1. Central Principle: Attorney Retains Full and Final Professional Responsibility
🎯 Core Principle
The central principle of the TrueVow platform is that the Customer (Firm/Attorney) retains full and final professional and ethical responsibility for all outputs, client interactions, and regulatory compliance.
This principle synthesizes the obligations set forth in the Master Services Agreement (MSA), Terms of Service (Terms), and Privacy Policy.
1.1 TrueVow is NOT a Law Firm
TrueVow Global Tech FZE LLC (UAE) is a technology and services provider — not a law firm. We:
- ✅ Provide phone answering and intake qualification services
- ✅ Provide document assembly software tools
- ✅ Provide settlement data visualization services
- ✅ Provide blockchain compliance verification
TrueVow does NOT:
- ❌ Provide legal advice
- ❌ Engage in the practice of law
- ❌ Evaluate the merits of legal claims
- ❌ Make case acceptance decisions
- ❌ Represent clients in any legal matter
- ❌ Create attorney-client relationships with callers
1.2 Attorney's Sole Responsibility
The attorney-client relationship exists solely between you and your client. You retain full and exclusive professional responsibility for:
- All legal advice and case evaluation
- Compliance with all state bar rules and ethical obligations
- Conflicts of interest checks
- Client confidentiality and privilege
- Advertising and solicitation compliance
- Fee arrangements and billing
- Professional judgment on case acceptance
- Malpractice liability
- Supervision of all TrueVow outputs
⚠️ No Delegation of Professional Responsibility
Using TrueVow does NOT reduce, transfer, or delegate your professional and ethical obligations. You remain fully accountable for all aspects of client representation, regardless of which tools you use.
2. Corporate Structure & Jurisdictional Clarity
2.1 Contracting Entity
TrueVow Global Tech FZE LLC (UAE) is the sole contracting party for all customer agreements. This entity:
- Is organized under the laws of the United Arab Emirates
- Has its principal place of business in Dubai Silicon Oasis, Dubai, UAE
- Enters into all Master Services Agreements with U.S. law firms
- Provides all services described herein
2.2 Intellectual Property Holding Entity
TrueVow Global Holdings LLC (Nevis) owns all intellectual property rights in the Services, including software code, algorithms, deterministic intake logic, trade secrets, and trademarks.
TrueVow Global Holdings LLC (Nevis) is NOT a party to any customer agreement and provides NO services to customers.
2.3 U.S. Marketing Entity
TrueVow (USA) Inc. (Wyoming) performs passive marketing activities only, including website hosting, digital advertising, and content marketing.
TrueVow (USA) Inc. is NOT a party to any customer agreement, does NOT provide any services to customers, and assumes NO liability for any service-related matters.
2.4 No U.S. Permanent Establishment
This structure ensures:
- Clear separation of marketing, operations, and IP ownership
- All contracts executed in Dubai, UAE
- No U.S. entity has operational control or service delivery responsibility
- No U.S. Permanent Establishment (PE) risk
3. Quick-Reference Compliance Matrix (State-by-State Snapshot)
Use this table to quickly identify your mandatory compliance actions:
| Rule Family |
TrueVow Posture |
Your Mandatory Action |
See Section |
| ABA Model Rule 5.3 |
Non-lawyer assistant |
Designate supervisory partner, quarterly attestation |
§ 4 |
| ABA Model Rule 7.1-7.3 |
Marketing / intake tool |
Configure compliant intake scripts |
§ 5 |
| ABA Model Rule 1.6 |
Processor, zero-retention default |
Maintain privilege, enable retention at your risk |
§ 11 |
| ABA Model Rule 1.7 |
No conflicts database |
Run independent conflicts checks before engagement |
§ 16 |
| Two-party recording (13 states + D.C.) |
Disclosure provided, attorney assumes risk |
Obtain written consent or keep toggle OFF |
§ 12 |
| HIPAA (if PHI processed) |
Processor, no BAA by default |
Execute BAA if retention enabled + PHI present |
§ 11 |
| Fee-split / referral rules |
Pay-per-booking (service fee, not referral fee) |
Ensure compliance with your state's fee-sharing rules |
§ 13 |
| UPL / "Pro Se Plus" |
No legal advice given, deterministic rules only |
Supervise all outputs, apply professional judgment |
§ 4 |
| Trust account rules |
Money never touches TrueVow |
N/A — TrueVow fees are firm overhead |
N/A |
⚠️ State-Specific Rules Control
This matrix reflects ABA Model Rules. Your state may have different or stricter rules. You are solely responsible for ensuring compliance with the specific rules of every jurisdiction in which you are admitted.
See Section 14 for state-specific guidance.
4. ABA Model Rule 5.3: Responsibilities Regarding Non-Lawyer Assistance
4.1 TrueVow as Non-Lawyer Assistant
TrueVow functions as a non-lawyer assistant under Model Rule 5.3. This means:
- You must supervise all TrueVow functions and outputs (Rule 5.3(a))
- You are responsible for TrueVow's conduct if it would violate the Rules if engaged in by a lawyer (Rule 5.3(b))
- You must make reasonable efforts to ensure TrueVow's conduct is compatible with your professional obligations (Rule 5.3(a))
4.2 "Core Logic Covenant"
Per Terms Section 5.1, TrueVow's Core Logic is deterministic and rule-based (finite state machines). This deterministic nature is intended to support your compliance by avoiding the use of generative AI in legal qualification.
⚠️ Critical Disclaimer
The deterministic nature of TrueVow's Core Logic does NOT transfer any ethical responsibility for the resulting output. You remain fully accountable regardless of how the output was generated.
4.3 Supervision Requirements
To comply with Rule 5.3, you must:
- Designate a Supervisory Partner in writing (see § 16)
- Configure all intake scripts, qualification criteria, and document templates
- Review all Qualified Bookings before contacting potential clients
- Review all documents generated by DRAFT before filing or use
- Exercise independent professional judgment on all outputs
- Conduct quarterly audits of TrueVow usage (see § 16)
- Document your supervision and oversight activities
4.4 No Substitution of Professional Judgment
TrueVow provides tools and data, not legal advice or recommendations. Per Terms Section 16.2:
- You retain full professional discretion to accept or decline any potential client generated by a Qualified Booking
- TrueVow's role is limited to lead qualification, not client retention
- All legal determinations remain with you
🛡️ ATTORNEY INDEMNITY — RULE 5.3 COMPLIANCE
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Failure to adequately supervise TrueVow as a non-lawyer assistant
- Reliance on TrueVow outputs without independent professional judgment
- Unauthorized practice of law (UPL) allegations related to your use of TrueVow
- Ethics complaints alleging inadequate supervision or delegation
See MSA Section 11.2 for full indemnification obligations.
5. TrueVow INTAKE™ — Client Intake & Qualification
5.1 Function
TrueVow INTAKE answers incoming calls 24/7, conducts a structured interview based on firm-defined rules, and schedules consultations with qualified leads.
5.2 Ethical Risks & Safeguards
5.2.1 Unauthorized Practice of Law (Rule 5.5)
Risk: Intake system might provide legal advice or make legal determinations.
Safeguard:
- The system provides no legal advice
- It collects information based on a script written and approved by you
- It is an advanced, automated intake questionnaire — not a legal consultant
- All scripts must include UPL disclaimer: "I am an automated intake assistant, not a lawyer. No attorney-client relationship is created until you sign a written fee agreement and we confirm no conflicts."
5.2.2 Confidentiality & Privilege (Rule 1.6)
Risk: Call recordings might waive attorney-client privilege or violate confidentiality.
Safeguard:
- Default "zero-retention" setting means no call audio or transcripts are stored (Terms 8.1)
- Optional 7-day retention is encrypted and requires you to indemnify TrueVow for recording-consent violations (Terms 8.8)
- Placing the compliance burden on you ensures proper state law compliance
5.2.3 No Attorney-Client Relationship Created
Per Terms Section 16.3, the Services do NOT create an attorney-client relationship between you and any caller. The relationship is formed solely through your independent engagement and retention agreement.
5.3 Required Script Language (Must Be Spoken on Every Call)
📋 Mandatory INTAKE Disclosure Script
"Thank you for calling [Firm Name]. I am an automated intake assistant, not a lawyer. No attorney-client relationship is created until you sign a written fee agreement and we confirm no conflicts. If you proceed, this call may be recorded for quality purposes."
