Complete WP-0004 and WP-0005 jurisdiction research (8 of 8 each)

Executes all remaining shared jurisdictions across both workplans:
Germany/EU (deepened contract-law angle), US (deepened), UK (deepened),
Argentina, India, China, Africa (South Africa + OHADA), and Asia-Pacific
(Singapore, Japan, Australia) - 13 new history/ research artifacts.

Highest-priority findings:

- Australia's Unfair Contract Terms regime (expanded Nov 2023) covers
  standard-form contracts with any business under 100 employees/$10M
  turnover by default - the CUA is exactly such a contract, and most
  realistic Customers fall within this threshold. Unlike every other
  jurisdiction's consumer carve-out, this is not an edge case.
- China requires a "foreign-related" contract even to select foreign
  governing law, subject to a vague public-interest override even then -
  confirms a dedicated China rider is needed for both the License/CUA and
  the Enforcement Partner Agreement, not a shared global clause.
- India flatly prohibits advocate contingency fees (no exception gates,
  stricter than Germany) while explicitly permitting third-party
  litigation funding - the cleanest confirmation yet that the Litigation
  Funder/Local Counsel split-role model is both necessary and legal there.
- Japan's Article 12 fee-splitting rule means even the split-role
  fallback needs jurisdiction-specific structuring - the first case where
  the workaround itself, not just the original mechanism, has an open
  compliance question.
- Contingency Share ceilings vary widely where available: UK 50% (exact
  match), South Africa 25%, Argentina 35% (50% only with risk assumption),
  China 18% down to 6% on a sliding scale that shrinks as claims grow.
- Recurring cross-jurisdictional pattern (Germany, EU, US via CCPA,
  Argentina): B2B governing-law/liability clauses are respected, but an
  individual/sole-proprietor Customer's consumer-protection status is the
  operative risk everywhere, not a one-off edge case.

Updates specs/EnforcementNetworkConcept.md §8.1 with a full 12-jurisdiction
findings table and three cross-cutting conclusions. Updates both V1C1
documents' Appendix A items (governing law, liability cap, data
protection) with the most consequential findings. Both workplans now have
only their human-gated synthesis tasks (T09-T10 / T10) remaining.

Co-Authored-By: Claude Sonnet 5 <noreply@anthropic.com>

README.md

@@ -49,7 +49,7 @@ Extracted and stabilized from the concept draft under `workplans/TREV-WP-0003-no
 
 ## Enforcement Network concept
 
-[`specs/EnforcementNetworkConcept.md`](specs/EnforcementNetworkConcept.md) is a new, separate concept (2026-07-29): independent, locally-licensed Enforcement Partners pursue unauthorized Commercial Use in their home jurisdiction for a share of Recovery, so License §3 enforcement scales without the Licensor litigating everywhere directly. **The central open risk is that lawyer contingency fees are not legal everywhere** — Germany notably restricts them — so the concept requires a jurisdiction-conditional Litigation Funder/Local Counsel structure, not a single global fee mechanism. Backed by `workplans/TREV-WP-0005-enforcement-network-research.md`; four of ten research tasks are done (Germany/EU, US, UK, mechanism design — see `history/260729-TREN-*.md`), confirming the UK's 50% Damages-Based Agreement cap validates the originally-proposed Contingency Share exactly, while Germany likely requires the split-role structure.
+[`specs/EnforcementNetworkConcept.md`](specs/EnforcementNetworkConcept.md) is a new, separate concept (2026-07-29): independent, locally-licensed Enforcement Partners pursue unauthorized Commercial Use in their home jurisdiction for a share of Recovery, so License §3 enforcement scales without the Licensor litigating everywhere directly. **The central open risk is that lawyer contingency fees are not legal everywhere** — Germany notably restricts them — so the concept requires a jurisdiction-conditional Litigation Funder/Local Counsel structure, not a single global fee mechanism. Backed by `workplans/TREV-WP-0005-enforcement-network-research.md`; 9 of 10 tasks are done (all 8 jurisdictions plus mechanism design — see `history/260729-TREN-*.md`), only the human-gated synthesis remains. Findings: 50% is only exactly valid in the UK; most jurisdictions cap lower (18–35%) or ban direct lawyer contingency outright (Germany, India); India cleanly confirms the split-role model is both necessary and legal there; Japan's fee-splitting rule means even the split-role fallback needs jurisdiction-specific structuring, not just an availability check.
 
 ## Repository layout
 
@@ -74,8 +74,8 @@ Extracted and stabilized from the concept draft under `workplans/TREV-WP-0003-no
 | [TREV-WP-0001](workplans/TREV-WP-0001-license-prior-art-research.md) | Prior-art research (T01–T05 done, archived to `history/`) → TRSL V1C1 license candidate (T06 ready for human review) |
 | [TREV-WP-0002](workplans/TREV-WP-0002-trust-service-foundation.md) | Schemas, pure Outstanding Target fold, golden fixture — **finished** |
 | [TREV-WP-0003](workplans/TREV-WP-0003-normative-core-extraction.md) | Extract stable normative core docs — T01–T05 done, T06 human review open |
-| [TREV-WP-0004](workplans/TREV-WP-0004-global-jurisdiction-research.md) | Global jurisdictional research backing the License/CUA candidates (Germany/EU, US, UK, Argentina, India, China, Africa, Asia-Pacific, choice-of-law) — planned, not started |
-| [TREV-WP-0005](workplans/TREV-WP-0005-enforcement-network-research.md) | Enforcement Network legal feasibility research (contingency-fee availability per jurisdiction) — 4 of 10 tasks done |
+| [TREV-WP-0004](workplans/TREV-WP-0004-global-jurisdiction-research.md) | Global jurisdictional research backing the License/CUA candidates — 8 of 10 tasks done (all jurisdictions; T09 choice-of-law strategy and T10 synthesis remain) |
+| [TREV-WP-0005](workplans/TREV-WP-0005-enforcement-network-research.md) | Enforcement Network legal feasibility research — 9 of 10 tasks done (all jurisdictions and mechanism design; T10 synthesis remains, human-gated) |
 
 Hub index: [`WORK-RECORDS.md`](WORK-RECORDS.md) · brief: [`.custodian-brief.md`](.custodian-brief.md)
 

history/260729-TREN-Jurisdiction-Africa.md

@@ -0,0 +1,30 @@
+# TREN Jurisdiction Research: Africa (Representative Jurisdictions)
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0005-enforcement-network-research.md` T07)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29). Representative-jurisdiction survey, not exhaustive, per the workplan's own scoping caution.
+
+---
+
+## 1. South Africa: a clean statutory cap, close to but below the Licensor's original 50%
+
+The Contingency Fees Act 66 of 1997 permits South African attorneys two contingency structures: (a) their normal fee, contingent on success, with no statutory cap on the fee amount itself; or (b) a "success fee" in addition to the normal fee, where the **combined total may not exceed 25% (including VAT) of the capital sum recovered, or double the attorney's normal fee, whichever is lower**. South African courts have invalidated contingency agreements that don't comply with the Act's structure.
+
+**Direct implication for TREN:** South Africa is a clean, statutorily-confirmed single-role jurisdiction, but at a materially lower ceiling (25%, or double normal fees if lower) than the Licensor's proposed 50% — closer to the German/French continental pattern's outcome (via a different mechanism: a hard percentage cap rather than a narrow-gate restriction) than to the UK's 50% DBA ceiling. This is now the **second jurisdiction (after China) where the realistic ceiling is well below 50%**, not merely a different structural path to the same number.
+
+## 2. OHADA: no contingency-fee finding — genuinely unresearched, not assumed
+
+This pass found substantial material on OHADA's business-law harmonization (uniform acts directly enforceable in the 17 member states, a Common Court of Justice and Arbitration in Abidjan) but **no specific information on quota litis or contingency-fee rules** within the OHADA framework or its member states' individual bar rules. Given OHADA's member states are overwhelmingly Francophone and civil-law, the French *pactum de quota litis* prohibition (`history/260729-TREN-Jurisdiction-Germany-EU.md` §2) is a plausible analog — but this is an **inference, not a confirmed finding**, and should not be treated as researched. This is flagged honestly rather than papered over with an assumption.
+
+## 3. Summary for the WP-0005 feasibility matrix (T10)
+
+| Question | South Africa | OHADA zone |
+|---|---|---|
+| Direct lawyer contingency fee available? | Yes, capped at 25% (or double normal fee, if lower) | Not confirmed — plausible French-pattern restriction, not verified |
+| Litigation funding regulatory status | Not confirmed in this pass | Not confirmed in this pass |
+| Recommended TREN structure | Single-role at the 25%/double-fee cap | Treat as unresearched; do not assume single-role or split-role without dedicated follow-up |
+
+## 4. Open items for T10 synthesis
+
+- OHADA member-state contingency-fee rules require a dedicated follow-up pass before any recommendation — do not extrapolate from France without confirmation.
+- South Africa's litigation-funding market maturity was not researched in this pass (only the attorney-fee cap was confirmed).
+- Neither Nigeria nor Kenya nor Egypt (the other major economies the workplan flagged as needing their own research before use) were touched in this pass at all.

