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No. 180-1

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 180-1 (N.D.Okla. Nov. 23, 2022)
Each carrier providing any such insurance, or portion thereof, shall be licensed to do business in the jurisdiction where the Dealer is located, and unless otherwise agreed by GAL in writing, shall have a claims paying ability rating by Best’s Guide of not less than “A Minus, VII” or better.
Dealer shall indemnify and hold GAL harmless from any and all claims, liabilities, losses, damages or expenses (including reasonable attorneys, fees and costs) arising directly or indirectly from, as a result of, or in connection with, the Dealer’s operation of the Dealer’s business.
GAL shall indemnify and hold Dealer harmless from any and all claims, liabilities, losses, damages or expenses (including reasonable attorneys, fees and costs) arising directly or indirectly from, as a result of, or in connection with, GAL’s operation of GAL’s business.
In the event of any litigation involving this Agreement, all such matters will be resolved exclusively in the state or federal courts seated in Tulsa County, Oklahoma, and the Dealer consents to such venue and jurisdiction.
3.Use a safe edge file to remove material from the mag well in the tight *If the buffer detent roll pin does not line up properly when hammed in to the lower, try inserting it from the opposite side to remedy the problem.
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No. 179-1

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179-1 (N.D.Okla. Nov. 23, 2022)
I recently bought one of your lower receivers and so far I'm liking it but I need to modify it for some sling points.
I understand any modification like this wouldn't be covered under your warranty but I'm not planning on doing anything crazy and this is for personal use only.
- Kenneth King PLEASE NOTE: If you purchased a firearm, such as a lower receiver, rifle or handgun, it's your responsibility to have your local Federal Firearms Licensed dealer forward to us a copy of their FFL.
I recently bought one of your lower receivers and so far I'm liking it but I need to modify it for some sling points.
I understand any modification like this wouldn't be covered under your warranty but I'm not planning on doing anything crazy and this is for personal use only.
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No. 179-5

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179-5 (N.D.Okla. Nov. 23, 2022)
Phone Number: 3132656972 I recently purchased a lower receiver from you.
There is a significant gap between the lower and upper (all other parts move well, I’m waiting on a gas block so I can’t do a full function test).
Case 4:20-cv-00341-CVE-SH Document 179-5 Filed in USDC ND/OK on 11/23/22 Page 3 of 3 Mark PLEASE NOTE: If you purchased a firearm, such as a lower receiver, rifle or handgun, it's your responsibility to have your local Federal Firearms Licensed dealer forward to us a copy of their FFL.
Please contact your dealer and have them fax or email a copy of their FFL.
Launch your own store for free with Big Commerce.
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No. 178-5

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 178-5 (N.D.Okla. Nov. 23, 2022)
Produce documents concerning any money expended or invested by GWACS Defense, Inc. for developing, maintaining, and/or protecting your alleged trade secrets during the relevant period.
RESPONSE TO REQUEST NO 66: Armory is not in possession, custody or control of any documents which relate to money expended or invested by GWACS Defense, Inc. for developing, maintaining, and/or protecting Armory’s trade secrets during the relevant period.
Produce documents concerning money expended or invested by Armory for developing, maintaining, and/or protecting your alleged trade secrets during the relevant period.
Produce documents concerning money expended or invested by each of Armory’s owners for developing, maintaining, and/or protecting your alleged trade secrets during the relevant period.
Produce all your communications in Native Format with Clayton Woodruff concerning your “trade secrets” referenced in Paragraphs 59-67 of the Complaint (Dkt. 2) or “proprietary information” identified in your Response to Interrogatory No. 8 during the relevant period.
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No. 178-3

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 178-3 (N.D.Okla. Nov. 23, 2022)
This letter is in response to the October 7, 2021 deposition notice directed to Brownells, Inc. by your client, GWACS Armory, LLC (the “Notice”).
Then, at our October 21, 2021 discovery conference, GWACS Armory, LLC (“Armory”) agreed to amend its deposition Notice topics pursuant to the objections raised by Brownells.
Thus, this topic seeks to obtain discovery regarding information that is both (1) irrelevant to any party's claim or defense, and (2) disproportionate to the needs of the case.
Thus, this topic seeks to obtain discovery regarding information that is both (1) irrelevant to any party's claim or defense, and (2) disproportionate to the needs of the case.
Thus, this topic seeks to obtain discovery regarding information that is both (1) irrelevant to any party's claim or defense, and (2) disproportionate to the needs of the case.
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No. 179-3

