World Championship of Trading - Official Rules

NO PURCHASE OR PAYMENT OF ANY KIND NECESSARY TO PARTICIPATE OR WIN. THE CHANCES OF WINNING ARE BASED ON SKILL AND DEPEND ON THE NUMBER OF PARTICIPATING ENTRANTS AND THEIR RESPECTIVE SKILL IN ASSEMBLING AND MANAGING A FANTASY STOCK PORTFOLIO. A PURCHASE WILL NOT INCREASE YOUR CHANCES OF WINNING. YOUR CHANCES OF WINNING WITHOUT MAKING A PURCHASE ARE THE SAME AS THE CHANCES OF SOMEONE WHO PURCHASES SOMETHING. IT IS ILLEGAL TO GIVE ANY ADVANTAGE TO PURCHASERS IN A CONTEST.

OPEN TO LEGAL RESIDENTS OF THE ELIGIBLE TERRITORIES (AS DEFINED BELOW) OF ELIGIBLE AGE (AS DEFINED BELOW). DO NOT PARTICIPATE IF YOU ARE NOT ELIGIBLE, NOT LOCATED IN AN ELIGIBLE TERRITORY AT THE TIME OF ENTRY, AND/OR LOCATED IN A TERRITORY WHERE PARTICIPATION WOULD BE UNLAWFUL AT THE TIME OF ENTRY. VOID WHERE PROHIBITED.

ALL DISPUTES WILL BE RESOLVED SOLELY BY BINDING ARBITRATION AND ENTRANTS WAIVE THE ABILITY TO BRING CLAIMS IN A CLASS ACTION FORMAT.

By participating in the Program (as defined below), a participant in the Program (each, an “Entrant”) agrees to these Official Rules, which are final and binding in all respects.

1. ABOUT THE CONTEST: World Championship of Trading (the “Contest(s)” or “Program”) is a game of skill in which TradeZero users can compete against other TradeZero users to win prizes based on the user’s knowledge and skill in assembling and managing a fantasy stock portfolio (a “Fantasy Portfolio”) using fantasy money (“Fantasy Cash”) on a platform provided by TradeZero (as defined below) and/or its affiliates. FANTASY CASH PROVIDED AND TRADED IN CONNECTION WITH THE PROGRAM IS NOT ACTUAL CASH. ENTRANTS WILL NOT RECEIVE ANY PROFITS EARNED IN CASH OR OTHER CONSIDERATION.

2. ELIGIBILITY: The Program is open to legal residents (excluding corporate or other entities) of the fifty (50) United States, Washington DC, and Canada (in the provinces of Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland, Nova Scotia, Ontario, Quebec, and Saskatchewan only) (the “Eligible Territories”), who are the older of: (a) twenty one (21) years old or older prior to the date the Contest(s) commence trading activity; and (b) the age of majority in their respective state or province prior to the date the Contest(s) commence trading activity (the “Eligible Age”); and who also: (i) are not a professional trader, meaning they meet the requirements in Schedule 1 hereto for the applicable securities exchanges to be deemed to be non-professional traders; (ii) are not subject to any investigations or sanctions administered or imposed by the Office of Foreign Assets Control of the U.S. Department of the Treasury, the Government of Canada, any other regulatory authority in the United States or Canada or any other government entity or regulatory authority which has jurisdiction over the Contests; (iii) meet the requirements of applicable TradeZero-affiliated broker-dealers to open a margin trading account for receipt of a prize, if any, awarded pursuant to the Program. Employees, contractors, directors and officers of TradeZero USA Inc. (referred to herein as “TradeZero”), of Accretive Capital, LLC d/b/a Benzinga (referred to herein as “Benzinga” or “Administrator,” and, collectively with TradeZero, referred to at times as the “Promotion Entities”), and each of their respective parent companies, affiliates, and their respective subsidiaries and all other service agencies involved with the Program, and members of the immediate family (spouse, parent, child, sibling and their respective spouse) and household of each such employee, contractor, director or officer are not eligible to participate. Entrants are subject to verification, including verification of age. If an Entrant is found not to be eligible or not in compliance with these Official Rules, the Entrant will be disqualified.

Administrator reserves the right to disqualify any Entrant If Administrator determines that Entrant’s participation in the Program or receipt of a prize could violate applicable laws or regulations or these Official Rules or cause damage to the reputation of the Promotion Entities, their affiliates and/or any other party. Entrants are limited to solely one (1) registration/entry per person with a valid email address and mobile phone number (note that use of a mobile phone may result in Entrant incurring text message and/or other mobile charges by Entrant’s carrier). Any entries that do not comply with this limitation will not be eligible to win a prize. These Official Rules are available at https://www.tradezeroedge.com/world-championship-of-trading/rules .