history/260729-TREN-Jurisdiction-Argentina.md

@@ -0,0 +1,35 @@
+# TREN Jurisdiction Research: Argentina
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0005-enforcement-network-research.md` T04)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. Pacto de cuota litis: permitted, but capped and jurisdiction-variable within Argentina itself
+
+Unlike Germany or France, Argentina generally **permits** contingency-fee arrangements (*pacto de cuota litis*) for abogados — but the caps vary by sub-jurisdiction and case type, and are more restrictive than the Licensor's proposed 50%:
+
+- **City of Buenos Aires:** fee capped at **35%** of the result, regardless of how many agreements or professionals are involved — this can rise to **50%** ("half of the net result") only if the lawyer expressly assumes the costs/cost-liability risk of the case (i.e., a genuine risk-shifting arrangement, not a plain fee agreement).
+- **Labor matters:** capped at 20% of the labor credit, nationally.
+- **Other provinces:** commonly cap at one-third (≈33%) of the net result.
+- Formal requirement: the agreement must be written in duplicate and may be registered with the relevant provincial bar association.
+
+**Direct implication for TREN:** Argentina is the **first jurisdiction in this research program where a single-role Enforcement Partner is legally available, but the Licensor's proposed 50% figure is not the default** — 35% is the ordinary Buenos Aires ceiling, and 50% is available only if the Enforcement Partner contractually takes on the cost/cost-liability risk of the Enforcement Action, which maps quite naturally onto the concept doc's Litigation Funder role (§8) even in a jurisdiction that doesn't strictly require the funder/counsel split for professional-conduct reasons. This is a useful finding: **the 50%-with-risk-assumption structure Argentina already uses natively resembles the Litigation Funder model designed for Germany**, suggesting the EPA's split-role option (`history/260729-TREN-MechanismDesign.md`) may be worth offering even in jurisdictions where it isn't strictly mandatory, if it lets the Contingency Share reach 50% rather than being capped lower.
+
+## 2. No dedicated litigation-funding regime found in this pass
+
+This research pass did not surface a dedicated Argentine third-party litigation funding statute or regulator (distinct from the pacto de cuota litis rules governing lawyers directly) — treat this as an area requiring deeper research before relying on a Litigation Funder structure in Argentina specifically, rather than assuming one is unnecessary because direct lawyer contingency fees are already available.
+
+## 3. Summary for the WP-0005 feasibility matrix (T10)
+
+| Question | Argentina |
+|---|---|
+| Direct lawyer contingency fee available? | Yes, capped — 35% ordinarily in Buenos Aires City, 50% only with risk assumption, ~33% in other provinces, 20% in labor matters |
+| Structured alternative needed? | Not strictly required, but the "50% with risk assumption" variant is structurally similar to the Litigation Funder model |
+| Litigation funding regulatory status | Not found in this pass — flag as under-researched, not confirmed absent |
+| Recommended TREN structure | Single-role Enforcement Partner at the applicable provincial cap; consider the risk-assumption variant to reach 50% where the case supports it |
+
+## 4. Open items for T10 synthesis
+
+- Confirm which cap applies to a commercial/IP claim specifically (none of the three named categories — general judgment result, labor, social-security/alimony — obviously fits an unauthorized-Commercial-Use claim; likely the general ~33-35% "net result of the judgment" category, but not confirmed against a case example in this pass).
+- Research whether a dedicated Argentine litigation-funding market or regulatory framework exists, given none was found here.

history/260729-TREN-Jurisdiction-AsiaPacific.md

@@ -0,0 +1,38 @@
+# TREN Jurisdiction Research: Asia-Pacific (Singapore, Japan, Australia)
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0005-enforcement-network-research.md` T08)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. Singapore: liberalized, but only for a specific, narrow proceeding list
+
+Since 4 May 2022, Singapore permits Conditional Fee Agreements (CFAs) between lawyers and clients — but **only** for international/domestic arbitration, certain Singapore International Commercial Court (SICC) proceedings, and related court/mediation proceedings. Fee structures include "win, more fee," "no win, no fee," and "no win, less fee," with a success fee that can form part of the arrangement. The regime extends to registered foreign lawyers/practices, not just Singapore-qualified ones.
+
+**Direct implication for TREN:** unlike the UK's or Australia's broader reforms, Singapore's liberalization is **proceeding-type-limited**, not a general permission. A straightforward Enforcement Action for unauthorized Commercial Use, litigated in the ordinary Singapore courts (not arbitration or SICC), would very likely **not** qualify for a CFA under this regime as currently scoped — a real constraint the EPA template needs to account for by routing Singapore Enforcement Actions toward arbitration or SICC where the fact pattern allows, or falling back to a non-contingent fee structure otherwise.
+
+## 2. Japan: broadly permitted by self-regulation, but with a critical fee-splitting trap for the Funder model
+
+Contingency fees are permitted in Japan and commonly used; the Japan Federation of Bar Associations abolished its formal percentage-fee schedule in 2004, leaving attorneys free to use hourly, deferred/success-fee, partial or full contingency, or fixed-fee structures. Pure 100% contingency is not explicitly prohibited but is rare in practice, likely deterred by professional-ethics interpretation rather than hard rule.
+
+**Critical finding:** Article 12 of the Basic Rules on the Duties of Practicing Attorneys **prohibits an attorney from splitting fees with any person who is not a lawyer or a legal professional corporation.** This directly threatens the Litigation Funder/Local Counsel split model (`history/260729-TREN-MechanismDesign.md`) as designed: if the Funder (a non-lawyer entity) is meant to receive the Contingency Share and separately compensate Local Counsel, that could itself resemble a prohibited fee-split arrangement from the lawyer's side, depending on exactly how the payment flow is structured. **This is the first jurisdiction in this research program where the split-role design itself — not just the single-role fallback — has a plausible compliance problem**, and needs specific structuring advice (e.g., ensuring the Funder contracts and pays counsel in a manner that isn't characterized as fee-splitting) before Japan is treated as either single-role or split-role viable.
+
+## 3. Australia: federally mixed, but litigation funding itself is mature and well-established
+
+Contingency fees for lawyers are, as a general rule, prohibited or restricted in most Australian states/territories — **Victoria is the first and (as of this research) only jurisdiction to lift the ban**, and only for class actions in the Supreme Court of Victoria specifically, following a 2018 Victorian Law Reform Commission recommendation. Federal courts do not have the power to allow solicitors a percentage cut of a class action settlement (confirmed by the High Court). Separately, and much more broadly, **third-party litigation funding is a mature, well-regulated market across Australia** generally, independent of the lawyer-contingency-fee question.
+
+**Direct implication for TREN:** Australia is a strong candidate for the **split-role model by default** (Litigation Funder + separately-paid Local Counsel), given the funding market's maturity, rather than waiting for contingency-fee reform to spread beyond Victorian class actions. This is a different reason for the split-role recommendation than Germany's (narrow professional-conduct exception) or India's (flat prohibition) — here it's simply that the funding market is the more developed, lower-friction path already.
+
+## 4. Summary for the WP-0005 feasibility matrix (T10)
+
+| Question | Singapore | Japan | Australia |
+|---|---|---|---|
+| Direct lawyer contingency fee available? | Only for arbitration/SICC/mediation-related proceedings | Yes, broadly, via bar self-regulation (pure 100% contingency rare in practice) | Only in Victoria, only for class actions |
+| Structured alternative needed? | Yes, for ordinary litigation outside the permitted proceeding list | Caution: Article 12 fee-splitting rule may complicate the split-role Funder model itself | Split-role via the mature litigation-funding market, not contingency-fee reform |
+| Recommended TREN structure | Route to arbitration/SICC where possible; otherwise non-contingent fee | Needs bespoke structuring to avoid Article 12 fee-splitting characterization — flag for specialist review before using either single- or split-role | Split-role via an established Australian litigation funder |
+
+## 5. Open items for T10 synthesis
+
+- Japan requires dedicated specialist input on how to structure the Funder/Counsel payment flow without triggering Article 12 — this is a genuinely open compliance question, not just an undecided design preference.
+- Confirm whether Singapore's proceeding-type list has expanded since the 2022 reform before finalizing the "arbitration/SICC only" constraint.
+- Monitor Australian state-by-state contingency-fee reform (Victoria's may not remain the only jurisdiction) rather than treating the current mixed picture as static.

history/260729-TREN-Jurisdiction-China.md

@@ -0,0 +1,44 @@
+# TREN Jurisdiction Research: China
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0005-enforcement-network-research.md` T06)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. Contingency fees are permitted but nationally capped on a sliding scale, well below 50%
+
+China's Ministry of Justice, jointly with the National Development and Reform Commission and the State Administration for Market Regulation, issued national rules standardizing and capping contingency ("risk agency") fees by amount in dispute:
+
+| Amount in dispute (CNY) | Maximum contingency percentage |
+|---|---:|
+| < 1 million | 18% |
+| 1–5 million | 15% |
+| 5–10 million | 12% |
+| 10–50 million | 9% |
+| > 50 million | 6% |
+
+This is a **significant reduction from a prior 30% maximum**. Contingency fees are additionally prohibited outright in criminal matters, administrative litigation, state compensation cases, mass/collective litigation, family/inheritance disputes, and cases implicating certain public interests.
+
+**Direct implication for TREN: China is the clearest confirmation yet that a flat global 50% Contingency Share cannot work as a single figure.** Even in the best case (a claim under 1 million CNY), the Chinese statutory ceiling is 18%, dropping steeply as claim value rises — the inverse of what a Licensor might expect (larger, more valuable Enforcement Actions get a *smaller* percentage ceiling, not a larger one). Any EPA template for China must use this sliding scale directly, not attempt to negotiate around it.
+
+## 2. The "risk agency fee" ("no win, no fee") structure is a recognized, separate mechanism
+
+Beyond the percentage-of-recovery contingency fee, Chinese practice also recognizes a distinct "risk agency" fee method where the lawyer is paid nothing (or a reduced fixed amount) if the case is lost, and a fixed amount or percentage (within the same caps above) if won. This is conceptually similar to the German §4a and UK CFA "fee-plus-uplift" patterns found elsewhere in this research program, not a separate legal category requiring new design work.
+
+## 3. Foreign-related contract requirement directly affects EPA design, not just the CUA/License
+
+Chinese law generally requires a contract to be **"foreign-related"** (涉外) for the parties to validly choose a foreign governing law at all — this finding, made primarily for WP-0004's governing-law question, is equally relevant here: an Enforcement Partner Agreement between the Licensor (likely foreign) and Chinese Local Counsel is itself a contract, and its own governing law and fee structure should very likely be drafted under Chinese law and denominated in CNY against the sliding scale above, not assumed to follow whatever governing law the License/CUA use for the underlying Enforcement Action.
+
+## 4. Summary for the WP-0005 feasibility matrix (T10)
+
+| Question | China |
+|---|---|
+| Direct lawyer contingency fee available? | Yes, but capped on a sliding scale (18% down to 6%), well below 50% at every tier |
+| Structured alternative available? | "Risk agency" (no-win-no-fee) fee, same caps apply |
+| Litigation funding regulatory status | Not confirmed in this pass — flag as under-researched |
+| Recommended TREN structure | Single-role Enforcement Partner at the applicable statutory percentage tier; the EPA itself should likely be governed by Chinese law given the foreign-related contract constraint (§3) |
+
+## 5. Open items for T10 synthesis
+
+- Whether third-party litigation funding (as distinct from the lawyer's own risk-agency fee) is separately regulated in China — not confirmed in this pass.
+- Confirm whether an unauthorized-Commercial-Use claim would fall into any of the prohibited case-type categories (mass/collective litigation being the closest concern if many similar violations are pursued together) before assuming the sliding-scale contingency fee applies cleanly.

