Summary

HBTPower Limited ("HBTPower"), by and through its undersigned counsel and pursuant to the Federal Arbitration Act, 9 U.S.C. § 1 et seq. ("FAA"), hereby respectfully submits the following Petition to Confirm Final Arbitration Award ("Petition") against Defendant Mohawk Energy, LLC. In support of same, HBTPower submits the accompanying Declaration and states as follows:

INTRODUCTION

1. On April 13, 2026, a Judicial Arbitration and Mediation Services, Inc. ("JAMS") arbitrator entered a final award ("Final Award") in favor of HBTPower against Defendant Mohawk Energy, LLC ("Mohawk"). This Court should confirm the Final Award pursuant to 9 U.S.C. § 9.

2. The purpose of the FAA is to promote the efficient and inexpensive resolution of disputes. The presumption under the FAA is that arbitration awards will be confirmed under 9 U.S.C. § 9. Dawahare v. Spencer, 210 F.3d 666, 669 (6th Cir. 2000). This presumption may only be overcome if one or more of four limited statutory exceptions are present. See 9 U.S.C. § 10. In fact, an arbitration award will not be vacated simply because a court disagrees with the arbitrator's findings, or even where the arbitrator has committed a serious error. All that a court must determine in reviewing the decision of an arbitrator is whether the arbitrator did the job he or she was told to do - not whether he or she did it well or correctly or reasonably.

3. No grounds for vacatur exist in this case and none of the limited statutory exceptions to confirmation of an arbitration award is present. Mohawk was afforded ample opportunity throughout the arbitration to present its case. Mohawk also did not seek any correction of the Final Award within the time permitted under the JAMS Streamlined Arbitration Rules.

4. Accordingly, HBTPower is entitled to entry of a judgment confirming the Final Award, and further requests that the Court enter a permanent injunction consistent with the Arbitrator's recommendations, order that Mohawk return HBTPower's property, and such other relief as outlined below.

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The Arbitrator issued the Interim Award on December 16, 2025, and ordered further briefing on attorneys' fees, costs, prejudgment interest, punitive damages, and the scope of injunctive relief.

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On April 13, 2026, the Arbitrator issued the Final Award, which was duly rendered in accordance with the JAMS Streamlined Arbitration Rules and Procedures. (Id. ¶ 14.) In the Final Award, the Arbitrator concluded that HBTPower met its burden of proof by both a preponderance of the evidence and clear and convincing evidence that Mohawk breached the License Agreement. (Id. ¶ 15.) As to HBTPower's conversion claim, the Arbitrator found that after ousting HBTPower from the Premises, Mohawk unlawfully retained HBTPower's S19-Series mining machines and sold HBTPower's 2,059 M-Series mining machines to third parties without HBTPower's authorization, thereby converting HBTPower's property. (Id.)

19. The Arbitrator awarded HBTPower: (a) $46,700,000.00 in compensatory damages as to the breach of contract claim; (b) $600,000.00 in damages as to the conversion claim; and (c) $128,125.00 in prejudgment interest on the conversion damages at the Kentucky statutory rate of 6% compounded annually under Ky. Rev. Stat. Ann. § 360.040, calculated from the date of the conversion (November 30, 2023) through February 2026. (Id. ¶ 16.)

20. The License Agreement expressly provides that "the arbitrator shall award to the prevailing party, if any, the costs and attorneys' fees reasonably incurred by the prevailing party in connection with the arbitration." (Id. at Ex. 1-A, § 20.) Based on that, the Arbitrator further awarded HBTPower $3,531,320.07 in attorneys' fees, finding that HBTPower was the prevailing party and that the fees incurred by HBTPower's counsel at DLA Piper LLP (US) and Stoll Keenon Ogden PLLC were reasonable. (Id. ¶ 16.)

21. The Arbitrator also awarded HBTPower $559,008.23 in costs, including JAMS fees, e-discovery fees, expert fees in arbitration, court reporter fees, interpretation services, and reproduction charges. (Id..)

22. The total Award to HBTPower is $51,518,453.30. (Id.)

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Also included in this document:

• JAMS - Demand for Arbitration
• JAMS - Defendant Mohawk Energys Response to Demand for Arbitration and Request to Hold Matter in Abeyance