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getraxx.com Copy Draft Cluster — Attorney Review Package

Status: research-only draft. This document does NOT constitute legal or tax advice. Before publishing any copy derived from this document, consult a consumer-protection attorney with FTC Section 5 and PA UTPCPL experience, AND a securities attorney with Investment Advisers Act experience. Matthew Crosby (IP/trademark) is NOT sufficient for this material. Last updated: 2026-05-29. Sources as of that date — verify freshness.

How to use this document

This package stages copy options for seven open tickets — all currently blocked on attorney sign-off. The attorney's job is to pick an option (A, B, or C) for each ticket, or propose Option D. Once the attorney records a decision on each ticket, the implementing developer can ship the corresponding copy without further review.

Each section includes: 1. Ticket reference + current state 2. Proposed copy options 3. Legal framing rationale 4. Specific questions for the attorney 5. Ready-to-implement note (file + location)

Attorney type required: - Consumer-protection attorney with FTC Section 5 AND PA UTPCPL experience - Recommended firms: Duane Morris LLP (Philadelphia), Ballard Spahr LLP (Philadelphia), or Eckert Seamans Cherin & Mellott LLC - For backtest and IA-Act framing (#2862): a securities attorney with Investment Advisers Act and SEC Marketing Rule experience; same attorney may handle both if dual-qualified

Estimated attorney time: 30–60 minutes for a focused copy-review pass using this pre-staged brief; 2–3 hours for a written opinion letter with citations.

Section 1 — #2855: Epic Executive Summary (attorney-meeting one-pager)

Ticket reference + current state

2855 is the parent epic for the dual-audience messaging refresh. Six sub-cards (#2856,

2859, #2862, #2863, #2864, #2865) are each blocked on attorney clearance. All six must

be cleared before the copy cluster ships.

What getraxx.com shows today (as of 2026-05-29): - Hero h1: "Stack raxx. No guessing." (via HeroHeadlineAB.jsx) - Hero sub-headline: "You already decided the structure. Entry, credit, exit — defined before the trade. Raxx holds you to it." - PillarsSection: three pillars ("Test the structure," "Paper is the qualifying round," "Your broker. Your account.") with a ProductWindow showing +34.2% total return, no proximate disclaimer - LandingFooter: entity attribution ("A product of MooseQuest LLC, operating as Raxx") and address; no investment-adviser disclaimer - PricingPage: clean paper-first framing; no process-insight copy; no backtest disclaimer proximate to any mock

What the operator wants to add: - Dual-audience copy addressing both newcomers and existing traders - A fourth pillar: retrospective process insight (win-rate adherence) - A backtest hypothetical disclaimer (proximate to the +34.2% mock) - An investment-adviser disclaimer block in the footer - Refreshed pricing page copy referencing process records - Safe newcomer-audience framing (without "break into trading")

Single highest-risk item per BLR review (PR #3078): The newcomer framing and the +34.2% mock without a disclaimer. Both require attorney sign-off before any public-facing copy ships.

Seven yes/no questions for the attorney (30-minute agenda)

# Question Ticket
Q1 Is the proposed hero h1 "Know your structure. Know your process." legally safe under FTC Section 5 and PA UTPCPL as a description of the tool's function? #2856
Q2 Does the proposed hero sub-headline ("Raxx enforces the rules you set — and shows you what your trading actually looks like when you follow them") constitute performance representation, or is it a process-description that requires no substantiation? #2856
Q3 Is the four-sentence investment-adviser footer disclaimer (§5A language from BLR brief) sufficient for PA UTPCPL strict-liability exposure, or does it need to be longer or more specific? Is 11px font size sufficient for FTC "clear and conspicuous"? #2859
Q4 What is the minimum proximate disclaimer language for a hypothetical backtest mock showing specific numbers (+34.2%, 58.3%, etc.)? Is the proposed language in Option A of this package adequate, or does it need to match SEC Marketing Rule 206(4)-1 standards? #2862
Q5 Does the PricingPage FAQ entry explaining "process insight" (win-rate adherence split) constitute performance commentary requiring a disclaimer, or is it a factual description of a retrospective feature? #2863
Q6 Does the proposed Pillar 04 body ("Win-rate when you held the rules. Win-rate when you didn't. Not a signal. Your own data.") require substantiation, or is "your own data" framing sufficient to characterize it as a retrospective display feature? #2864
Q7 What is the specific substantiation standard that would apply under FTC Section 5 if a newcomer-audience rewrite (Option A, B, or C in this package) were the subject of an FTC inquiry — and which option best avoids that inquiry? #2865

Section 2 — #2856: Hero h1 + Sub-headline

Ticket reference + current state

File: frontend/getraxx-landing/src/components/getraxx/HeroSection.jsx Current h1 rendered via HeroHeadlineAB.jsx. Current sub-headline (line 421–423): "You already decided the structure. Entry, credit, exit — defined before the trade. Raxx holds you to it."