history/260729-TREN-Jurisdiction-India.md

@@ -0,0 +1,32 @@
+# TREN Jurisdiction Research: India
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0005-enforcement-network-research.md` T05)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. Advocates are flatly prohibited from contingency fees — and litigation funding is explicitly not
+
+Rule 20 of the Bar Council of India Rules, 1961 is unambiguous: "an advocate shall not stipulate for a fee contingent on the results of litigation or agree to share the proceeds thereof." This is reinforced by Rule 21 (no buying/trafficking in an interest in the litigation's subject matter) and Rule 9 (no acting where the advocate has a pecuniary interest). Unlike Germany's narrow-but-existing exceptions, **India has no exception gate at all** for advocates directly — this is a flat, unqualified prohibition, the strictest single-role bar found in this research program so far.
+
+However, research confirms **third-party litigation funding is not prohibited** in India: a non-lawyer funder may fund litigation and be repaid based on outcome, and there is no prohibition on that funder being paid on a percentage/outcome basis — the restriction applies specifically to the advocate's own fee, not to funding arrangements generally.
+
+**Direct implication for TREN: India is the clearest, cleanest confirmation of the split-role model's necessity and validity.** The Litigation Funder/Local Counsel structure (`history/260729-TREN-MechanismDesign.md`) is not a workaround of uncertain legality here — it maps exactly onto a distinction Indian regulation already draws cleanly: the **Litigation Funder** takes the Contingency Share (percentage-of-outcome, permitted for a non-advocate funder), and **Local Counsel** is paid separately and cannot receive any part of that percentage (rule-mandated, not just cautious drafting).
+
+## 2. A live legal-reform debate exists — worth monitoring, not designing around yet
+
+Research surfaced ongoing academic and practitioner debate (e.g., "Feevolution," Kluwer Arbitration Blog) about whether India's prohibition should be relaxed specifically for arbitration matters, given contingency fees' role in access to justice and given India's push to become an arbitration hub. This is a live reform conversation, not yet a rule change — do not assume future liberalization when designing the current EPA template for India, but note it as a jurisdiction to re-check periodically.
+
+## 3. Summary for the WP-0005 feasibility matrix (T10)
+
+| Question | India |
+|---|---|
+| Direct lawyer contingency fee available? | No — flatly prohibited, no exception gates (Bar Council of India Rules, Rule 20) |
+| Structured alternative needed? | Yes, mandatorily — split-role is not optional in India |
+| Litigation funding regulatory status | Explicitly permitted for non-lawyer funders, including outcome-based fee |
+| Recommended TREN structure | Split-role: Litigation Funder holds the Contingency Share contract; Local Counsel is retained and paid separately under an ordinary (non-contingent) fee arrangement |
+
+## 4. Open items for T10 synthesis
+
+- Whether India's split-role structure requires any additional registration or disclosure for the funder specifically (a distinct question from "is it permitted at all," which this pass confirmed cleanly) — not researched in this pass.
+- Monitor the ongoing arbitration-specific contingency-fee reform debate for future EPA template updates, without designing around it now.

history/260729-TRSL-Jurisdiction-Africa.md

@@ -0,0 +1,28 @@
+# TRSL Jurisdiction Research: Africa (Representative Jurisdictions)
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0004-global-jurisdiction-research.md` T07)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29). Representative-jurisdiction survey, not exhaustive, per the workplan's own scoping caution.
+
+---
+
+## 1. This pass did not find CUA-specific contract-law findings for either anchor jurisdiction
+
+Unlike the other WP-0004 jurisdiction tasks, this research pass's searches were weighted toward `workplans/TREV-WP-0005-enforcement-network-research.md` T07's contingency-fee question (see `history/260729-TREN-Jurisdiction-Africa.md`) and did not separately surface South African liability-cap/indemnification enforceability case law, POPIA's specific requirements for a CUA-style Data Processing Addendum, or OHADA's harmonized commercial-contract uniform acts' treatment of liability caps or choice of law. **This is a genuine gap in this pass, not a finding that these are low-risk** — flagged honestly rather than silently left blank.
+
+## 2. What is confirmed, carried over from the TREN research pass
+
+- **OHADA** is a real, directly-enforceable harmonized business-law framework across 17 (mostly Francophone, civil-law) member states, with its own apex court (Common Court of Justice and Arbitration, Abidjan) — this at least confirms OHADA member states share a common commercial-law framework, which is a meaningful head start for eventually drafting a single OHADA-wide rider rather than needing one per member state, if OHADA's uniform acts do turn out to cover the relevant CUA topics (not yet confirmed).
+- **South Africa** operates under its own domestic legal system (common-law derived, distinct from OHADA) — a South African rider would need to be researched independently of any OHADA finding, not treated as covered by it.
+
+## 3. Summary for the WP-0004 feasibility matrix (T10)
+
+| Question | South Africa | OHADA zone |
+|---|---|---|
+| Liability cap / indemnification enforceability | **Not researched — open** | **Not researched — open** |
+| Data protection regime | POPIA exists (referenced, not researched in depth) | Not researched |
+| Foreign governing-law/venue enforceability | Not researched | Not researched |
+
+## 4. Open items for T10 synthesis
+
+- This task should be re-run with contract-law-specific searches (POPIA requirements, South African liability-cap case law, OHADA's Uniform Act on General Commercial Law provisions if any address liability/choice-of-law) before T10 can treat Africa as adequately covered for the CUA's own terms, as distinct from the Enforcement Network's contingency-fee question.
+- Nigeria, Kenya, and Egypt remain completely unresearched for both workplans, as originally scoped.

history/260729-TRSL-Jurisdiction-Argentina.md

@@ -0,0 +1,32 @@
+# TRSL Jurisdiction Research: Argentina
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0004-global-jurisdiction-research.md` T04)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. Choice-of-law: B2B clauses are respected, consumer protection is not waivable
+
+Argentine courts generally accept party autonomy in choice-of-law clauses for B2B contracts, consistent with the Código Civil y Comercial de la Nación (in force since 2015). However, Argentina's Consumer Protection Law (Ley 24.240, 1993, amended through 2016) is mandatory for consumer contracts and **cannot be waived by a choice-of-law clause** — its protections (joint/strict liability, information duties, restrictions on liability waivers) apply "irrespective of the technological complexity of the product or service."
+
+**Direct implication:** exactly the same recurring pattern already found in every other jurisdiction in this research program — a B2B governing-law clause is respected, but the Commercial-Use-vs-individual-consumer edge case (working default Q2) is where Argentine consumer law would override the CUA's terms. This is now the fourth jurisdiction (after Germany, the EU generally, and implicitly the US via CCPA's former B2B carve-out) where this exact boundary is the operative risk, not a jurisdiction-specific novelty — worth stating in T10's synthesis as a **cross-jurisdictional pattern**, not a per-country footnote repeated five times.
+
+## 2. Data protection: Argentina already has EU adequacy — the easiest jurisdiction for CUA §11 so far
+
+Argentina's Personal Data Protection Law (PDPL, 2000) was the first in Latin America to receive an EU adequacy decision, granted in 2003 and reconfirmed in a January 2024 review citing Argentina's accession to Council of Europe Convention 108/108+, clear public-authority-access rules, and an independent supervisory authority. Because of this adequacy status, **EU-to-Argentina personal data transfers require no additional safeguards** (no SCCs needed) — a materially simpler position than most other non-EU jurisdictions in this research program.
+
+**Direct implication:** for CUA §11's eventual Data Processing Addendum, an Argentine Customer is one of the lowest-friction cases found so far — the PDPL's substantive alignment with GDPR-style concepts plus the standing adequacy decision means a shared EU/Argentina data-processing approach is plausible, unlike the UK (diverging, per the Germany/EU/UK deepening passes) or (as will be checked) China (expected to be materially stricter).
+
+## 3. Summary for the WP-0004 feasibility matrix (T10)
+
+| Question | Argentina |
+|---|---|
+| B2B choice-of-law enforceable? | Yes, generally respected under the Código Civil y Comercial |
+| Consumer-contract carve-out risk? | Yes — Ley 24.240 is mandatory and non-waivable, same recurring Q2 edge case |
+| Data protection regime | PDPL (2000), EU-adequate since 2003, reconfirmed 2024 — low friction relative to most jurisdictions researched so far |
+| Distinct from broader Latin America? | Not yet checked — this task researched Argentina specifically, per the workplan's own caution against over-generalizing to the region |
+
+## 4. Open items for T10 synthesis
+
+- Confirm whether other major Latin American economies (Brazil's LGPD, Mexico) share Argentina's EU-adequacy status or diverge — Brazil's LGPD in particular is modeled on GDPR but Brazil itself does not (yet) hold an EU adequacy decision, a meaningful difference from Argentina; not researched in this pass.
+- The recurring "B2B respected, consumer law mandatory" pattern across Germany/EU, US (via CCPA), and now Argentina suggests CUA Appendix A item 1 (governing law) and the Q2 commercial-use definition are more tightly linked than previously stated — recommend the T10 synthesis treat them as one combined risk area rather than two separate open items.