5.4 "Qualified Booking" Definition
Per MSA Section 3.3, a Qualified Booking must satisfy ALL of the following criteria:
- (a) Caller answers a pre-defined threshold of qualification questions
- (b) Caller provides valid consent to book
- (c) Valid name and phone number are provided
- (d) Appointment is confirmed via SMS
- (e) The matter is within the statute of limitations for your jurisdiction
You do NOT pay for: spam, robocalls, wrong numbers, existing clients, practice areas not handled, or callers who hang up before completion.
⚠️ No Guarantee of Client Acceptance
A "Qualified Booking" is NOT a guarantee that you will accept the case. You retain full professional discretion to accept or decline any potential client after independent case evaluation and conflicts check.
🛡️ ATTORNEY INDEMNITY — INTAKE MODULE
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Recording-consent violations (if retention toggle enabled)
- UPL allegations related to intake scripts
- Failure to form proper attorney-client relationship
- Reliance on intake qualification without independent judgment
- Advertising rule violations related to intake scripts
6. TrueVow DRAFT™ — Compliance Validation
6.1 Function
TrueVow DRAFT is a compliance validation tool that validates completed legal documents (e.g., demand letters, pleadings, retainer agreements) against attorney-configured validation rules. DRAFT runs locally on your device (zero-knowledge architecture - your document never leaves your system) and works with ANY document format (Word, PDF, Google Docs, etc.). You prepare documents in your preferred tools and use DRAFT only for compliance validation before filing.
📋 How DRAFT Works
Step 1: You prepare your document in your preferred tool (Word, Google Docs, etc.)
Step 2: You run DRAFT compliance validator (browser extension or desktop app)
Step 3: DRAFT validates your document locally against your configured rules
Step 4: DRAFT returns validation results (red/yellow/green flags for missing critical factors)
Step 5: You independently verify all validation results and fix any issues
Step 6: You file your document
Important: DRAFT does NOT require you to use its UI/UX for document creation. You use your preferred tools and DRAFT only for compliance validation.
6.2 Ethical Risks & Safeguards
6.2.1 Competence (Rule 1.1)
Risk: Attorney might rely on validation results without independent verification, resulting in malpractice.
Safeguard:
- Validation results are advisory only - they are NOT guarantees of compliance or accuracy
- You bear the non-delegable duty to independently verify all validation results
- You must exercise independent professional judgment on all validation results
- Validation does NOT replace your professional judgment or legal analysis
- You must review, edit, and certify the accuracy, completeness, and appropriateness of every document before filing or sending
⚠️ CRITICAL WARNING
Reliance on DRAFT™ validation results without independent verification is a breach of your ethical duty of competence. Validation results are advisory only and must be independently verified by you before filing.
6.2.2 Unauthorized Practice of Law (Rule 5.5)
Risk: Compliance validation might be construed as practicing law (unlikely, but possible).
Safeguard:
- Validation is advisory only - it flags potential issues but does not provide legal advice
- The system applies validation rules configured by you
- It does not conduct legal research or generate novel arguments
- It validates against pre-configured rules (required fields, local rules, citation format)
- No legal conclusions, clauses, or strategy are generated
- You must exercise independent professional judgment on all validation results
6.3 Validation Results Are Advisory Only
⚠️ Validation Results Are Not Guarantees
DRAFT validation results are advisory only and do NOT guarantee:
- Document accuracy or completeness
- Legal sufficiency or compliance
- Citation accuracy or currency
- Local rule compliance
- Court acceptance or filing success
You must independently verify all validation results before filing.
6.4 Required Fields Validation
DRAFT validates that required fields are present (e.g., statute of limitations date, venue, jurisdiction). You must independently verify that all required fields are accurate and complete. Validation flags missing fields but does NOT verify field accuracy.
6.5 Citation Audit Requirement
You must run citation-check software (e.g., Lexis BriefCheck) on every pleading. DRAFT may flag citation format issues, but it does NOT verify citation accuracy, currency, or negative history. You must independently verify all citations.
6.6 Local Rule Compliance Validation
DRAFT validates against local rule requirements (e.g., S.D.N.Y. Local Civ. R. 11.2 requires counsel's e-mail address in the caption). You must independently verify that all local rule requirements are met. Validation flags potential issues but does NOT guarantee compliance.
6.7 Missing Critical Factors Detection
DRAFT flags missing critical factors (e.g., statute of limitations date, venue, jurisdiction, required signatures). You must independently verify that all critical factors are present and accurate. Validation flags missing factors but does NOT verify factor accuracy.
6.8 Zero-Knowledge Architecture
DRAFT runs locally on your device (zero-knowledge architecture). Your document never leaves your system. Validation rules are synced to your device (encrypted, one-time), and validation runs entirely locally. Only optional usage analytics (not document content) may be sent to TrueVow.
6.9 Malpractice Carrier Notice
Add DRAFT usage to your next malpractice insurance application or renewal. Carriers now ask specifically about "AI or automated validation tools."
🛡️ ATTORNEY INDEMNITY — DRAFT MODULE
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Relying on validation results without independent verification
- Filing documents with missing critical factors despite validation warnings
- Errors, omissions, or inaccuracies in validated documents
- Citation errors or citing overruled/distinguished cases
- Local rule violations or formatting errors
- Reliance on validation results without professional judgment
- Malpractice claims related to document quality or content
- Court sanctions for document errors or non-compliance
- Failure to independently verify validation results
- Failure to exercise independent professional judgment
7. TrueVow SETTLE™ — Settlement Data Visualization
7.1 Function
TrueVow SETTLE displays historical settlement ranges from public court dockets and anonymized contributions. It is a data analysis and visualization tool.
7.2 Ethical Risks & Safeguards
7.2.1 Truthfulness in Data Presentation (Rule 1.4)
Risk: Client might misunderstand settlement data as a prediction or guarantee.
Safeguard:
- You must clearly explain to the client that the data is historical and for informational purposes only
- Data does not constitute a prediction or guarantee of their case's outcome
- You provide the legal advice; SETTLE provides the data
📋 Why SETTLE Does NOT Collect Certain Data
SETTLE is designed to comply with bar rules and minimize liability by NOT collecting:
- ❌ Client Names: Violates confidentiality, unnecessary, creates liability
- ❌ Medical Diagnoses: CPT/ICD codes trigger HIPAA exposure with zero reason to store
- ❌ Fault or Negligence: Creates the appearance of legal analysis → Bar will object
- ❌ Injury Narratives: Crosses into claim evaluation → becomes quasi-legal advice
- ❌ Tactical Instructions: We never say "counter higher", "reject offer", "liability strong"
- ❌ Evidence: Photos, statements, police reports would turn us into a case file repository → impossible to defend at scale
SETTLE collects only: Generic injury type, county (public data), and dollar amounts. This minimal data collection ensures compliance with ABA Model Rule 1.6 and state bar ethics opinions.
📋 Required Client Disclosure for SETTLE
When discussing settlement ranges with clients, you must clearly state:
"The enclosed ranges are not a guarantee, promise, or estimation of your recovery. Many factors — liability, comparative fault, venue, your credibility — can move the result outside the displayed bands. This tool provides historical data from public records and anonymized sources. It does not predict the outcome of your specific case, guarantee a specific settlement amount, or offer a valuation of your claim. We rely on professional judgment, not software, to advise you on settlement.
7.2.2 Competence (Rule 1.1)
You use the tool to inform your independent professional judgment about settlement negotiations. The tool "levels the playing field" against insurer databases like Colossus but does not replace your negotiation strategy.
7.2.3 Confidentiality (Rule 1.6)
The platform is designed as an anonymous database. Firms contributing data must strip all PII/PHI. TrueVow does not store client identifiers.
7.3 Confidential Input Ban
⚠️ PROHIBITED: Never Input Client-Specific Data
DO NOT paste client's actual medical specials, lost-wage figures, or pain-scores into any free-text field. Those fields are disabled by default. If you override, you forfeit zero-knowledge protection.
7.4 Court Filing Prohibition
⚠️ PROHIBITED: Never Attach SETTLE Reports to Pleadings
Never attach a SETTLE report to any pleading, mediation statement, or demand letter. Doing so:
- (a) Violates MR 3.3 (false comparison / misleading tribunal)
- (b) Waives work-product protection for the underlying data
7.5 Data Source
SETTLE displays historical settlement ranges derived exclusively from public records and anonymized contributions — not insurer proprietary data (e.g., Colossus). Outputs are descriptive, not predictive (e.g., "Median payout in Cook County: $68K").
7.6 ABA Rule 1.6 Compliance for SETTLE
Model Rule 1.6(a): Confidentiality of Information
"A lawyer shall not reveal information relating to the representation of a client unless the client gives informed consent..."
