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's primary basis for non-registration as a commodity trading advisor (CTA) is the self-executing exemption under CFTC Rule 4.14(a)(9), 17 CFR § 4.14(a)(9), adopted by the CFTC effective March 2000. This rule exempts from CTA registration any person who provides standardized, non-customized commodity trading advice through media such as websites, newsletters, and non-customized computer software, provided the person does not (i) direct any client's commodity interest account 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 satisfies both conditions: all signals are identical and standardized for every subscriber, and Cotes AI holds no trading authority or powers of attorney over any account.

Cotes AI additionally notes that its publishing activities may qualify for the CTA statutory exclusion under Section 1a(12)(B)(iv) of the Commodity Exchange Act (the "CEA"), 7 U.S.C. § 1a(12)(B)(iv), which excludes publishers and producers of electronic data of general and regular dissemination from the CTA definition. However, Cotes AI does not rely on this provision as its primary basis and does not represent that all of its publishing activities are "solely incidental" to a separate primary business, as that provision requires. Rule 4.14(a)(9) is the operative exemption.

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 publisher status under Rule 4.14(a)(9).

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:

You are solely responsible for all investment and trading decisions
You will conduct your own research and due diligence
You will consult with qualified professionals as appropriate
You understand the experimental nature of spectral analysis and signals
You will not rely exclusively on our pattern recognition results or signals
You have the financial ability to bear total loss
You will maintain realistic expectations about outcomes
You accept all risks associated with securities, commodity interest, and event/binary contract trading
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:

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

CONTACT INFORMATION

Cotes AI, Inc. 16192 Coastal Hwy Lewes, DE 19958 Email: support@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. Our primary CFTC non-registration basis is the self-executing exemption under CFTC Rule 4.14(a)(9), 17 CFR § 4.14(a)(9). On the securities side, we operate under the publisher's exclusion of Section 202(a)(11)(D) of the Investment Advisers Act of 1940. We additionally note the CTA statutory exclusion under Section 1a(12)(B)(iv) of the Commodity Exchange Act (7 U.S.C. § 1a(12)(B)(iv)) as a secondary matter; Rule 4.14(a)(9) is the operative exemption for our commodity-interest publishing activities.