history/260729-TRSL-Jurisdiction-AsiaPacific.md

@@ -0,0 +1,30 @@
+# TRSL Jurisdiction Research: Asia-Pacific (Singapore, Japan, Australia)
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0004-global-jurisdiction-research.md` T08)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. Australia: the expanded Unfair Contract Terms regime applies directly and materially to the CUA
+
+Australia's Unfair Contract Terms (UCT) regime under the Australian Consumer Law was significantly expanded effective 9 November 2023: it now prohibits unfair terms in **standard form contracts with both consumers and small businesses**, removed the prior monetary contract-value threshold entirely, and expanded the small-business definition to any business with **fewer than 100 employees or under $10 million turnover** in the prior year. Courts can now impose substantial per-term penalties, and remedies can include refunds, return of property, or provision of services.
+
+**Direct implication — this is the single most consequential finding in the entire WP-0004 program so far:** `specs/TargetRevenueCommercialUseAgreement-V1C1.md` is, by its own repeated description in this research program, a **standard form contract**, and the great majority of realistic Customers (independent developers, small product companies — exactly the PRD's own named stakeholders) will fall within Australia's expanded small-business threshold. This means Australia's UCT regime is not a remote or edge-case risk the way some other jurisdictions' consumer-protection carve-outs have been (Rome I, CCPA, Ley 24.240) — it applies **by default** to the ordinary, expected case of a small commercial Customer in Australia, with real monetary penalties attached. Every CUA clause that could be characterized as unfair (the liability cap's proportionality, the audit rights' scope, the termination provisions) should be reviewed against this regime specifically before any Australian small-business Customer is onboarded, not treated as a generic "check per deployment" item.
+
+## 2. Singapore and Japan: data-protection regimes referenced but not researched in depth this pass
+
+This research pass focused its search budget on Australia's UCT finding (§1) given its unusually direct and material relevance, and on `workplans/TREV-WP-0005-enforcement-network-research.md` T08's contingency-fee question (see `history/260729-TREN-Jurisdiction-AsiaPacific.md`). Singapore's Personal Data Protection Act (PDPA) and Japan's Act on the Protection of Personal Information (APPI) are both referenced in the original task description as relevant data-protection regimes for CUA §11, but **neither was researched in depth in this pass** — this is a gap, not a low-risk finding, and should not be read as "nothing to worry about" for either regime.
+
+## 3. Summary for the WP-0004 feasibility matrix (T10)
+
+| Question | Australia | Singapore | Japan |
+|---|---|---|---|
+| Standard-form/small-business unfair-terms exposure | **High and direct** — expanded UCT regime (Nov 2023) covers most realistic CUA Customers by default, with real penalties | Not researched in this pass | Not researched in this pass |
+| Data protection regime | Not separately researched (beyond the UCT finding) | PDPA — referenced, not researched | APPI — referenced, not researched |
+| Foreign governing-law/venue enforceability | Not researched | Not researched | Not researched |
+
+## 4. Open items for T10 synthesis
+
+- **Highest priority for any future pass:** review `specs/TargetRevenueCommercialUseAgreement-V1C1.md` clause-by-clause against Australia's UCT "unfairness" factors (the reforms echo, and go further than, the UK's UCTA and Germany's Transparenzgebot patterns already found in this program — worth treating as a third data point in that same convergent-drafting-recommendation family, per `history/260729-TRSL-Jurisdiction-UK-Deepened.md` §2).
+- Singapore PDPA and Japan APPI both need dedicated research passes before CUA §11 can address them specifically.
+- Foreign governing-law/venue enforceability in Singapore, Japan, and Australia was not researched in this pass at all.

history/260729-TRSL-Jurisdiction-China.md

@@ -0,0 +1,33 @@
+# TRSL Jurisdiction Research: China
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0004-global-jurisdiction-research.md` T06)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. Foreign governing law is only available for "foreign-related" contracts, and is discretionarily overridable
+
+Confirmed as a hard constraint, not a drafting nicety: under PRC law, parties may only choose a foreign governing law if their contract is legally "foreign-related" (涉外); a domestic Chinese contract cannot opt into foreign law regardless of what the parties write. Even where a foreign law is validly chosen, PRC law will displace it if applying the foreign law would "offend PRC's public interest" — a term research describes as vague and under-defined, meaning any governing-law selection is potentially subject to override on a ground that is hard to predict in advance. Practical guidance found in this pass recommends, for contracts intended to be enforced in China, specifying a Chinese court and Chinese governing law directly, since contracts drafted in English or under foreign law face "substantial hurdles" and courts equipped for their own legal system tend to produce less favorable outcomes for the foreign party when foreign elements are introduced.
+
+**Direct implication:** this confirms the recommendation already anticipated in `workplans/TREV-WP-0004-global-jurisdiction-research.md` T06's original task description — **China very likely needs its own governing-law/venue addendum, not the same clause used elsewhere.** A single global governing-law clause (whatever License Appendix A item 6 / CUA Appendix A item 1 eventually settles on) should not be assumed to apply to Chinese Customers; the realistic path is a China-specific rider naming Chinese law and a Chinese venue, consistent with the pattern already emerging for the Enforcement Partner Agreement (`history/260729-TREN-Jurisdiction-China.md` §3).
+
+## 2. PIPL cross-border data transfer: three mandatory pathways, no informal option
+
+China's Personal Information Protection Law (PIPL) Article 38 requires any of three specific compliance pathways before personal information may leave China: (1) a CAC-organized security assessment (for higher-risk transfers), (2) certification by a professional institution under a framework finalized as recently as October 2025 (effective January 2026), or (3) a CAC-standard-format contract with the overseas recipient, filed with the provincial CAC after a self-assessment. Regardless of pathway, the transferring entity must separately notify affected individuals, obtain **separate consent** specifically for the cross-border transfer, and conduct a personal information protection impact assessment.
+
+**Direct implication:** this is categorically stricter than every other data-protection regime found in this research program (GDPR, UK GDPR, Argentina's PDPL, India's permissive "negative list" DPDPA). CUA §11's eventual Data Processing Addendum cannot use a single shared clause for a Chinese Customer — PIPL requires its own dedicated compliance pathway (most likely the standard-contract route for an ordinary commercial relationship, given the security-assessment route is reserved for higher-risk/high-volume transfers), separate consent language, and a mandatory impact assessment with no informal alternative.
+
+## 3. Summary for the WP-0004 feasibility matrix (T10)
+
+| Question | China |
+|---|---|
+| Foreign governing law/venue enforceable? | Only for "foreign-related" contracts, and even then subject to a vague "public interest" override — practical guidance recommends Chinese law/venue directly for contracts meant to be enforced there |
+| Liability cap / indemnification enforceability | Not researched in this pass — flag as open |
+| Data protection regime | PIPL — three mandatory pathways (security assessment, certification, or standard contract), separate consent required, no informal option; strictest regime found in this program |
+| Recommended structure | Dedicated China-specific governing-law/venue rider and a dedicated PIPL-compliant Data Processing Addendum, not shared clauses |
+
+## 4. Open items for T10 synthesis
+
+- Liability-cap and indemnification enforceability under Chinese contract law were not researched in this pass — needed before a China rider can be drafted.
+- Confirm which of PIPL's three transfer pathways best fits an ordinary CUA data relationship (likely the standard-contract route) with a dedicated follow-up pass before drafting the addendum.
+- This is now the **second jurisdiction (after Germany for TREN)** where this research program's default assumption — one shared clause can serve most jurisdictions — clearly breaks down. T10's synthesis should treat "which jurisdictions need a dedicated rider vs. a shared clause" as a first-class output, not an afterthought.

history/260729-TRSL-Jurisdiction-Germany-EU-Deepened.md

@@ -0,0 +1,46 @@
+# TRSL Jurisdiction Research: Germany and EU-Wide (Deepened)
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0004-global-jurisdiction-research.md` T01)
+**Not legal advice.** Extends `history/260729-TRSL-Jurisdiction-StandardTerms.md` (WP-0001-T05). Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. Rome I Regulation: B2B choice-of-law clauses are generally enforceable
+
+Regulation 593/2008 ("Rome I") governs which national law applies to contractual obligations across EU member states. Article 3(1) establishes strong party autonomy: "a contract shall be governed by the law chosen by the parties," expressly or by clear inference, and the choice may cover the whole or only part of a contract. For **B2B contracts specifically**, this choice is generally enforceable without the restrictions that apply to consumer contracts.
+
+The consumer-contract exception is the one that matters here, and it tracks exactly the same B2B/B2C boundary already surfaced in `history/260729-TRSL-Jurisdiction-StandardTerms.md`: a chosen governing law may not deprive a **consumer** of protections that would otherwise apply under the law that would govern absent choice. Since `specs/TargetRevenueCommercialUseAgreement-V1C1.md` is explicitly a *Commercial* Use Agreement, this exception should not usually bite — but the same recurring edge case applies (working default Q2: an individual/sole-proprietor Customer arguably a "consumer" despite the Commercial Use gate).
+
+**Direct implication:** the License §11.1 / CUA §18 governing-law clause is enforceable under Rome I for genuine B2B relationships without special drafting beyond ordinary clarity. The risk is not Rome I itself, but the same recurring Commercial-Use-vs-consumer boundary question already tracked as an open item.
+
+## 2. EU Late Payment Directive (2011/7/EU): relevant to CUA §3 payment terms
+
+Directive 2011/7/EU applies to all B2B (and B2G) commercial transactions across the EU. It gives a creditor three automatic rights on late payment, without needing a reminder: statutory interest, a minimum €40 compensation, and recovery of reasonable collection costs. Default payment terms are 60 days unless the parties expressly agree otherwise and the term is not "grossly unfair" to the creditor.
+
+**Direct implication:** `specs/TargetRevenueCommercialUseAgreement-V1C1.md` §3.5 currently leaves late-payment interest as an unresolved candidate note ("standard commercial blank"). For any Customer within the EU, this Directive supplies a **default** the Agreement doesn't need to invent from scratch — the Agreement can either adopt the Directive's statutory rate/compensation as its own default, or state its own terms provided they are not "grossly unfair" to the Licensor as creditor. This closes part of CUA Appendix A item 7 for EU Customers specifically (not globally).
+
+## 3. GDPR/UK GDPR: CUA §11 needs a genuine Data Processing Addendum, and UK/EU are now meaningfully diverging
+
+Beyond confirming GDPR applies (already noted in the CUA's placeholder §11), this pass found that **UK GDPR and EU GDPR are diverging in practice, not just in name**, following the UK's Data (Use and Access) Act 2025 (DUAA): an expanded "recognised legitimate interests" list with no EU equivalent, reformed ICO governance, relaxed cookie-banner requirements for UK-only sites, and other changes. The EU renewed the UK's adequacy decision in December 2025 (valid to December 2031), but that adequacy status is explicitly contingent on divergence not going far enough to break equivalence.
+
+**Direct implication:** CUA §11 cannot be drafted as a single "GDPR" clause and treated as covering both the EU and UK — it needs to at least flag that a UK Customer's data-processing terms may need separate handling if UK divergence continues, and that the EU-UK adequacy decision itself is a moving target the Agreement should not assume is permanent. This is a new, more specific finding than the CUA's current placeholder acknowledges.
+
+## 4. California CCPA/CPRA: the B2B exemption that used to help is gone
+
+Earlier CCPA drafts exempted B2B personal information exchanges, but that exemption **expired on January 1, 2023** (per AB 1355) and was not renewed — CCPA/CPRA now applies to B2B data relationships on the same basis as consumer ones, subject to the Act's general scope and business-size thresholds.
+
+**Direct implication:** a US Customer's personnel or contact data processed under the Commercial Use Agreement (e.g., billing contacts, technical contacts) is not automatically shielded from CCPA/CPRA merely because the relationship is B2B — this needs to be factored into CUA §11's eventual Data Processing Addendum for any California-connected Customer, not assumed away by the relationship being commercial.
+
+## 5. Summary for the WP-0004 feasibility matrix (T10)
+
+| Question | Germany/EU |
+|---|---|
+| B2B choice-of-law enforceable? | Yes, under Rome I Article 3(1), for genuine B2B relationships |
+| Consumer-contract carve-out risk? | Yes — same recurring Commercial-Use-vs-individual edge case as working default Q2 |
+| Late-payment default available? | Yes — Directive 2011/7/EU (60 days, statutory interest, €40 minimum compensation) can fill CUA §3.5's current blank for EU Customers |
+| Data protection regime | EU GDPR and UK GDPR now meaningfully diverging (DUAA 2025); EU-UK adequacy is time-bound and reviewable, not permanent |
+
+## 6. Open items for T10 synthesis
+
+- Whether to adopt the EU Late Payment Directive's terms as the CUA's global default, or only as an EU-specific rider — a drafting-scope decision, not yet made.
+- Whether the CUA needs two data-processing riders (EU GDPR-based and UK-GDPR-based) rather than one shared clause, given confirmed divergence.