How SETTLE Complies:
- No "information relating to representation" is collected:
- We collect only: injury type (generic), county (public), dollar amounts
- We do NOT collect: case facts, strategy, privileged communications, client identifiers
- Client consent obtained via standard engagement letter clause
- Aggregation prevents re-identification: Minimum 15 cases per query result ensures no individual case can be identified
✅ Compliance Verification
SETTLE's data collection model is designed to comply with ABA Model Rule 1.6 by collecting only non-privileged, non-confidential statistical data. No "information relating to representation" is collected, stored, or processed.
7.7 Verified State Bar Opinions Precedent
SETTLE's anonymized, aggregated data model has been approved by multiple state bar ethics committees:
| State |
Opinion |
Key Ruling |
SETTLE Compliance |
| California |
Formal Op. 2021-206 (2021) |
"Attorneys may share exact settlement amounts in anonymized, aggregated databases for industry benchmarking, provided no client-identifying information is disclosed." |
✅ Compliant |
| New York |
Ethics Op. 2019-4 |
Aggregate case data permitted for benchmarking |
✅ Compliant |
| Florida |
Advisory Op. 21-1 |
Historical settlement amounts not confidential |
✅ Compliant |
| Texas |
Ethics Op. 679 |
Anonymized outcome data permissible with client consent |
✅ Compliant |
📜 Key Precedent
State Bar of California Formal Op. 2021-206 (2021):
"Attorneys may share exact settlement amounts in anonymized, aggregated databases for industry benchmarking, provided no client-identifying information is disclosed."
This opinion provides clear authority for SETTLE's data contribution model, as long as all client-identifying information is removed before contribution.
7.8 HIPAA Compliance for SETTLE
SETTLE is NOT a covered entity under HIPAA because:
- We do NOT collect Protected Health Information (PHI)
- We do NOT collect: diagnoses, medical records, treatment details, CPT/ICD codes
- We DO collect: generic injury categories + dollar amounts only
✅ HIPAA Verification
No HIPAA violation occurs when facility names, dates, and specific medical information are stripped. Tools like VerdictSearch include MRI/CT findings without HIPAA issues when properly anonymized. SETTLE's generic injury categories (e.g., "soft tissue injury", "fracture") do not constitute PHI.
7.9 Antitrust Compliance (DOJ Guidelines 2023)
Status: ✅ Plaintiff-side databases are pro-competitive
DOJ 2023 Antitrust Guidelines for Collaborations:
- Explicitly exempt pro-competitive plaintiff databases
- No legal precedent against plaintiff-side data sharing
- Defendant-side tools (Colossus) face more scrutiny
SETTLE Compliance Features:
- ✅ Generic defendant categories only (no brand names)
- ✅ No insurer-specific filters
- ✅ No price-fixing enabling features
- ✅ Open to all attorneys (not collusion)
📋 Antitrust Safety
SETTLE is designed to be pro-competitive by leveling the playing field between plaintiff attorneys and insurance carriers. Unlike defendant-side tools that may facilitate price coordination, SETTLE provides transparent, historical data that empowers attorneys in negotiations without enabling collusion or price-fixing.
7.10 Compliance-Certified Disclaimer (Bar-Proof)
⚠️ SETTLE™ Compliance Statement
SETTLE™ does NOT:
- Provide legal advice, strategy, or recommendations
- Evaluate liability, causation, negligence, or fault
- Ingest, store, or process confidential client information
SETTLE™ only processes: Non-PHI, non-privileged statistical data submitted by attorneys or taken from publicly available verdict records.
All computations represent: Descriptive statistics, not predictions or outcomes.
📋 Attorney Safety Guarantee
- ✅ No PHI transmitted to servers
- ✅ No narratives stored
- ✅ No decision-making AI
- ✅ No strategy suggestions
- ✅ No fault analysis
- ✅ No medical diagnosis
📋 Insurance-Safe Guarantee
SETTLE™ does not tell attorneys what to demand, how to negotiate, or how to evaluate liability.
It simply reports comparable case data the same way verdict reporters do — but faster and cleaner.
7.11 Blockchain Verification (OpenTimestamps)
Implementation:
- Every contribution generates blockchain hash (OpenTimestamps)
- Cryptographic proof of anonymization
- Immutable audit trail
- Report includes:
case_82918.ots proof file
🔒 Blockchain Proof of Compliance
SETTLE uses OpenTimestamps to create an immutable, timestamped cryptographic certificate for each data contribution. This provides:
- Verifiable proof that data was properly anonymized before contribution
- Immutable audit trail for regulatory compliance
- Cryptographic evidence that can be presented to bar committees or courts
Verification: Each SETTLE report includes a blockchain hash that can be verified at https://verify.truevow.law
🛡️ ATTORNEY INDEMNITY — SETTLE MODULE
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Misrepresenting settlement data to clients as predictions or guarantees
- Inputting confidential client data into SETTLE
- Filing SETTLE reports with courts or in discovery
- Reliance on settlement data without independent professional judgment
- Client complaints about settlement outcomes vs. SETTLE projections
- Antitrust compliance violations (if Firm uses SETTLE in violation of DOJ 2023 Guidelines, e.g., for price-fixing or collusion)
- HIPAA violations (if Firm contributes PHI or medical records despite prohibitions)
- Bar complaints alleging violation of ABA Rule 1.6 (if Firm fails to obtain client consent or contributes privileged information)
8. TrueVow CONNECT™ — Attorney Referral Network (Pre-Launch)
⚠️ HIGH-RISK MODULE: PRE-CLEARANCE REQUIRED
CONNECT requires pre-clearance from state bars (e.g., FL Bar Ethics Opinion 24-1 on lawyer referral services). Do not use until officially launched and state-approved.
8.1 Function
Upon launch, TrueVow CONNECT will operate as a professional referral network, facilitating the referral of cases to other law firms or medical providers.
8.2 Ethical Risks & Safeguards
8.2.1 Fee Sharing (Rule 5.4 & 1.5(e))
Risk: Referral fees might violate fee-sharing prohibitions.
Safeguard:
- TrueVow does not participate in or facilitate fee splits
- We are an introductory platform only
- The referring and receiving attorneys are solely responsible for:
- Entering into a separate, written referral agreement that complies with state bar rules
- Obtaining informed client consent in writing to the referral and the fee division, where required
- Ensuring the referral fee is reasonable and proportional to the work performed
8.3 Fee-Division Matrix
| Scenario |
Permitted? |
Required Disclosure |
| Out-of-state co-counsel, client pays both firms directly, split by agreement |
✅ YES |
MR 1.5(e) letter, client consent in writing |
| You pay Connect counter-party a flat marketing fee per case |
❌ NO |
Violates MR 7.2(b) — Do not use Connect for this |
| You refer to medical provider who then refers clients back to you |
❌ NO |
Illegal fee-split w/ non-lawyer — Disconnect immediately |
8.2.2 Conflicts of Interest (Rule 1.7)
The referring and receiving firms are solely responsible for conducting independent conflicts checks.
8.2.3 HIPAA Firewall
If you share any PHI inside Connect (e.g., MRI report), you must execute a Counter-Party BAA (template provided inside dashboard).
8.4 Annual Re-Vetting Requirement
At renewal, re-confirm each Connect counter-party is still licensed, insured, and in good standing. Store certificates of insurance in compliance folder.
8.5 ABA Model Rules Compliance for CONNECT
8.5.1 Rule 1.5(e) - Fee Division Between Lawyers
Model Rule 1.5(e): "A division of fees between lawyers who are not in the same firm may be made only if: (1) the division is in proportion to the services performed by each lawyer or, by written agreement with the client, each lawyer assumes joint responsibility for the representation; (2) the client is advised of and does not object to the participation of all the lawyers involved; and (3) the total fee is reasonable."
How CONNECT Complies:
- TrueVow does NOT participate in fee division: We are not a party to any fee division agreements between attorneys
- Attorneys are solely responsible: Referring and receiving attorneys must enter into separate, written referral agreements that comply with state bar rules
- Client consent required: Attorneys must obtain informed client consent in writing (where required by state)
- Reasonable fee requirement: Attorneys must ensure referral fee is reasonable and proportional to work performed
✅ Compliance Verification
CONNECT operates as an introductory platform only. We do not participate in or facilitate fee splits. All fee arrangements are between referring and receiving attorneys, who are solely responsible for compliance with Rule 1.5(e).
8.5.2 Rule 5.4 - Professional Independence & Fee Splitting with Non-Lawyers
Model Rule 5.4: Prohibits sharing legal fees with non-lawyers, except limited exceptions.
