Introduction Follow RIA1 is a newly formed investment adviser that provides limited advisory services to individuals exclusively through its mobile application (collectively, the “Follow App” or the “App”). Follow RIA is directly owned by Udon Labs, Inc. (“Parent”). Follow RIA’s advisory services assist clients in identifying and self-reporting their investment objectives, risk profile, and financial sophistication, and, if a client so chooses, facilitates securities trading that is derived from a portfolio maintained by individuals who publish investment-related content on a regular basis for compensation, known as a “Leader.” A more detailed explanation of these services is set forth below. Description of Follow RIA’s Advisory Services Becoming a Client Follow RIA only offers limited advisory services to its clients. Persons who wish to become clients must do so via the Follow App or another digital channel approved by Follow RIA. The Follow App will be available through Google’s “Google Play” or Apple’s “App Store,” or other such digital channels approved by Follow RIA. After downloading the Follow App, individuals should then follow the App’s prompts. The Follow App is operated by both Follow RIA, a registered investment adviser, and its affiliate, referred to herein as the “Publishing Affiliate.” Through the Follow App, the Publishing Affiliate allows persons to subscribe to the services of “Leaders,” i.e. those who regularly create and publish investment-related commentary to their subscribers, as described in further detail later in this Brochure. This subscription service is provided by the Publishing Affiliate only, and is not provided by Follow RIA. The subscription process is described in this Brochure solely for the purpose of providing background information regarding Follow RIA’s advisory services, which operate in conjunction with, but are separate from, the publishing services provided by the Publishing Affiliate. Neither the Leaders nor the Publishing Affiliate provide investment advice, and neither are registered investment advisers. Once a person subscribes to one or more Leaders through the Follow App, they may then choose to also create a securities portfolio derived from the portfolio of a Leader to which they have subscribed,2 provided that they meet Follow RIA’s client-screening criteria, as discussed 1 As used in this Brochure, the term “Follow RIA” refers solely to Udon RIA Sub, LLC, which is the SEC-registered investment adviser and the provider of this brochure. Any use of the term “Follow” refers collectively to Follow RIA (Udon RIA Sub, LLC), Udon OPP Sub, LLC (the “Publishing Affiliate,”) and Udon Labs, Inc., the shared parent company of both Follow RIA and the Publishing Affiliate, which together operate the Follow App. The Follow App provides both investment advisory services, and non-advisory services, and, for the avoidance of doubt, the Publishing Affiliate is not a registered investment adviser and does not provide investment advice, as discussed elsewhere in this Brochure. 2 Follow RIA may, in its sole discretion, choose not to create a Leader-derived portfolio based on the portfolio for a given Leader. further herein. A person becomes a client of Follow RIA, and will receive its additional advisory services, only once they (1) indicate a desire to create a Leader-derived portfolio and (2) Follow RIA determines that the client meets Follow RIA’s screening criteria. For the avoidance of doubt, Follow RIA’s clients include only those persons who receive its advisory services, and individuals who subscribe to one or more Leaders through the Follow App (a“Subscriber”) may or may not also be a client of Follow RIA, depending upon whether or not the individual Subscriber wants to engage Follow RIA’s advisory services and subsequently satisfies Follow RIA’s criteria to become a client, as discussed further herein. This assessment of whether a potential client satisfies these criteria is made solely by Follow RIA. When an individual first seeks to subscribe to a Leader’s content, they will be asked to create an account with the Publishing Affiliate through the Follow App. If a subscriber also wishes to receive Follow RIA’s advisory services, they will then have to apply to create a separate account with Follow RIA, known as the advisory account. As part of the application process for the advisory account, individuals will be asked to provide certain information about themselves, including information that is designed to help assess their investment objectives, risk profile, and financial sophistication. Follow RIA only provides electronic disclosures, and as a condition of becoming an Follow RIA client, clients must consent to receive electronic disclosures and to receive documents electronically. The App will also ask each individual to agree to the terms of Follow RIA’s advisory agreement, which will be available through the App, and may also request or provide other information, or require the execution of other agreements. Follow RIA may, in its sole discretion, decline to open an account for a potential client or may decide, at any time, that an existing account must be closed. In