3. THE PROGRAM PERIODS: The Program will consist of three separate contests, which will take place during the following periods:

  • The first contest (the “First Contest”) begins at 12:01 AM ET on September 15, 2024, and ends at 8:00 PM ET on October 14, 2024 (the “First Contest Period”);
  • The second contest (the “Second Contest”) begins at 12:01 AM ET on October 15, 2024, and ends at 8:00 PM ET on November 14, 2024 (the “Second Contest Period”);
  • The third contest (the “Third Contest”) begins at 12:01 AM ET on November 15, 2024, and ends at 8:00 PM ET on December 14, 2024 (the “Third Contest Period”);

(the First Contest Period, Second Contest Period, and Third Contest Period are each referred to in these Official Rules as a “Contest Period” and collectively referred to as the “Program Period”).

4. TO PARTICIPATE: To participate in the Program, visit the Contest Entry Page at https://www.tradezeroedge.com/world-championship-of-trading (the “Contest Site”). Registration for all Contest Periods begins August 15, 2024 and ends, as to each Contest Period, at 9 AM ET one day prior to the date when there are no less than five days remaining to trade on which the New York Stock Exchange is open for trading during each Contest Period. Entrant must first register for a free TradeZero account at https://www.tradezeroedge.com/world-championship-of-trading/sign-up, with which Entrant may participate in the Program. Entrant’s free TradeZero account is subject to TradeZero’s then-current Privacy Policy and account-related terms and conditions at all times, including, without limitation, the terms and conditions for receipt and use of NASDAQ basic data for equities. Entrant’s Fantasy Portfolio will only earn Fantasy Cash and participate in the Program after Entrant registers for a TradeZero account and signs up to participate in the Program. NASDAQ BASIC DATA FOR EQUITIES IS INCLUDED IN THE CONTEST ACCOUNT REGISTRATION AND REQUIRED FOR ENTRANTS TO USE, SUBJECT TO THE APPLICABLE TERMS AND CONDITIONS AND AT NO COST TO ENTRANT. NO-COST ACCESS TO, AND USE OF, NASDAQ BASIC DATA FOR EQUITIES WILL CEASE AT THE END OF THE CONTEST PERIOD. ENTRANT MAY ALSO USE OPRA AND NYSE DATA SOURCES OFFERED BY TRADEZERO AT THEIR OWN DISCRETION WITHOUT COST. NO- COST ACCESS TO, AND USE OF, NYSE AND OPRA DATA WILL CEASE AT THE END OF THE CONTEST PERIOD.

To participate and be eligible to win a prize during any given Contest Period, Entrant must register and set up Entrant’s Fantasy Portfolio by 9 AM ET one day prior to the date when there are no less than five days remaining to trade on which the New York Stock Exchange is open for trading during each Contest Period and must place at least one (1) stock or option trade in Entrant’s Fantasy Portfolio on each of at least five days on which the New York Stock Exchange is open for trading (trading activity within one day is considered to be a purchase or sale of a securities position between 00:00:00 to 23:59:00 ET on that calendar day) during the applicable Contest Period. Entrant must set up a separate fantasy portfolio for each Contest Period.

Entries will only be accepted via the above-noted online method. All entries must be submitted by the person whose entry information appears on the TradeZero account associated with the entry. Entry for any one Contest Period will result in registration for all subsequent Contest Periods (subject to the applicability of other Contest rules). All entries become the property of TradeZero and/or its affiliates and will not be returned to Entrant.

In addition to these Official Rules, additional rules and guidelines regarding the Contest and scoring may be found in the Contest Instructions, which are located at https://www.tradezeroedge.com/world-championship-of-trading/contest-instructions and are attached as Exhibit A hereto, and incorporated into these Official Rules by reference.

5. Winner(s) Selection and Notification: At the conclusion of each Contest Period, the top qualifying Entrants (i.e., the Entrant with the highest U.S. dollar amount (in Fantasy Cash) at the conclusion of that Contest Period) will potentially win the applicable Contest Period prizes described in Section 6, below, for that Contest Period (the “Potential Contest Period Winner”). In the event of a tie between two (2) or more Entrants for the same Contest Period prize, the prize will be awarded to the qualifying Entrant (among those still tied Entrants) who made the highest number of trades during the applicableContestPeriod. In the event that the tie is still not broken after applying the tiebreaker above, the prize will be awarded to the qualifying Entrant (among those still tied Entrants) who made the largest percentage gain in a single fantasy trade during the applicable Contest Period. In the event that the tie is still not broken, the prize will be awarded to the qualifying Entrant (among those still tied Entrants) who made the highest number of trades in the last full week of the applicable Contest Period. In the event that the tie is still not broken after applying the tie breakers above, the prize will be awarded in the Administrator’s sole discretion. An Entrant may not win more than one prize in any Contest Period but may win a prize in more than one Contest Period.