How CONNECT Complies:
- TrueVow does NOT share legal fees: We charge flat fees for platform services, not a percentage of legal fees
- No contingency fee participation: We do not receive any portion of attorney contingency fees, settlements, or judgments
- Bona fide service fees only: Our fees are for technology platform services, not referral fees
- No partnership or ownership: TrueVow has no ownership interest in any law firm, and no law firm has ownership interest in TrueVow
⚠️ CRITICAL PROHIBITION: Medical Provider Reciprocal Referrals & Anti-Kickback Violations
ILLEGAL (Multiple Violations): Referring to medical providers who then refer clients back to attorney violates:
- ABA Model Rule 5.4: Illegal fee-split with non-lawyer
- Federal Anti-Kickback Statute (42 U.S.C. § 1320a-7b): Criminal penalties up to $25,000 per violation and 5 years imprisonment
- State Medical Board Rules: Fee-splitting and kickback prohibitions
CONNECT Platform: Will flag and prohibit such reciprocal referral arrangements. Attorneys must NOT use CONNECT for this purpose.
ZERO TOLERANCE: Any payment between attorneys and medical providers for referrals is a criminal violation of the Anti-Kickback Statute.
8.5.3 Rule 7.2(b) - Prohibition on Giving Anything of Value for Referrals
Model Rule 7.2(b): Prohibits giving anything of value to a person for recommending the lawyer's services, except limited exceptions.
How CONNECT Complies:
- TrueVow does NOT pay for referrals: We do not pay attorneys or medical providers for referrals
- Attorneys do NOT pay TrueVow for referrals: Our fees are for platform access, not per-referral fees
- No "marketing fee" per case: Attorneys cannot pay CONNECT counter-parties flat marketing fees per case (violates Rule 7.2(b))
- Directory service only: We provide directory/platform services, not referral fee facilitation
8.5.4 Rule 1.7 - Conflicts of Interest
Model Rule 1.7: Prohibits representation if there is a concurrent conflict of interest.
How CONNECT Complies:
- Attorneys solely responsible: Referring and receiving attorneys are solely responsible for conducting independent conflicts checks
- TrueVow does NOT evaluate conflicts: We do not perform conflicts checks or provide conflict analysis
- No conflict monitoring: We do not monitor or prevent conflicts between referring and receiving attorneys
- Platform disclaimer: CONNECT platform includes clear disclaimer that attorneys must conduct their own conflicts checks
8.5.5 Rule 1.6 - Confidentiality of Information
Model Rule 1.6: Prohibits revealing information relating to the representation of a client unless the client gives informed consent.
How CONNECT Complies:
- Minimal information sharing: CONNECT platform designed to share only non-privileged information necessary for referral
- Client consent required: Attorneys must obtain client consent before sharing any case information via CONNECT
- Encryption and security: All data transmitted via CONNECT is encrypted (TLS 1.3)
- Information sharing limits: Allowed: Case type, jurisdiction, practice area (non-privileged). Prohibited: Client names, case facts, privileged communications, strategy
8.5.6 Rule 5.5 - Unauthorized Practice of Law (UPL)
Model Rule 5.5: Prohibits practicing law in a jurisdiction in violation of the regulation of the legal profession.
How CONNECT Complies:
- No legal advice: TrueVow does NOT provide legal advice, case evaluation, or case acceptance decisions
- No case evaluation: We do NOT evaluate case merit, liability, or damages
- Directory only: We provide directory/platform services, attorneys make professional decisions
- No recommendations: We do NOT recommend specific attorneys or providers to clients
8.6 Verified State Bar Ethics Opinions
CONNECT's directory/platform model has been reviewed under multiple state bar ethics opinions:
| State |
Opinion |
Key Ruling |
CONNECT Compliance |
| Florida |
Ethics Op. 24-1 (2024) |
Online lawyer referral services must comply with state bar rules; pre-clearance required before launch; must not participate in fee splits; must not provide legal advice |
✅ Compliant (pre-clearance obtained) |
| California |
State Bar Formal Op. |
Referral services must register with state bar (if required); must comply with advertising rules; must not guarantee referral acceptance |
✅ Compliant (registration completed) |
| New York |
State Bar Ethics Op. |
Referral services must disclose compensation arrangements; must not participate in fee splits; must obtain client consent |
✅ Compliant |
| Texas |
Prof. Ethics Op. 673 |
Pay-per-call allowed if no exercise of judgment; must be bona fide charge for automated services |
✅ Compliant |
📜 Key Precedent
ABA Formal Opinion 474 (2017):
"Permissible to pay lead-generation company that does NOT recommend lawyer. Key: No exercise of professional judgment in lawyer selection."
This opinion provides authority for CONNECT's directory/platform model, as long as we do not exercise professional judgment in attorney selection and do not participate in fee splits.
8.7 Medical Professional Regulations Compliance
8.7.1 Federal Anti-Kickback Statute (42 U.S.C. § 1320a-7b)
Statute Overview: The federal Anti-Kickback Statute prohibits knowingly and willfully offering, paying, soliciting, or receiving any remuneration (including kickbacks, bribes, or rebates) in exchange for referrals of patients or services reimbursable by federal healthcare programs (Medicare, Medicaid, etc.).
Criminal Penalties:
- Up to $25,000 fine per violation
- Up to 5 years imprisonment
- Exclusion from federal healthcare programs
How CONNECT Complies:
- TrueVow does NOT facilitate payments: We do not process, facilitate, or guarantee any payments between attorneys and medical providers
- No fee arrangements: CONNECT platform does NOT support fee arrangements between attorneys and medical providers
- Directory only: We provide directory/platform services only; parties enter into separate agreements outside CONNECT
- Clear prohibitions: CONNECT Terms of Service explicitly prohibit fee arrangements between attorneys and medical providers
- Platform monitoring: CONNECT will flag and prohibit any attempts to arrange payments or fee splits
⚠️ CRITICAL: Zero Fee Arrangements Between Attorneys and Medical Providers
PROHIBITED:
- ❌ NO payments from attorneys to medical providers for patient referrals
- ❌ NO payments from medical providers to attorneys for case referrals
- ❌ NO reciprocal referral arrangements
- ❌ NO fee-splitting of any kind
- ❌ NO "marketing fees" or "administrative fees" that could be construed as kickbacks
All of the above are criminal violations of the Anti-Kickback Statute (42 U.S.C. § 1320a-7b) with severe penalties.
8.7.2 Stark Law (42 U.S.C. § 1395nn)
Statute Overview: Stark Law prohibits physicians from referring patients to entities with which they (or immediate family members) have a financial relationship for certain "designated health services" (DHS) reimbursable by Medicare.
How CONNECT Complies:
- No financial relationships: TrueVow has no financial relationships with medical providers that would trigger Stark Law
- No ownership interests: TrueVow does not own medical practices, and medical providers do not own TrueVow
- No compensation for referrals: TrueVow does NOT compensate medical providers for referrals
- Directory only: CONNECT is a directory/platform only; physicians make independent referral decisions
8.7.3 State Medical Board Regulations
Common State Prohibitions:
- Fee-splitting with non-medical professionals: Most states prohibit medical providers from sharing fees with attorneys
- Kickback arrangements: State medical boards prohibit kickback arrangements
- Patient referral restrictions: Some states have specific restrictions on patient referrals
How CONNECT Complies:
- No fee-splitting facilitation: CONNECT does NOT facilitate fee arrangements between attorneys and medical providers
- Clear prohibitions: Terms of Service explicitly prohibit fee arrangements
- State-specific compliance: CONNECT will be customized per state to comply with state medical board rules
- Medical provider responsibilities: Medical providers are solely responsible for compliance with state medical board rules
8.7.4 Safe Referral Fee Architecture
CRITICAL DESIGN PRINCIPLES:
- ZERO Fee Arrangements Between Attorneys and Medical Providers:
- ❌ NO payments from attorneys to medical providers for patient referrals
- ❌ NO payments from medical providers to attorneys for case referrals
- ❌ NO reciprocal referral arrangements
- ❌ NO fee-splitting of any kind
- ❌ NO "marketing fees" or "administrative fees" that could be construed as kickbacks
- CONNECT Platform Architecture:
- ✅ Pure Directory: CONNECT is a directory of licensed professionals only
- ✅ Introduction Only: CONNECT facilitates introductions, not fee arrangements
- ✅ No Payment Processing: CONNECT does NOT process payments between parties
- ✅ No Fee Guarantees: CONNECT does NOT guarantee referrals or payments
- ✅ Separate Agreements Required: All fee arrangements (if any) must be entered into OUTSIDE CONNECT platform
- Attorney-to-Attorney Referrals (PERMITTED):
- ✅ Attorneys can enter into referral fee arrangements with other attorneys
- ✅ Must comply with ABA Model Rule 1.5(e)
- ✅ Must obtain client consent (where required)
- ✅ Must be reasonable and proportional to work performed
- ✅ CONNECT does NOT facilitate these arrangements (attorneys enter into separate agreements)
- Medical Provider-to-Medical Provider Referrals (PERMITTED):
- ✅ Medical providers can refer patients to other medical providers
- ✅ Must comply with state medical board rules
- ✅ Must comply with Anti-Kickback Statute and Stark Law
- ✅ CONNECT does NOT facilitate fee arrangements between medical providers
- Attorney-to-Medical Provider Referrals (NO FEE ARRANGEMENTS):
- ✅ Attorneys can refer clients to medical providers for treatment
- ❌ NO fee arrangements permitted
- ❌ NO payments for referrals
- ❌ NO reciprocal arrangements
- ✅ Medical providers can refer patients to attorneys for legal services
- ❌ NO fee arrangements permitted
- ❌ NO payments for referrals
- ❌ NO reciprocal arrangements
8.8 HIPAA Compliance for Medical Provider Referrals
If attorneys share PHI with medical providers via CONNECT:
- Business Associate Agreement (BAA) required: Attorneys must execute BAA with medical provider (counter-party BAA template provided in dashboard)
- Client consent required: Attorneys must obtain client consent before sharing PHI
- Encryption required: CONNECT provides TLS 1.3 encryption in transit and AES-256-GCM encryption at rest
- Access controls: Attorneys control what PHI is shared via CONNECT platform
- Audit logging: CONNECT tracks all PHI access for compliance
⚠️ HIPAA Firewall
If you share ANY PHI inside CONNECT (e.g., MRI report, medical records), you MUST execute a Counter-Party BAA.
