The notice was issued against Yash Thakur alias Arvind Srivastava and Pardeep Bakshi on Sunday, a police official said.
Abhijeet Bomble, a director of one of Raj Kundra's firm, was arrested by the Mumbai police's crime branch.
Raj Kundra and his associate Ryan Thorpe were arrested by the Mumbai Crime Branch on July 19, and are presently in judicial custody.
Shilpa Shetty stated that her husband Raj Kundra is innocent and that it is London-based Pradeep Bakshi who was involved with the Hotshot app and its functioning.
Earlier in a video clip, the model had claimed that Raj Kundra offered her a role in a web series and allegedly asked to give an audition in the nude.
As per section 41A, the police may, in cases where arrest is not warranted, issue summons to the accused person and record his or her statement.