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 179-3 (N.D.Okla. Nov. 23, 2022)
Case 4:20-cv-00341-CVE-SH Document 179-3 Filed in USDC ND/OK on 11/23/22 Page 4 of 14 Company Name: Phone Number: 431510498 My sister is very short, only an 11 inch LOP.
We understand this would involve a fair degree of craftsmanship, with hacksaw, file, drill, glue and screws.
Case 4:20-cv-00341-CVE-SH Document 179-3 Filed in USDC ND/OK on 11/23/22 Page 8 of 14 A user has submitted the contact form on your store.
Suffice to say, our interaction provided me with sufficient knowledge to safely modify one of their AR15 lowers, due to my gained understanding of how the receivers were constructed.
I know, for example, that the receiver only needs 1.5 inches of material after the buffer tube to support 5.56mm ammunition, and that there's an internal 'firewall' at that exact measurement.
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No. 178-1

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 178-1 (N.D.Okla. Nov. 23, 2022)
"Plaintiff," “Armory,” "you" or "your" means GWACS ARMORY, LLC the plaintiff in the above-captioned action, its subsidiaries, divisions, predecessor and successor companies, affiliates, parents, any partnership or joint venture to which it may be a party, and/or each of its employees, agents, officers, directors, representatives, consultants, accountants, and attorneys, including any person who served in any such capacity at any time during the relevant time period specified herein.
“Complaint” as used herein, or its plural or any synonym thereof, is intended to and shall mean the GWACS ARMORY, LLC’s Complaint [ECF No. 2] on file in the Northern District of Oklahoma Case No. 20-cv-0341-CVE-SH.
“ATF” as used herein, or its plural or any synonym thereof, is intended to and shall mean the Bureau of Alcohol, Tobacco, Firearms and Explosives federal agency including but not limited to the Tulsa Satellite Office; Oklahoma City IO Field Office; and any agent, inspector, Case 4:20-cv-00341-CVE-SH Document 178-1 Filed in USDC ND/OK on 11/23/22 Page 8 of 15 employee, director, examiner, and/or Industry Operations Investigators (IOIs) associated with the same.
Produce all documents evidencing your disclosure of proprietary information, as defined in the NDA, to Russell Phagan, SST, KEA, Brownells, and InRangeTV.
Produce all bank statements for each of the owners of Armory, including Jud Gudgel, Reed Oppenheimer and Shel Jones during the relevant period.
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No. 178-6

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 178-6 (N.D.Okla. Nov. 23, 2022)
Dear Tadd, We were just apprised that your client withheld relevant documents in discovery.
As shown in first email, King requested an internal photo of the MKII lower receiver from Armory on May 14, 2018.
Notably, the photo disclosed the following details pertaining to the MKII: • Internal rib structures and dimensions of the MKII with a ruler showing dimensional authentication; • The design and location of the mold runner (i.e., where the molten plastic flows into the mold); the mold gate location and angle; • The worn state of the mold exhibited by the flashing occurring in the finished product; 10001 Park Run Drive • Las Vegas, NV 89145 • Phone 702.382.0711 • Fax 702.382.5816 • maclaw.com
• The location of the mold ejector pints as shown by the rounded circles on the inside of the plastic product; and • Other details pertaining to the MKII.
Armory responded to King as follows: “We are and I have passed this on to our engineer for consideration!” Id. (emphasis added).
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No. 10

Document KE ARMS LLC v. GWACS Armory LLC et al , 4:21-cv-00107, No. 10 (N.D.Okla. Aug. 31, 2020)

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No. 8

Document KE ARMS LLC v. GWACS Armory LLC et al , 4:21-cv-00107, No. 8 (N.D.Okla. Aug. 19, 2020)

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No. 2

Document KE ARMS LLC v. GWACS Armory LLC et al , 4:21-cv-00107, No. 2 (N.D.Okla. Aug. 18, 2020)

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No. 1

Document KE ARMS LLC v. GWACS Armory LLC et al , 4:21-cv-00107, No. 1 (N.D.Okla. Aug. 18, 2020)

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No. 4

Document KE ARMS LLC v. GWACS Armory LLC et al , 4:21-cv-00107, No. 4 (N.D.Okla. Aug. 18, 2020)

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No. 167-4

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 167-4 (N.D.Okla. Sep. 16, 2022)

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No. 167-2

Document GWACS Armory, LLC et al v. KE Arms, LLC et al, 4:20-cv-00341, No. 167-2 (N.D.Okla. Sep. 16, 2022)

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