Eckert Seamans 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 — copy + disclaimer review, PA UTPCPL, FTC Section 5
Body
To the Consumer Protection Practice Group at Eckert Seamans Cherin & Mellott LLC,
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 enforces the structured entry, credit, and exit rules a retail options trader defines before any capital moves. Raxx is currently in pre-launch personal-use testing with public launch expected in the near term.
I found Eckert Seamans through your firm's published analysis of Gregg v. Ameriprise Financial (2021) and the strict-liability expansion under the UTPCPL catch-all provision. That article addressed exactly the issue I am trying to get ahead of before our marketing copy goes public, which is why you are my first call.
What I need: A focused 2-hour copy and disclaimer review of the getraxx.com marketing copy, with specific attention to:
- PA UTPCPL strict-liability exposure (Gregg v. Ameriprise, 2021) arising from any newcomer-audience framing on the landing page
- FTC Section 5 truth-in-advertising substantiation standard as applied to a process-enforcement tool with no outcome claims
- The adequacy of our proposed footer disclaimer (draft language already prepared) and a proximate disclaimer on a hero-section backtest mock showing hypothetical results
- Whether Raxx's current product posture — user-defined rules, retrospective results only, no AI recommendations, no trade execution by Raxx — definitively sits outside the SEC §202(a)(11) investment-adviser definition, and whether a verbal opinion is sufficient or a formal opinion letter is warranted before launch
I have staged a full compliance research brief (covering each of these topics with primary-source citations) and a meeting-ready attorney question list that I can send before any call. Our budget for this initial review is $700–$1,200 flat for the 2-hour session. If your scope or rate structure works differently, I am open to discussing it.
Would someone at Eckert Seamans with PA UTPCPL and FTC Section 5 experience be available for a focused consultation in the next two to three weeks? I can work around your schedule.
Thank you for your time.
Kristerpher Henderson Founder, MooseQuest LLC kris@moosequest.net
Pre-meeting materials Kristerpher can send on request
- Internal compliance research brief covering PA UTPCPL, FTC Section 5, SEC §202(a)(11) analysis, and the Gregg v. Ameriprise exposure analysis (linked via Google Drive)
- The prepared attorney-question list for the session (6 specific questions under section P of our questions-for-attorney document)
- Current getraxx.com copy in text form for pre-read
Draft prepared: 2026-05-27 UTC Send from: kris@moosequest.net Recipient: Eckert Seamans Cherin & Mellott LLC consumer protection practice group Contact page:
https://www.eckertseamans.com/services/practices/consumer-protection