The current hero speaks only to existing traders who already have a defined structure. The operator direction is to address both newcomers (who need to build a structure) and existing traders (who want to see how they trade, not just what they made).

BLR §7 item 1 flags newcomer copy at HIGH risk. BLR §7 item 2 flags the process-insight framing at LOW-MEDIUM risk. The sub-headline proposed in ticket #2856 is the primary copy requiring attorney review.

Proposed copy options

h1: Know your structure. Know your process.

Sub-headline: Raxx enforces the rules you set — and shows you what your trading actually looks like when you follow them. Start in paper. No credit card required.

Rationale: "Know your structure" reads to newcomers as "I need to build one" and to existing traders as "do I follow mine?" "Know your process" is the operator's insight dimension. The sub-headline is process-descriptive — it says what Raxx shows the user, not what Raxx produces for the user. No outcome claim.

Option B — More confrontational; existing-trader emphasis

h1: You decided the rules. Do you know if you follow them?

Sub-headline: Raxx holds your structure and shows you, in your own data, whether you did. Start in paper. No credit card required.

Rationale: Direct. "Your own data" is a key legal anchor — this is retrospective display of user-owned data, not a performance claim about what Raxx produces. The question-form h1 implies no outcome. Slightly alienating to newcomers who have not yet decided rules.

Option C — Softer; newcomer emphasis

h1: Trade with a structure. Learn from your own history.

Sub-headline: Raxx enforces the entry, stop, and exit rules you define. As you trade, it builds your process record — so you can see how you traded, not just what you made. Start in paper.

Rationale: "Trade with a structure" is an invitation, not a guarantee. "Learn from your own history" is retrospective and process-focused. BLR safe-phrasing list (§3B) supports "see how you trade, not just what you made" as an equivalent to "P&L tells you what happened; Raxx shows you why."

Sources: - FTC Act § 5: https://www.ftc.gov/legal-library/browse/statutes/federal-trade-commission-act - Gregg v. Ameriprise (2021): https://klehr.com/publications/pennsylvania-businesses-are-strictly-liable-for-violations-of-pennsylvanias-unfair-trade-practices-and-consumer-protection-law-the-pennsylvania-supreme-court-holds/ - SEC IA-1092 Release (1987): https://www.sec.gov/files/rules/interp/1987/ia-1092.pdf

Questions for the attorney

  1. Does "shows you what your trading actually looks like when you follow them" (Option A sub-headline) constitute a performance representation that requires substantiation, or is it a factual description of the product's retrospective display function?
  2. Of Options A, B, and C: which (if any) is approvable as-is? Which requires editing? If none, what is the attorney's Option D?
  3. Does the phrase "Start in paper. No credit card required." carry any legal implication the attorney wants to address?

Ready-to-implement note

File: frontend/getraxx-landing/src/components/getraxx/HeroSection.jsx

The h1 is currently rendered by HeroHeadlineAB.jsx — that component controls the A/B variant. The sub-headline is a <p> element starting at line 421 in HeroSection.jsx. Once the attorney picks an option, the developer updates HeroHeadlineAB.jsx to set the approved h1 as the default (variant A) and replaces the <p> text at line 421–423.

Ticket reference + current state

File: frontend/getraxx-landing/src/components/getraxx/LandingFooter.jsx

Current state: The footer contains entity attribution ("A product of MooseQuest LLC, operating as Raxx") and a physical address (line 97–108). There is no investment-adviser disclaimer anywhere on the site.

BLR §5A identifies this as a required gap to close before public launch. BLR §1A confirms that Raxx's current product design (user-defined rules, no personalized recommendations, fully retrospective) is consistent with the §202(a)(11)(F) "inanimate tool" exclusion from the Investment Advisers Act — but only if the site does not affirmatively misrepresent Raxx as something that advises users.