addition, Follow RIA will not open an account for a subscriber if Follow RIA determines that its screening criteria indicate that the investment products that it makes available to its clients are not a good match for the potential client. Follow RIA provides limited advisory services. As discussed in the following section, these advisory services are intended only to assist in facilitating clients’ access to portfolios derived from certain holdings of certain Leaders, as well as providing clients with information regarding the risk of creating such Leader-derived portfolios. Follow RIA’s services are not intended to be a substitute for a client’s comprehensive financial plan. Accordingly, Follow RIA recommends that its clients also seek the advice of an accountant or financial adviser. Follow RIA does not provide accounting, tax, or legal advice to its clients. Subscribing to Leader Content As previously discussed, Follow RIA’s affiliate, the Publishing Affiliate, provides individuals the ability to subscribe to content provided by individuals or entities, called Leaders, who publish content and commentary though the Follow App by email, or by other electronic means approved by Follow RIA. The Follow App includes a profile for each Leader to assist the individual in deciding which Leader subscription services to purchase. This profile will include biographical information regarding each Leader, a profile picture and a link to their social media handle. The Leader’s profile will also provide a description of the type and frequency of content that the Leader may be expected to provide to Subscribers. This content may include original economic/sector commentary, market color, and company-specific research or commentary that is not tied to market events. Leaders’ content will be made available to clients through the Follow App, by email, or by other electronic means approved by Follow RIA and agreed to by the client. Clients should expect to see information provided in the Leader’s profile change from time-to-time. Once an individual subscribes to receive a Leader’s content, the individual may then view information on the Follow RIA-owned Leader-derived portfolio corresponding to that Leader, known as a “Proxy Account,” which is described in more detail herein. Follow RIA will also provide a risk “score” for each Leader-derived portfolio, which is intended to describe the relative level of risk involved in securities portfolios derived from that Leader as compared to the other Leader-derived portfolios available on the Follow App and the risk “score” itself. Follow RIA describes this relative risk “score” by using the term “investment style” and describing them in the categories of Aggressive, Leaning In, Balanced, Moderate, and Conservative after applying a risk methodology to the Leader-derived portfolios. Follow RIA also provides commentary on each Proxy Account’s risk “score” and meaning, which is intended to help individuals decide whether they wish to establish a portfolio derived from that Proxy Account. Individuals who choose to subscribe to a Leader’s content will be charged a subscription fee determined by each Leader and posted on the Leader’s profile on the App. Subscription fees are assessed through the Follow App and are paid to the Publishing Affiliate. The Publishing Affiliate will pay a portion of the subscription fee to the corresponding Leader. In addition, and as discussed in more detail at Item 5, the Publishing Affiliate may also share a portion of the subscription fee with Follow RIA for providing its advisory services. Clients will always have the ability to subscribe to additional Leaders or cancel an existing Leader subscription. Clients should understand that all content from the Leader(s) is not provided by Follow RIA, and, therefore, that such content does not represent the views or opinions of Follow RIA. Leaders and the Publishing Affiliate are not investment advisers, and Leaders’ content does not constitute investment advice. Follow RIA does not make any representations or warranties with respect to the accuracy, reliability, applicability, fitness, or completeness of any content provided by the Leaders. In addition to subscribing to individual Leaders, users may also sign up for Follow Basic, a trial subscription option offered to users of the Follow mobile app. A Follow Basic subscription provides introductory information about all Leaders on Follow’s app so that users can determine to which Leaders they are most interested in subscribing. Subscribing to Follow Basic allows a user to access one sample piece of previously-published written commentary from each Leader as well as further biographical information about each Leader, including that Leader’s interests, favorite books, etc. Subscribers to Follow Basic may also view information on the Follow RIA- owned Leader-derived portfolio corresponding to each Leader, known as a “Proxy Account,” as well as the holdings of each Proxy Account. Currently, users do not pay a fee during the first month they access Follow Basic, and then pay $1 per month to subscribe to Follow Basic. Identification and Screening of Leaders Potential