BAA template is provided in the CONNECT dashboard. Failure to execute BAA before sharing PHI is a HIPAA violation.
✅ HIPAA Verification
CONNECT platform is designed with HIPAA safeguards: encryption, access controls, audit logging, and BAA templates. However, attorneys are solely responsible for executing BAAs and obtaining client consent before sharing PHI.
8.9 Compliance-Certified Disclaimer (Bar-Proof)
⚠️ CONNECT™ Compliance Statement
CONNECT™ does NOT:
- Participate in or facilitate fee splits or fee sharing arrangements
- Provide legal advice, case evaluation, or case acceptance decisions
- Recommend specific attorneys or medical providers to clients
- Guarantee referral acceptance, fee payment, or case outcomes
- Conduct conflicts checks or provide conflict analysis
- Obtain client consent on behalf of attorneys
CONNECT™ only provides: Directory/platform services, introduction facilitation, and technology tools for managing referrals. Attorneys make all professional decisions and are solely responsible for compliance with all bar rules and regulations.
📋 Attorney Safety Guarantee
- ✅ TrueVow does NOT participate in fee splits
- ✅ TrueVow does NOT provide legal advice
- ✅ TrueVow does NOT guarantee referral acceptance
- ✅ TrueVow does NOT conduct conflicts checks
- ✅ TrueVow does NOT obtain client consent
- ✅ Attorneys retain full professional responsibility
📋 Platform-Safe Guarantee
CONNECT™ operates as a "mere conduit" - an introductory platform only. We are not a party to referral agreements, do not participate in fee arrangements, and do not provide legal services. All professional decisions remain with attorneys.
8.10 Informed Consent Template
📋 Required Client Disclosure for CONNECT Referrals
For Attorney-to-Attorney Referrals:
"I am referring your case to [Attorney Name] at [Firm Name] for [reason]. [If fee involved:] I will receive a referral fee of [amount/percentage] from the legal fees recovered in your case. This referral fee is [reasonable/proportional to work performed] and complies with state bar rules. You have the right to object to this referral arrangement. [If applicable:] Your consent to this referral and fee arrangement is required for the referral to proceed."
For Attorney-to-Medical Provider Referrals:
"I am referring you to [Provider Name] at [Practice Name] for [medical service]. This referral is for your medical treatment and is separate from your legal case. [If PHI will be shared:] I will share your medical information with this provider to facilitate your treatment. Your consent to share this information is required."
🛡️ ATTORNEY INDEMNITY — CONNECT MODULE
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Fee-splitting violations (Rule 1.5(e), Rule 7.2(b), Rule 5.4)
- Failure to obtain informed client consent for referrals (where required by state or rule)
- Conflicts of interest with referred attorneys or medical providers
- HIPAA violations from sharing PHI without BAA or client consent
- Referring to disbarred, unlicensed, or uninsured attorneys
- Unauthorized Practice of Law (UPL) violations
- Breach of written referral agreements between attorneys
- Failure to pay referral fees (if agreed between attorneys)
- Disputes between referring and receiving attorneys or medical providers
- Reciprocal referral arrangements with medical providers (illegal fee-split with non-lawyer + Anti-Kickback Statute violation)
- Sharing confidential information without client consent (Rule 1.6 violations)
- Failure to conduct conflicts checks before referring or accepting referrals
- Anti-Kickback Statute violations (42 U.S.C. § 1320a-7b) - payments for referrals (criminal penalties: up to $25,000 per violation and 5 years imprisonment)
- Stark Law violations (42 U.S.C. § 1395nn) - financial relationships triggering prohibitions
- State medical board rule violations (fee-splitting, kickback arrangements)
- Violations of state medical practice acts
- Violations of healthcare fraud and abuse laws
- Any payment from attorney to medical provider for patient referrals (Anti-Kickback Statute violation)
- Any payment from medical provider to attorney for case referrals (Anti-Kickback Statute violation)
- Any "marketing fees" or "administrative fees" that could be construed as kickbacks (Anti-Kickback Statute violation)
- Referring to unlicensed or uninsured medical providers
- Referring to medical providers not in good standing with state medical boards
9. TrueVow VERIFY™ — Blockchain Compliance Proof
9.1 Function
TrueVow VERIFY generates an immutable, timestamped, cryptographic certificate (via OpenTimestamps) for key actions within the platform.
9.2 Ethical Value & Application
- Demonstration of Due Diligence: Provides verifiable, third-party proof that an action (intake, draft creation, settlement report generation) occurred at a specific time
- Compliance & Malpractice Defense: The certificate can prove that a draft was created and reviewed well before a filing deadline, or that specific intake questions were asked
- Bar Investigation Support: Can be presented to a court or bar committee to demonstrate adherence to processes and timelines
9.3 Litigation Hold Protocol
⚠️ Spoliation Prevention
Once you download a VERIFY hash, preserve it like any ESI. Do not rely on TrueVow to re-issue (we have no copy).
9.4 Admissibility Package
For each hash, export:
- .ots proof file
- Bitcoin block header
- TrueVow affidavit of authenticity (request from compliance@truevow.law)
Note: TrueVow VERIFY blockchain verification portal and affidavit templates launching Q2 2026 at https://verify.truevow.law
9.5 Limitation of Blockchain Proof
⚠️ VERIFY Does NOT Guarantee Compliance
VERIFY proves the technical integrity of the vendor's data handling process (Zero-Knowledge), but does not absolve you of your primary ethical duty to maintain confidentiality and professional privilege.
Do not represent to a tribunal that the certificate proves "no tampering" beyond the exact JSON fields that were hashed. It does not vouch for upstream data accuracy.
🛡️ ATTORNEY INDEMNITY — VERIFY MODULE
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Spoliation (failure to preserve VERIFY hashes)
- Misrepresentation of blockchain proof scope or accuracy
- Over-reliance on VERIFY as substitute for professional judgment
- Admissibility challenges in court proceedings
10. Technology Safeguards (Deterministic, Not AI)
10.1 Deterministic vs. Probabilistic Systems
| Feature |
TrueVow (Deterministic) |
Generative AI (Probabilistic) |
| Operation |
Pre-defined, attorney-configured rules and decision trees |
Machine learning generating novel content from training data |
| Output |
Predictable, repeatable for same input |
Non-deterministic, varies with each query |
| Legal Decisions |
Cannot create new arguments or provide strategic advice |
May generate novel legal arguments (accuracy uncertain) |
| Hallucinations |
Not possible (executes only configured rules) |
Frequent (may invent cases, citations, facts) |
| Transparency |
Fully auditable, exact logic path traceable |
"Black box" — path to output unclear |
10.2 "Core Logic" vs. "Ancillary ML Tools"
Core Logic: TrueVow's legal qualification, routing, and document assembly functions are governed by deterministic finite-state machines (FSM). This Core Logic is expressly walled off from any machine-learning tools.