BLR §6 flags PA UTPCPL strict liability: MooseQuest LLC is domiciled in Pennsylvania, and any PA consumer who joins Raxx based on marketing copy has a potential UTPCPL claim if the copy had "capacity to deceive." A footer disclaimer is a first-layer defense against the argument that Raxx's marketing implied advisory services.

Proposed copy options

Option A — Minimum language (verbatim from BLR §5A)

Raxx is a trade-management and process-enforcement tool. Raxx does not provide investment advice, financial advice, or recommendations to buy or sell any security. MooseQuest LLC is not a registered investment adviser. Use of Raxx does not constitute an advisory relationship. Trading involves risk of loss. Past backtest results do not predict future performance.

Five sentences, ~57 words. Addresses the §202(a)(11) posture directly without citing the statute. Does not invite regulatory attention by referencing a specific exclusion the attorney may not want to flag publicly.

Option B — Explicit inanimate-tool reference

Raxx is a trade-management tool that applies rules defined entirely by the user to historical and live market data. It does not provide investment advice, financial advice, or recommendations to buy or sell any security. MooseQuest LLC is not a registered investment adviser, and use of Raxx does not create an advisory relationship. Trading involves substantial risk of loss. Backtest results are hypothetical and do not represent actual trading results or guarantee future performance.

Six sentences, ~73 words. Adds "rules defined entirely by the user" which maps directly to the FPL/SunAmerica no-action-letter framing of what an inanimate tool is. Attorney should assess whether this language is more protective or draws unnecessary attention.

Option C — Minimal (32 words)

Raxx is not investment advice and does not recommend securities. MooseQuest LLC is not a registered investment adviser. Trading involves risk of loss. Past backtest results do not predict future performance.

Four sentences, 32 words. The most readable option. Lower word count may increase legibility at 11px but may be insufficient for PA UTPCPL purposes. Attorney call.

Sources: - 15 U.S.C. § 80b-2(a)(11): https://www.govinfo.gov/content/pkg/COMPS-1878/pdf/COMPS-1878.pdf - FTC clear-and-conspicuous guidance: https://www.ftc.gov/news-events/news/press-releases/2023/06/federal-trade-commission-announces-updated-advertising-guides-combat-deceptive-reviews-endorsements - PA UTPCPL text: https://www.attorneygeneral.gov/wp-content/uploads/2018/02/Unfair_Trade_Practices_Consumer_Protection_Law.pdf

Questions for the attorney

  1. Of Options A, B, and C: which is approvable? Which requires editing?
  2. Is 11px font (rendered as var(--raxx-n-500) — muted grey on near-black background) sufficient for the FTC "clear and conspicuous" standard for a footer disclaimer on a financial tool's marketing site? If not, what is the minimum acceptable size?
  3. Should the disclaimer cite any statute number (73 P.S. § 201; 15 U.S.C. § 80b-2) or is explicit statutory citation unnecessary and potentially counterproductive?
  4. Does the current product design (user supplies all rules; Raxx applies them mechanically; no personalized recommendations) definitively place Raxx outside §202(a)(11)? Is a verbal confirmation sufficient, or does the operator need a formal no-action opinion before launch?

Ready-to-implement note

File: frontend/getraxx-landing/src/components/getraxx/LandingFooter.jsx

After the entity-location block (currently ending at line 108), a new <div> is added below the existing two-column flex layout with the approved disclaimer text. Ticket #2859 specifies styling: var(--raxx-n-500), fontSize: '11px', lineHeight: 1.5, full-width, separated from the two-column block by a 1px var(--raxx-ink-3) top border. The implementing developer swaps in the attorney-approved option verbatim.

Section 4 — #2862: Backtest Hypothetical Disclaimer

Ticket reference + current state

Files: - frontend/getraxx-landing/src/components/getraxx/HeroSection.jsx — HeroProductMock component renders a stats column showing: total return +34.2%, sharpe 1.87, max dd -8.4%, win rate 58.3%, trades 247 (lines 102–148) - frontend/getraxx-landing/src/components/getraxx/PillarsSection.jsx — ProductWindow renders the same stats with a <figcaption> that reads "This is what SPY mean-reversion v3 returned over 2019–2025 in paper. Before a dollar moved." (lines 168–183)

Current state: The +34.2% total return figure appears in the hero mock and the product window with no proximate disclaimer. The figcaption notes it is "in paper" but does not include the words "hypothetical," "backtest," or "past performance."