Leaders are identified, selected, and managed by Follow RIA’s Publishing Affiliate and not by Follow RIA itself. This identification and selection process may be based, in part, upon the Leader’s content (i.e., original economic or sector commentary, market color, and company specific research or content), the Leader’s investing style, the number or capitalization of securities held by the Leader, as well as other factors. The identification and selection process may also be partly based on the Leader’s social media presence. Publishing Affiliate may, or may not, take into account a person’s financial expertise, experience, account return, or other factors that are traditionally used to identify persons likely to provide valuable content. Potential Leaders are also subject to a screening process both before they are permitted to act as Leaders and periodically thereafter. This process is designed to identify events relating to the screened individual that may raise concerns as to the individual’s fitness to act as a Leader. Representative events may include the presence of criminal or administrative proceedings or other events that warrant excluding a Leader from the Follow App. Diligence of Leaders is conducted by the Publishing Affiliate to determine whether a Leader should appear on the Follow App and provide individuals with access to their published content. Once a Leader is onboarded, Follow RIA conducts its own screening process to determine whether it will create portfolios derived from that Leader for its clients. Because the Publishing Affiliate and Follow RIA conduct independent analyses of a Leader, it is possible that Follow RIA will not create Leader-derived portfolios for all Leaders onboarded onto the App. Therefore, a client may be able to subscribe to a Leaders’ content but not create a portfolio derived from that Leader. It is important to understand that this screening process will depend, in part, on information provided by the Leader, which information may or may not be independently verified. There can be no guarantee that the process employed to screen Leaders will necessarily be successful in identifying all matters of possible concern regarding the fitness of a Leader. Clients should understand that the Publishing Affiliate and Follow RIA’s screening processes may rely on representations made by the Leaders themselves. Clients may want to conduct their own review of a Leader before subscribing to the Leader. Clients should understand that investment advice is being provided solely by the Follow RIA, and not by the Publishing Affiliate or any individual Leader. All persons who become Leaders must agree to abide by the terms of the Leader Code of Ethics. Clients may obtain a copy of the Leader Code of Ethics from the Publishing Affiliate by emailing support@follow.co. At its discretion, Follow RIA may terminate clients’ ability to create a portfolio derived from a Leader at any time. Leaders may be removed from the Follow App at the discretion of Follow RIA or the Publishing Affiliate at any time, and in such event individuals will no longer be able to subscribe to that Leader’s content. Investing Individuals who subscribe to one or more Leaders may, through Follow RIA’s App, establish and maintain a securities portfolio derived from a Leader’s portfolio, as described in further detail below. This is the only securities trading option offered by Follow RIA. Each Leader managed by Follow RIA’s Publishing Affiliate will establish and maintain a securities portfolio with a pre-approved brokerage firm with which Follow RIA has established a contractual relationship (the “Brokerage Provider”). Follow RIA Leaders provide Follow RIA viewing access to their portfolios with the Brokerage Provider. Leaders’ portfolios are held in brokerage accounts in their own name, and at no point does Follow RIA have custody of the funds in such accounts. Before Follow RIA exposes its own Leader- derived portfolio (the “Proxy Account”) to clients, or creates portfolios derived from that Leader for clients, Follow RIA reviews at least thirty (30) days of a Leader’s trading. As discussed above, Follow RIA assigns to each Leader-derived portfolio a relative risk “score,” referred to in the app as an “investment style” category which is based on the Proxy Account. Follow RIA also provides clients with a classification of their investment profile that is intended to reflect the client or prospective client’s risk tolerance and their investment goals, and is intended to help individuals decide whether they wish to establish a portfolio derived from a certain Leader. This “investor classification” is based on the information submitted by users when they create an advisory account with Follow RIA, as described above. Although Follow RIA’s clients may choose to establish a Leader-derived portfolio from any Leader to which they subscribe, if there is substantial divergence between a client’s investor classification and a certain Leader’s “risk score,” Follow RIA will notify the client of this divergence via a dialogue box in the Follow App, and the client is notified of this risk before the client creates a portfolio derived from that Leader. It is important to understand

