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COTES AI, INC.

COMPREHENSIVE LEGAL DISCLOSURES & TERMS OF USE

IMPORTANT LEGAL NOTICE

PLEASE READ THESE DISCLOSURES CAREFULLY BEFORE USING OUR SERVICES. BY ACCESSING OR USING COTES AI'S SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

1. NOT INVESTMENT OR TRADING ADVICE

CRITICAL DISCLAIMER: THE INFORMATION, DATA, ANALYSES, SIGNALS, AND SCREENING RESULTS PROVIDED BY COTES AI, INC. ("COTES AI," "WE," "US," OR "OUR") ARE FOR INFORMATIONAL AND EDUCATIONAL PURPOSES ONLY AND DO NOT CONSTITUTE:

  • Investment advice or recommendations
  • Trading advice regarding any commodity interest, futures contract, option, event contract, or binary/prediction-market contract
  • Solicitations to buy, sell, or hold any security, commodity interest, or event contract
  • Personal financial advice
  • Tax, legal, or accounting advice
  • Guarantees or predictions of future performance
  • Fiduciary communications of any kind

Our proprietary spectral analysis, frequency domain indicators, and directional signals are technical tools that identify historical patterns and mathematical relationships in market data. These patterns, indicators, and signals represent historical and statistical observations only and are not predictions of future market movements. A signal indicating a directional reading (e.g., "up" or "down") is an impersonal, generally disseminated data point and is not a recommendation that any particular person take any particular action.

2. PUBLISHER'S EXCLUSION STATUS (SEC AND CFTC)

Cotes AI, Inc. operates exclusively as a publisher of impersonal, generally disseminated market-related information and does not provide individualized advice. Our publisher status is grounded in two parallel regulatory frameworks:

A. Securities — Investment Advisers Act of 1940 (SEC)

Cotes AI operates under the "publisher's exclusion" from the definition of "investment adviser" pursuant to Section 202(a)(11)(D) of the Investment Advisers Act of 1940 (the "Advisers Act"), as interpreted by the United States Supreme Court in Lowe v. Securities and Exchange Commission, 472 U.S. 181 (1985).

Cotes AI is NOT registered as an investment adviser with the Securities and Exchange Commission (SEC) or any state securities regulatory authority, and is not required to register based on our status as a publisher.

B. Commodity Interests & Event Contracts — Commodity Exchange Act (CFTC)

To the extent any of our signals or analyses concern commodity interests, futures contracts, options, or CFTC-regulated event/binary contracts (including contracts traded on designated contract markets such as prediction-market exchanges), Cotes AI operates as a publisher under the "commodity trading advisor" ("CTA") publisher exclusion set forth in Section 1a(12)(B)(iv) of the Commodity Exchange Act (the "CEA"), 7 U.S.C. § 1a(12)(B)(iv), which excludes from the definition of CTA the publisher or producer of any print or electronic data of general and regular dissemination.

In addition, and to the extent applicable, Cotes AI relies on the exemption from CTA registration under CFTC Rule 4.14(a)(9), 17 CFR § 4.14(a)(9), which is available to persons who provide standardized advice through media such as websites, newsletters, and non-customized software, and who do not (i) direct client accounts or (ii) provide commodity trading advice based on or tailored to the commodity interest positions, cash-market positions, or other circumstances or characteristics of any particular client.

Cotes AI is NOT registered as a commodity trading advisor, commodity pool operator, futures commission merchant, introducing broker, or in any other capacity with the CFTC or the National Futures Association (NFA), and is not required to register based on our status as a publisher.

C. Common Conditions of Our Publisher Status

Under both frameworks, We:

  • Provide identical information to all subscribers without customization
  • Do not tailor our analyses, signals, or screening to any individual's financial situation, positions, or circumstances
  • Maintain arms-length relationships with all subscribers
  • Do not provide personalized investment or trading strategies
  • Have no knowledge of your individual financial circumstances
  • Do not direct, manage, or monitor your accounts, positions, trades, or portfolio
  • Do not accept discretionary authority over any account

3. NO FIDUCIARY OR ADVISORY RELATIONSHIP

NO FIDUCIARY, ADVISORY, OR BROKERAGE RELATIONSHIP EXISTS OR WILL BE CREATED BETWEEN COTES AI AND YOU.

We do not:

  • Act as your investment adviser, commodity trading advisor, financial advisor, or broker
  • Owe you any fiduciary duties
  • Have any obligation to act in your best interest
  • Consider your individual suitability for any investment or transaction
  • Provide ongoing investment or trading monitoring or alerts tailored to your positions
  • Accept, hold, route, or execute any orders, funds, or accounts on your behalf
  • Accept discretionary authority over any accounts

Your subscription is purely for access to our technical analysis tools, data, and impersonal signals. You maintain complete independence and sole responsibility for all investment and trading decisions, which you execute (if at all) through your own independently chosen brokerage or exchange accounts.

