Project Condor assets (including through bankruptcy §363 sale) is subject to:

Standing to Challenge Asset Transfers

Multiple parties have standing to challenge any future transfer of Project Condor assets:

Party Basis for Standing
Sravan Puttagunta 44% Common Stock holder; former director; creditor with equitable interest
Anuj Gupta 14.0% Common Stock holder
Jason Creadore 5.3% Common Stock holder

6. SEC Compliance Issues and Regulatory Scrutiny

A. SEC Subpoenas to Luminar Technologies
Reported SEC Activity:
B. Potential Securities Law Violations

Potential 10b-5 violations in the Project Condor transaction:

Important Note: SEC Rule 10b-5 applies to private company transactions when interstate commerce is involved, which is satisfied here through wire transfers, electronic communications, and multi-state parties.
C. Ongoing Disclosure Obligations

Luminar Technologies now faces continuing disclosure obligations regarding:

7. Bankruptcy and Fraudulent Transfer Issues

If Luminar Technologies enters bankruptcy or restructuring, the Project Condor transaction may be subject to scrutiny under U.S. Bankruptcy Code fraudulent transfer provisions.

A. Initial Fraudulent Transfer (2022 Transaction)

Elements potentially satisfied:

B. Bankruptcy Code Section 363 Sale Challenges

If Luminar attempts to sell Project Condor assets in bankruptcy, objections may be filed asserting:

§363(f) - Sale Free and Clear of Interests:
C. Creditor Rights and Objections

Former Solfice stockholders and creditors have preserved rights to:

8. Notice and Preservation Requirements

Multiple parties have been put on notice of the contested transaction and disputed asset ownership.

Parties on Notice
October 31, 2025: Formal notice sent to Luminar counsel regarding tainted asset title
November 1, 2025: Formal notice of disputed ownership sent to Luminar board
November 4, 2025: Notice sent to U.S. Trustee offices regarding anticipated bankruptcy sale
November 9, 2025: Material dispute notice sent regarding Chancery Court docket C.A. No. 2024-1296-SEM
Document Preservation Obligations

Luminar Technologies and related parties are obligated to preserve:

9. Summary of Material Risks

1. Invalid Corporate Vote

Transaction may be void due to insufficient stockholder approval and vote manipulation

2. Vote Buying Scheme

$800K inducement offer evidences systematic vote manipulation

3. Management Self-Dealing

Officers received undisclosed compensation while stockholders received $0 or took massive losses

4. Disclosure Fraud

Material facts concealed from 40%+ of voting stockholders

5. Contested Asset Title

Luminar may not own the IP it claims to have acquired

6. Reported SEC Subpoenas

Subpoenas reportedly issued to Luminar; connection to Project Condor unclear

7. Fiduciary Breaches

Directors violated duties of loyalty and care

8. Fraudulent Transfer

Management received undisclosed benefits as part of transaction

9. Bankruptcy Risk

Future asset sales subject to clawback and rescission claims

10. Securities Fraud

Multiple violations of SEC Rule 10b-5

Pending Litigation: Delaware Court of Chancery Case No. 2024-1296-SEM (Books and Records Action) seeks to uncover the full extent of vote manipulation, undisclosed compensation, and fiduciary breaches. Success in this action may lead to derivative or direct litigation to rescind the transaction and recover damages.
Key Takeaway: The Project Condor transaction presents multiple overlapping legal issues that collectively create substantial risk of rescission, clawback, securities fraud liability, and contested asset ownership. The combination of vote buying, undisclosed management compensation, and fiduciary breaches makes this a high-risk transaction with significant potential for unwinding.