Gea Sphere, LLC (hereinafter referred to as “Gea Sphere” or the “Firm” or “we” or “our”) is an investment adviser registered with U.S. Securities and Exchange Commission (“SEC”) and was registered with the State of Rhode Island from 2009 through 2021. In September 2021, the Firm became registered with the SEC. The Firm was founded in 2009 by Eduard Hamamjian. Prior to forming Gea Sphere, Mr. Hamamjian was a member of Global Equity Advisors LLC. Gea Sphere’s principal members are the following persons: (i.e., those individuals and/or entities controlling 25% or more of this company).
• Eduard Hamamjian, Managing Member, Portfolio Manager, Chief Compliance Officer
• Perchuhy Hamamjian, CFO and Member
• George Hamamjian, Financial Advisor and Insurance Specialist Fund Management Gea Sphere is the investment adviser to Alpha Dog ETF (the “Alpha Dog Fund”). The Alpha Dog Fund is a non-diversified series of ETF Opportunities Trust, a Delaware statutory trust (the “Trust”), which is registered as an open-end management investment company. The Alpha Dog Fund is an exchange-traded fund that is listed on a national securities exchange (“NYSE Arca”). Gea Sphere provides investment advisory services pursuant to an investment advisory agreement (the “Advisory Agreement”). Gea Sphere may recommend an investment in Alpha Dog Fund to certain clients based on their financial situations and investment objectives. When this occurs, a potential conflict of interest exists since Gea Sphere receives management fees for being the adviser to the Alpha Dog Fund and a client’s account assets. To address this potential conflict of interest, Gea Sphere will conduct training of its personnel, perform periodic review of the investment selections, provide appropriate disclosures, and implement applicable policies and procedures. Under the terms of the Advisory Agreement, Gea Sphere manages the investment portfolio of the Alpha Dog Fund, subject to the policies adopted by the Trust’s Board of Trustees. In addition, Gea Sphere: (i) furnishes office space and all necessary office facilities, equipment, and executive personnel necessary for managing the assets of the Alpha Dog Fund; (ii) provides guidance and policy direction in connection with its daily management of the Alpha Dog Fund’s assets; and (iii) is responsible for oversight of the sub-adviser. Under the Advisory Agreement, Gea Sphere assumes and pays, at its own expense and without reimbursement from the Trust, all ordinary expenses of the Alpha Dog Fund, except the fee paid to Gea Sphere pursuant to the Advisory Agreement, distribution fees or expenses under a Rule 12b-1 plan (if any), interest expenses, taxes, acquired fund fees and expenses, brokerage commissions and any other portfolio transaction related expenses and fees arising out of transactions effected on behalf of the Alpha Dog Fund, credit facility fees and expenses, including interest expenses, and litigation and indemnification expenses and other extraordinary expenses not incurred in the ordinary course of the Fund’s business. For its services with respect to the Alpha Dog Fund, Gea Sphere is entitled to receive an annual management fee 0.90%, calculated daily and payable monthly as a percentage of the Fund’s average daily net assets. Model Portfolios and Financial Planning Gea Sphere creates and manages model portfolios for its clients, other registered investment advisers and employer sponsors of retirement plans and Investment Exchanges. Gea Sphere provides portfolio management services where we manage money for clients who prefer an aggressive portfolio, a moderately aggressive portfolio, or a conservative portfolio. We also manage our client’s money for growth and income purposes. Additionally, some of our clients may ask us, from time to time, for advice on how to allocate assets to their third-party retirement accounts. We do not have discretion over these third-party retirement accounts; however, we will provide asset allocation advice based on a larger portfolio and risk analysis to ensure our clients are receiving well-rounded investment advice for all their investment portfolios. The client has sole discretion over these third-party retirement accounts and can decide whether or not they want to follow our advice. We provide financial planning where we recommend products and services that help clients reduce their taxable income. We provide cash flow analysis for retiree clients to help them identify their cash flow and then compare such cash flow to their expenses. For estate planning services, we help clients identify and ensure they have the appropriate documentation needed to maximize their tax savings and protection planning. We also assist clients with making appointments with estate planning attorneys and make sure their estate planning affairs are set up properly. Lastly, we provide general advisory services to clients who need advice regarding life changes or large purchases, etc. Some examples include advising clients on whether to buy or lease a vehicle; another example is advising clients on how to spend capital gains. Gea Sphere evaluates each client's overall investment experience, financial goals, targeted retirement date and tolerance for market risk. Based on this information, Gea Sphere selects certain model investment portfolios for each client. An account typically consists of, but is not limited to, stocks, mutual funds, real estate investment trusts (“REITs”), exchange traded funds (“ETFs”), inverse ETFs, bonds, and bond funds. We hedge portfolios by buying inverse ETFs for a short-term basis to reduce portfolio drawdowns during market corrections. We also reduce model portfolio drawdowns by using our proprietary stock selection process of purchasing