Potential Contest Period Winners will be notified via email or text message after the end of each Contest Period. In addition, during and after each Contest Period a leaderboard may be displayed on the Contest Site, and on the websites and social media of Benzinga and TradeZero (and, in TradeZero’s sole discretion may be displayed on each TradeZero-affiliated broker-dealers’s website and in TradeZero and each TradeZero-affiliated broker-dealers’s promotion and marketing, including, without limitation social media channels) listing each Entrant’s total profit and loss across all trades being made during the applicable Contest Period. Each Entrant’s total fantasy profit and fantasy loss will be calculated daily. Leaderboards may show rankings of top Entrants, but such leaderboard is for informational purposes only, is not official, may not be accurate and should not be relied upon in any way, including with respect to the awarding of prizes hereunder. Leaderboards may identify top Entrants including, by Promotion Entity generated assigned user ids or, potentially, by the use of nicknames selected by Entrants (to the extent nick-name selection is enabled, no nick-name may be chosen that is vulgar or which may bring any Promotion Entity into disrepute, as determined in the sole discretion of the Promotion Entities). Administrator and/or TradeZero Promotion Entities reserve the right to modify, remove, or amend the leaderboard in the event of any misconduct, in their discretion.PLEASE NOTE THAT EVEN IF AN ENTRANT’S FANTASY PORTFOLIO IS LISTED AS THE WINNER AS OF THE CLOSE OF THE CONTEST PERIOD OR ANY CONTEST WEEK, ENTRANT HAS NOT YET WON A PRIZE. ALL POTENTIAL WINNERS ARE SUBJECT TO VERIFICATION BY THE PROMOTION ENTITIES, AND MUST MEET ALL ELIGIBILITY REQUIREMENTS BEFORE A PRIZE WILL BE AWARDED.

The following applies to all Potential Winners: Each potential prize winner may be required to sign, notarize and return (within seven (7) days) an Affidavit of Eligibility and Liability/Publicity Release (except where prohibited by law), correctly answer a time-limited mathematical skill-testing question without assistance of any kind, whether mechanical or otherwise, to be administered by telephone at a mutually convenient time (for Canadian residents), and provide any additional information (such as social security number or social insurance number) that may be required by Administrator within seven (7) days following the initial attempted notification by Administrator. A potential prize winner’s failure to comply with these deadlines, failure to correctly answer the skill-testing question (for Canadian residents), or return of any prize/prize notification as undeliverable, within seven (7) days, will result in disqualification and selection of an alternate winner according to the standings from among all remaining eligible Entrants in the Contest, and if necessary, subject to the tiebreaker requirements described above. Prizes will be delivered between six (6) to eight (8) weeks after winner verification by depositing same in a TradeZero-affiliated broker-dealer account that must be opened by the applicable winner and accepted by the applicable TradeZero-affiliated broker-dealer using its standard forms based on the residency of the applicable winner (non-acceptance by the relevant TradeZero- affiliated broker-dealer of Entrant for an account means that Entrant may not receive a prize). If any U.S. dollar amounts require conversion into Canadian dollar amounts or vice versa, the conversion rate will be the applicable rate for same published in the Wall Street Journal five (5) business days prior to the date the conversion occurs. The United States of America Internal Revenue Service (“IRS”) requires Form 1099- MISC (for U.S. residents) or Form W- 8ECI (IRS form for Canadian residents) to be issued and filed for each recipient who receives a prize if the amount of the prize is $600 or more. Administrator will send the winner an IRS W-9 form (or Canadian withholding form(s)), which must be completed and returned to Administrator within seven (7) days for the winner to receive the prize. A copy of the applicable IRS forms filed by Administrator will be sent to the winner. The Form 1099-MISC or Form W- 8ECI will be issued for the fair market value of the prize as described in Section 6 below. Any winner who fails to provide information sufficient to complete Form 1099-MISC or Form W-8ECI (including, without limitation, their social security number or other applicable tax id number) within seven (7) days shall forfeit any and all rights to the applicable prize. If Administrator cannot find an eligible winner for a prize, or if a winner fails to claim a prize, that prize will not be awarded.

6. PRIZES:

First Contest Period Prizes: There are three (3) prizes (awarded to the highest- placing qualified potential prize winners in descending order) for the First Contest Period, as follows:

  • First prize consisting of five thousand United States Dollars ($5,000 USD), which will be delivered in the form of a deposit in winner’s brokerage account with an approved broker-dealer affiliate of TradeZero (to be determined in TradeZero’s sole discretion based on the residency of the winner), plus a lifetime subscription (i.e., until the earlier of: (a) the end of the life of the winner, (b) if Benzinga ceases to offer such service, or (c) Benzinga ceases its business operations) of Benzinga Pro “Essential” news and research (ARV $6,000 USD), plus one (1) tour of the New York Stock Exchange (“NYSE”) and lunch for Entrant and a guest at the NYSE (ARV $250 USD; Entrant is responsible for their, and their guest’s, own travel, lodging and related expenses as the prize is limited to the tour and lunch; must be used within twelve (12) months of award).
  • Second prize consisting of one thousand United States Dollars ($1,000 USD), which will be delivered in the form of a deposit in winner’s brokerage account with an approved broker-dealer affiliate of TradeZero (to be determined in TradeZero’s sole discretion based on the residency of the winner), plus one (1) year of Benzinga Pro “Essential” news and research subscription (ARV $1,997 USD).
  • Third prize consisting of five hundred United States Dollars ($500 USD), which will be delivered in the form of a deposit in winner’s brokerage account with an approved broker-dealer affiliate of TradeZero (to be determined in TradeZero’s sole discretion based on the residency of the winner), plus one (1) year of Benzinga Pro “Essential” news and research subscription (ARV $1,997 USD).