that while a client’s securities portfolio may be derived from a Leader’s portfolio, it is not intended or expected that the client’s securities portfolio will duplicate the Leader’s portfolio or otherwise provide the client with the same or even a similar return as is obtained by the Leader’s portfolio. Follow RIA maintains a Proxy Account that corresponds to each Leader that Follow RIA has separately decided to permit on its advisory platform, and displays returns of the Proxy Accounts, and clients may view the returns of the Proxy Account. For this reason, Follow RIA does not publish or otherwise provide detailed information to clients with respect to a Leader’s portfolio and does not publish returns related to Leader portfolios. On each trading day, Follow RIA takes the following steps to create and maintain each client’s securities portfolio:  Follow RIA identifies the securities holdings in the relevant Leader’s portfolio, which are referred to as the Leader’s Raw Holdings. Through agreements with the Brokerage Provider and each Leader, each time a Leader trades a security in its Raw Holdings, Follow RIA will receive this trade information and the updated Raw Holdings shortly thereafter.  The Leader’s Raw Holdings are then filtered to eliminate all positions other than cash positions, long-only positions in stocks and exchange-traded funds (also known as “ETFs,” which term is inclusive of exchange-traded notes) listed on the New York Stock Exchange, the Nasdaq, or other U.S. securities exchanges that also (1) meet a certain market capitalization threshold and (2) are available for fractional trading through the Brokerage Provider. The resulting positions are referred to as the “Filtered Holdings.”  The resulting portfolio consisting of the Filtered Holdings is referred to as the Target Portfolio. In order to more closely approximate the Leader’s portfolio, the Target Portfolio is priced using then-current market prices each time trade instructions are issued for an individual client’s account and takes place shortly before Follow RIA issues trade instructions for that individual client account. However, Follow RIA cannot guarantee that this process may not be delayed for a variety of reasons, whether within its control or otherwise. It is important to understand that pricing of the Filtered Holdings to create the Target Portfolio may be undertaken sequentially for each client securities portfolio. This means that the pricing used to create the Target Portfolio may vary between client securities portfolios. That is, on any given day, even client securities portfolios derived from the same Filtered Holdings and Target Portfolios may have different allocations and pricing. Follow RIA then issues trading orders for clients’ securities portfolio accounts to Follow RIA’s Brokerage Provider for execution and alignment with the Target Portfolio such that clients’ portfolios hold securities in approximately the same ratios as that of the Target Portfolio. Additionally, prior to the issuance of trade execution orders for each specific client account, Follow RIA will re-price the Target Portfolio to then current market prices in order to maintain the securities weight ratios established in the initial Target Portfolio. It is anticipated that trade execution orders will be issued as close in time as practicable to the pricing process and the creation of the relevant Target Portfolio. However, Follow RIA will not initiate a position in a client account derived from the Target Portfolio if the ratio applied to the client account results in the position being valued by the Brokerage Provider as less than 10 cents. Follow RIA issues client trade execution orders on a randomized basis; at the time of each execution cycle, the process randomly assigns a trading order to all clients’ trades so that no client is any more likely than another to have a favored execution position. Clients should understand that, to the extent clients’ trades are executed sequentially, the lack of order aggregation means that some clients are likely to get more favorable trade prices and some less favorable. However, it is expected that, over time, the random assignment process should address some of the variability in pricing among clients. Follow RIA will monitor the dispersion between the Proxy Account and corresponding client accounts and periodically rebalance to account for items that were not accounted for during daily trading operations. Clients should understand, however, that Follow RIA’s own systems, as well as those of the Brokerage Provider, place certain limitations on the volume of trading instructions that Follow RIA can issue and the Brokerage Provider can execute. Therefore, the process of aligning multiple client accounts with the Target Portfolios may happen simultaneously, sequentially, or in batches across accounts, and may be conducted over the course of the trading day. Clients should further understand that, while it is always Follow RIA’s goal to provide execution within the same trading day, Follow RIA cannot guarantee that the issuance of trade execution orders and