BLR §7 item 3 rates this MEDIUM-HIGH risk. BLR §5B prescribes minimum language. The figcaption is currently hidden-xs (hidden on mobile), which makes it absent from the DOM on mobile viewports entirely — the disclaimer must not be similarly hidden.

FTC "clear and conspicuous" requires the disclaimer to be proximate to the claim it disclaims. Footer-only placement is insufficient for a specific number (+34.2%) in the hero. The disclaimer must appear adjacent to or immediately below the mock.

Proposed copy options

Option A — Minimalist (matching BLR §5B minimum)

Hypothetical backtest illustration. Does not represent actual trading results. Past backtest performance does not predict future results.

Three sentences, 20 words. Directly mirrors the language required by ticket #2862. Consistent with the spirit of SEC Marketing Rule 206(4)-1 backtest-limitation disclosure requirements (though Rule 206(4)-1 applies only to registered investment advisers — Raxx is not currently registered; the spirit is adopted as a conservative posture).

Option B — Mid-length with FTC framing

This is a hypothetical backtest illustration — numbers are generated by applying the user-defined strategy rules to historical market data. Hypothetical results have inherent limitations and do not represent actual trading results. Past backtest performance is not indicative of future results.

Three sentences, 43 words. Adds "user-defined strategy rules applied to historical market data" — this language anchors the mock to the inanimate-tool framing and reduces the risk that a consumer reads the +34.2% as a promise of what Raxx itself delivers.

Option C — Compliance-style (longest; strongest cover)

Hypothetical backtest results shown are for illustrative purposes only. They are based on rules the user defines, applied mechanically to historical market data. Hypothetical results have inherent limitations, do not account for all market conditions, and do not represent actual trading results achieved by any user. Past backtest performance does not predict, guarantee, or suggest future results. All trading involves substantial risk of loss.

Five sentences, 62 words. Adds "do not represent actual trading results achieved by any user" (addresses the scenario where a visitor reads the mock as representative of typical Raxx user experience) and "all trading involves substantial risk of loss" (FINRA Rule 2210 / FTC standard risk-disclosure language). Most protective; heaviest text load on the UI.

Placement options

Placement P1 (recommended): Disclaimer appears as a <p> directly below the stats column in both HeroProductMock and ProductWindow. Adjacent to the numbers. Satisfies FTC "clear and conspicuous" requirement for proximity to the specific claim. Styled identically to the BLR-specified style: var(--raxx-n-500), fontSize: '11px', lineHeight: 1.5, fontFamily: 'var(--raxx-font-mono)', visible on ALL viewports (not hidden-xs).

Placement P2 (attorney alternative): Disclaimer appears as an asterisk label on the +34.2% stat cell, with the full disclaimer text at the bottom of the product window section. This is how mutual fund advertising handles footnotes. Attorney must confirm whether this satisfies FTC proximate-disclosure standard for a web page.

Placement P3 (weakest, not recommended): Disclaimer in footer only, not proximate to the mock. BLR §5B and FTC clear-and-conspicuous doctrine both indicate footer-only placement is insufficient for a specific performance number in the hero. Listed for completeness so the attorney can confirm it is inadequate.

Sources: - SEC Marketing Rule 206(4)-1: https://www.sec.gov/files/rules/final/2020/ia-5653.pdf - FTC deceptive advertising guidance: https://www.ftc.gov/legal-library/browse/statutes/federal-trade-commission-act - FTC clear-and-conspicuous standard: https://www.ftc.gov/system/files/ftc_gov/pdf/p204500_endorsement_guides_in_2023.pdf

Questions for the attorney

  1. Of Options A, B, and C: which minimum text is sufficient? Which placement (P1, P2, P3) is acceptable?
  2. Is "Hypothetical backtest illustration" alone sufficient as a three-word label, or is the full sentence form required?
  3. Should the mock statistics be removed entirely, relabeled ("sample data"), or is the disclaimer approach adequate to make them legally defensible on a public marketing page?
  4. Does 11px font size on a var(--raxx-n-500) grey color on the dark mock background satisfy FTC clear-and-conspicuous, or does the attorney require a specific minimum contrast ratio or font size?