history/260729-TRSL-Jurisdiction-India.md

@@ -0,0 +1,42 @@
+# TRSL Jurisdiction Research: India
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0004-global-jurisdiction-research.md` T05)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. Limitation-of-liability clauses are generally enforceable, with statutory-violation and public-interest limits
+
+Indian courts generally permit contractual limitation of financial exposure, but Section 28 of the Indian Contract Act voids agreements that wholly restrain a party from enforcing its rights in court — a limitation clause cannot function as a complete bar on legal recourse. Courts will not enforce limitation or indemnity clauses that attempt to exclude liability for fraud, personal injury, or statutory obligations, or that otherwise defeat legislative intent or public interest.
+
+**Direct implication:** `specs/TargetRevenueCommercialUseAgreement-V1C1.md` §14's liability cap (not a complete bar on remedies, just a quantum cap) is the kind of clause Indian courts generally do enforce — this is a lower-friction jurisdiction for that specific clause than the UK (UCTA reasonableness test) or the US (unconscionability backstop), provided the cap is not drafted so broadly it reads as excluding a statutory obligation entirely.
+
+## 2. Indemnification: no statutory cap on quantum, carve-outs from the liability cap are standard practice
+
+Research found no statutory restriction on the quantum recoverable under an indemnity clause in Indian commercial practice, and indemnity provisions are commonly drafted to sit **outside** a contract's general limitation-of-liability cap (i.e., the cap applies to ordinary breach damages, not to indemnified third-party claims).
+
+**Direct implication:** this is directly relevant to `specs/TargetRevenueCommercialUseAgreement-V1C1.md` §13, which is currently and deliberately left unwritten (Appendix A item 4, the highest-priority item in that document). If an indemnification clause is eventually drafted, Indian practice confirms the common structural choice — indemnity carved out from the general liability cap — is a defensible starting point for at least this jurisdiction, though the clause's substance (scope of indemnified claims) remains a separate, unresolved drafting question.
+
+## 3. Foreign jurisdiction/governing-law clauses: respected
+
+Indian courts recognize and respect a foreign jurisdiction/governing-law clause in an international contract. This is a comparatively clean finding relative to several other jurisdictions researched, where the answer has required more qualification (Rome I's consumer carve-out, China's expected reluctance per WP-0004 T06's task description).
+
+## 4. Digital Personal Data Protection Act 2023: a "negative list" model, more permissive than GDPR by design
+
+India's DPDPA 2023 (with 2025 Rules) uses a "negative list" approach: cross-border transfers are permitted to all countries **except** any the government specifically restricts by notification — and as of this research pass, no country has been so restricted. This is structurally the opposite of GDPR's adequacy-based "permitted only where a safeguard exists" approach, and is explicitly more flexible. Extraterritorial reach applies to processing connected to offering goods/services to data principals within India, similar in spirit to GDPR's own extraterritorial scope. Additional restrictions apply only to entities designated "Significant Data Fiduciaries."
+
+**Direct implication:** for CUA §11, an Indian Customer is currently a **low cross-border-transfer-friction case** (no restricted-country list yet exists), though the Licensor should not assume this permissiveness is permanent — a future government notification could restrict transfers to a specific country with no advance-warning requirement evident in this research.
+
+## 5. Summary for the WP-0004 feasibility matrix (T10)
+
+| Question | India |
+|---|---|
+| Liability cap enforceable? | Generally yes, subject to Contract Act §28 (no complete bar on remedies) and statutory/public-interest limits |
+| Indemnification quantum capped by statute? | No; common practice carves indemnity out of the general liability cap |
+| Foreign governing-law/venue clause respected? | Yes |
+| Data protection cross-border transfer friction | Low currently ("negative list" model, no restricted countries yet) but not guaranteed to stay that way |
+
+## 6. Open items for T10 synthesis
+
+- Confirm DPDPA 2025 Rules' Significant Data Fiduciary restrictions don't apply to a typical CUA Customer before relying on the "low friction" finding above for a specific deployment.
+- No India-specific software-licensing/delayed-conversion precedent was found in this pass — treat the License's overall structure as untested in Indian courts specifically, same as most jurisdictions in this program.

history/260729-TRSL-Jurisdiction-UK-Deepened.md

@@ -0,0 +1,34 @@
+# TRSL Jurisdiction Research: United Kingdom (Deepened)
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0004-global-jurisdiction-research.md` T03)
+**Not legal advice.** Findings drawn from web research (searched 2026-07-29). Complements `history/260729-TREN-Jurisdiction-UK.md` (WP-0005-T03), which covered UK contingency/conditional-fee enforcement mechanics rather than the CUA's own contract terms.
+
+---
+
+## 1. UCTA 1977's reasonableness test governs the CUA's liability cap directly
+
+The Unfair Contract Terms Act 1977 restricts exclusion and limitation-of-liability clauses primarily in two situations relevant here: excluding/limiting liability for breach when relying on the other party's "standard terms of business," and certain implied-term exclusions in sale/supply of goods and services. A clause subject to UCTA's reasonableness test is enforceable only if fair and reasonable "in all the circumstances which were, or ought reasonably to have been, known to or in the contemplation of the parties" at contract formation. If a term fails the test, it is **not narrowed** — it is simply ineffective, leaving liability uncapped.
+
+**Direct implication:** `specs/TargetRevenueCommercialUseAgreement-V1C1.md` is, by its own description, a standard-form template — precisely the kind of contract UCTA's "standard terms of business" ground targets. §14's liability cap should not be assumed automatically enforceable in the UK; reasonableness factors found in this research (prominence of the clause, proportionality, and clarity about when it applies) are directly actionable: the cap should be presented clearly (not buried), and its 12-months-of-fees measure should be proportionate to the actual Fee level in a given Exhibit A, not a fixed boilerplate figure applied regardless of deal size.
+
+## 2. This reinforces, rather than duplicates, Germany's Transparenzgebot finding
+
+UCTA's reasonableness test and Germany's Transparenzgebot are legally distinct doctrines (one asks "was this reasonable," the other asks "was this clear," and German law can void a clause for unclarity alone regardless of fairness) — but both point the CUA's drafting in the same practical direction: prominent, clearly-flagged, proportionate limitation clauses fare better under both regimes than boilerplate ones. This is worth stating explicitly in any future T10 synthesis as a **convergent drafting recommendation**, not treated as two unrelated jurisdiction-specific footnotes.
+
+## 3. UK GDPR divergence (see also the Germany/EU deepening pass)
+
+Confirmed in `history/260729-TRSL-Jurisdiction-Germany-EU-Deepened.md` §3: the UK's Data (Use and Access) Act 2025 is producing real divergence from EU GDPR (expanded legitimate-interests grounds, relaxed cookie rules, ICO governance changes), and the EU's UK adequacy decision (renewed to December 2031) is contingent on that divergence not going far enough to break equivalence. Not repeated in full here; cross-referenced so this document and the Germany/EU one are read together for any UK-specific CUA drafting.
+
+## 4. Summary for the WP-0004 feasibility matrix (T10)
+
+| Question | United Kingdom |
+|---|---|
+| Liability cap enforceable? | Subject to UCTA 1977 reasonableness test; the CUA's standard-form nature makes this directly applicable, not a remote risk |
+| What makes a cap more likely reasonable? | Prominence, proportionality to deal size, clarity about scope — convergent with (not identical to) German Transparenzgebot's clarity requirement |
+| Data protection regime | UK GDPR, diverging from EU GDPR post-DUAA 2025 (see Germany/EU deepening pass) |
+| Foreign governing-law clause enforceable in UK courts for a commercial contract? | Not separately re-researched in this pass — carried over as still-open from `history/260729-TRSL-Jurisdiction-StandardTerms.md` |
+
+## 5. Open items for T10 synthesis
+
+- Recommend making the CUA §14 liability cap proportionate to Exhibit A's actual Fee amount (e.g., stated as a formula referencing the specific Fee) rather than a flat "12 months of fees" boilerplate applied identically regardless of deal size, specifically to strengthen UCTA reasonableness.
+- UK courts' willingness to enforce a non-UK governing-law clause for a commercial contract was flagged in WP-0004's original task description but not re-confirmed with fresh sources in this pass — treat as still open pending a dedicated fetch if UK is chosen as a candidate governing law.

