The judgement was passed in favour of Plaintiffs Kyko Global Inc. Confessions of Judgement in Kyko Global Inc vs Madhavi Vuppalapati & Prithvi Info Solutions Ltd

1. PAGE 1 – PLAINTIFFS’ MOTION FOR ISSUANCE OF JUDGMENT
IN AMOUNT AGAINST CERTAIN DEFENDANTS
PURSUANT TO CONFESSIONS OF JUDGMENT
Case No. 2:13-CV-1034-MJP
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SLINDE NELSON STANFORD
601 Union Street, Suite 4400
Seattle, WA 98101
p. 206-237-0020; f. 503.417.4250
The Honorable Marsha J. Pechman
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
KYKO GLOBAL, INC., a Canadian
corporation, and KYKO GLOBAL GMBH, a
Bahamian corporation,
Plaintiffs,
v.
PRITHVI INFORMATION SOLUTIONS,
LTD., a Pennsylvania corporation, PRITHVI
CATALYTIC, INC., a Delaware corporation,
PRITHVI SOLUTIONS, INC., a Delaware
corporation, PRITHVI INFORMATION
SOLUTIONS INTERNATIONAL, LLC, a
Pennsylvania limited liability company,
INALYTIX, INC., a Nevada corporation,
INTERNATIONAL BUSINESS
SOLUTIONS, INC., a North Carolina,
corporation, AVANI INVESTMENTS, INC., a
Delaware corporation, ANANYA CAPITAL
INC., a Delaware corporation, MADHAVI
VUPPALAPATI AND ANANDHAN
JAGARAMAN, husband and wife and the
marital community composed thereof, GURU
PANDYAR AND JANE DOE PANDYAR,
husband and wife and the marital community
composed thereof, and SRINIVAS SISTA
AND JOHN DOE SISTA, husband and wife
and the marital community composed thereof,
DCGS, INC., a Pennsylvania company, EPP,
Case No. 2:13-CV-1034 MJP
PLAINTIFFS’ MOTION FOR
ISSUANCE OF JUDGMENT IN
AMOUNT AGAINST CERTAIN
DEFENDANTS PURSUANT TO
CONFESSIONS OF JUDGMENT
NOTE ON MOTION CALENDAR:
AUGUST 9, 2013
[CLERK’S ACTION REQUIRED]
Case 2:13-cv-01034-MJP Document 41 Filed 08/08/13 Page 1 of 5

2. PAGE 2 – PLAINTIFFS’ MOTION FOR ISSUANCE OF JUDGMENT
IN AMOUNT AGAINST CERTAIN DEFENDANTS
PURSUANT TO CONFESSIONS OF JUDGMENT
Case No. 2:13-CV-1034-MJP
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SLINDE NELSON STANFORD
601 Union Street, Suite 4400
Seattle, WA 98101
p. 206-237-0020; f. 503.417.4250
INC., a Washington corporation, FINANCIAL
OXYGEN, INC., a Washington corporation,
HUAWEI LATIN AMERICAN SOLUTIONS,
INC., a Florida corporation, L3C, INC., a
Washington corporation.
Defendants.
I. INTRODUCTION
Pursuant to Fed. R. Civ. P. 58(b), Plaintiffs seek entry of judgment against the
Defendants, with the exception of Defendants International Business Solutions, Inc., Guru
Pandyar, and Srinivas Sista (who did not sign Confessions of Judgment). Each and every other
named Defendant in this case signed a Confession of Judgment, which has now been filed with
the Court. Defendants have duly executed Confessions of Judgment in the amount of $18
million as required under RCW 4.60.010 et seq. Since the date of the Confessions of Judgment
signed by those Defendants, Plaintiffs have received payments of $161,470 towards the total
amount owed of $18 million. Defendants confessed unconditionally and irrevocably to the
amount of $18 million in the Confessions of Judgment.
Plaintiffs reserve the right to file a subsequent motion with the Court seeking to amend
the judgment for additional accruing interest, costs and attorneys fees, but now seek entry of
immediate judgment for an amount certain against Defendants in the total amount of
$17,838,530 as confessed to by the Defendants under the Washington statutory procedure set
forth under RCW 4.60.010 et seq. and as further outlined below.
II. EVIDENCE RELIED UPON
Defendants Prithvi Information Solutions, Ltd.; Prithvi Information Solutions
International, LLC; Prithvi Catalytic, Inc.; Prithvi Solutions, Inc.; Inalytix, Inc.; Avani
Investments, Inc.; Ananya Capital, Inc.; Madhavi Vuppalapati; DCGS, Inc.; EPP, Inc.; Financial
Case 2:13-cv-01034-MJP Document 41 Filed 08/08/13 Page 2 of 5

