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Ballard Spahr Intro Email — 2026-05-27

Internal note: This is a draft for Kristerpher to review and send from kris@moosequest.net. Not legal advice. Outreach material only.

Subject

Pre-launch retail trading software — marketing copy + disclaimer review, PA UTPCPL, FTC, SEC

Body

To the Consumer Financial Services Practice Group at Ballard Spahr LLP,

My name is Kristerpher Henderson, and I am the founder of MooseQuest LLC, a Pennsylvania single-member LLC building Raxx — a rule-based trade-management platform for retail options traders. The platform enforces the structured entry, credit, and exit rules a trader defines before any capital moves. We are in pre-launch personal-use testing, approaching a public launch in the near term.

I identified Ballard Spahr through your Philadelphia presence and your firm's multi-practice breadth in consumer financial services. The nature of this review spans consumer protection, FTC advertising, and the SEC investment-adviser perimeter — and I want a firm that can address all three of those lanes in one conversation rather than routing to separate specialists.

What I need: A focused 2-hour copy and disclaimer review of the getraxx.com marketing copy, covering:

  1. PA UTPCPL strict-liability exposure under the 2021 Gregg v. Ameriprise ruling — as a PA-domiciled LLC, any marketing copy with the capacity to be read in a misleading way creates exposure regardless of intent, and I want to close that gap before we go public
  2. FTC Section 5 substantiation standard — specifically whether a newcomer-audience framing (positioning Raxx as a structured starting point for traders who want to know their process before risking capital) creates an implied outcome claim, and if so what substantiation would be required
  3. Footer and backtest-mock disclaimer adequacy — draft language is already prepared; we need attorney approval before it goes live
  4. SEC §202(a)(11) investment-adviser perimeter — confirming our current product posture (user-defined rules only, retrospective results, no AI recommendations, no execution by Raxx) sits outside the advisory definition, and identifying the precise behavior that would change that analysis

I have staged a full compliance research brief and a meeting-ready question list covering all four areas, which I can share ahead of any call. Our budget for this review is $700–$1,200 flat for the 2-hour session; if that does not fit your engagement model I am open to a conversation about scope.

Would someone on your consumer financial services team be available in the next two to three weeks? I can work around your schedule.

Kristerpher Henderson Founder, MooseQuest LLC kris@moosequest.net

Pre-meeting materials Kristerpher can send on request

Draft prepared: 2026-05-27 UTC Send from: kris@moosequest.net Recipient: Ballard Spahr LLP consumer financial services practice group Contact page: https://www.ballardspahr.com/services/practices/consumer-financial-services