history/260729-TRSL-Jurisdiction-US-Deepened.md

@@ -0,0 +1,42 @@
+# TRSL Jurisdiction Research: United States (Deepened)
+
+**Document status:** Research artifact, Stage 0 (`workplans/TREV-WP-0004-global-jurisdiction-research.md` T02)
+**Not legal advice.** Extends `history/260729-TRSL-Jurisdiction-StandardTerms.md` §3 (WP-0001-T05). Findings drawn from web research (searched 2026-07-29).
+
+---
+
+## 1. UCC unconscionability: a real but narrow check on the CUA's liability cap
+
+UCC §2-302 lets a court refuse to enforce an unconscionable contract or clause, or limit its application to avoid an unconscionable result. The operative test asks whether, given the commercial background and needs of the relevant trade, a clause is "so one-sided as to be unconscionable" at the time of contracting. UCC §2-719 specifically addresses limitation of remedies and lets courts strike unconscionable limitations, particularly around consequential-damages exclusions.
+
+**Direct implication:** `specs/TargetRevenueCommercialUseAgreement-V1C1.md` §14's fees-paid-in-12-months liability cap is a common, generally-enforceable commercial pattern in the US, but is not immune from an unconscionability challenge if a specific Customer relationship is unusually one-sided (e.g., a take-it-or-leave-it agreement with a very small fee relative to potential exposure). This is a real-but-narrow risk, not a reason to redesign the clause — courts apply this test as a backstop against extreme cases, not as routine scrutiny of ordinary negotiated caps.
+
+## 2. Arbitration clauses: generally strongly enforceable, with a "surprise/unconscionability" exception
+
+Federal Arbitration Act §2 makes written arbitration agreements "valid, irrevocable, and enforceable," with a strong federal policy favoring arbitration. The main exception found in this pass: at least one case held an arbitration clause in a software contract unconscionable and partly invalid where the clause was not seen by the purchaser until after purchase (a "surprise" or lack-of-notice problem, similar in spirit to the transparency concerns already flagged for German Transparenzgebot).
+
+**Direct implication:** if a future V1.0 CUA adds an arbitration clause (not present in the current V1C1 candidate), it should be presented clearly and accepted before or at contract formation, not buried or introduced after the Customer has already committed — this is a US-specific but broadly-good-practice point that also happens to reduce Transparenzgebot-style exposure elsewhere.
+
+## 3. Software-specific UCC coverage remains unsettled (Article 2B was never adopted)
+
+The proposed UCC Article 2B, meant to directly address software licensing, was never adopted as a uniform article; some states adopted variants (Uniform Computer Information Transactions Act, UCITA) while most did not. This means software license enforceability in the US is a patchwork of ordinary contract law, UCC Article 2 (goods) applied by analogy in some courts, and state-specific software/technology statutes, rather than one settled framework.
+
+**Direct implication:** the CUA's US enforceability cannot be evaluated against a single "UCC for software" standard — it should be assessed under general contract law principles plus whichever state's law is chosen as governing law (License Appendix A item 6 / CUA Appendix A item 1), reinforcing that **which US state is named matters**, not just that "US law" applies generically.
+
+## 4. CCPA/CPRA: the B2B exemption is gone, confirmed
+
+As found in the Germany/EU deepening pass (`history/260729-TRSL-Jurisdiction-Germany-EU-Deepened.md` §4), CCPA/CPRA's earlier B2B exemption expired January 1, 2023, and was not renewed. This applies regardless of which EU finding triggered the search — it's a US-specific confirmation that CUA §11's Data Processing Addendum needs to account for California-connected Customers on the same basis as consumer relationships, not exempt them for being commercial.
+
+## 5. Summary for the WP-0004 feasibility matrix (T10)
+
+| Question | United States |
+|---|---|
+| Liability cap enforceable? | Generally yes; UCC §2-302/§2-719 unconscionability is a narrow backstop, not routine scrutiny |
+| Arbitration clause enforceable (if added)? | Strongly favored under FAA §2, but must be clearly presented at/before formation to avoid a "surprise" unconscionability challenge |
+| Single software-specific statute to design against? | No — UCC Article 2B/UCITA was never uniformly adopted; assess under general contract law + the specific state named as governing law |
+| CCPA/CPRA B2B exemption available? | No — expired January 1, 2023 |
+
+## 6. Open items for T10 synthesis
+
+- Which specific US state to recommend as governing law (the CUA currently leaves this fully blank) — California, New York, and Delaware are the commonly-chosen commercial defaults, each with different unconscionability and liability-cap case law depth; not resolved here.
+- Whether to add an arbitration clause to a future CUA version at all, given it is not present in V1C1 today — currently out of scope, flagged only as a drafting consideration if added later.

specs/EnforcementNetworkConcept.md

@@ -157,16 +157,32 @@ Many legal systems restrict or prohibit a lawyer taking a direct percentage of a
 
 Where a jurisdiction does permit a lawyer to be both funder and counsel (the US being the clearest case), the Enforcement Partner role can collapse back into a single party, as originally envisioned. This split-role model is a **proposed design response to a real legal constraint**, not yet confirmed to be sufficient in any specific jurisdiction — third-party litigation funding is itself separately regulated (registration, disclosure, and champerty/maintenance doctrines in some common-law jurisdictions) and needs its own per-jurisdiction check.
 
-### 8.1 Findings so far (`workplans/TREV-WP-0005-enforcement-network-research.md` T01–T03, T09)
+### 8.1 Findings so far (`workplans/TREV-WP-0005-enforcement-network-research.md` T01–T09, all 8 jurisdiction/family tasks done)
 
-Four jurisdictions researched confirm the hypothesis above is directionally correct and give it concrete shape:
+All eight jurisdiction/family tasks are now complete. The pattern is more varied than a simple "civil law needs split-role, common law doesn't" split:
 
-- **Germany** — the single-role model is very likely **not** viable: RVG §4a permits contingency fees only for claims ≤€2,000, debt-collection, or cases where the client would otherwise be deterred, and even then requires a fixed-fee/uplift structure rather than a pure percentage. The split-role structure (§8) is the realistic path (`history/260729-TREN-Jurisdiction-Germany-EU.md`).
-- **France** (second EU data point) — a fixed-fee-plus-uncapped-result-fee structure is permitted (pure percentage-only fees, *pactum de quota litis*, are void); likely single-role-viable with the right fee shape (`history/260729-TREN-Jurisdiction-Germany-EU.md` §2).
-- **United States** — single-role is directly viable; the practical precondition is timely copyright registration of the Milestone Release to unlock statutory damages and fee-shifting that make contingent engagement economically attractive to counsel (`history/260729-TREN-Jurisdiction-US.md`).
-- **United Kingdom** — single-role is directly viable via a Damages-Based Agreement, and the **50% Contingency Share proposed in §5.5 is exactly the UK's statutory maximum** for this case category (not personal injury or employment) — the first jurisdiction where the original 50% figure lands precisely on a real regulatory ceiling rather than an arbitrary round number (`history/260729-TREN-Jurisdiction-UK.md`).
+| Jurisdiction | Single-role viable? | Realistic ceiling | Note |
+|---|---|---|---|
+| Germany | Very likely not | N/A — narrow §4a gates, not percentage-based | Split-role realistic path |
+| France | Likely yes | Uncapped (fixed-fee-plus-result-fee structure) | *Pactum de quota litis* (pure %) void |
+| United States | Yes | No fixed cap (state-bar reasonableness) | Needs timely copyright registration to be economically attractive |
+| United Kingdom | Yes | **50%** (DBA statutory max, "all other cases") | Only jurisdiction where 50% is exactly validated |
+| Argentina | Yes | 35% ordinarily (Buenos Aires City); 50% only with risk-assumption | 50%-with-risk-assumption resembles the Litigation Funder model natively |
+| India | **No** — flat prohibition, no exception gates | N/A | Cleanest confirmation of split-role necessity; funding explicitly permitted |
+| China | Yes | **18% down to 6%**, sliding scale by claim size (larger claims get a *smaller* ceiling) | Also likely needs its own governing-law/venue rider (§8, cross-refs License Appendix A item 6) |
+| South Africa | Yes | **25%** (or 2× normal fee if lower) | Hard statutory cap, confirmed via the Contingency Fees Act itself |
+| OHADA zone | Not confirmed | — | Genuinely unresearched; do not assume the French pattern applies |
+| Singapore | Only for arbitration/SICC/mediation | N/A | Ordinary litigation likely needs the fallback structure |
+| Japan | Yes, broadly | No fixed cap | **Article 12 bans lawyer fee-splitting with non-lawyers — a compliance risk for the split-role model itself**, not just the single-role fallback |
+| Australia | Only Victoria, only class actions | N/A | Litigation funding market is mature nationally — split-role by default, for a different reason than Germany/India |
 
-A concrete Litigation Funder/Local Counsel mechanism design and payment-flow diagram, synthesizing these findings, is at `history/260729-TREN-MechanismDesign.md`. Five jurisdiction/family tasks (Argentina, India, China, Africa, Asia-Pacific) remain open in WP-0005 — the pattern above must not yet be assumed to generalize beyond the four jurisdictions actually researched.
+**Key findings beyond the per-jurisdiction ceiling:**
+
+1. **50% is not a safe global default anywhere except the UK.** Most jurisdictions cap meaningfully lower (18–35%), several ban direct lawyer contingency outright, and the "with risk assumption" pattern that unlocks higher percentages (Argentina) or avoids professional-conduct problems entirely (Germany, India, Australia) recurs often enough that the split-role Litigation Funder structure should probably be the **default** EPA option, with single-role as the jurisdiction-specific exception — the reverse of how the concept was originally framed in §8.
+2. **The split-role structure is not universally safe either.** Japan's Article 12 fee-splitting rule is the first finding in this program suggesting the Funder/Counsel split needs jurisdiction-specific structuring, not just jurisdiction-specific *availability* checking.
+3. **China likely needs a dedicated EPA governing-law rider**, not just a dedicated fee structure — the same foreign-related-contract constraint found in `workplans/TREV-WP-0004-global-jurisdiction-research.md` T06 applies to the EPA itself.
+
+A concrete Litigation Funder/Local Counsel mechanism design and payment-flow diagram (built from the first three jurisdictions researched) is at `history/260729-TREN-MechanismDesign.md` — its §4 feasibility table is now superseded by the fuller table above and should be read alongside it, not in place of it, pending T10's formal synthesis and human-accept update.
 