Ready-to-implement note

Files: - frontend/getraxx-landing/src/components/getraxx/HeroSection.jsx — add approved disclaimer <p> after the stats column </div> closing tag, inside HeroProductMock (after line 148). Must be visible on all viewports (no hidden-xs). - frontend/getraxx-landing/src/components/getraxx/PillarsSection.jsx — add approved disclaimer <p> after the <figcaption> closing tag (after line 182), inside the <figure> element. Must be visible on all viewports.

Section 5 — #2863: Pricing Page Copy Refresh

Ticket reference + current state

File: frontend/getraxx-landing/src/pages/PricingPage.jsx

Current hero body (line 39 area, Free tier description has precedent; actual hero body text is the intro paragraph above the tier cards): "Every path through Raxx starts with paper. No card required to test your structure on real historical data."

Current FAQ items end at "Are the prices final?" (line 152). No "process insight" FAQ entry exists.

The operator wants to add one sentence bridging to the process-insight dimension in the hero body, and one new FAQ entry. BLR §7 item 2 flags the win-rate reference as LOW-MEDIUM risk, requiring attorney confirmation that the FAQ entry is retrospective data display rather than performance commentary.

Proposed copy options

Option A — Hero body sentence addition (matches ticket #2863 exactly)

Append to existing hero body:

As you trade, Raxx builds your process record — so you can see how you trade, not just what you made.

Resulting full hero body:

Every path through Raxx starts with paper. No card required to test your structure on real historical data. As you trade, Raxx builds your process record — so you can see how you trade, not just what you made.

Rationale: "See how you trade, not just what you made" is verbatim in the BLR §3C safe-phrasing table ("P&L tells you what happened. Raxx shows you why."). The process vs. outcome distinction is explicitly documented as legally clean in the BLR brief.

Option B — Hero body sentence addition (softer)

Append to existing hero body:

As you trade, Raxx builds a record of what you did vs. what your structure said to do — your process in your own data.

Rationale: "What you did vs. what your structure said to do" is directly from the BLR §3B safe-phrasing table. "Your process in your own data" is fully retrospective with no outcome implication.

Option C — Hero body sentence addition (most minimal)

Append to existing hero body:

Raxx records your process — not just your P&L.

Rationale: Shortest possible addition. Retrospective, no outcome claim, matches the core dual-audience thesis. Less explanatory than A or B but legally the cleanest surface area.

FAQ Option A — Process insight entry (matches ticket #2863 exactly)

Q: What does "process insight" mean?

A: Raxx tracks whether you followed your own rules on each trade — entry timing, stop placement, exit target. Over time, you can see your win-rate when you followed your structure vs. when you deviated. That is your process record. It is built from your own data, not market signals.

Attorney consideration: The phrase "win-rate when you followed your structure vs. when you deviated" is retrospective data display on the user's own historical data. It compares two subsets of the user's own trade record — it does not claim Raxx produces a superior outcome. However, the implicit inference (following your structure leads to better win-rate) is a potential FTC concern if Raxx cannot substantiate that inference for a typical user.

FAQ Option B — Process insight entry (avoids win-rate comparison)

Q: What does "process insight" mean?

A: Raxx logs whether you followed your own rules on each trade — entry timing, stop placement, exit target. Over time, you build a record of how you actually traded vs. how you planned to trade. That record is yours, built from your own data.

This version removes the win-rate comparison entirely. No comparative framing, no metric that implies one outcome is better than another. Lower legal surface area. Trade-off: less specific about what the feature surfaces.

FAQ Option C — Process insight entry (most conservative)

Q: What does "process insight" mean?

A: Raxx can track whether you followed your own structure on each trade. That record — your process log — is available for your review. It is built entirely from your own trading data and does not include market signals or recommendations.

Completely neutral. No win-rate reference, no comparative framing. Minimum legal exposure. Trade-off: lowest marketing utility.

