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>
tegwick
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