Approximate Retail Value (“ARV”) of all First Contest Period prizes: $16,744 USD.

Second Contest Period Prizes: There are three (3) prizes (awarded to the highest- placing qualified potential prize winners in descending order) for the Second Contest Period, as follows:

  • First prize consisting of ten thousand United States Dollars ($10,000 USD), which will be delivered in the form of a deposit in winner’s brokerage account with an approved broker-dealer affiliate of TradeZero (to be determined in TradeZero’s sole discretion based on the residency of the winner), plus a lifetime subscription (i.e., until the earlier of: (a) the end of the life of the winner, (b) if Benzinga ceases to offer such service, or (c) Benzinga ceases its business operations) of Benzinga Pro “Essential” news and research (ARV $6,000 USD), plus one (1) tour of the NYSE and lunch for Entrant and a guest at the NYSE (ARV $250 USD, Entrant is responsible for their, and their guest’s, own travel, lodging and related expenses as the prize is limited to the tour and lunch; must be used within twelve (12) months of award).
  • Second prize consisting of two thousand United States Dollars ($2,000 USD), which will be delivered in the form of a deposit in winner’s brokerage account with an approved broker-dealer affiliate of TradeZero (to be determined in TradeZero’s sole discretion based on the residency of the winner), plus one (1) year subscription to Benzinga Pro “Essential” news and research subscription (ARV $1,997 USD).
  • Third prize consisting of one thousand United States Dollars ($1,000 USD), which will be delivered in the form of a deposit in winner’s brokerage account with an approved broker-dealer affiliate of TradeZero (to be determined in TradeZero’s sole discretion based on the residency of the winner), plus one (1) year of Benzinga Pro “Essential” news and research subscription (ARV $1,997 USD).

ARV of all Second Contest Period prizes: $23,244 USD.

Third Contest Period Prizes: There is one prize (awarded to the highest-placing qualified potential prize winner) for the Third Contest Period, as follows:

  • First prize, consisting of fifteen thousand United States Dollars ($15,000 USD), which will be delivered in the form of a deposit in winner’s brokerage account with approved broker-dealer affiliates of TradeZero (to be approved in TradeZero’s sole discretion based on the residency of the winner), plus a lifetime subscription (i.e., until the earlier of: (a) the end of the life of the winner, (b) if Benzinga ceases to offer such service, or (c) Benzinga ceases its business operations) of Benzinga Pro “Essential” news and research subscription (ARV $6,000 USD), plus one (1) tour of the NYSE and lunch for Entrant and a guest at the NYSE (ARV $250 USD, Entrant is responsible for their, and their guest’s, own travel, lodging and related expenses as the prize is limited to the tour and lunch; must be used within twelve (12) months of award).

ARV of all Third Contest Period prizes: $21,250 USD.

The following applies to all prizes: ARV of all prizes during the Program Period is sixty one thousand two hundred thirty-eight United States Dollars ($61,238 USD). Prizes cannot be used in conjunction with any other promotion or offer and may not be separated. Prizes may not be transferred or assigned except with the approval of the Promotion Entities. Only listed prizes will be awarded and no substitutions will be made. Expenses not specifically stated in these Official Rules, together with the reporting and payment of all applicable taxes, fees, and/or surcharges, if any, arising out of, or resulting from, acceptance or use of a prize, are the sole responsibility of the winner of that prize. The distribution of the prizes will not be unduly delayed. Promotion Entities expressly disclaim any responsibility or liability for injury or loss to any person or property relating to the delivery and/or subsequent use of the prizes awarded. Any unclaimed prizes will not be awarded. Restrictions, conditions, and limitations apply. Promotion Entities will not replace any lost or stolen prize items.

A risk of exposure to COVID-19 or other diseases exists in any public place or accommodation. COVID-19 is an extremely contagious disease that can cause severe illness and death. By accepting any prize including the tour and lunch at the NYSE or attending and/or participating in a tour and/or lunch at the NYSE, Entrant and their guest voluntarily assume all risks related to exposure to COVID-19 and any other environmental hazard. Failure to complete the tour and lunch prize does not relieve the winner of his/her tax obligations associated with winning the tour and lunch prize. It is the prize winner’s and his/her guest’s sole responsibility to comply with all travel requirements, which may include, without limitation, presenting necessary identification (including photograph) at the time of travel and any documentation necessary for travel (for example, a passport or any required visa). Promotion Entities are not liable for any missed prize events, opportunities or expenses incurred as a consequence of flight cancellation/delay or ground transportation delay. Prize winner is responsible for all travel, lodging, transportation and related expenses in connection with the tour and lunch at the NYSE prize. All meals, gratuities, in-room charges, travel expenses, travel and other insurance, carrier fees, government charges, transfers, ground transportation, taxes (federal, state and local) and other expenses not specified in these Official Rules as being provided as part of a prize are the sole responsibility of the prize winner. Prize winner’s guest must be the age of majority in the guest’s state or province of residence, unless winner is the guest’s parent or legal guardian. Prize winner agrees that his/her guest must comply with Promotion Entities’ and each prize provider’s procedures and policies and must complete, sign, have notarized and return a release of liability and, where legal, a publicity release to Promotion Entities in the timeframe specified by Administrator or participation in any tour and lunch prize will not be allowed. Once selected by prize winner, guest cannot be changed without the express consent of Administrator, which may be withheld for any reason. Each winner understands and agrees that Promotion Entities or prize providers have the right, in their sole discretion, to disqualify and remove the winner or his/her guests from any activity at any time if the winner’s or any of his/her guest’s behavior at any point is uncooperative, disruptive, or may or does cause damage to person, property, or the reputation of or otherwise violates the policies of Promotion Entities or any prize provider. In the event Promotion Entities are unable to provide the tour and lunch opportunity to be included in any prize (as applicable) due to any reason beyond their reasonable control, no compensation or substitution will be provided in lieu thereof; however, remainder of prize package will be awarded and Promotion Entities will have no further obligation to such winner.