Sources: - BLR brief §3B, §3C: docs/business/raxx-marketing-compliance-brief-2026-05-27.md - FTC Section 5: https://www.ftc.gov/legal-library/browse/statutes/federal-trade-commission-act

Questions for the attorney

  1. Of hero body Options A, B, C: which (if any) is approvable as-is?
  2. Of FAQ Options A, B, C: does Option A require a proximate disclaimer noting that win-rate results on the user's own historical data are not predictive of future results? Or is "built from your own data, not market signals" sufficient to characterize the feature as retrospective display?
  3. If the rule-adherence feature has not yet shipped when this copy goes live, is the FAQ entry (describing a feature that does not yet exist) a material misrepresentation? Or is it acceptable as a product description for an announced upcoming feature?

Ready-to-implement note

File: frontend/getraxx-landing/src/pages/PricingPage.jsx

The hero body paragraph is rendered above the tier cards. The developer appends the attorney-approved sentence to that paragraph's text node. The FAQ entry is appended to the faqItems array (currently ending at line 152 area) with the approved Q and A strings verbatim.

Section 6 — #2864: Fourth Pillar — Retrospective Process Insight

Ticket reference + current state

File: frontend/getraxx-landing/src/components/getraxx/PillarsSection.jsx

Current state: Three pillars in the pillars array (lines 16–32): - 01: "Test the structure on real history." - 02: "Paper is the qualifying round." - 03: "Your broker. Your account."

Section head h2: "You defined the structure." Sub-headline <p>: "Raxx is the system that keeps you inside it."

The operator wants to add a fourth pillar that introduces the retrospective process-insight dimension. BLR §7 item 2 rates the win-rate framing at LOW-MEDIUM risk. The proposed body copy explicitly uses "your own history" and "your own data" — both BLR-documented anchors for retrospective-only framing.

There is a secondary operator decision still open on this ticket: should the pillar copy ship before the underlying rule-adherence feature exists? Per feedback_hide_dont_gray_unavailable_features, the pillar should either wait for the feature or be clearly labeled "coming soon." This document does not resolve that operator decision — it stages the copy for attorney review only.

Proposed copy options

Option A — Section head + sub-headline update (matches ticket #2864 exactly)

Current sub-headline: Raxx is the system that keeps you inside it.

Proposed sub-headline: Raxx keeps you inside it and shows you what it looks like when you do.

Rationale: Minimal change. Adds "shows you what it looks like when you do" — the process-mirror dimension — without altering the enforcement-first framing. BLR §3B safe-phrasing table supports "see your own decision patterns against your own rules" as legally clean; this sub-headline is a shorter equivalent.

Option B — Section head + sub-headline update (stronger insight emphasis)

Current sub-headline: Raxx is the system that keeps you inside it.

Proposed sub-headline: Raxx is the system that keeps you inside your structure — and shows you the record of when you did.

Rationale: "Shows you the record of when you did" is fully retrospective (past tense, record implies historical log). Slightly more explicit about the logging function.

Option C — Sub-headline unchanged; insight absorbed into section kicker

Keep sub-headline as-is. Update the section kicker from "What Raxx holds" to "What Raxx holds — and what it shows you."

Rationale: Minimally invasive. The insight dimension is signaled by the kicker rather than the sub-headline. Lowest risk of altering the enforcement-first brand tone that has been validated with existing users.

Option A — Pillar 04 (matches ticket #2864 exactly)

num: '04'
title: 'Your trading, in retrospect.'
body: 'Raxx tracks what your structure returned on your own history — and whether you followed it. Win-rate when you held the rules. Win-rate when you didn\'t. Not a signal. Your own data.'

The "Win-rate when you held the rules. Win-rate when you didn't." construction is the same framing as FAQ Option A in Section 5. If the attorney approves the FAQ version, the same approval logic applies here.

Option B — Pillar 04 (win-rate comparison removed)

num: '04'
title: 'Your trading, in retrospect.'
body: 'Raxx builds a record of what your structure did on your own history — and whether you followed it. What you said you would do vs. what you actually did. Your data, your record.'

Removes the win-rate metric reference. "What you said you would do vs. what you actually did" is in the BLR §3B safe-phrasing table. No comparative metric, no inference about what "good" looks like.

Option C — Pillar 04 (most conservative)

num: '04'
title: 'The mirror.'
body: 'Your structure, applied to your history. Did you follow it? Raxx logs the answer — in your own data, not market signals.'

Shortest. "The mirror" is a documented brand metaphor from the positioning doc (Raxx as the mirror for existing traders). No metric at all — just the logging function described.

