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// SECTION_01

LEGAL_DISCLOSURES

[LAST_UPDATED / 2026-04-21_R4]
// CRITICAL_NOTICE

The 9mm.pro / XCH Terminal (the “Interface”) is an informational, non-custodial interface built by the 9mm Pro team. It surfaces public market data and deep-links users to third-party venues. No trading occurs on this Interface.Any trade you execute happens entirely on the destination venue, with your own self-custodial wallet, under that venue's terms.

The Interface operates within the conditions of the SEC Division of Trading and Markets staff statement dated April 13, 2026 covering Covered User Interfaces. When in-app trading is added in a future phase (EVM execution + a Chia-side Sage wallet adapter), these disclosures will be revised and re-reviewed by counsel before that functionality ships.

Digital asset trading involves significant financial, technical, and regulatory risk. You are solely responsible for your own transactions and for determining whether your activity is lawful in your jurisdiction.

01_

What 9mm Pro Is & Affiliation With This Interface

9mm Pro is a multi-chain decentralized exchange operating on PulseChain, Base, Sonic, Ethereum, BNB Chain, and related networks. 9mm Pro publishes and maintains on-chain smart contracts (v2 AMM pools, v3 concentrated liquidity, aggregator routing, and related tooling) that users interact with through their own self-custodial wallets.

The 9mm Pro XCH Terminalis created, offered, and operated by the 9mm Pro team. It is not independent of 9mm Pro. The Interface connects to and interacts with the 9mm Pro DEX on the same publicly-available terms and conditions as any other unaffiliated interface that connects to those contracts — i.e., direct on-chain smart-contract calls and public RPC / quote APIs. No preferential routing, fee-rebates, order-flow arrangements, or gated access exist between this Interface and the 9mm Pro DEX.

02_

What the Interface Does

The Interface surfaces publicly-available quote data from third-party venues — TibetSwap, Dexie, 9x Aggregator, KyberSwap, and the 9mm Pro DEX — across the chains each venue supports (Chia for TibetSwap / Dexie; Base and Ethereum for Kyber and 9x, subject to the respective venue's own supported chain list at any given time) and presents execution routes in sortable form.

Execution is click-out only.When the user selects a route, the Interface deep-links to the destination venue's own frontend with the tokens pre-filled. The user connects their self-custodial wallet to that venue and signs the transaction there. The Interface does not connect a wallet, does not prepare transaction calldata, does not submit transactions, and has no view of the user's addresses, balances, or signatures.

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Staff Statement on Covered User Interfaces

On April 13, 2026 the SEC's Division of Trading and Markets issued a staff statement regarding broker-dealer registration of certain user interfaces used to prepare crypto asset security transactions. The staff indicated it will not object to providers of a “Covered User Interface” operating without registering as a broker-dealer, provided the interface meets specified neutrality and transparency conditions. The statement is an interim step and is considered withdrawn effective five years from April 13, 2026.

The Interface is designed to operate within those conditions. Nothing in the staff statement prohibits the underlying venue (e.g., the 9mm Pro DEX) from deploying smart contracts, operating liquidity pools, or incentivizing market makers — those are protocol-level activities separate from the interface conditions described below.

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Not Registered With The SEC

The 9mm Pro team, in its capacity as the provider of this Interface, is not registered with or regulated by the U.S. Securities and Exchange Commission (SEC) in connection with the creation, offering, or operation of the Interface.

The Interface is not a broker-dealer, is not a securities exchange, is not an alternative trading system, and is not a national securities association. It does not effect transactions for the account of others within the meaning of Section 3(a)(4) of the Exchange Act; users effect their own transactions by signing with their own self-custodial wallets. No registration statement has been filed with the SEC covering any crypto asset displayed in the Interface.

