Objection

Listing description

What the seller provided

Objection Case 26-62642-pwb Doc 197 Filed 10/22/26 Entered 10/22/26 16:05:19 Desc Main Document Page 1 of 9 IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION In re: ) ) STORJ LABS, INC., Case 26-62642-pwb Doc 197 Filed 10/22/26 Entered 10/22/26 16:05:19 Desc Main Document Page 1 of 9 IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION In re: ) ) STORJ LABS, INC., ) Case No. 26-62642-PWB ) Debtor. ) Chapter 11 ) OBJECTION OF MICHAEL WARD AND ROBERT LAMB TO DEBTOR’S EXPEDITED MOTION FOR ENTRY OF AN ORDER (A) ESTABLISHING BIDDING AND SALE PROCEDURES, (B) SCHEDULING FINAL DEADLINE TO SUBMIT BIDS, AND (C) APPROVING THE FORM AND MANNER OF NOTICE THEREOF Michael Ward and Robert Lamb (together, the “Collateral Agents”), in their capacity as Collateral Agents for certain entities with liens on shares of the Debtor (the “Pledgees”), file this Objection to Debtor’s Expedited Motion for Entry of an Order (A) Establishing Bidding and Sale Procedures, (B) Scheduling Final Deadline to Submit Bids, and (C) Approving the Form and Manner of Notice Thereof [ECF No. 189] (the “Sale Motion”). BACKGROUND 1. On December 17, 2024, the Pledgees1 entered into a Stock Purchase Agreement (the “SPA”) with Inveniam Capital Partners, Inc., (“Inveniam”), the parent company and proposed DIP Lender of the Debtor, Storj Labs, Inc. (the “Debtor”), whereby the Pledgees agreed to sell their shares of Hedgehog Invest Limited (the “Shares”) to Inveniam. In partial consideration for the Pledgees’ sale of the Shares to Inveniam, on December 17, 2024, Inveniam executed a promissory note (the “Note”) in favor of the Pledgees in the aggregate principal amount of $9,609,265.57. The balance now exceeds $11,000,000.00. 1 The Pledgees referred to herein include the Collateral Agents, as well as the Adam and Stephanie Howarth Revocable Trust, Bharath Srinivaas Rajagopolan, Four Peaks LLC, Khalid Mohamed Murgian, Leila Govi, Pembroke US Investments LLC, Randolph Investments Ltd, Seedrs Nominees Limited of Stylus Building, Boutique Capital Pty Ltd ATF Tectonic Digital Asset Opportunities Fund, and Watermill Ltd. Case 26-62642-pwb Doc 197 Filed 10/22/26 Entered 10/22/26 16:05:19 Desc Main Document Page 2 of 9 2. Following certain defaults by Inveniam under the Note, in May 2026, Inveniam and the Collateral Agents, on behalf of the Pledgees, executed (i) a Forbearance Agreement (the “Forbearance Agreement”), whereunder the Pledgees agreed to forbear from exercising their rights and remedies under the Note and SPA so long as certain conditions and obligations were satisfied by Iveniam, and (ii) a Security Agreement (the “Security Agreement”) in favor of the Collateral Agents, for themselves and on behalf of the Pledgees, pursuant to which Inveniam granted the Collateral Agents, on behalf of the Pledgees, a security interest in, inter alia, all equity interests in the Debtor and in all assets of the Debtor. 3. Inveniam has defaulted under the Forbearance Agreement by failing to make payments when due under the Forbearance Agreement. 4. On July 26, 2026, the Debtor commenced a chapter 11 bankruptcy case (the “Bankruptcy Case”) in the Bankruptcy Court for the Northern District of West Virginia. 5. By order dated September 18, 2026 [ECF No. 168], the Bankruptcy Court for the Northern District of West Virginia found that venue in the Northern District of West Virginia was improper and transferred the bankruptcy case to the Bankruptcy Court for the Northern District of Georgia. 6. On October 5, 2026, the Debtor filed the Sale Motion. 7. In the Sale Motion, the Debtor requests approval of bidding procedures and authorization of the sale or sales (the “Sale Transaction”) of the (i) the intellectual property, brand, digital properties, commercial contracts, inbound licenses, cloud infrastructure, books and records, marketing assets, prepaid expenses, deposits, and advance payments, and goodwill related to the

Record details

Sale date

Nov 15, 2026

Case #

26-62642

Court

United States Bankruptcy Court, N.D. Georgia

Official document

courtlistener.com/docket/74825726/197/storj-labs-inc/ ↗

Filing (PDF)

storage.courtlistener.com/recap/gov.uscourts.ganb.1305606/gov.uscourts.ganb.1305606.197.0.pdf ↗

Docket

courtlistener.com/docket/74825726/storj-labs-inc/ ↗

Attorneys

Alan Hinderleider, Shari Lynne Collias, Gregory D. Ellis, Christopher R. Arthur, Bruce Michael Jacobs

Case name

Storj Labs Inc.

Chapter

Chapter 11

Document description

Objection

Document number

197

Filed date

Oct 22, 2026

Judge

Paul W. Bonapfel

Law firms

Office of the United States Trustee, 362 Richard B Russell Federal Building; Lamberth Cifelli Ellis & Nason PA; Spilman Thomas & Battle; DOJ-Ust; Bruce Michael Jacobs

Page count

9

Parties

United States Trustee, Storj Labs Inc.

Trustee

Nistendirk, Robert L