Sources: - BLR §3B safe-phrasing table: docs/business/raxx-marketing-compliance-brief-2026-05-27.md - FTC Section 5: https://www.ftc.gov/legal-library/browse/statutes/federal-trade-commission-act - PA UTPCPL: https://www.attorneygeneral.gov/wp-content/uploads/2018/02/Unfair_Trade_Practices_Consumer_Protection_Law.pdf

Questions for the attorney

  1. Of pillar Options A, B, C: does any version of win-rate comparison language require a proximate disclaimer ("this is your historical data — past win-rate split does not predict future results"), or is "your own data" framing sufficient?
  2. Is the section head update (any of Options A, B, C) approvable as-is?
  3. If the underlying rule-adherence feature is not yet live when this pillar ships, does pillar copy describing that feature constitute a material misrepresentation?

Ready-to-implement note

File: frontend/getraxx-landing/src/components/getraxx/PillarsSection.jsx

Step 1: Update the sub-headline <p> at line 232 to the attorney-approved option. Step 2: Add the attorney-approved pillar object to the pillars array (lines 16–32) as the fourth entry. Step 3: The developer must assess whether the repeat(auto-fit, minmax(240px, 1fr)) grid at line 241 produces an orphan pillar at ~800px viewport. If so, the grid should be updated to a fixed 2-column layout at ≥768px. This is a layout task for the developer; it does not require attorney review.

Section 7 — #2865: Newcomer-Audience Framing

Ticket reference + current state

This ticket is a tracking card only — it does not currently map to a specific JSX file. The newcomer-audience copy, once approved, would be incorporated into: - frontend/getraxx-landing/src/components/getraxx/HeroSection.jsx (sub-headline, potentially) - frontend/getraxx-landing/src/pages/WaitlistPage.jsx (hero paragraph)

BLR §11 identifies "break into trading" and any equivalent newcomer framing as the single highest-risk item in the entire copy cluster. The risk is specific:

Under PA UTPCPL § 201-2(4)(xxi) strict liability (Gregg v. Ameriprise, 2021), a PA consumer who joins Raxx after reading newcomer-framed marketing copy, loses money trading, and can argue the copy implied a likelihood of success has a facially viable claim without proving Raxx intended to deceive. "Break into trading" implies difficulty overcome and future success — both of which are outcome claims that require FTC substantiation under the IM Mastery Academy (2025) standard.

The operator's intent is valid: communicate that Raxx is a structured starting point for people who have not yet traded live. The question is which phrasing of that intent is defensible.

BLR-pre-approved phrases (no attorney review needed)

These phrases are in the BLR §3A safe-phrasing table and do not require separate attorney approval:

These can be used in any surface immediately, without waiting for attorney clearance on the options below.

Proposed newcomer-audience options (require attorney confirmation)

Option A — Process-focused, outcome-agnostic

"The structured entry point for traders who want to know their process before they risk capital."

FTC analysis: "structured entry point" positions Raxx as a tool, not a gateway to success. "Know their process before they risk capital" describes a state of preparation, not an outcome. No claim that using Raxx results in successful trading. The FTC's IML standard requires substantiation only for claims that "a significant proportion" of users will achieve the described outcome — "knowing your process" is a process milestone the user verifies themselves, not a performance outcome Raxx delivers.

Risk: LOW. The phrase implies newcomers who use Raxx will become more prepared. "More prepared" is a process milestone, not an outcome claim. Attorney should confirm.

Option B — Mirror-and-discipline framing

"Start with a structure. See what it actually does — before you put capital behind it."

FTC analysis: "See what it actually does" refers to backtesting — seeing historical results of the user's strategy. "Before you put capital behind it" is the risk-management framing that positions Raxx as caution-first. No implied promise of success. Consistent with "paper is the qualifying round" framing that is already on the live site.

Risk: LOW. No outcome claim present. The phrase describes what Raxx enables the user to observe (backtest results) before committing capital.

Option C — Audience-split explicit statement

"If you have never traded live, Raxx is where you build the structure first. If you are already trading, Raxx is where you see whether you're following yours."

FTC analysis: Addresses both audiences explicitly without implying either will succeed. "Build the structure first" and "see whether you're following yours" are both process descriptions. No outcome language. Slightly long for a headline; better for a sub-head or landing page paragraph.

Risk: LOW for this specific phrasing. The phrase "if you have never traded live" acknowledges the newcomer hasn't yet traded — no implied success from having done so.