resulting executions will not be delayed for a variety of reasons, whether within Follow RIA’s control or otherwise. These reasons could include, but are not necessarily limited to, trading in securities with low liquidity, trading halts, technical malfunctions, or other market factors. Since the pricing of Target Portfolios may vary between client accounts, the trade execution orders for those accounts may also vary. Moreover, because client orders may be executed sequentially, execution quality may also vary from one client account to another. For these and other reasons it is expected that returns on client securities portfolios relating to the same Leader’s Filtered Holdings will likely differ – perhaps significantly. There can be no guarantee these differences will smooth out over time. It should be understood that no trade execution orders will be issued for a client’s securities portfolio unless one or more of the following conditions are met (or other conditions are met supporting a need for trade execution in the relevant account):  The Filtered Holdings have changed from the immediately prior Filtered Holdings, except if this change is solely an addition or reduction of cash by the Leader.  The client is allocating additional funds to the client’s securities portfolio.  The client seeks to liquidate some, or all funds currently allocated to the client’s securities portfolio.  The client’s portfolio has not been re-aligned for a specified period of time determined by Follow RIA. It is important to understand that the foregoing is intended only as a summary description of the process used by Follow RIA with respect to the execution and maintenance of client securities portfolios. This description may leave out details regarding the process, and may not reflect changes made by Follow RIA from time-to-time to improve the operation of the process. A graph depicting Follow RIA’s securities trading process is shown in the following Figure 1. Additionally, Follow RIA’s advisory services are subject to its policies related to securities trading, including its Cash Handling Policy and Pattern Day Trading Policy. Adherence to these policies may, from time to time, result in handling of client accounts that does not completely conform to the process described above. Clients with questions regarding the operation of this process are also encouraged to contact Follow RIA with their questions. A phone number that can be used for this purpose is provided at the beginning of this Brochure. Figure 1 – Graph Depiction of Follow RIA Securities Trading Process Clients should be aware that Follow RIA’s trading platform does not permit active securities trading by clients outside the process outlined above. Upon termination of a client’s subscription with a Leader, the Publishing Affiliate will notify Follow RIA, and Follow RIA will cause the client’s account to cease tracking the Leader-derived portfolio associated with that Leader. The client’s holdings related to that Leader-derived portfolio will be sold and the cash proceeds will be returned to the client for reengagement in the app or for transfer to their linked banking account. Likewise, upon termination of a client’s advisory relationship with Follow RIA (including termination due to the client’s decision or non-payment of subscription fees) Follow RIA will no longer issue trading instructions on the client’s behalf to the Brokerage Provider, and the client’s holdings related to that Leader-derived portfolio will be sold and the cash proceeds will be returned to the client for reengagement in the app or for transfer to their linked banking account. Terminated advisory clients, or individuals who are otherwise not active subscribers, will not be able to trade in their brokerage accounts at will through the Follow App. In such an event, clients will receive an electronic notification from Follow RIA or the Publishing Affiliate, as appropriate, describing this change in the operation of their account. However, if a client no longer wishes to maintain a portfolio derived from a certain Leader, provided that the client has remained current on its subscription fees the client may terminate securities trading derived from that Leader, but retain the client’s subscription to that Leaders’ content through the Publishing Affiliate. The Proxy Account For each Leader, Follow RIA has created a corresponding Proxy Account. Follow RIA has funded each Proxy Account in a nominal manner and maintains each Proxy Account in the same manner as Leader-derived portfolios are maintained for individual clients: this process is described in the immediately preceding section. This means that the Proxy Account associated with a particular Leader should buy and sell the same securities in approximately the same ratios and at approximately the same times as each of the client securities portfolios associated with that Leader. For this reason, it is expected that the Proxy Account returns and other information published through the App with respect to each Proxy Account will provide clients with meaningful information that they can use to make an assessment of whether they would like to create and