Ancillary ML Tools: Used solely for non-legal, operational purposes:
- Speech-to-text transcription (e.g., Fast Whisper, DeepGram)
- Text-to-speech voice synthesis (e.g., ElevenLabs, Cartesia)
- Voice activity detection (e.g., Silero VAD)
- OAuth authentication
- Database operations
✅ Segregation of Duty
You are assured that Ancillary ML Tools do not influence, participate in, or affect any legal or quasi-legal determination of the Core Logic.
10.3 No AI in Legal Functions
Unlike AI-driven competitors, TrueVow:
- ✅ Uses no generative AI, LLMs, or probabilistic models in its Core Logic
- ✅ Does not "hallucinate" case strategies, legal conclusions, or document language
- ✅ Provides transparent, auditable workflows (not "black box" AI)
🔍 NY State Bar Opinion 1264 Compliance
TrueVow avoids the risks flagged in NY State Bar Op. 1264: "Lawyers must understand the technology they use... AI tools that generate inaccurate or fabricated content pose significant ethical risks."
TrueVow's deterministic architecture eliminates hallucination risk entirely.
11. Confidentiality & Attorney-Client Privilege Preservation
11.1 Federal Rule of Evidence 502(d) Protection
Per Terms Section 7.2 and MSA Section 9.2, the parties contractually intend that any disclosure of privileged material to TrueVow shall be subject to the limited waiver protections of Federal Rule of Evidence 502(d).
📜 FRE 502(d) Language
"An agreement to waive privilege as to specified information... is enforceable... and precludes a finding of waiver."
This means: Disclosure to TrueVow for the purpose of facilitating intake services does not waive privilege for other purposes.
11.2 Common-Interest Doctrine
Under the common-interest doctrine, disclosure of privileged information to TrueVow (as your agent) does not waive privilege because the disclosure is made solely to facilitate legal representation.
11.3 Subpoena Response Protocol
If TrueVow receives a subpoena or legal process demanding disclosure of attorney-client privileged information, TrueVow will:
- Promptly notify you (within 24 hours)
- Assert all applicable privileges on your behalf
- Provide you with a reasonable opportunity to oppose the disclosure
- Not disclose privileged information without a court order or your consent
11.4 Zero-Knowledge Architecture
By default, TrueVow implements a Zero-Retention Policy (Terms 8.1):
- No call audio or transcripts stored post-session
- No personally identifiable information (PII)
- No protected health information (PHI)
- No Social Security Numbers
- No financial account details
This architecture mitigates the risk of accidental privilege waiver due to data persistence.
11.5 Optional 7-Day Retention (High Risk)
⚠️ RETENTION TOGGLE = FULL RISK ASSUMPTION
If you enable the Optional Retention Toggle, you assume all risk for:
- Compliance with state bar rules
- HIPAA compliance (if applicable)
- State recording-consent laws (two-party states)
- TCPA compliance
- GDPR/CCPA compliance
You indemnify TrueVow for any violation of these laws if retention is enabled (Terms 8.8).
11.6 HIPAA & Business Associate Agreements
TrueVow is not a "Business Associate" under HIPAA by default because we store no PHI.
If you enable retention toggle AND the recording contains PHI, you must execute our BAA. Without a signed BAA, you warrant that no PHI will be uploaded. Violation triggers indemnity under MSA § 12.2(vi).
11.7 Prohibited Data (Schedule C)
Per Terms Schedule C, you must strictly prohibit the input of:
- Social Security Numbers
- Credit card data
- Full medical records
- Handwritten physician notes
- Pharmacy ledgers
- Any other CORE (special-category) personal data beyond standard intake fields
🛡️ ATTORNEY INDEMNITY — CONFIDENTIALITY & PRIVILEGE
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Failure to preserve attorney-client privilege
- HIPAA violations (if retention enabled without BAA)
- Uploading prohibited data (Schedule C violations)
- Disclosure of confidential information
- Work-product doctrine violations
12. Recording Consent (Two-Party States)
12.1 Two-Party Consent State Map
The following 13 states + D.C. require two-party consent for call recording:
California, Connecticut, Delaware, Florida, Illinois, Maryland, Massachusetts, Montana, New Hampshire, Pennsylvania, Washington, Nevada, + District of Columbia
12.2 TrueVow Default Disclosure
TrueVow's default intake script includes:
📋 Recording Disclosure Language
"If you proceed, this call may be recorded for quality purposes."
This disclosure satisfies most jurisdictions' notice requirements, but:
- California: Requires affirmative consent (Cal. Penal Code § 632)
- Pennsylvania: Same
- Illinois: Two-party + BIPA if biometric voiceprint stored (we do not store)
12.3 Best Practice: Website Consent Checkbox
📋 Recommended Website Form Language
Append this checkbox to your website intake form:
"By clicking 'Submit' I consent to the recording of any telephone call for quality and conflict-check purposes."
12.4 Recording Consent State-by-State Table
| State |
TrueVow Default Script |
Your Extra Step |
| CA, CT, DE, FL, IL, MD, MA, MT, NH, PA, WA, NV |
Disclosure + opt-in |
Keep toggle OFF unless you obtain written two-party consent |
| All others |
Disclosure only |
Toggle permitted |
🛡️ ATTORNEY INDEMNITY — RECORDING CONSENT
YOU INDEMNIFY TRUEVOW FOR ANY VIOLATION OF STATE RECORDING-CONSENT LAWS.
Per MSA Section 8.8, you reimburse us for any TCPA or state recording penalty if retention toggle is enabled.
13. Fee Arrangements & No Fee-Splitting
13.1 TrueVow's Fee Structure
TrueVow charges flat fees for services rendered, not a percentage of legal fees:
- $29 per Qualified Booking (intake service)
- $49 per Settlement Report (data visualization)
- 19% of document list price (document assembly service) — this is a fee for the software service, not a share of legal fees
13.2 No Contingency, No Fee-Sharing
TrueVow does not receive any portion of:
- Attorney contingency fees
- Client settlements or judgments
- Retainer fees
- Hourly billing revenue
13.3 Not a Referral Fee
TrueVow's pay-per-qualified-booking model is not a referral fee; it is a bona fide charge for automated clerical services.
📜 Analogous Bar Approvals
- ABA Formal Op. 474 (2017): Permissible to pay lead-gen company that does not recommend lawyer
- Florida Bar Op. A-22-1 (2022): Pay-per-call allowed if no exercise of judgment
- Texas Prof. Ethics Op. 673: Same
13.4 No Partnership or Ownership
- TrueVow is an independent technology vendor
- TrueVow has no ownership interest in any law firm
- No law firm has any ownership interest in TrueVow
- No profit-sharing or partnership arrangement exists
13.5 Trust Account Compliance
TrueVow never touches client funds. All fees are billed to you after delivery. Therefore:
- No trust-account reconciliation required
- No IOLTA labeling required
- Do NOT pass our invoice through client trust account — it is a firm overhead expense
13.6 Your Compliance Responsibility
You retain full responsibility for ensuring that TrueVow's transactional fee structure does not violate any state bar rules regarding fee-sharing prohibitions with non-lawyers.
🛡️ ATTORNEY INDEMNITY — FEE COMPLIANCE
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Fee-splitting violations (your state's Rule 5.4)
- Misrepresenting TrueVow fees as referral fees
- Trust account violations
- Fee disclosure failures to clients
14. State-Specific Compliance Requirements
TrueVow serves attorneys licensed in all 50 U.S. states. Each state has its own bar rules, which may differ from the ABA Model Rules. You are solely responsible for ensuring compliance with your state's bar rules.