4. EXPERIMENTAL TECHNOLOGY NOTICE

IMPORTANT: Our spectral analysis, frequency domain indicators, and directional signals represent experimental, novel technical analysis methodologies.

These indicators and signals:

  • Are based on proprietary mathematical models and algorithms
  • Have not been independently verified by any regulatory authority
  • May produce results that differ significantly from traditional technical analysis
  • Should not be relied upon as the sole basis for any investment or trading decision
  • May be difficult to understand without advanced mathematical knowledge
  • Are subject to modification as we refine our methodologies

BY USING OUR SERVICE, YOU ACKNOWLEDGE THE EXPERIMENTAL NATURE OF OUR TECHNOLOGY.

5. RISK DISCLOSURE

TRADING AND INVESTING IN SECURITIES, COMMODITY INTERESTS, FUTURES, OPTIONS, AND EVENT/BINARY CONTRACTS INVOLVES SUBSTANTIAL RISK OF LOSS THAT YOU MUST BE PREPARED TO BEAR. ALL TRADING AND INVESTING CARRIES RISK, AND PAST PERFORMANCE DOES NOT GUARANTEE FUTURE RESULTS.

General Risks Include:

  • You may lose some or all of your invested or committed capital
  • Technical analysis patterns and signals can and do fail
  • Market conditions can change rapidly, rendering any analysis obsolete
  • Spectral patterns and signals that worked historically may not work in the future
  • External events can override any technical patterns
  • Frequency domain analysis is unproven in live market conditions
  • False signals are common in all forms of technical analysis
  • High-frequency patterns may be particularly susceptible to market noise

Event / Binary / Prediction-Market Contract Risks (Specific):

  • Event and binary contracts are typically all-or-nothing instruments: a contract may settle at its maximum value or expire entirely worthless
  • You can lose 100% of the amount paid for a position
  • Short-duration contracts (e.g., intraday or sub-hourly) are especially sensitive to noise, timing, fees, and slippage
  • Exchange fees and the bid/ask spread can materially erode or eliminate any theoretical edge
  • Liquidity may be limited, and you may be unable to enter or exit at expected prices
  • These markets are relatively new and may be subject to evolving rules, halts, or regulatory change

Pattern Recognition Limitations:

  • Historical patterns do not guarantee future occurrences
  • Our algorithms may identify patterns that are coincidental, not causal
  • Market structure changes can invalidate previously reliable patterns
  • Backtested and hypothetical results do not ensure future performance and have inherent limitations

6. YOUR RESPONSIBILITIES

By subscribing to Cotes AI, you acknowledge and agree that:

  1. You are solely responsible for all investment and trading decisions
  2. You will conduct your own research and due diligence
  3. You will consult with qualified professionals as appropriate
  4. You understand the experimental nature of spectral analysis and signals
  5. You will not rely exclusively on our pattern recognition results or signals
  6. You have the financial ability to bear total loss
  7. You will maintain realistic expectations about outcomes
  8. You accept all risks associated with securities, commodity interest, and event/binary contract trading
  9. You will execute any trades solely through your own independently chosen and maintained brokerage or exchange accounts, for which Cotes AI bears no responsibility

7. REQUIRED CONSULTATION WITH PROFESSIONALS

WE STRONGLY RECOMMEND THAT YOU:

  • Consult with a registered investment adviser and/or a registered commodity trading advisor before making any investment or trading decision
  • Speak with a qualified financial planner about your specific situation
  • Consult tax professionals regarding tax implications
  • Seek legal counsel for legal questions
  • Never trade or invest more than you can afford to lose completely

8. INTELLECTUAL PROPERTY & RESTRICTIONS

Proprietary Technology:

All spectral analysis algorithms, frequency domain indicators, signal-generation systems, screening methodologies, and pattern recognition systems are proprietary to Cotes AI and protected by trade secret, copyright, and other intellectual property laws.

