Terms of Service

1Acceptance of Terms

These Terms of Service (“Terms”) form a binding agreement between you and Edwin Research LLC (“Company,” “we,” “us,” or “our”) and govern your access to and use of our websites, products, and services, including FOIAsearch.com, CommentLetterSearch.com, 8KSearch.com, StockPromotionTracker.com, StopNasdaqChinaFraud.com, and any related applications, APIs, content, or features (collectively, the “Services”).

By accessing or using the Services, you:

• acknowledge that you have read and understand these Terms;
• agree to be bound by them and all policies referenced in them (including our Privacy Policy); and
• represent that you are at least 18 years old and legally able to enter into this agreement.

If you are using the Services on behalf of an organization, you represent that you have authority to bind that organization, and “you” includes that organization and its Authorized Users.

We may update these Terms from time to time. When we do, we will revise the “Last updated” date above and, where required, provide notice. Your continued use of the Services after changes become effective constitutes acceptance of the updated Terms. If you do not agree, you must stop using the Services.

2Description of Services

Our Services help users discover, search, and analyze publicly available documents and information, including (for example):

• U.S. federal FOIA-released records and agency materials;
• SEC comment letters, issuer correspondence, and selected filing types (e.g., Forms 8-K);
• public claims of stock promotion activity and related public sources; and
• curated datasets, enrichment, tagging, and search interfaces we create to organize public information.

No Legal, Financial, or Investment Advice. The Services and any content are for informational purposes only. We are not a broker-dealer, investment adviser, law firm, or fiduciary. We do not recommend securities, transactions, or strategies. You are solely responsible for any decisions you make based on the Services and should consult qualified professionals as needed.

Coverage & Availability. Our content coverage, features, sources, and availability may evolve, be corrected, or be discontinued at any time. Public sources can be incomplete, delayed, changed, or withdrawn. We may offer beta or experimental features with reduced reliability; such features are offered as-is and may be changed or removed.

Third-Party Materials. We may display or rely on third-party materials (including market data, logos, links, or APIs). We don’t endorse or control third-party content and aren’t responsible for its accuracy, timeliness, licensing, or legality.

3User Accounts

Registration. Some features require an account. You must provide accurate, current information and keep it updated. Do not share your login; one seat = one natural person unless your plan expressly allows otherwise.

Security. You are responsible for maintaining the confidentiality of your credentials and for activities under your account. Notify us immediately if you suspect unauthorized access.

Organization Accounts. If your account is provisioned by an organization, your use may be controlled by that organization’s administrator(s). We may disclose account information to the organization and follow its instructions.

Account Types & Access. Plans may vary by features, usage limits, and Authorized Users. We may throttle, rate-limit, or suspend accounts to protect the Services, enforce these Terms, or comply with law.

Accuracy of Use. You agree not to misrepresent your identity or affiliation, and not to circumvent access restrictions (for example, metered paywalls or seat limits).

4User Conduct

You agree to use the Services lawfully and responsibly, and you will not:

• access or use the Services in violation of any applicable law, regulation, or third-party rights (including IP rights and securities laws);
• attempt to scrape, harvest, crawl, index, or bulk-export data except through features or APIs we explicitly provide and within published rate limits;
• bypass or defeat access controls, metering, or paywalls (including cookies and tokens used to enforce quotas or trials);
• upload, transmit, or distribute malware, spam, or harmful code;
• reverse engineer, decompile, or interfere with the Services except to the extent such restrictions are prohibited by law;
• use the Services to dox, harass, or otherwise harm individuals;
• misrepresent or remove source attributions or legal notices;
• use outputs to build a substantially similar competing service without our written permission; or
• resell, sublicense, or provide the Services to third parties except as expressly permitted by your plan.

We may investigate and enforce violations, including by suspending or terminating access and cooperating with authorities where appropriate.

5Payment Terms

Plans & Billing. Some features are paid on a subscription basis (monthly or annual) or metered usage. Fees, features, and limits are described at checkout or in your order form.

Trials & Promotions. If provided, free trials or promotional periods convert to paid subscriptions unless you cancel before the trial ends. We may revoke or modify trials at any time.

Auto-Renewal. Subscriptions auto-renew at the then-current price unless you cancel prior to renewal. You can manage or cancel via your account or by contacting us.

Refunds. Except where required by law or explicitly stated for your plan, fees are non-refundable and non-creditable, including for partial periods.

Upgrades/Downgrades. Upgrades take effect immediately (we may prorate). Downgrades take effect at the next renewal and may reduce features, limits, or data access.

Taxes. Prices typically exclude taxes. You are responsible for any applicable taxes, duties, or withholdings (other than our income taxes).

Late/Failed Payments. If a payment fails or is reversed, we may suspend or terminate access, and you remain responsible for unpaid amounts. Chargebacks may be treated as a material breach.

Changes to Pricing. We may change prices and plan features with notice, effective upon the next renewal or a new order.