3. PAGE 3 – PLAINTIFFS’ MOTION FOR ISSUANCE OF JUDGMENT
IN AMOUNT AGAINST CERTAIN DEFENDANTS
PURSUANT TO CONFESSIONS OF JUDGMENT
Case No. 2:13-CV-1034-MJP
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SLINDE NELSON STANFORD
601 Union Street, Suite 4400
Seattle, WA 98101
p. 206-237-0020; f. 503.417.4250
Oxygen, Inc.; Huawei Latin American Solutions, Inc.; and L3C, Inc. separately executed
Confessions of Judgment on or about July 16-17, 2013, which have now been filed with the
Court.
The Declaration of Kiran Kulkarni filed herewith sets forth the amounts paid to date in
the amount of $161,470.
III. LEGAL ANALYSIS
Confessions of Judgment are defined under Washington law by statute. “On the
confession of the defendant, with the assent of the plaintiff or his or her attorney, judgment may
be given against the defendant in any action before or after answer, for any amount or relief not
exceeding or different from that demanded in the complaint.” RCW 4.60.010. “The confession
and assent thereto shall be in writing and subscribed by the parties making the same, and
acknowledged by each before some officer authorized to take acknowledgments of deeds.”
RCW 4.60.040. “A judgment by confession may be entered without action, either for money due
or to become due, or to secure any person against contingent liability on behalf of the defendant,
or both, in the manner prescribed by this chapter.” RCW 4.60.050. “The statement must be
presented to the superior court or a judge thereof, and if the same be found sufficient, the court or
judge shall indorse thereon an order that judgment be entered by the clerk; whereupon it may be
filed in the office of the clerk, who shall enter a judgment for the amount confessed, with costs.
Execution may be issued and enforced thereon in the same manner as upon judgments in other
cases.” RCW 4.60.070.
Plaintiffs have filed with the Court the Confessions of Judgment against Defendants in
the amount of $18 million executed in the manner prescribed by RCW 4.60.040 and a
declaration of Kiran Kulkarni setting forth the amounts paid to date against the total amount
Case 2:13-cv-01034-MJP Document 41 Filed 08/08/13 Page 3 of 5

4. PAGE 4 – PLAINTIFFS’ MOTION FOR ISSUANCE OF JUDGMENT
IN AMOUNT AGAINST CERTAIN DEFENDANTS
PURSUANT TO CONFESSIONS OF JUDGMENT
Case No. 2:13-CV-1034-MJP
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SLINDE NELSON STANFORD
601 Union Street, Suite 4400
Seattle, WA 98101
p. 206-237-0020; f. 503.417.4250
owed of $18 million. The amount of $18 million has been reduced by payments of just
$161,470. Thus, Plaintiffs hereby ask for entry of judgment against those Defendants in the
amount of $17,838,530.
Pursuant to Fed. R. Civ. P. 58(b)(1), “[S]ubject to Rule 54(b) and unless the court orders
otherwise, the clerk must, without awaiting the court’s direction promptly prepare, sign and enter
the judgment when: …. (B) the court awards only costs or a sum certain.” Rule 58(b)(2)
provides for Court approval of the form of the judgment, which the clerk must promptly enter,
when . . . . (B) the court grants other relief not described in subdivision (b).” Since the judgment
is for an amount certain, the clerk “must” directly enter judgment pursuant to the Confessions of
Judgment as provided under Rule 58(b)(1) for the amount of $17,838,530. However, pursuant
to the presentation requirements of RCW 4.60.070, an Order granting Plaintiff’s Motion for the
Court’s Issuance of Judgment in Amount Certain against Defendants pursuant to Confessions of
Judgment is submitted herewith for the Court’s approval. There is no just cause for delay.
IV. CONCLUSION
Based on the foregoing and the record and file herein, Plaintiffs’ motion should be
granted.
Dated this 8th
day of August, 2013.
SLINDE NELSON STANFORD
By: /s/ Christina Haring-Larson
Christina Haring-Larson, WSBA No. 30121
Of Attorneys for Plaintiffs
Case 2:13-cv-01034-MJP Document 41 Filed 08/08/13 Page 4 of 5

5. PAGE 1 – CERTIFICATE OF SERVICE
Case No. 2:13-CV-1034-MJP
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SLINDE NELSON STANFORD
601 Union Street, Suite 4400
Seattle, WA 98101
p. 206-237-0020; f. 503.417.4250
CERTIFICATE OF SERVICE
I hereby certify that I served the foregoing PLAINTIFFS’ MOTION FOR ISSUANCE
OF JUDGMENT IN AMOUNT AGAINST CERTAIN DEFENDANTS PURSUANT TO
CONFESSIONS OF JUDGMENT on:
Mark D. Kimball
MDK Law Associates
777 108th
Ave NE, Suite 2170
Bellevue, WA 98004-5118
Stellman Keehnel
DLA Piper LLP
701 5th
Ave, Suite 7000
Seattle, WA 98104-7004
by the following indicated method(s):
by faxing full, true, and correct copies thereof to said attorney to the fax number noted
above, which is the last known fax number for said attorney, on the date set forth
below.
by emailing full, true, and correct copies thereof to said attorney to the email address
noted above, which is the last known email address for said attorney, on the date set
forth below.
by notice of electronic filing using the CM/ECF system (LR 100.7(a)(2)).
by causing full, true and correct copies thereof to be mailed to the attorney(s) at the
attorney(s) last-known office address(es) listed above on the date set forth below.
Dated this 8th day of August, 2013.
SLINDE NELSON STANFORD
By: /s/ Christina Haring-Larson ____
Christina Haring-Larson, WSBA No. 30121
Of Attorneys for Plaintiffs
Case 2:13-cv-01034-MJP Document 41 Filed 08/08/13 Page 5 of 5