You May Not:

  • Reverse engineer our algorithms, indicators, or signals
  • Redistribute, resell, republish, or relay our data, signals, or analyses
  • Create derivative works based on our methodologies
  • Share your subscription access or signal feed with others
  • Use our data or signals for any unlawful purposes
  • Claim our analyses or signals as your own work

9. INDEMNIFICATION & LIABILITY LIMITATION

Indemnification:

You agree to indemnify, defend, and hold harmless Cotes AI, Inc., its officers, directors, employees, agents, licensors, and suppliers from and against all losses, expenses, damages, and costs, including reasonable attorneys' fees, resulting from:

  • Your use of our services
  • Your investment and trading decisions
  • Your violation of these terms
  • Your violation of any rights of another

Limitation of Liability:

IN NO EVENT SHALL COTES AI BE LIABLE FOR ANY:

  • Investment or trading losses
  • Lost profits or opportunities
  • Indirect, incidental, or consequential damages
  • Damages exceeding the subscription fees paid

10. NO WARRANTIES

OUR SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO:

  • Accuracy or completeness of data or signals
  • Reliability of pattern recognition
  • Profitability of identified patterns or signals
  • Fitness for any particular purpose
  • Non-infringement of third-party rights

11. REGULATORY COMPLIANCE

Market Manipulation:

You agree not to use our services for market manipulation, insider trading, or any other unlawful purpose under the federal securities laws, the Commodity Exchange Act, the rules of the SEC, CFTC, or any exchange, or any other applicable law.

International Users:

Our services are designed for U.S. markets and may not be suitable or available in all jurisdictions. You are responsible for compliance with local laws.

Regulatory Changes:

We reserve the right to modify our services to comply with changing regulations under either the securities or commodities regulatory frameworks.

12. DATA ACCURACY & SOURCES

While we strive for accuracy:

  • Market data may contain errors or delays
  • Technical calculations and signals depend on data quality
  • We do not guarantee real-time data
  • Historical data may be revised
  • Corporate actions, contract settlements, or exchange events may affect accuracy

13. SUBSCRIPTION TERMS

Access:

  • Subscription provides access to tools, data, and signals only
  • No refunds for market or trading losses
  • We may modify or discontinue features
  • Terminated accounts lose all access immediately

Prohibited Uses:

  • Commercial redistribution or relaying of signals
  • Automated scraping or downloading
  • Sharing login credentials or signal access
  • Circumventing access controls

14. DISPUTE RESOLUTION

Arbitration Agreement:

Any disputes shall be resolved through binding arbitration under JAMS rules, not through court litigation.

Class Action Waiver:

You waive any right to bring claims as part of a class action.

Governing Law:

These terms are governed by Delaware law.

15. COMMUNICATIONS

Electronic Communications:

You consent to receive all communications electronically.

Customer Support Limitations:

Our support team cannot and will not:

  • Provide investment or trading advice
  • Interpret patterns or signals for specific trades
  • Recommend securities, commodity interests, or event contracts
  • Discuss individual portfolios or positions

16. MODIFICATIONS

We reserve the right to modify these terms at any time. Continued use constitutes acceptance of modified terms.

17. SEVERABILITY

If any provision is deemed invalid, the remaining provisions continue in full force.

18. ENTIRE AGREEMENT

These disclosures, along with our Privacy Policy and Terms of Service, constitute the entire agreement between you and Cotes AI.


FINAL ACKNOWLEDGMENT

BY CLICKING "I AGREE" OR ACCESSING OUR SERVICES, YOU ACKNOWLEDGE THAT:

  1. ✅ Cotes AI is NOT an investment adviser and NOT a commodity trading advisor
  2. ✅ We provide impersonal technical data, analysis, and signals — NOT investment or trading advice
  3. ✅ NO fiduciary, advisory, or brokerage relationship exists between us
  4. ✅ Our spectral indicators and signals are EXPERIMENTAL
  5. ✅ You are SOLELY responsible for all investment and trading decisions
  6. ✅ You execute any trades through YOUR OWN brokerage/exchange accounts
  7. ✅ You understand ALL risks, including total loss on event/binary contracts
  8. ✅ You WILL consult appropriate professionals
  9. ✅ You WILL NOT hold Cotes AI liable for losses

CONTACT INFORMATION

Cotes AI, Inc. 16192 Coastal Hwy Lewes, DE 19958 Email: legal@cotes.ai Website: www.cotes.ai

For investment advice tailored to your individual needs, please consult a registered investment adviser or registered commodity trading advisor.

Document Version: 2.0 Effective Date: June 7, 2026 Last Updated: June 7, 2026

Cotes AI, Inc. is a Delaware corporation operating as a publisher of impersonal technical analysis information under the publisher's exclusion of Section 202(a)(11)(D) of the Investment Advisers Act of 1940 and the commodity trading advisor publisher exclusion of Section 1a(12)(B)(iv) of the Commodity Exchange Act (7 U.S.C. § 1a(12)(B)(iv)), and, to the extent applicable, the exemption under CFTC Rule 4.14(a)(9) (17 CFR § 4.14(a)(9)).

Questions about these policies? Email info@cotes.ai.

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