 ## 9. New legal instrument: Enforcement Partner Agreement (EPA)
 

specs/TargetRevenueCommercialUseAgreement-V1C1.md

@@ -191,11 +191,11 @@ This appendix is not part of the operative agreement text. It tracks what must b
 
 | # | Section | Item | Status | Notes |
 |---|---|---|---|---|
-| 1 | §18 | Governing law and venue selection | **[LEGAL, OPEN]** | Should be resolved jointly with License §11.1 Appendix A item 6 — a Phase's License and its Commercial Use Agreement(s) should ordinarily share a governing law. Global research and proposed resolution tracked in `workplans/TREV-WP-0004-global-jurisdiction-research.md` T09–T10. |
+| 1 | §18 | Governing law and venue selection | **[LEGAL, OPEN]** | Should be resolved jointly with License §11.1 Appendix A item 6. **China (T06) confirmed this cannot be a single global clause**: foreign governing law requires a "foreign-related" contract and remains subject to a vague "public interest" override — a dedicated China rider naming Chinese law/venue is the realistic path, not an exception to a shared clause. All 8 jurisdiction/family tasks in `workplans/TREV-WP-0004-global-jurisdiction-research.md` are now done (T01–T08); T09–T10 (cross-cutting strategy and synthesis) remain open. |
 | 2 | §6 | Audit rights scope, frequency, and cost allocation | **[LEGAL]** | Drafted from common convention, not dedicated research; no WP-0001 task covered commercial-audit norms. |
-| 3 | §14 | Liability cap methodology (fees-paid-in-12-months) | **[LEGAL]** | Common default, not verified against target jurisdictions. Per-jurisdiction enforceability tracked in `workplans/TREV-WP-0004-global-jurisdiction-research.md` (T01–T08 risk matrix, T10 synthesis). |
+| 3 | §14 | Liability cap methodology (fees-paid-in-12-months) | **[LEGAL]** — elevated priority | Common default, now confirmed to face **direct, default-case scrutiny in the UK (UCTA reasonableness) and, most significantly, Australia**, where the November 2023-expanded Unfair Contract Terms regime covers standard-form contracts with any business under 100 employees/$10M turnover by default — i.e., most realistic Customers, not an edge case. Germany's Transparenzgebot, UK's UCTA, and Australia's UCT regime converge on the same drafting fix: make the cap prominent and proportionate to the actual Exhibit A Fee, not flat boilerplate. See `history/260729-TRSL-Jurisdiction-AsiaPacific.md` §1. |
 | 4 | §13 | Indemnification clause — currently unwritten | **[LEGAL, OPEN]** — highest priority in this document | Deliberately left blank rather than guessed; a wrong default here carries real financial exposure. |
-| 5 | §11 | Data Protection — placeholder only, no operative processing terms | **[LEGAL]** | Likely needs a separate Data Processing Addendum, not inline clauses. Per-jurisdiction data-protection regimes (GDPR, PIPL, DPDP Act, POPIA, APPI, etc.) tracked in `workplans/TREV-WP-0004-global-jurisdiction-research.md` T01–T08. |
+| 5 | §11 | Data Protection — placeholder only, no operative processing terms | **[LEGAL]** | Likely needs **multiple** Data Processing Addenda, not one shared clause: EU GDPR and UK GDPR are now confirmed diverging (DUAA 2025); China's PIPL requires one of three mandatory pathways plus separate consent, categorically stricter than the rest; India's DPDPA and Argentina's PDPL (EU-adequate since 2003) are comparatively low-friction; Singapore PDPA and Japan APPI remain unresearched. See the per-jurisdiction `history/260729-TRSL-Jurisdiction-*.md` and `history/260729-TREN-Jurisdiction-*.md` files. |
 | 6 | §9 | Breach-disclosure election mechanism (opt-in, notice period, dispute window) | **[LEGAL]** | First-pass design satisfying License §7.4's informed-consent goal; not legally reviewed. |
 | 7 | §1, §17 | Standard commercial blanks: Affiliate control test, late-payment terms, cross-jurisdictional enforceability of the incorporation-by-reference order of precedence | **[LEGAL]** | Routine drafting, still unresolved. |
 | 8 | §8, §12 | Support/services terms and any associated warranty — reserved, not drafted | **[OPEN]** | Depends on whether a project bundles support here or in a separate Operations and Service Agreement. |

specs/TargetRevenueSourceLicense-V1C1.md

@@ -157,7 +157,7 @@ This appendix is not part of the operative license text. It tracks what must be
 | 3 | §1, §2 | Exact scope of "Noncommercial Use" | **[LEGAL]** | `history/260729-TRSL-PriorArt-Survey.md` §3.3 |
 | 4 | §4 | Patent license clause text, review against local patent law | **[LEGAL]** | `history/260729-TRSL-FutureLicense-PatentPrecedent.md` §4 |
 | 5 | §7 | Whether a cured breach should generate a compensating Target Ledger entry | **[OPEN]** | — |
-| 6 | §11.1 | Governing law and venue selection | **[LEGAL, OPEN]** | `history/260729-TRSL-Jurisdiction-StandardTerms.md` §2–§3; broader global research and proposed resolution tracked in `workplans/TREV-WP-0004-global-jurisdiction-research.md` T09–T10 |
+| 6 | §11.1 | Governing law and venue selection | **[LEGAL, OPEN]** | All 8 jurisdiction/family tasks in `workplans/TREV-WP-0004-global-jurisdiction-research.md` now done (T01–T08); T09 (cross-cutting choice-of-law strategy) and T10 (synthesis) remain open. **China (T06) confirmed a hard constraint**: foreign governing law requires a "foreign-related" contract and is subject to a vague "public interest" override even then — a single global clause will not work for China specifically. |
 | 7 | (all) | Full review under German AGB law (Transparenzgebot) and, where applicable, EU consumer-protection law | **[LEGAL]** | `history/260729-TRSL-Jurisdiction-StandardTerms.md` §1–§2 |
 | 8 | (all) | Contributor rights sufficient to grant this License and the Future License (CLA) | **[LEGAL]**, separate deliverable | `history/260729-TRSL-ContributorRights-Research.md` §4 |
 | 9 | (all) | Full specialist legal review in every jurisdiction of intended use | **[LEGAL]** | `specs/TargetRevenueLicenseConcept.md` §21.5 |

workplans/TREV-WP-0004-global-jurisdiction-research.md

@@ -54,11 +54,23 @@ Appendix A and `specs/TargetRevenueSourceLicense-V1C1.md` Appendix A directly.
 
 ```task
 id: TREV-WP-0004-T01
-status: todo
+status: done
 priority: high
 state_hub_task_id: "46dc2cd5-99b1-4d4c-b0ab-8dde7822fcc6"
 ```
 
+Result 2026-07-29: `history/260729-TRSL-Jurisdiction-Germany-EU-Deepened.md`
+produced. Confirmed Rome I Article 3(1) makes B2B governing-law clauses
+generally enforceable (consumer carve-out is the same recurring Q2 edge
+case, not a new risk). EU Late Payment Directive 2011/7/EU supplies a
+ready-made default (60 days, statutory interest, €40 minimum compensation)
+that could fill CUA §3.5's currently-blank late-payment term for EU
+Customers. Found UK GDPR and EU GDPR are now meaningfully diverging
+(UK Data (Use and Access) Act 2025), with EU-UK adequacy renewed only to
+December 2031 and contingent on divergence not going too far — CUA §11
+likely needs separate EU/UK data-processing treatment, not one shared
+clause.
+
 Extend `history/260729-TRSL-Jurisdiction-StandardTerms.md` (German AGB/
 Transparenzgebot, already primary-source-confirmed for §31/§32 UrhG) to
 cover: EU-wide contract-law harmonization instruments relevant to a B2B
@@ -77,11 +89,21 @@ placeholder acknowledging the obligation without operative terms.
 
 ```task
 id: TREV-WP-0004-T02
-status: todo
+status: done
 priority: high
 state_hub_task_id: "3018e32c-f0a3-41d0-bed9-7511c0f6ca9d"
 ```
 
+Result 2026-07-29: `history/260729-TRSL-Jurisdiction-US-Deepened.md`
+produced. UCC §2-302/§2-719 unconscionability is a real but narrow backstop
+on CUA §14's liability cap, not routine scrutiny. FAA §2 strongly favors
+arbitration enforceability, with a "surprise/lack of notice" exception
+relevant if an arbitration clause is ever added. Confirmed UCC Article 2B/
+UCITA was never uniformly adopted — no single "US software law" exists;
+enforceability depends on general contract law plus whichever state is
+named as governing law. Confirmed CCPA/CPRA's B2B exemption expired
+January 1, 2023 and was not renewed.
+
 Deepen the shallow US comparison already flagged in
 `history/260729-TRSL-Jurisdiction-StandardTerms.md` §3. Research: UCC
 Article 2 and state-law variance relevant to software licensing (noting at
@@ -100,11 +122,21 @@ gate (working default Q2 edge case).
 
 ```task
 id: TREV-WP-0004-T03
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "b449169d-cc7d-43ef-8577-fda49c5577cf"
 ```
 
+Result 2026-07-29: `history/260729-TRSL-Jurisdiction-UK-Deepened.md`
+produced. UCTA 1977's reasonableness test applies directly to CUA §14's
+liability cap since the CUA is, by its own description, a standard-form
+"business" contract — the exact target of UCTA's "standard terms of
+business" ground. Found this converges with (without duplicating) German
+Transparenzgebot: both favor prominent, proportionate, clearly-scoped
+limitation clauses over generic boilerplate. Recommends making the
+liability cap proportionate to the actual Exhibit A Fee rather than flat
+boilerplate. UK GDPR/EU GDPR divergence confirmed via the Germany/EU pass.
+
 Research UK contract law post-Brexit divergence from the EU baseline:
 the Unfair Contract Terms Act 1977's reasonableness test for liability
 caps and exclusion clauses (a different mechanism from both German
@@ -118,11 +150,20 @@ venue clause in UK courts for a commercial (non-consumer) contract.
 
 ```task
 id: TREV-WP-0004-T04
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "2e7e41ae-b7b2-4ed1-9499-37e500034633"
 ```
 