7. General Conditions: This Contest may not be used in connection with any form of gambling. Subject to, and without limiting Section 10 below, entry into this Program constitutes Entrant’s permission for the Promotion Entities and their affiliates to send Entrant periodic emails and/or text messages during the Program Period relating to the Contest, and for identity verification purposes in connection with the Contest and to send periodic emails after the Program Period about future TradeZero and affiliated entities’ contests. Entry into this Contest constitutes Entrant’s permission for TradeZero and affiliated entities to publish Entrant’s TradeZero profile name, assigned user id’s and/or selected nick-names and contest fantasy net worth and ranking on any TradeZero and affiliated entities’ website and in any TradeZero and affiliated entities’ marketing materials (whether on TradeZero or third-party media outlets and websites), including on the leaderboards and for promotional purposes throughout the Contest. Except where prohibited by law, a winner’s acceptance of a prize constitutes permission for Promotion Entities to use such winner’s name, city and state/province of residence, statements, photograph, voice and/or likeness for any advertising and promotional purposes relating to the Contest without further notice, compensation, consideration, notification, review or consent, and hereby releases the Promotion Entities from any liability with respect thereto.

8. Conduct: By entering this Contest, Entrants agree to be bound by these Official Rules, which will be posted at the Contest Site throughout the Contest. Entrants further agree to be bound by the decisions of the Promotion Entities and/or their affiliates, which shall be final and binding in all respects. Each Promotion Entity reserves the right at its sole discretion to disqualify any individual it finds to be, or ban from Contest leaderboards any individual it suspects may be, (a) tampering or attempting to tamper with the entry process or the operation of the Contest or any Promotion Entity’s or affiliate’s website; (b) violating the Official Rules or any of the guidelines of the Contest; (c) violating the terms of service, conditions of use and/or general rules or guidelines of any TradeZero or affiliate’s website, property or service; (d) acting in an unsportsmanlike or disruptive manner, or with intent to annoy, abuse, threaten or harass any other person; or (e) engaging in suspicious game activity. CAUTION: ANY ATTEMPT BY AN ENTRANT OR ANY OTHER INDIVIDUAL TO DELIBERATELY DAMAGE ANY WEBSITE OR UNDERMINE THE LEGITIMATE OPERATION OF THE CONTEST MAY BE A VIOLATION OF CRIMINAL AND CIVIL LAWS. SHOULD SUCH AN ATTEMPT BE MADE, PROMOTION ENTITIES AND/OR THEIR AFFILIATES RESERVE THE RIGHT TO IMMEDIATELY TERMINATE THE USER’S ACCOUNT, IF ANY, AND SEEK DAMAGES FROM ANY SUCH PERSON TO THE FULLEST EXTENT PERMITTED BY LAW.

9. Limitations of Liability: Promotion Entities and their affiliates assume no responsibility or liability for lost, late, misdirected, or garbled entries, or for theft, destruction, or unauthorized access to, entries. Promotion Entities and their affiliates assume no responsibility for any incorrect or inaccurate information, whether provided by the Entrant, caused by website users or by any of the equipment or programming associated with or utilized in the Contest or by any technical or human error which may occur in the processing of submissions in the Contest. Promotion Entities and their affiliates assume no responsibility for any error, omission, interruption, deletion, defect, delay in operation or transmission, failures or technical malfunction of any telephone network or lines, markets, exchanges, computer online systems, servers, providers, computer equipment, software, email, text messaging, players, or browsers, whether on account of technical problems, traffic congestion on the Internet or at any website, or on account of any combination of the foregoing, that may occur (including but not limited to any such problems which may result in the ability to access the Contest Site or to process any game transaction(s) in connection with the Contest). Promotion Entities and their affiliates assume no responsibility for any injury or damage to Entrants or to any computer related to or resulting from participating or downloading materials in this Contest. If, for any reason, the Contest is not capable of running as planned, including infection by computer virus, bugs, tampering, suspicious game activity, cheating, unauthorized intervention, fraud, technical failures, errors (including, without limitation, human error), or any other causes beyond the control of Promotion Entities and their affiliates which corrupt or affect the administration, security, fairness, integrity or proper conduct of this Contest, Promotion Entities reserve the right at their sole discretion to cancel, terminate, modify or suspend the Contest. In addition, should trading on the New York Stock Exchange, NASDAQ, AMEX or other applicable exchange be suspended, shortened, interrupted, modified, or cancelled for any reason, Promotion Entities reserve the right at its sole discretion to award prizes as of the time the disruption takes place, or to cancel, terminate, modify, or suspend the Contest.

