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Duane Morris 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 fintech — copy + disclaimer review, FTC Section 5, PA UTPCPL, SEC marketing

Body

To the Consumer Financial Services Practice Group at Duane Morris 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 that helps retail options traders enforce the structured entry, credit, and exit rules they define before any capital moves. We are in pre-launch personal-use testing and approaching a public launch within the near term.

I identified Duane Morris through your firm's consumer financial services track record in Philadelphia and your documented experience at the intersection of fintech product positioning and consumer-protection regulatory exposure. That combination — financial-technology context plus PA and FTC familiarity — is exactly what this review requires.

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

  1. FTC Section 5 truth-in-advertising substantiation — specifically whether newcomer-audience copy framing Raxx as a structured starting point for new traders creates an implied outcome claim under the FTC's "capacity to deceive" standard
  2. PA UTPCPL strict-liability exposure following the 2021 Gregg v. Ameriprise ruling — given MooseQuest LLC is a PA entity, any landing-page copy with the capacity to be interpreted in a misleading way creates potential exposure regardless of intent
  3. Footer and proximate disclaimer adequacy — we have drafted language but need attorney review before it goes live
  4. SEC §202(a)(11) investment-adviser perimeter — confirming that a tool operating exclusively on user-defined rules, with retrospective results and no personalized recommendations, sits outside the advisory definition, and identifying the specific product behavior that would cross that line

I have staged a full compliance brief (PA UTPCPL analysis, FTC precedent review, SEC no-action framing) and a prepared question list that I can share before any call. Our budget for this initial review is $700–$1,200 flat for the 2-hour session. If your fee structure differs, I am glad to discuss.

Would someone on your consumer financial services team be available for a consultation in the next two to three weeks? I am flexible on timing.

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: Duane Morris LLP consumer financial services practice group Contact page: https://www.duanemorris.com/practices/consumerfinancialservices.html