+Result 2026-07-29: `history/260729-TRSL-Jurisdiction-Argentina.md` produced.
+B2B choice-of-law respected under the Código Civil y Comercial; Ley 24.240
+consumer protection is mandatory/non-waivable — the same recurring
+Commercial-Use-vs-individual edge case found in every jurisdiction so far
+(Germany, EU, US via CCPA), now confirmed as a cross-jurisdictional
+pattern rather than a one-off. Argentina's PDPL has held EU adequacy since
+2003 (reconfirmed 2024) — the lowest-friction data-protection case found
+in this program so far.
+
 Research Argentine civil-law contract norms (Código Civil y Comercial),
 the Ley de Defensa del Consumidor's applicability boundary (parallel to the
 EU/Germany B2B-vs-consumer question already surfaced), Argentina's Personal
@@ -138,11 +179,20 @@ to the whole region.
 
 ```task
 id: TREV-WP-0004-T05
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "4c1ce8a8-d287-4d4f-9652-4b9643382368"
 ```
 
+Result 2026-07-29: `history/260729-TRSL-Jurisdiction-India.md` produced.
+Liability caps generally enforceable (Contract Act §28 bars only a complete
+remedy bar, not a quantum cap); indemnification has no statutory quantum
+cap and is commonly carved out of the general liability cap in practice —
+directly relevant to CUA §13, currently unwritten. Foreign governing-law/
+venue clauses are respected by Indian courts. DPDPA 2023's "negative list"
+model is more permissive than GDPR by design — low cross-border-transfer
+friction currently, though not guaranteed to stay that way.
+
 Research the Indian Contract Act 1872's treatment of liability limitation
 and indemnification clauses, the Digital Personal Data Protection Act 2023's
 requirements relevant to CUA §11, Indian courts' historical approach to
@@ -156,11 +206,22 @@ a source-available/delayed-conversion model.
 
 ```task
 id: TREV-WP-0004-T06
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "6db1ed56-b9be-481a-a285-0441805237f6"
 ```
 
+Result 2026-07-29: `history/260729-TRSL-Jurisdiction-China.md` produced.
+Confirmed a hard constraint, not a drafting nicety: foreign governing law
+is only selectable for a "foreign-related" contract, and even then subject
+to a vague "public interest" override; practical guidance recommends
+Chinese law/venue directly for enforcement in China. PIPL requires one of
+three mandatory cross-border transfer pathways (security assessment,
+certification, or CAC standard contract) plus separate consent and an
+impact assessment — no informal option, the strictest data-protection
+regime found in this program. Recommends a dedicated China rider for both
+governing law and data processing, not shared clauses.
+
 Research the contract provisions of China's Civil Code, the Personal
 Information Protection Law (PIPL)'s data-localization and cross-border
 transfer requirements (materially stricter than GDPR and likely to require
@@ -178,11 +239,20 @@ path for Chinese Customers.
 
 ```task
 id: TREV-WP-0004-T07
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "916b64c2-6a73-4cbb-a39a-bb281fc469a0"
 ```
 
+Result 2026-07-29: `history/260729-TRSL-Jurisdiction-Africa.md` produced,
+but honestly incomplete: this pass's search budget went to WP-0005 T07's
+contingency-fee question, and did not separately confirm South African
+liability-cap/indemnification case law, POPIA's CUA-specific requirements,
+or OHADA's uniform acts' treatment of liability/choice-of-law. Flagged
+explicitly as an open gap rather than assumed low-risk — recommend
+re-running this task with contract-law-specific searches before treating
+Africa as covered for the CUA's own terms.
+
 The African continent spans multiple legal families; this task surveys
 representative jurisdictions rather than attempting exhaustive coverage.
 Research: South Africa as a common-law anchor (POPIA data-protection law,
@@ -199,11 +269,22 @@ anchors generalize.
 
 ```task
 id: TREV-WP-0004-T08
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "cab3a353-d758-4169-b6f2-49ac0997aec7"
 ```
 
+Result 2026-07-29: `history/260729-TRSL-Jurisdiction-AsiaPacific.md`
+produced. **Highest-priority finding in the whole WP-0004 program:**
+Australia's Unfair Contract Terms regime, expanded 9 November 2023, covers
+standard-form contracts with small businesses (<100 employees or <$10M
+turnover) by default, with real penalties — the CUA is exactly such a
+standard-form contract, and most realistic Customers will fall within this
+threshold. This is not an edge case like the other jurisdictions'
+consumer carve-outs; it applies to the ordinary expected case. Singapore
+PDPA and Japan APPI were not researched in depth this pass (flagged
+honestly, not assumed low-risk).
+
 Research representative Asia-Pacific jurisdictions: Singapore (common-law
 commercial hub, PDPA data protection, strong arbitral-award enforcement
 tradition — relevant to T09's choice-of-forum strategy); Japan (civil-law

workplans/TREV-WP-0005-enforcement-network-research.md

@@ -142,11 +142,20 @@ enforcement procedure.
 
 ```task
 id: TREV-WP-0005-T04
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "b40fef09-f2a4-4fb4-9743-57de96b9b30f"
 ```
 
+Result 2026-07-29: `history/260729-TREN-Jurisdiction-Argentina.md`
+produced. Argentina permits *pacto de cuota litis* — the first jurisdiction
+where single-role is available AND the cap is close to but below 50%:
+35% ordinarily in Buenos Aires City, rising to 50% only if the lawyer
+contractually assumes the case's cost/cost-liability risk (a structure
+that naturally resembles the Litigation Funder role even though not
+strictly required here). ~33% in other provinces, 20% in labor matters.
+No dedicated litigation-funding regime confirmed in this pass.
+
 Research *pacto de cuota litis* availability for Argentine abogados
 (generally more permissive than continental Europe, often with statutory
 caps) and the broader Latin American pattern this represents or diverges
@@ -159,11 +168,21 @@ for unauthorized commercial software use.
 
 ```task
 id: TREV-WP-0005-T05
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "cb8ec312-4afa-4812-b5fd-5193c6c57140"
 ```
 
+Result 2026-07-29: `history/260729-TREN-Jurisdiction-India.md` produced.
+**Cleanest confirmation of the split-role model's necessity so far**:
+Bar Council of India Rule 20 flatly prohibits advocates from any
+contingent-fee or proceeds-sharing arrangement, with no exception gates
+at all (stricter than Germany's narrow-but-existing gates). Third-party
+litigation funding is explicitly not prohibited, including outcome-based
+funder compensation — the split-role structure maps exactly onto a
+distinction Indian law already draws cleanly. A live reform debate exists
+for arbitration specifically but is not yet a rule change.
+
 Research the Bar Council of India Rules' prohibition on advocates
 charging contingency fees, whether a Litigation Funder/Local Counsel split
 (concept §8) is viable under Indian law and professional-conduct rules
@@ -177,11 +196,23 @@ themselves, subject to some uncertainty), and IP enforcement procedure.
 
 ```task
 id: TREV-WP-0005-T06
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "e83722de-de3e-4a2b-ba8f-7f5d16ac5dae"
 ```
 
+Result 2026-07-29: `history/260729-TREN-Jurisdiction-China.md` produced.
+Contingency fees are permitted but nationally capped on a steep sliding
+scale (18% below 1M CNY, down to 6% above 50M CNY) — well below 50% at
+every tier, and counterintuitively *lower* for larger, more valuable
+claims. Contingency is prohibited outright in several case categories
+(criminal, administrative, mass/collective litigation among them —
+worth checking whether a multi-violation Enforcement campaign could be
+characterized as the latter). A separate "risk agency" no-win-no-fee
+structure exists under the same caps. Recommends the EPA itself likely be
+governed by Chinese law given the foreign-related-contract constraint
+found in the parallel WP-0004 T06 pass.
+
 Research Chinese lawyers' contingency-fee rules (permitted in specified
 case types, typically capped, under Ministry of Justice regulation),
 litigation funding's presence and regulatory treatment in China, and the
@@ -196,11 +227,20 @@ counsel and pursuing enforcement in Chinese courts — building on
 
 ```task
 id: TREV-WP-0005-T07
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "c84f991f-34cc-42e0-acfd-4a5822a35f56"
 ```
 
+Result 2026-07-29: `history/260729-TREN-Jurisdiction-Africa.md` produced.
+South Africa's Contingency Fees Act 66 of 1997 confirms single-role is
+available but capped at 25% (including VAT) of the capital sum, or double
+the attorney's normal fee if lower — a hard statutory cap well below 50%,
+confirmed via the Act itself, and courts have invalidated non-compliant
+agreements. OHADA's contingency-fee rules were **not found** in this pass
+— explicitly flagged as unresearched rather than assumed to follow the
+French pattern by inference alone.
+
 Research South Africa's Contingency Fees Act 1997 (a statutory framework
 explicitly permitting capped contingency fees for attorneys — likely the
 most permissive African anchor jurisdiction) and the OHADA zone's
@@ -214,11 +254,24 @@ WP-0004 T07.
 
 ```task
 id: TREV-WP-0005-T08
-status: todo
+status: done
 priority: medium
 state_hub_task_id: "35c7f74e-f70b-4c4b-9445-03c8dde53bb7"
 ```
 
+Result 2026-07-29: `history/260729-TREN-Jurisdiction-AsiaPacific.md`
+produced. Singapore permits CFAs only since May 2022, and only for
+arbitration/SICC/mediation-related proceedings — not ordinary litigation,
+a real scope limit for a straightforward Enforcement Action. Japan permits
+contingency broadly, but Article 12 of its Basic Rules on the Duties of
+Practicing Attorneys bans fee-splitting with non-lawyers — a genuine,
+previously-unflagged compliance risk for the Litigation Funder model
+itself, the first jurisdiction where even the split-role fallback has an
+open compliance question. Australia restricts lawyer contingency fees to
+Victoria-only class actions, but has a mature, broadly-regulated
+litigation-funding market nationally, making split-role the more natural
+default there for reasons distinct from Germany's or India's.
+
 Research Singapore's recent liberalization permitting Conditional Fee
 Agreements for certain proceedings (a change from its historical
 prohibition), Japan's customary success-fee arrangements under bar-