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Conditions The Interface Meets

  • Self-custody only.The Interface never holds, handles, routes, or directs user funds, private keys, or seed phrases, and does not connect to a user's wallet at all. All execution happens on the destination venue after the user clicks through, via that venue's own wallet-connection and signing flow.
  • User-customizable parameters. Users may change slippage tolerance, input token, output token, amount, and route selection at any time before signing.
  • User-controlled sorting. When more than one execution route is available, a SORT control exposes four objective orderings (output descending, output ascending, DEX alphabetical, chain) and the user selects which to apply.
  • No commentary on routes.The Interface does not label any route as “best”, “recommended”, “fastest”, or “most reliable.” Route position is determined solely by the currently-selected objective sort key and is re-sortable at any time.
  • Educational material. The Manual tab explains how routes are sourced, how the bridge operates, and the risks of participation.
  • Strict neutrality. The Interface does not make personalized recommendations, does not solicit specific transactions for specific users, does not negotiate terms on behalf of users, does not take or match orders, and does not exercise discretion over any execution decision.
  • No transaction-based compensation. The Interface does not charge per-trade fees, does not participate in the spread of any route it surfaces, and does not receive payment for order flow. Compensation is product, execution route, execution venue, and counterparty agnostic (specifically, zero).
  • Public, objective data.Quotes, APR, TVL, and price impact are mechanical calculations derived from public third-party APIs. The parameters are independently verifiable from the Interface's open source.
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Default Transaction Parameters

The Interface presents the following defaults, which the user can override at any time before signing:

  • Slippage tolerance — 0.5%. Chosen as a common value that balances fill reliability against price drift for typical EVM aggregator trades. The user may set any value via the slippage control. Higher values increase the risk of sandwich MEV; lower values increase the risk of revert-on-slippage.
  • Quote staleness window — 20 seconds. After that window the Interface marks the quote expired and requires the user to refresh before proceeding.
  • Sort default — output descending. Re-orderable via the SORT bar.

The Interface does not override, inject, or silently adjust any transaction parameter beyond what the user has selected.

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Informational Purpose Only

Everything displayed by the Interface — quotes, route orderings, APR and TVL figures from Merkl, output-delta-vs-avg figures, price impact, 7d sparklines, and token rankings — is informational only. It summarizes public third-party data and may be stale, incomplete, or incorrect.

Final execution prices, gas costs, slippage, and outcomes are determined exclusively by the destination venue and the Ethereum / Base network at the moment you sign a transaction from your own wallet. You are expected to independently verify every parameter before signing.

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No Investment Advice

Nothing on the Interface — including route orderings, output-delta callouts, incentivized-pool listings, APR rankings, trending/gainers/losers sections, or any UI copy — constitutes investment, financial, tax, legal, or accounting advice.

The Interface does not know you, your jurisdiction, your risk profile, or your intent, and nothing it displays is tailored to you individually.

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Material Conflicts Of Interest

You should be aware of the following conflicts when using this Interface:

  • Affiliation with 9mm Pro DEX.The Interface is created by the 9mm Pro team and may direct volume toward the 9mm Pro DEX when a 9x Aggregator route offers the best output for a given pair. The Interface does not modify or bias the displayed amounts to favor 9mm Pro — quotes are read verbatim from the public API — but the 9mm Pro team has a business interest in higher 9mm Pro DEX volume and in the utility of CAT-wrapped assets bridged to Base and Ethereum.
  • Bridged-asset ecosystem. Many of the tokens displayed are wrapped CATs that exist because of bridges operated by third parties (e.g., warp.green). Wider Interface adoption increases demand for those bridged tokens and therefore indirectly benefits the bridge operators.
  • Merkl incentive campaigns. Some pools surfaced in the Incentives section are campaigns funded by 9mm Pro or its ecosystem partners. Campaign parameters (reward amount, duration, eligible pools) may be adjusted by the campaign funder at any time.

No user-specific information held by the Interface (there is none — no account is required) is used to direct execution decisions. The Interface's own code is open source and its sorting logic is auditable end-to-end.

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Trading Information & Third-Party APIs

The Interface reaches the following third-party services to display market data, exposing your IP address to those services under their own privacy terms:

  • TibetSwap — pairs / token / quote endpoints.
  • Dexie — quote endpoint and CAT image CDN. A backend indexer operated by the 9mm Pro team also ingests Dexie's public offers feed into a read-only database that the Interface's server-side API routes query; under normal Interface use your IP is not exposed to Dexie directly by that path.
  • 9x Aggregator (9mm.pro) — quote endpoint on each chain 9x supports.
  • 0x Swap API — route quotes on Base. Requests are proxied through a server-side Cloudflare Worker so the 0x-version header (which 0x's CORS policy does not permit from browsers) and the API key are injected server-side; the browser never sees the key.
  • KyberSwap — route quote on Base and Ethereum.
  • DexScreener — bulk token prices for the Markets / Arb tabs.
  • Merkl (by Angle Labs) — incentive campaign data.
  • Chia full-node RPC — read-only block / offer / coin state. Called only from the indexer backend; not from the browser.