equities in pairs of sometimes non-correlating equities. The Gea Sphere Analysis System (“System”) and the Price to Free Cash Flow (“PFCF”) research study principals are the foundation of our model construction and stock picking philosophy. The “Gea Sphere Analysis System” methodology offers a disciplined, rules- based, investment approach employing tactical asset class decisions within the guidelines of strategic boundaries. Our portfolio construction begins with our proprietary stock valuation process which includes fundamental and technical analysis. These methods are further defined in Item 8 of this Brochure. Gea Sphere manages 10 Core ETF model portfolios. These are fully diversified model portfolios that are built using low-cost ETFs and offer the full range of risk parameters for every type of investor. The selection ranges from the Gea Sphere Core EFT 100 to Gea Sphere Core ETF 10-90 and all combinations in between. These models are rebalanced and revalued annually to overweight leading domestic and international sectors that are emerging and leading and simultaneously under-weighting declining domestic and international sectors on an annual basis. These funds are designed to be stand-alone fully diversified portfolios. Gea Sphere offers these model portfolios to clients of Mid-Atlantic Trust Company (“Mid-Atlantic”). Gea Sphere does not interact directly with clients on the Mid-Atlantic platform. Mid-Atlantic provides trust and custody solutions for retirement plans and other accounts. Gea Sphere will assign Clients one or more of the 10 Core ETF model portfolios based on a client’s individual Riskalyze Score, which ranges from 10-100. This score is calculated based on the client’s responses provided in the completed Risk Questionnaire. Clients can contact their adviser for additional information on factors that impact a client’s Riskalyze Score and subsequent model assignment. Gea Sphere monitors the performance of Gea Sphere model portfolios against relevant benchmarks. Additionally, Gea Sphere monitors performance against the relative risk of the models to determine whether the characteristics of those models are suited to the clients. The 10 Core ETF model portfolios are listed below. The first number represents the percentage of stocks and the second number represents the percentage of bonds and bond- like instruments. Each 10 Core ETF model portfolio is fully diversified throughout. Aggressive Growth Category
• Gea Sphere Core ETF 100
• Gea Sphere Core ETF 90-10
• Gea Sphere Core ETF 80-20 Moderate Aggressive Category
• Gea Sphere Core ETF 70-30
• Gea Sphere Core ETF 60-40 Moderate Category
• Gea Sphere Core ETF 50-50
• Gea Sphere Core ETF 40-60 Conservative Category
• Gea Sphere Core ETF 30-70
• Gea Sphere Core ETF 20-80
• Gea Sphere Core ETF 10-90 Gea Sphere also offers five individual rules-based models each of which use the Gea Sphere Analysis System, and which are further described below:
• Gea Sphere Bond Portfolio buys ETFs and fixed income instruments including inverse ETFs and seeks to reduce risk and protect portfolio values during periods of volatility. Gea Sphere’s Analysis System is used along with the strategic allocation method to provide an over and underweight fixed income class of investments.
• Gea Sphere High Income Portfolio buys equities and other instruments like REITS or high yielding bonds strategically invested to produce above average income used by clients for living expense. This is an actively managed portfolio designed to help clients with above average income requirements or needs, in exchange for potentially higher risk.
• Alpha Dog ETF is an actively traded portfolio where it purchases stocks of leading sectors and stocks leading those sectors using the Gea Sphere Analysis System. The objective of the ETF is aggressive growth. The ETF will have no more than 50 securities with a new economy bias. Option contracts will be used on occasion to reduce risk and protect principal against market corrections.

• Gea Sphere Dividend Grower Portfolio invests in 30 large or mid cap stocks that meet the Gea Sphere price to free cash flow criteria for value. The use of strategic asset allocation to reduce volatility and improve returns over time. This is a tax efficient portfolio as there is low turnover. All stocks in the portfolio have a history of raising dividends and also meet the strict criteria of the Gea Sphere Analysis System for free cash flow to determine the value of equities.
• Gea Sphere PFCF Dow Portfolio invests only in stocks of the Dow Jones Industrial Average each year that meet our strict criteria of The Gea Sphere Analysis System as explained in the Firm’s empirical study of Price to Free Cash Flow. Gea Sphere’s financial planning, cash flow analysis, estate planning and general advisory services are optional and are offered as a free service through eMoney’s Wealth Management Technology Platform. This platform evaluates each client's overall investment experience, financial goals, targeted retirement date and tolerance for market risk. Gea Sphere also offers tax advice through other professional affiliates. Gea Sphere may also coordinate with other legal professionals for its estate planning services. Amount of Managed Assets As of December 31, 2023, assets under management were approximately $102,200,000 managed on discretionary basis and 5,500,000 with Mid-Atlantic platform on a non- discretionary basis for a total of $107,700,000 of regulatory assets under management.