6Privacy Policy

Your privacy matters. Our Privacy Policy explains how we collect, use, and share information when you use the Services, including through cookies and similar technologies such as a signed, anonymous cookie used to manage metered access and paywalls.

• By using the Services, you also agree to our Privacy Policy.
• For enterprise customers, we may offer additional data-processing terms (e.g., a DPA).
• We use reasonable technical and organizational measures to protect data but cannot guarantee absolute security.
• We may send you service, transactional, and administrative communications. You can opt out of non-essential marketing per our Privacy Policy.

[Link your Privacy Policy from here in your UI.]

7Intellectual Property

Our IP. The Services—including software, UI, databases, indexes, models, designs, compilations, and original content—are owned by us or our licensors and are protected by IP and other laws. Except as expressly permitted by these Terms and your plan, we grant you a limited, revocable, non-exclusive, non-transferable license to access and use the Services for your internal purposes.

Public Documents. Many underlying documents we surface are public records. However, our selection, arrangement, enrichment, tagging, and derived datasets are protected as compilations and/or original works. You may not reproduce or redistribute our curated datasets or bulk download content except as expressly allowed by your plan or applicable law.

Your Content. If you upload, submit, or create content in the Services (e.g., notes, saved lists, metadata you contribute), you grant us a worldwide, non-exclusive, royalty-free license to host, display, and process that content to operate and improve the Services. You represent you have the rights to provide it and that it doesn’t infringe others’ rights.

Feedback. If you provide ideas or suggestions, we may use them without restriction or compensation.

Third-Party Rights & DMCA. We respect IP rights. If you believe something on the Services infringes your copyright, please send a notice to our designated agent (DMCA Agent) with the required information (17 U.S.C. §512). We may remove or disable access to alleged infringing material and, where appropriate, terminate repeat infringers.

8Termination

By You. You may stop using the Services at any time and, where applicable, cancel your subscription before the next renewal to avoid future charges.

By Us. We may suspend or terminate your access immediately if you breach these Terms, pose security or legal risks, fail to pay fees, or if we discontinue the Services in whole or part.

Effect of Termination. Upon termination, your license ends and access to the Services (and associated data accessible only via the Services) may cease. We may retain certain information as required by law or for legitimate business purposes consistent with our Privacy Policy. If your plan includes an export feature, you should export your permitted data before termination.

Certain sections survive termination, including Ownership, Payment obligations, Disclaimers, Limitation of Liability, Indemnity, and Dispute Resolution.

9Disclaimers

A. No Warranties. The Services are provided “AS IS” and “AS AVAILABLE.” To the fullest extent permitted by law, we disclaim all warranties—express, implied, statutory, or otherwise—including merchantability, fitness for a particular purpose, title, non-infringement, and warranties arising from course of dealing or usage of trade. We do not warrant that: (i) the Services will be uninterrupted, secure, or error-free; (ii) data will be current, complete, or accurate; or (iii) defects will be corrected.

B. Data & Market Information. Public records and market information can be delayed, altered, incomplete, or withdrawn by their sources. Any market data or pricing displayed may be for informational display, not for trading or time-critical use. You assume all risk of reliance.

C. Limitation of Liability. To the maximum extent permitted by law:

• No consequential damages. We are not liable for any indirect, incidental, special, punitive, or consequential damages, or loss of profits, revenues, data, or goodwill.
• Cap. Our total liability for any claim arising out of or relating to the Services or these Terms is limited to the greater of (i) the amount you paid to us for the Services in the 12 months before the event giving rise to liability, or (ii) $100.
• These limits apply even if a remedy fails of its essential purpose.

D. Indemnification. You will indemnify and hold us (and our affiliates, officers, directors, employees, and agents) harmless from and against claims, damages, liabilities, costs, and expenses (including reasonable attorneys’ fees) arising out of or related to: (i) your use of the Services; (ii) your content; (iii) your violation of these Terms or applicable law; or (iv) disputes between you and any third party.

E. Dispute Resolution; Venue. Before filing a claim, the parties will attempt to resolve disputes informally for 30 days after written notice.

• Court Venue: The parties consent to the exclusive jurisdiction and venue of the state and federal courts located in [New York, NY], under the laws of [NY], without regard to conflict-of-law rules. OR
• Arbitration: Any dispute will be resolved by binding arbitration administered by [arbitration body] under its rules, with venue in [New York, NY], and the laws of [NY] governing. Class actions and jury trials are waived.

F. Export & Sanctions. You represent that you are not prohibited from using the Services under applicable export control or sanctions laws and will not use the Services in embargoed countries or for prohibited end uses.

G. Force Majeure. We are not liable for delays or failures due to events beyond our reasonable control (e.g., outages, DDoS, labor disputes, acts of God, government actions).

H. Miscellaneous. These Terms are the entire agreement regarding the Services, superseding prior agreements. If any part is unenforceable, the remainder stays in effect. You may not assign these Terms without our consent; we may assign to an affiliate or successor. No waiver is implied by delay or failure to enforce. Headings are for convenience only.

10Contact Information

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