Because execution is click-out only, the Interface does not request your wallet address, does not submit transactions, and does not pass any user-identifiable data to the destination venues. Any wallet connection or signing you perform happens on the destination venue's own site, governed by its privacy terms.

The Interface does not require an account, does not store wallet signatures, and does not sell, broker, or monetize user trading information. Read-through caches on the server hold public third-party market data for fifteen to sixty seconds to reduce API load; no user-identifiable data is held in those caches. Theme preference and the acceptance of these disclosures are stored locally via localStorage on your own device.

11_

Destination-Venue Risk (MEV, Failed Txs, Slippage)

Because execution happens on the destination venue, risks associated with how transactions are submitted — public-mempool visibility, MEV / sandwiching, slippage overruns, reverted transactions — are governed entirely by that venue and by your wallet's RPC configuration. Failed, reverted, or MEV-impacted transactions are not reimbursable by the Interface or by 9mm Pro.

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Cybersecurity Posture

The Interface's frontend runs in the user's browser as JavaScript. Server-side API routes query a read-only indexer database that contains public market data only (CAT token metadata, Dexie offer history, pool states, and a few indexer state keys such as the XCH/USD reference price) and proxy select third-party APIs (currently the 0x Swap API) server-side to handle CORS or keep API keys off the client bundle. There is no server-side user session, no custodial infrastructure, no wallet connection, and no transaction-submission surface. Dependencies are pinned in the project's lockfile and reviewed before deployment. The Interface cannot modify any underlying smart contract — upgrades are the responsibility of the respective protocols (9mm Pro, Kyber, TibetSwap, Dexie, warp.green).

No software is free of bugs. Report suspected issues responsibly; the Interface disclaims liability for losses resulting from bugs, exploits, or upstream protocol failures to the maximum extent permitted by applicable law.

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Merkl Incentive Data

Incentivized pool information is sourced from the Merkl protocol operated by Angle Labs. APR, TVL, reward token lists, and campaign durations are estimates published by Merkl and update with delay. Rewards are distributed off-chain via Merkl's proof system, are subject to Merkl's own terms, and may be adjusted or cancelled without notice.

Providing liquidity to a pool is an action the user performs directly on the underlying venue with their own wallet. The Interface only surfaces the opportunity and deep-links to the venue's LP interface.

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Jurisdiction & Restricted Persons

You are responsible for determining whether your use of the Interface, the 9mm Pro DEX, or any linked third-party venue is lawful in your jurisdiction. The Interface is not intended for use by persons located in any jurisdiction where the display of digital asset trading information or participation in DeFi protocols is prohibited by applicable law.

15_

Risk Disclosure

  • Digital assets are volatile and may lose all their value, quickly and without warning.
  • Bridged assets introduce bridge risk. If the underlying bridge is compromised, wrapped tokens may become worthless.
  • Smart contracts can have bugs, exploits, and upgrade risk beyond the Interface's control.
  • Liquidity pool participation is subject to impermanent loss.
  • Merkl rewards may be reduced, revoked, or unclaimable.
  • MEV, front-running, sandwich attacks, and failed transactions are not reimbursable by the Interface or 9mm Pro.
  • Cross-chain swaps require that you already hold the EVM-side asset (e.g., wXCH on Base). The Interface does not move value across chains; that is a separate bridge operation performed on warp.green or a comparable venue.
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No Warranty, No Liability

The Interface is provided “as is”, without warranty of any kind. To the maximum extent permitted by applicable law, 9mm Pro, its contributors, and its operators disclaim all warranties, express or implied, and shall not be liable for any damages arising out of your use of the Interface.

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Changes To These Disclosures

These disclosures may be updated from time to time to reflect changes in functionality, regulatory posture, or applicable law. Continued use of the Interface after a change constitutes acceptance of the updated disclosures. The “last updated” date reflects the most recent material change.