10. Privacy: TradeZero and its authorized agents will collect, use, and disclose the personal information the Entrants provide when they enter the Contest for the purpose of administering the Contest and prize fulfillment. The Contest website is hosted on servers in the United States, and the personal information you provide may therefore also be subject to the laws of the United States. For further information about TradeZero’s privacy practices, please see TradeZero’s Privacy Policy at: https://www.tradezeroedge.com/privacy-policy.

11. Governing Law and Arbitration: Except where prohibited, each Entrant agrees that this Contest shall be governed by and construed in accordance with, the laws of the United States and the state of New York without giving effect to its or any other country, state’s or province’s choice of law or conflict of law statutes, regulations or rules. Entrants each agree that any and all disputes, claims, causes of action, or controversies (“Claims”) arising out of or in connection with the Contest shall be resolved, upon the election by either the Entrant, Promotion Entities and/or their affiliates (each, a “Party”) by arbitration conducted by a single arbitrator in New York, New York (USA), which may be conducted by telephone or online without any personal appearance by the parties or witnesses unless otherwise mutually agreed by the parties, pursuant to this provision and the then current rules of the American Arbitration Association (“AAA”). The arbitrator shall be selected pursuant to the then-current AAA rules and procedures. The arbitrator shall apply New York law consistent with the Federal Arbitration Act and applicable statutes of limitations, and shall honor claims of privilege recognized at law. UNLESS ARBITRATION IS PROHIBITED BY LAW WITH RESPECT TO A CLAIM, NEITHER PARTY WILL HAVE THE RIGHT TO LITIGATE THAT CLAIM IN COURT OR HAVE A JURY TRIAL ON THAT CLAIM. FURTHER, NEITHER ENTRANT OR ANY PROMOTION ENTITIES WILL HAVE THE RIGHT TO PARTICIPATE IN A REPRESENTATIVE CAPACITY ON BEHALF OF THE GENERAL PUBLIC OR OTHER PERSONS SIMILARLY SITUATED, OR AS A MEMBER OF ANY CLASS OF CLAIMANTS PERTAINING TO ANY CLAIM SUBJECT TO ARBITRATION. EXCEPT AS SET FORTH BELOW, THE ARBITRATOR’S DECISION WILL BE FINAL AND BINDING. NOTE THAT OTHER RIGHTS THAT ENTRANT WOULD HAVE IF ENTRANT WENT TO COURT ALSO MAY NOT BE AVAILABLE IN ARBITRATION. Unless the Entrant and Promotion Entities mutually agree otherwise, the arbitrator may not consolidate more than one person’s claims and may not otherwise preside over any form of a representative or class proceeding. The arbitrator’s authority to resolve Claims is limited to Claims between the Promotion Entities and/or their affiliates and Entrant, alone and the arbitrator’s authority to make awards is limited to awards to the Promotion Entities and/or their affiliates and the Entrant alone. Furthermore, claims brought by either party against the other may not be joined or consolidated in arbitration with Claims brought by or against any third party, unless agreed to in writing by all parties. The arbitrator may award declaratory or injunctive relief only in favor of the individual party seeking relief and only to the extent necessary to provide relief warranted by that party’s individual claim. No arbitration award or decision will have any preclusive effect as to issues or claims in any dispute with anyone who is not a named party to the arbitration. Notwithstanding any other provision in these Official Rules and without waiving either party’s right to appeal such decision, should any portion of this Section 11 be deemed invalid or unenforceable as to any Claims, then the entirety of this arbitration provision (without limiting Section 12 below below) shall be null and void with respect to the applicable Claims.

12. Class Action and Damages Waiver: Subject to Section 11 above, all claims arising from or related to these Official Rules and the Contest shall be resolved individually, without resort to any form of class action and all claims, judgments and awards shall be limited to actual out-of-pocket costs incurred, and, except as expressly provided in these Official Rules, in no event include attorney or legal fees, and under no circumstances will any Entrant be permitted to obtain awards for, and each Entrant waives all rights to claim, any punitive, incidental, special, consequential damages and any other damages, other than for actual out-of-pocket expenses and Entrant waives all rights to have damages multiplied or otherwise increased. By entering, Entrants release and hold harmless Promotion Entities, their affiliates and their respective directors, officers, employees and agents from any and all liability for any injuries, loss or damage of any kind to persons, including death, or property damage resulting in whole or in part, directly or indirectly, from acceptance, possession, misuse or use of any prize, participation in this promotion, or while traveling to, preparing for, or participating in any prize-related activity. ENTRANTS, BY ENTERING, SPECIFICALLY AND KNOWINGLY WAIVE ANY RIGHT TO A TRIAL BY JURY AND A TRIAL BY JURY IS HEREBY WAIVED BY PROMOTION ENTITIES AND ENTRANTS IN ANY CLAIM OR COUNTERCLAIM ARISING OUT OF OR RELATING TO THIS CONTEST IN ANY WAY. ENTRANTS UNDERSTAND THAT EACH ENTRANT IS WAIVING RIGHTS WITH RESPECT TO CLAIMS THAT ARE AT THIS TIME UNKNOWN OR UNSUSPECTED, AND IN ACCORDANCE WITH SUCH WAIVER, ENTRANT ACKNOWLEDGES THAT ENTRANT HAS READ AND UNDERSTANDS, AND HEREBY EXPRESSLY WAIVES, THE BENEFITS OF SECTION 1542 OF THE CIVIL CODE OF CALIFORNIA, AND ANY SIMILAR LAW OF ANY STATE, COUNTRY, PROVINCE OR TERRITORY, WHICH PROVIDES AS FOLLOWS: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR.”

