Introduction to Upturn’s Business Upturn was incorporated in October 2015 and commenced business in November 2017. Upturn is an investment adviser that is registered with the SEC as an internet adviser. That means that Upturn provides investment advice to clients exclusively through an interactive online presence - - via its website, mobile or desktop apps, or REST APIs (a means to request and access information) integrated into third party applications. Upturn’s website is located at http://www.upturn.io and its mobile app is designed to be purchased at a mobile or online store that sells apps. Using these technologies -- that is, interactive computer software-based applications -- users submit and receive information through the website, apps or REST APIs and help Upturn provide investment advice. Upturn has no assets under management, and provides no discretionary investment advisory services. That means that a client, rather than Upturn, will make all investment decisions. Clients must make their own brokerage arrangements and bear their own brokerage and other costs. Upturn should only be used by investors who have experience in trading individual stocks and other assets, as opposed to, for example, investors whose investment experience is limited to passively holding shares of diversified mutual funds. The Upturn App and Upturn Website The firm currently has a mobile application, also called Upturn, and a website, www.upturn.io, that provides you with information to make decisions about buying and selling publicly traded stocks and certain other assets. The firm also may offer desktop apps, website access, or REST APIs integrated into third party applications. Upturn uses a proprietary algorithm to provide you with a quantitative analysis of how certain selected stocks are performing. This algorithm alerts you as to when a stock might potentially be on an “Upturn,” based on a technical analysis of historical data. The recommendations are to be taken purely as “potential” upward indicators and has no guarantees on the stock movements and the user should further investigate before making any stock purchase or selling decisions. Users of the app can access information for particular stocks regarding their historical performance, star or similar rating (based on historical performance), upturn indication, ending of upturn, loss, and other data. Since the recommendations (or advisories) are based on technical analysis of historic patterns, historic performance has no guarantees on how a stock could perform in the future. There could be many reasons why a stock could perform well or otherwise. Further, the analysis being technical in nature, fundamental characteristics of a company such as balance sheet, quarterly earnings performance, and others is not yet considered while making these recommendations. Fundamental characteristics will be added in the future for the user to further filter the stocks based on their criteria. These recommendations or advisories are to be treated as a suggestion and it is the responsibility of the end user to fully investigate the stock from all angles before deciding to “buy” or “sell” or “hold” a position or “wait” before buying or “pass”. Further, “buy” advisory could have annotation such as “strong buy” or “regular buy” or “weak buy”. All of these indicate a “buy” advisory based on technical analysis but shows different degree of trends or factors which are positively influencing the “buy” advisory. For instance, “strong buy” has more trends or factors in the algorithm showing positive “buy” trend compared to “regular buy” and has much lower trends or factors suggesting “buy” for “weak buy”. A “pass” advisory indicates that there are no upturns or upward trends seen in the stock or ETF to recommend a “buy” for now and hence the stock or ETF could be passed for now. Additionally, Upturn’s recommendations cannot be used to purchase options. The star or similar ratings provided in the application next to the ticker are derived from the historical performance of the stock with respect to the technical analysis of Upturn and are not a fundamental rating of the stock by any financial analyst or

the current rating of the company in terms of performance. A higher rating does not guarantee a better performance in the future neither does a lower rating indicate a poor performance in the future. Upturn Instant Robo-Portfolios are collections of stocks and electronic traded funds (ETFs), matching a specific criterion selected by the user for which Upturn updates advisories on a daily basis and could also provide notifications to these updated advisories either through Website update, emails or mobile notifications. Creation of Instant Robo-Portfolio by Upturn application involves creating close to five hundred portfolios or collections of stocks and ETFs in the backend which are matching these criteria selected by the user and choosing the collection or the portfolio which gave highest returns historically for the last two or two and half years based on simulation. Users can also choose stocks or ETFs based on any other filter or criterion or of their own choice and add it to any portfolio called a Robo-Portfolio in Upturn. User will receive daily Upturn advisory updates for stocks or ETFs within these Robo-Portfolios directly on the website, app, mobile notifications and other means such as emails in the future. Upturn expects to, but is not required to, update the algorithm from time to time. Such updates will be announced on Upturn’s web site and users of the app should visit the web site from time to time to see whether changes have been made. It is possible that, as a result of the updating process, the algorithm will not provide for a “sell” recommendation in connection with a “buy” recommendation that was previously made. This could occur if, for example, the new algorithm would not have recommended a “buy” order or would have recommended an earlier “sell” order, and does not recognize that a “buy” order remains outstanding. An app user should not rely on the app, and should view it as informative and just one factor among many, rather than as the sole reason to buy, sell, or hold a position. Users of the Upturn application are solely responsible for their decisions to buy, hold, or sell a position in a company and may not hold Upturn responsible in anyways for their trading decisions and its performance. Upturn’s Founder Upturn’s founder and sole principal is Karthik Krishna (formerly known as Karthik Kulkarni). He has a background in software technology rather than in recommending investments for other people. He has long followed the stock market and analyzed patterns. On that basis he has developed a technology solution for stock market watching for investors who may wish for a different kind of approach. Karthik works full time on Upturn. He was most recently employed, until Dec 2021, as a software architect and senior lead on Big Data Solutions at Cisco Systems Inc., a technology company, where he began work a decade ago. Cisco Systems has no involvement with Upturn. Before Cisco Systems, Karthik spent about two years as a biotechnology-focused Research Assistant at the University of Delaware while earning his Master of Science degree (MS). Before that, for about two years he was a member of the technical staff at Oracle’s India presence working primarily in server technologies. He has a Bachelor of Engineering degree in Computer Science and Engineering from Visvesvaraya Technological University in India, and a Master of Science degree in Computer & Information Science from the University of Delaware. Upturn Today and in the Future The universe of stocks and other investments on which Upturn will provide suggestions may range from narrow, such as an initial focus on selected large capitalization (large cap) stocks, to broader, such as including exchange-traded funds (ETFs), mutual funds, and other instruments. Although it has flexibility to do so, Upturn does not commit to provide suggestions on any particular additional kinds of investments. At the outset, the advice is expected to be fairly generic. Over time, it is expected that data provided by a client will be used to personalize the advice. In addition, clients may specify particular stocks that they wish to follow. Upturn may expand its product offering, increase the use of personalized data, and enhance other aspects of its business over time.