FTC analysis by option

Option Outcome claim? "Capacity to deceive"? Substantiation required?
BLR pre-approved phrases No No No
Option A No Unlikely No — process milestone, not performance outcome
Option B No No No — describes a feature (backtest), not a user outcome
Option C No No No — explicitly process-framed, no success implication
"Break into trading" (current operator phrase) Yes — implies overcoming barrier to success Yes under PA UTPCPL strict liability Yes — requires evidence typical newcomers successfully "break into" trading using Raxx

Sources: - FTC v. IM Mastery Academy: https://www.ftc.gov/news-events/news/press-releases/2025/05/ftc-state-nevada-take-action-against-im-mastery-academy-deceiving-consumers - FINRA v. Robinhood ($70M, 2021): https://www.cnbc.com/2021/06/30/robinhood-to-pay-70-million-for-misleading-customers-and-outages-the-largest-finra-penalty-ever.html - FTC Section 5: https://www.ftc.gov/legal-library/browse/statutes/federal-trade-commission-act - PA UTPCPL: https://www.attorneygeneral.gov/wp-content/uploads/2018/02/Unfair_Trade_Practices_Consumer_Protection_Law.pdf

Questions for the attorney

  1. Is framing Raxx as a "structured entry point" for people who have not traded live yet (Option A) legally safe under FTC Section 5 and PA UTPCPL § 201-2(4)(xxi), without carrying an implied promise of trading success? Does it require substantiation of any outcome claim?
  2. Of Options A, B, C: which (if any) is approvable for use across all getraxx.com surfaces (hero, waitlist page, about page, email copy)?
  3. The BLR pre-approved phrases (§3A): does the attorney agree these require no further review, or should one or more be examined?
  4. What is the specific substantiation standard that would apply if any of Options A–C were the subject of an FTC inquiry? What evidence would Raxx need to have on file?
  5. Is there a phrase that the attorney would propose to address the newcomer audience that is more conservative than the three options presented here?

Ready-to-implement note

This ticket does not resolve to a single JSX file until the attorney selects a phrase. Once approved: - WaitlistPage.jsx: hero paragraph updated to include the approved newcomer framing - HeroSection.jsx sub-headline: optionally includes the approved phrase (operator decision on whether the hero sub-headline addresses newcomers explicitly or defers to the waitlist page) - Any instance of "break into trading" in .jsx, index.html, or documentation must be removed — no version of that phrase ships without separate attorney clearance.

30-Minute Attorney Meeting Agenda

Participants: Kristerpher (MooseQuest LLC); attorney with FTC § 5 + PA UTPCPL experience (Duane Morris / Ballard Spahr / Eckert Seamans)

Materials for the attorney in advance: This document + docs/business/raxx-marketing-compliance-brief-2026-05-27.md

Minutes 0–5 — Context - Raxx is a trade-management and process-enforcement tool - User supplies all rules; Raxx applies them mechanically; fully retrospective - MooseQuest LLC is a Pennsylvania single-member LLC; not registered as an investment adviser or broker-dealer - No live customers yet; launch is imminent

Minutes 5–10 — Blockers 1 and 2 (highest priority) - Q3: Footer disclaimer — Option A, B, or C? Font size OK? - Q4: Backtest mock disclaimer — Option A, B, or C? Placement P1, P2, or P3? These two unblock three tickets (#2859, #2862, and the backtest risk in #2856).

Minutes 10–20 — Hero and pillar copy - Q1 and Q2: Hero h1 + sub-headline (#2856) - Pillar 04 (#2864): Options A, B, C for title + body - Q5 and Q6 can be addressed here if time permits

Minutes 20–28 — Newcomer framing (#2865) and pricing FAQ (#2863) - Q7: Newcomer framing — Options A, B, C - FAQ entry (#2863): Options A, B, C for "what does process insight mean?"

Minutes 28–30 — Standing questions - Is Raxx's current product design definitively outside §202(a)(11)? Verbal or written? - What is the SOP for testimonial approval when Raxx has customers? - Any copy the attorney wants to flag that is NOT in this package?

Deliverable from the attorney: Written (email is fine) confirmation of which option is approved for each of the 7 tickets, with any edits. This enables the developer to ship all 7 tickets in a single PR immediately after the meeting.

Sources (consolidated)