13. Winners List: While potential winners may be posted on the Contest Site at the conclusion of the Contest, and at the end of each Contest Period, all potential winners are still subject to verification and must meet all eligibility requirements before a prize will be awarded. The list of verified winners may be obtained after December 20, 2024, and no later than February 20, 2025, by sending a self-addressed stamped envelope to: TradeZero WCOT Contest Winners List, c/o Benzinga, 1 Campus Martius, Suite 201, Detroit, MI 48226, USA.

14. Official Rules: For a copy of the Official Rules, print this web page or send a self- addressed, stamped envelope to: TradeZero WCOT Contest Official Rules, c/o Benzinga, 1 Campus Martius, Suite 201, Detroit, MI 48226, USA. Requests received after the end of the Contest Period will not be honored.

15. Intellectual Property: The Contest, Contest Site, and all of the related pages, contents and code are copyright © TradeZero USA Inc. and/or Administrator. Copying or unauthorized use of any copyrighted materials, trademarks or any other intellectual property without the express written consent of its owner is strictly prohibited. NYSE and NEW YORK STOCK EXCHANGE are trademarks of NYSE GROUP, INC. NASDAQ is a trademark of Nasdaq, Inc. This Contest is not sponsored, endorsed or administered by NYSE or NASDAQ, nor is NYSE or NASDAQ associated with the Contest in any way. Any questions, comments or complaints regarding the Contest must be directed to the Sponsor or Administrator only.

16. TradeZero-Affiliated Broker: Dealers: TradeZero Holding Corp. is the ultimate controlling shareholder of TradeZero USA Inc. and the following TradeZero-affiliated broker-dealers:

  • TradeZero America, Inc. is registered in the United States with the Securities and Exchange Commission as a broker-dealer and is a member of the Financial Industry Regulatory Authority;
  • TradeZero Canada Securities ULC is registered in Canada with the Ontario Securities Commission as an investment dealer and is a member of the Canadian Investment Regulatory Organization; and
  • TradeZero Inc. is registered with the Securities Commission of the Bahamas and is a member of the Bahamas Financial Services Board. Any and all activities involving or related to the Contest that may be considered within the Eligible Territories to be registerable activities shall be deemed to have been undertaken and completed by the applicable TradeZero-affiliated broker-dealer for the applicable jurisdiction.

17. Remember, It’s Just a Game: By participating in the Contest, the Entrant acknowledges and agrees that the Contest is just a game and that the Program should not in any way be considered a solicitation to trade any security or pursue any investment strategy. The purpose of the Contest is to allow individuals ranging from newcomers to long-term enthusiasts the opportunity to explore their own do-it- yourself investment-research activities and then develop fantasy, novel and/or unique investment strategies for fun where such strategies might likely never be utilized in the real world. The nature of the Contest and some Entrant’s desire to win the Contest will likely encourage and result in some Entrants taking theoretically high risks with their fantasy portfolio that would not be appropriate for them in the real world. In the real world, an investor should generally seek to invest in a diversified portfolio of suitable securities based upon the investor’s investment objectives and financial circumstances and an investor should seek to obtain a reasonable expected return while minimizing the risks related thereto. Often investors should obtain and rely upon the tailored advice of registered investment-industry professionals for help with the investor’s investment and portfolio decisions in order to ensure that they are suitable for the investor. The TradeZero-affiliated broker-dealers offer order- execution-only account services to their clients without their clients receiving any recommendations or suitability assessments from the representatives of the TradeZero-affiliated broker-dealers.

The investment strategy or performance of any Entrant’s fantasy portfolio in the Contest should not be relied upon in the real world and it should not be considered indicative of the investment or portfolio performance that an Entrant may actually achieve in the real world. The past performance of any Entrant’s fantasy portfolio in the Contest will not guarantee or be indicative of any future results in the real world.

