Decentral Life Inc (WDLF)

[Anvil]

circa 4/19/24

Beyond these significant potential prejudices, an additional circumstance increases the
need for discovery now. While Defendants proclaim that there are no “strategic transactions”
underway at the company, Motion at 4, Defendants have recently engaged in significant changes
in relation to their securities’ registration status, which will dramatically change Defendants’ reporting and record-keeping obligations. Indeed, on March 29, 2024, Defendant Decentral filed a
Form 15 with the SEC, within which it disclosed it was deregistering its common stock (which
Plaintiff was once an investor in). As a result of this, Decentral will no longer be bound by a number of public company regulations, and will no longer be required to file financial reports with
the SEC. Such significant changes in Decentral’s securities and reporting obligations raise the
specter of underlying changes at the company in terms of its ownership and continued operations
that could affect the availability of witnesses, documents, and other issues. Prompt discovery is
the best way to ensure Plaintiff may prosecute his case without prejudice.