maintain a securities portfolio derived from a particular Leader’s portfolio. Therefore, Follow RIA’s App presents individuals who subscribe to that Leader with performance information regarding the Proxy Account corresponding to that Leader, rather than the performance of the Leader’s outside portfolio. It is important to understand, however, that, for the reasons identified in the immediately preceding section, returns on a Proxy Account may vary, perhaps significantly, from the returns experienced from any corresponding client securities portfolio and that the returns on client accounts may also vary significantly one from the other. In order to mitigate the conflict between Follow RIA’s proprietary Proxy Accounts and the interests of Follow RIA’s clients in their securities portfolios, net gains incurred by Follow RIA on a Proxy Account, that is, gains after payment of any brokerage fees charged to Follow RIA by the Brokerage Provider, will first be used to establish a suitable reserve for the payment of taxes on such gains and to fund new or existing Proxy Accounts, including the addition of funds thereon on account of prior losses. Gains that exceed the amount required for this reserve will be donated by Follow RIA to one or more charities of Follow RIA’s choosing. The Brokerage Provider charges Follow RIA its standard fees for opening and maintaining Follow RIA’s Proxy Accounts. In addition to the above, Follow RIA intends to re-balance each Proxy Account and client account approximately monthly, which will be designed to account for any items that were not accounted for during the daily trading operations (for example, divergence due to dividends, reverse splits, or cash added by the Leader to the Leader’s account). The Brokerage Provider Clients who choose to trade securities through the Follow App in the manner described above must first open a brokerage account in their name, through the App, with the Brokerage Provider chosen by Follow RIA for use by its clients, Alpaca Securities LLC (the “Brokerage Provider”). The Brokerage Provider is a SEC-registered brokerage firm that is also a member of, and regulated by, the Financial Industry Regulatory Authority, Inc. (“FINRA”) and a member of the Securities Investor Protection Corporation (“SIPC”), which is a corporation that was created by Congress to help protect customer assets when a SIPC-member brokerage firm fails. Follow RIA is not affiliated with the Brokerage Provider. Follow RIA has entered into an agreement with the Brokerage Provider that permits Follow RIA’s clients to trade securities as provided above. As part of the process of opening an account with the Brokerage Provider, a client must instruct the Brokerage Provider, in writing, to allow Follow RIA the ability to submit trade orders and instructions on behalf of its clients. Relationship between Follow RIA, Clients, and the Brokerage Provider The Brokerage Provider will enter into separate agreements with each of Follow RIA’s clients to establish the client’s account at the Brokerage Provider, subject to the Brokerage Provider’s approval. Follow RIA clients access their account at the Brokerage Provider through Follow RIA’s App. Through its App, Follow RIA will provide clients with the ability to access their account at the Brokerage Provider and receive notifications from the Brokerage Provider, but clients will not be able to trade directly through the App, except in accordance with the process described above. Upon termination of a client’s advisory relationship with Follow RIA, or if a client has no active subscriptions, the client’s account holdings will be liquidated and proceeds returned to the clients described in the Securities Trading section above. The Brokerage Provider does not provide investment, tax, legal, or other advice to Follow RIA or its clients, and does not offer opinions regarding the suitability or value of any securities transaction or investment strategy. Follow RIA’s clients will receive disclosures regarding the nature of the relationship between Follow RIA, its clients, and the Brokerage Provider. These disclosures include: (1) that Follow RIA is not a broker-dealer and does not open accounts or otherwise perform the brokerage services that Follow RIA’s clients access through its App, (2) that the Brokerage Provider opens and maintains accounts and provides brokerage services, (3) that Follow RIA and the Brokerage Provider are each independently accountable to the client for the services they provide, and do not supervise each other’s activities, (4) that under the client’s agreement with Follow RIA, Follow RIA will provide its App as the primary means of accessing and receiving information about the client’s account from the Brokerage Provider, (5) that Follow RIA’s clients may contact the Brokerage Provider directly at contact information to be provided by the Brokerage Provider, and (6) that, should the Follow RIA App become unavailable, Follow RIA’s clients may lose access to their account, as well as be unable to access customer support services provided by Follow RIA in connection with the account. Follow RIA does not participate in wrap fee programs.