1. To participate the Contest, Entrants need to set up and maintain a Fantasy Portfolio on the Contest Site which includes $100,000 in starting Fantasy Cash (at the beginning of each Contest Period); at the beginning of each Contest Period after the Initial Contest Period, all accounts for Entrants participating in multiple Contests will be reset to $100,000 Fantasy Cash. The main objective of the Contest is to increase the value of Entrant’s Fantasy Portfolio over time during the applicable Contest Period. The Entrant with the highest balance of Fantasy Cash in their fantasy portfolio at the end of the Contest Period may win a prize, subject to the Entrant’s verification and fulfilment of requirements. Amounts are not cumulative from one Contest Period to the next. ACCOUNT FANTASY FUNDS PROVIDED AND TRADED IN CONNECTION WITH THE PROGRAM ARE NOT ACTUAL CASH. ENTRANTS WILL NOT RECEIVE ANY PROFITS EARNED IN CASH OR OTHER FORM OF CONSIDERATION.

2. Entrants can buy fantasy equity and level one option positions in United States markets only using part or all of their Fantasy Cash on the Contest Site. Entrants cannot buy fractional shares. Entrants can maintain part cash, part equity, part option, or all equity or all option Fantasy Portfolios. During each Contest Period, Entrants must trade at least once on each of at least five days on which the New York Stock Exchange is open for trading (trading activity within one day is considered to be a purchase or sale of a securities position from 00:00:00 to 23:59:00 ET). Entrants may not use complex multi-leg options functionality in the Contest. To the extent Entrants use short selling, all securities will be deemed to be on the easy to borrow list avoiding the obligation to obtain securities locates and/or pre-borrow securities and incur Fantasy Cash charges in connection therewith. All options positions will be deemed to settle in cash for purposes of the Contest. As a result of the various Contest rules set forth, Entrants acknowledge and agree that the results of trading in the Contest will likely vary from actual trading results in a live trading environment.

3. Entrants who completely deplete their Fantasy Cash funds in connection with trading within a Contest Period will not receive additional account funds during the same Contest Period. Promotion Entities are not responsible for any trading errors. Commissions and fees from TradeZero affiliates, exchanges or regulators will not be considered in accounting profit and loss calculations. The operation of TradeZero’s risk platform may require/force position sellouts and/or other actions on an automated and/or discretionary basis. Entrants may participate in multiple Contest Periods assuming they meet all other applicable rules relating to the Contest.

4. Time of Fantasy Trade: Entrants can place fantasy trades at any time during a Contest Period; however, fantasy trades are only executed either at Market Open (generally 9:30 am ET on trading days) OR Market Close (generally 4:00 pm ET on trading days), whichever is the next event at the time of placing a fantasy trade. Fantasy trade executions may be delayed after Market Open or Market Close; however, if delayed, fantasy trade trading activity within one day is considered to be a purchase or sale of a securities position from 00:00:00 to 23:59:00 ET executions will still be priced at the Market Open price or Market Close price. Fantasy trades submitted after normal market trading hours (after Market Close, generally 4:00 pm ET on trading days and before Market Open, generally 9:30 am ET on trading days), including market holidays and weekends, will be executed at the next Market Open. Final time of a fantasy trade is based on the when the Entrant submits a fantasy trade and not when the Entrant initiates the fantasy trade. Fantasy trades will be executed, generally, per the time they were placed. Sell orders may execute first to free up cash availability.

5. Pricing Fantasy Trades: Fantasy trades submitted during normal market trading hours (between Market Open, generally 9:30 am ET and Market Close, generally 4:00pm ET on trading days), will be priced at the next market close price. Fantasy trades submitted after normal market trading hours (after Market Close, generally 4:00pm ET on trading days and before Market Open, generally 9:30 am ET), including market holidays and weekends will be priced at the next market open price. Fantasy trade executions may be delayed after Market Open or Market Close; however, if delayed, fantasy trade executions will still be priced at the Market Open price or Market Close price.

6. Fantasy Trade Executions: The Official Rules (including this Exhibit A) shall be enforced at time of placing a fantasy trade and during active trading. For equity and option fantasy buys, each fantasy trade will execute to result in a whole number of shares and using only the available Fantasy Cash to purchase fantasy trades up to the desired number of shares specified within the order. If an entrant does not have enough Fantasy Cash available to purchase even one (1) share or cover for commission during a sale, the fantasy trade will not be executed and will be automatically cancelled. All orders placed will be executed at next eligible time of fantasy trade. If there are issues with execution, that order will stand canceled.

7. Portfolio Valuation: All equity and option pricing information is as per the details outlined within this document, above. Fantasy portfolio and individual holding Fantasy Cash balances are always marked to market value during each trading day and trading time. After market close or during weekends or market holidays, the Fantasy Portfolio is valued at the last closing price of each equity and/or option.

8. Processing of Corporate Actions: Promotion Entities reserve the right to implement and enforce “processing of corporate actions” game-wide OR on a case-by-case basis. Dividends are not supported. Entrants with fantasy stock positions that pay dividends during the dates of the contest will not receive any Fantasy Cash credit for dividends as they would at a regular brokerage. The Contest will process limited corporate actions only in Promotion Entites’ sole discretion, potentially including: stock splits, mergers, and ticker symbol changes. The Contest will process corporate actions for an Entrant’s current equity and option fantasy holdings only. Processing may be delayed by several days after the effective date of the action. Entrants who sell/liquidate the fantasy equity or option position before that processing occurs may not receive the benefit of that action. If an equity or option is halted for more than one calendar day, it may be automatically sold at its latest available price.