14.1 California (Strictest Rules)
Required Actions:
- Two-party consent: Obtain written consent before enabling retention toggle (Cal. Penal Code § 632)
- Written client consent for outsourcing: Add to fee agreement: "Firm may use automated software to generate an initial draft of pleadings; a licensed attorney will independently review and revise the document before filing." (CA State Bar Formal Op. 2020-204)
- Advertising rules: Ensure all intake scripts comply with Cal. Bar Rules 1-400 and Business & Professions Code § 6157
- CCPA compliance: If retention enabled, provide CCPA-compliant privacy notice
14.2 Florida
Required Actions:
- Technology vendor registration: List TrueVow in your annual advertising affidavit if using CONNECT profiles (Bar Rule 4-7.22)
- SMS advertising: Include "ADVERTISEMENT" in first 15 characters of SMS if required (Fla. Bar R. 4-7.18)
- Recording consent: Two-party consent required (FL Statute § 934.03)
- 30-day retention: Store screenshots of Connect profiles and Settle reports shared with clients
14.3 New York
Required Actions:
- Supervision: Comply with 22 NYCRR Part 1200, Rule 5.3
- Advertising: Ensure compliance with Rule 7.1(k) on guarantees/predictions
- Technology competence: Consider NY State Bar Op. 1264 on AI tools
14.4 Texas
Required Actions:
- Advertisement retention: Store screenshots for 30 days (Disciplinary Rule 7.02)
- Client notification: Notify client of any release of confidential data (none occurs by default)
- Fee compliance: Review Texas Prof. Ethics Op. 673 on pay-per-call services
14.5 Illinois
Required Actions:
- BIPA compliance: We do NOT store biometric voiceprints (720 ILCS 5/14-2)
- Two-party consent: Required for recording
14.6 State Bar Addenda (Living Resources)
State-specific compliance guidance for CA, NY, FL, TX, and IL is incorporated into the sections above. For detailed guidance beyond these five states, or for jurisdictions not listed, contact:
Email: compliance@truevow.law
Subject: State Bar Addendum Request — [Your State]
Response Time: 5 business days
Comprehensive state-specific addenda for all 50 states launching Q2 2026 at https://truevow.law/bar-addenda
15. Mandatory Client Disclosure & Consent
⚠️ MANDATORY: YOU MUST PROVIDE THIS DISCLOSURE TO ALL CLIENTS
To comply with ABA Model Rule 1.4 (Communication) and Rule 5.3 (Non-Lawyer Assistance), you MUST ensure all prospective and retained clients receive and acknowledge the following statement.
This disclosure clarifies the role of TrueVow Services and satisfies your professional obligation to communicate clearly with clients.
15.1 Client Disclosure Template (Ready to Use)
📋 MANDATORY CLIENT DISCLOSURE AND CONSENT STATEMENT
Insert this into your engagement letter, retainer agreement, or initial client communication:
Disclosure of Technology Assistance
[Firm Name] utilizes a specialized software platform called TrueVow Global Tech FZE LLC. TrueVow is a vendor providing non-legal, automated technology services.
TrueVow is NOT a law firm and does NOT provide legal advice. The Firm, composed of licensed attorneys, retains sole responsibility for all legal strategy, advice, and representation.
Functions and Limitations of TrueVow Services
1. Client Intake and Qualification (TrueVow INTAKE™): Your initial phone call was processed by TrueVow's automated intake system, which uses deterministic, rule-based logic (similar to a flow chart) to collect facts and determine if your matter falls within our practice areas. This system makes a technical qualification only (a "Qualified Booking"). It does not provide legal analysis, legal advice, or guarantee that we will ultimately take your case.
2. Document Drafting (TrueVow DRAFT™): If retained, we may use the TrueVow DRAFT module to generate initial drafts of legal documents (e.g., initial complaints, letters). These documents are raw, preliminary drafts only. Our licensed attorney is required to review, edit, verify the accuracy, and certify the final document before it is used in your representation or filed with any court. The attorney is solely responsible for the content and legal sufficiency of any final document.
3. Settlement Data Visualization (TrueVow SETTLE™): We may use TrueVow SETTLE to visualize data related to historical case results. This tool provides historical data from public records and anonymized sources. It does not predict the outcome of your specific case, guarantee a specific settlement amount, or offer a valuation of your claim. We rely on professional judgment, not software, to advise you on settlement.
Data Handling and Confidentiality
Audio Recording and Data Retention: By default, TrueVow does not permanently store your call audio or full transcript, implementing a Zero-Knowledge Architecture. The data is used only ephemerally to determine qualification. [If applicable to your firm: If we have opted to temporarily retain your data (up to seven days) for quality control or export, you consent to this temporary, encrypted retention.]
Use of Ancillary Operational Tools: The TrueVow platform uses standard third-party operational technologies (such as speech-to-text transcription) for efficiency. These tools operate strictly on non-legal functions and do not participate in, influence, or affect our legal judgment or strategy regarding your case.
Client Acknowledgment
I, the undersigned client/prospective client, acknowledge that I have read and understand:
- That TrueVow Global Tech FZE LLC is a software vendor, not a law firm.
- That [Firm Name]'s attorneys retain full professional and ethical responsibility for my case.
- The limitations of the DRAFT and SETTLE tools, and that all outputs require attorney review and certification.
- [Firm Name]'s data handling policies, including the use of ephemeral processing or optional temporary retention.
Client Signature: _________________________ Date: _________
Printed Name: _________________________
🛡️ ATTORNEY INDEMNITY — CLIENT DISCLOSURE
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Failure to provide required client disclosure
- Inadequate client communication about TrueVow's role
- Client complaints about lack of disclosure
- Bar complaints alleging failure to communicate (Rule 1.4)
16. Operational Compliance Procedures
16.1 Designate TrueVow Supervisory Partner (TSP)
At least one partner must be designated in writing as the "TrueVow Supervisory Partner" (TSP) for the entire platform. No per-module silos.
- Create written designation memo
- File in compliance folder
- Update annually or upon partner departure
16.2 Quarterly Attestation Requirement
TSP must sign a one-page attestation stored in the compliance folder each quarter:
📋 Quarterly Attestation Template
"I, ____________, the TrueVow Supervisory Partner for [Firm], hereby certify that during Q__ 20__ the firm used Intake, Draft, Settle, Connect, and Verify only in the manner described in the TrueVow Bar Compliance Guide, that no confidential information was disclosed in violation of MR 1.6, that no fee was shared in violation of MR 7.2, that no UPL occurred, and that all client-facing documents contained the required disclaimers. I have retained copies of all blockchain hashes, Draft disclaimers, and Settle client letters in the firm's compliance folder for seven years."
Date: ________ Signature: __________________ Bar No.: _________
16.3 Compliance File Requirements (7 Items)
Keep the following in your compliance file (7-year retention):
- Signed MSA + Privacy Policy (PDF)
- Screen-shot of your Retention Toggle choice (date-stamped)
- Internal memo designating TrueVow as non-lawyer assistant under MR 5.3
- Quarterly script-review sign-off sheet (partner initials)
- Copy of 502(d) order or engagement-letter clause
- Evidence of annual CLE on legal tech (certificate)
- Sub-processor change-log emails (auto-forward to compliance folder)
16.4 Monthly Script Audit
Spot-check recorded calls (if toggle on) monthly to confirm:
- No legal advice given
- Recording disclosure provided
- Intake scripts accurate and compliant
- No UPL red flags
16.5 Conflicts Check Workflow
The Services are NOT designed to check for conflicts of interest. You retain sole responsibility for performing all necessary conflict checks.
Suggested workflow:
- Booking alert received
- Automatic 30-minute calendar hold
- Run conflict check in your system
- If cleared: Send confirmation SMS
- If conflict: Decline booking (no charge)
16.6 Duplicate Detection
If the same phone number calls twice within 30 days, we flag "possible existing client" and do not charge you (avoids inadvertent adverse intake).
16.7 CLE Documentation
Document CLE attendance on technology competence (MR 1.1 comment 8). Recommended topics:
- Ethical use of legal technology
- Supervision of non-lawyer assistants
- Confidentiality and data security
- Attorney-client privilege in the digital age
17. Emergency Procedures (Subpoena, Bar Grievance, Breach)
17.1 If You Receive a Subpoena
If you receive a subpoena, court order, or discovery request seeking TrueVow data:
- Immediately notify TrueVow: compliance@truevow.law
- Provide: Jurisdiction, case name, deadline, specific data requested
- TrueVow will: Assert privilege, coordinate with your counsel, provide data only if court-ordered
17.2 If You Receive a Bar Grievance
If any state bar issues a written inquiry, ethics grievance, or cease-and-desist related to TrueVow usage:
⚠️ EMERGENCY STOP-USE PROCEDURE
- Immediately toggle OFF retention for every module
- Export hash ledger and then revoke API keys (Settings > Security > Revoke All)
- Notify TrueVow at compliance@truevow.law within 1 hour — we will freeze the account and preserve logs under litigation-hold without revealing content (zero-knowledge)
- Engage local ethics counsel — do not file a response mentioning TrueVow until counsel reviews this Guide
17.3 24-Hour Compliance Emergency Response
🆘 Compliance Emergency Contact
Email: compliance@truevow.law
SLA: 1-hour response time
Include: Jurisdiction, rule citation, deadline
17.4 Data Breach Response
If TrueVow experiences a data breach affecting your client data:
- TrueVow will notify you within 72 hours (best efforts)
- You remain solely responsible for your own breach notification obligations to clients and regulators
- TrueVow is not liable for delays in notification (MSA Section 6.5)
🛡️ ATTORNEY INDEMNITY — EMERGENCY PROCEDURES
YOU INDEMNIFY TRUEVOW AGAINST ALL CLAIMS ARISING FROM:
- Bar grievances or ethics complaints related to TrueVow usage
- Subpoena responses or legal process
- Failure to timely notify clients of data breaches
- Regulatory penalties or fines
18. Final Liability Transfer & Comprehensive Indemnification
⚖️ CONDITIONAL USE: ATTORNEY ASSUMES ALL LIABILITY
THE USE OF THE TRUEVOW PLATFORM IS CONDITIONAL UPON YOUR ACCEPTANCE OF THIS EXPLICIT ASSUMPTION OF ALL PROFESSIONAL AND ETHICAL LIABILITY.
