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>

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 |