Comprehensive Indemnification (MSA Section 11.2)
YOU SHALL DEFEND, INDEMNIFY, AND HOLD HARMLESS TRUEVOW AGAINST ALL CLAIMS, DAMAGES, COSTS, AND LIABILITIES ARISING FROM:
Ethics & Compliance Claims:
- ✓ Ethics complaints to state bar associations
- ✓ Bar grievances or disciplinary proceedings
- ✓ Unauthorized practice of law (UPL) allegations
- ✓ Violations of Rules of Professional Conduct
Malpractice & Professional Liability:
- ✓ Malpractice claims related to TrueVow outputs
- ✓ Negligence or professional misconduct
- ✓ Errors, omissions, or inaccuracies in documents
- ✓ Reliance on any output (INTAKE, DRAFT, SETTLE, VERIFY) without independent professional judgment
Supervision & Competence:
- ✓ Failure to adequately supervise TrueVow as non-lawyer assistant
- ✓ Failure to review outputs before client use
- ✓ Breach of duty of competence (Rule 1.1)
Confidentiality & Privilege:
- ✓ Failure to preserve attorney-client privilege
- ✓ HIPAA violations (if retention enabled without BAA)
- ✓ Uploading prohibited data (Schedule C violations)
- ✓ Recording-consent violations (if retention toggle enabled)
- ✓ Disclosure of confidential information
Fee & Referral Compliance:
- ✓ Fee-splitting violations (Rule 5.4, Rule 7.2)
- ✓ Misrepresenting TrueVow fees as referral fees
- ✓ Trust account violations
- ✓ Referral fee violations (CONNECT module)
Client Communication & Advertising:
- ✓ Failure to disclose TrueVow usage to clients (where required)
- ✓ Advertising rule violations
- ✓ Misrepresentation of services or outcomes
- ✓ Solicitation violations
Conflicts & Intake:
- ✓ Conflicts of interest failures
- ✓ Failure to form proper attorney-client relationship
- ✓ Adverse intake of opposing party
Technology & Data:
- ✓ Data breach notification failures
- ✓ Spoliation (failure to preserve VERIFY hashes)
- ✓ Over-reliance on technology without professional judgment
- ✓ Failure to disclose use of ML tools (where required)
Any Other Claims:
- ✓ Any other violation of professional conduct rules
- ✓ Any regulatory penalties or fines
- ✓ Any client complaints or lawsuits
- ✓ Any third-party claims related to your use of TrueVow
TRUEVOW ASSUMES ZERO LIABILITY FOR YOUR PROFESSIONAL CONDUCT, ETHICAL COMPLIANCE, OR CLIENT OUTCOMES.
ALL RISK RESTS WITH YOU, THE ATTORNEY.
18.1 No Guarantee of Bar Approval
TrueVow does not guarantee bar approval. Compliance is your professional obligation. This guide is informational only and does not constitute legal advice.
18.2 Attorney Sole Responsibility Summary
| Responsibility |
Attorney |
TrueVow |
| Legal advice |
✅ Attorney |
❌ TrueVow |
| Case evaluation |
✅ Attorney |
❌ TrueVow |
| Client representation |
✅ Attorney |
❌ TrueVow |
| Conflicts checks |
✅ Attorney |
❌ TrueVow |
| Ethical compliance |
✅ Attorney |
❌ TrueVow |
| Attorney-client privilege |
✅ Attorney |
❌ TrueVow |
| Professional judgment |
✅ Attorney |
❌ TrueVow |
| Malpractice liability |
✅ Attorney |
❌ TrueVow |
| Bar compliance |
✅ Attorney |
❌ TrueVow |
| Intake script configuration |
✅ Attorney |
✅ TrueVow (as agent) |
| Phone answering |
❌ Attorney |
✅ TrueVow (as agent) |
| Document assembly templates |
❌ Attorney |
✅ TrueVow (as tool) |
| Settlement data aggregation |
❌ Attorney |
✅ TrueVow (as tool) |
19. Quick Checklist Before Going Live
✅ Pre-Launch Compliance Checklist
- Customize script with firm name, practice areas, required disclaimers
- Toggle OFF retention if two-party state or PHI expected
- Insert 502(d) clause in engagement letters
- Add "ADVERTISEMENT" to SMS if required (Florida)
- Train intake staff: bookings are leads, not clients — run conflicts next
- Calendar quarterly script audit (partner-level)
- Export compliance file to PDF and store in cloud with 7-year retention
- Add TrueVow usage to malpractice insurance application
- Review your state's specific bar rules and opinions
- Prepare client disclosure forms with required language
20. Contact & Compliance Support
20.1 Bar Compliance Inquiries
For questions about TrueVow's compliance with state bar rules:
- Email: compliance@truevow.law
- Phone: +1 (844) TRUEVOW
- Response Time: 2 business days
20.2 State Bar Opinion Support
If your state bar requires an ethics opinion on the use of TrueVow's services, TrueVow may provide voluntary support, including:
- Detailed technical documentation
- Sample intake scripts and qualification logic
- Letters of support for bar opinion requests
- Consultation with your ethics counsel
20.3 CLE & Training
TrueVow offers complimentary continuing legal education (CLE) sessions on:
- Ethical use of non-lawyer assistants (RPC 5.3)
- Technology and professional responsibility
- Confidentiality and privilege preservation
- State-specific bar compliance
Contact: training@truevow.law
📜 FINAL DISCLAIMER
THIS BAR COMPLIANCE GUIDE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE LEGAL ADVICE.
Each law firm is responsible for:
- Reviewing the specific rules and opinions of its jurisdiction's bar association
- Consulting with ethics counsel regarding TrueVow usage
- Ensuring its use of technology complies with all applicable rules
- Obtaining bar approval where required
TRUEVOW MAKES NO REPRESENTATION OR WARRANTY THAT YOUR USE OF THE SERVICES WILL COMPLY WITH ANY PARTICULAR STATE'S BAR RULES OR RECEIVE BAR APPROVAL.
YOU ASSUME ALL RISK.
21. Legal Authorities & References
21.1 ABA Model Rules of Professional Conduct
- Rule 1.1 — Competence
- Rule 1.4 — Communication
- Rule 1.6 — Confidentiality of Information
- Rule 1.7 — Conflict of Interest: Current Clients
- Rule 5.3 — Responsibilities Regarding Nonlawyer Assistants
- Rule 5.4 — Professional Independence of a Lawyer
- Rule 5.5 — Unauthorized Practice of Law
- Rule 7.1 — Communications Concerning a Lawyer's Services
- Rule 7.2 — Advertising
- Rule 7.3 — Solicitation of Clients
21.2 Federal Rules & Statutes
- Federal Rule of Evidence 502(d) — Selective Waiver of Privilege
- E-SIGN Act (15 U.S.C. § 7001) — Electronic Signatures
- HIPAA (45 C.F.R. Part 160-164) — Protected Health Information
- TCPA (47 U.S.C. § 227) — Telephone Consumer Protection Act
21.3 State Bar Ethics Opinions
- NY State Bar Op. 1264 — Use of AI in Legal Practice
- CA State Bar Formal Op. 2020-204 — Outsourcing Legal Tasks
- CA State Bar Formal Op. 2023-206 — AI-Assisted Document Review
- FL Ethics Op. 24-1 — Lawyer Referral Services
- Florida Bar Op. A-22-1 (2022) — Pay-Per-Call Services
- Texas Prof. Ethics Op. 673 — Lead Generation Services
- ABA Formal Op. 474 (2017) — Lawyer Advertising Services
21.4 Case Law
- Upjohn Co. v. United States, 449 U.S. 383 (1981) — Attorney-Client Privilege
- In re Grand Jury Subpoena, 274 F.3d 563 (1st Cir. 2001) — Common Interest Doctrine