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Disclosure
Important Disclosures, Disclaimers and Limitations regarding Marketocracy Investment Research
Introduction

The following important disclosures, disclaimers, limitations, frequently asked questions and policies (collectively, this Policy) apply to all investment and other research published or otherwise disseminated by Marketocracy, Inc. (Parent) and its affiliates, in particular its wholly owned subsidiary, Marketocracy Data Services LLC (MDS), a financial publisher (all collectively, Marketocracy, "we" or "us").


This is the current version of this Policy. We reserve the right to amend or supplement all or any part of this Policy at any time without notice.


MDS Prepares and Is Responsible for All Marketocracy Investment Research

All of our investment and other research (research) and information in connection therewith is prepared by, and is attributable to, MDS, which bears sole responsibility for its content and for its publication and other dissemination, and unless otherwise expressly stated in each case, none of our research is prepared by or otherwise attributable to Marketocracy Capital Management LLC, a registered investment adviser and wholly owned subsidiary of Parent (MCM). Also, unless otherwise expressly stated in each case, any references to, or statements by, Kendrick W. Kam in connection with any of our research are made solely in respect of his capacities of President of Parent and Editor in Chief of MDS Research and not in respect of his capacities as President, Chief Compliance Officer or Portfolio Manager for MCM. See Conflicts of Interests, Including Trading Securities We Research below.


Model Portfolio Performance Information

The performance information presented and discussed pertains to Marketocracy.com model funds.


For all model performance results, there are inherent limitations which investors should understand. Unlike an actual performance record, model results do not represent actual investment performance or trading. Since the trades have not actually been executed, the results may under- or over-compensate for the impact, if any, of certain market factors, such as the effect of limited trading liquidity.


No representation is being made that any investor will or is likely to achieve results similar to those shown. The results presented reflect past performance and should not and cannot be viewed as an indicator of future performance. The results shown are not an indicator of the returns a client would have realized or will realize in relying on any model mentioned.


The analysts who manage the model funds are not employees of Marketocracy or any of its affiliates, but are independent investment researchers acting solely as independent contractors.


General Disclosures and Disclaimers

No Warranties or Guarantees


Our research is based on sources we believe to be reliable. However, neither we nor any of our affiliates or any other person makes any representation or warranty, express or implied, as to our researchs accuracy, completeness, or correctness or make any guarantee or other promise as to any results that may be obtained from using our research. To the maximum extent permitted by law, neither we, any of our affiliates, nor any other person, shall have any liability whatsoever to any person for any loss or expense, whether direct, indirect, consequential, incidental or otherwise, arising from or relating in any way to any use of or reliance on our research or the information contained therein.


No Solicitation


Our research is not a solicitation, or offer, to buy or sell any security.


Subject to Change


All of our research, including the estimates, opinions and information contained therein, reflects our judgment as of the publication or other dissemination date of the research, and is subject to change without notice. Further, we expressly disclaim any responsibility to update such research.


Impersonal Research


Nothing in our research constitutes legal, accounting or tax advice or individually tailored investment advice. Our research is prepared for general circulation and has been prepared without regard to the individual financial circumstances and objectives of persons who receive or obtain access to it.


Investment Risks


Investing involves substantial risk. Past performance is not a guarantee of future results, and a loss of original capital may occur. No one receiving or accessing our research should make any investment decision without first consulting his or her own personal financial adviser and conducting his or her own research and due diligence, including carefully reviewing any applicable prospectuses, press releases, reports and other public filings of the issuer of any securities being considered.


Important Disclosure Regarding Certain Inapplicable Laws, Rules and Regulations

We intend that our research and our publication or other dissemination of it comply with all applicable laws, rules and regulations.


However, neither Parent nor MDS is, or acts as, an investment adviser or a broker-dealer. Consequently, neither Parent nor MDS is registered or qualified as such with any securities authorities or self-regulatory organizations, including the U.S. Securities and Exchange Commission (the SEC), any state or foreign securities authorities, the National Association of Securities Dealers (the NASD) or the New York Stock Exchange (the NYSE).


Thus, specific laws, rules and regulations applicable to communications with the public generally or research prepared by registered investment advisers and more importantly, registered broker-dealers, including certain prohibited communications, mandatory broker-dealer disclosures, research analyst registrations and certifications, and prohibited conflicts of interest, including restrictions on trading in securities referenced in research, such as SEC Regulation AC, NASD Rules 2210 and 2711 and NYSE Rule 472, are expressly not applicable to our research and our publication and other dissemination of it. Further, we expressly disclaim the applicability of those laws, rules and regulations and any responsibility to adhere to them regarding our research. See Conflicts of Interests, Including Trading Securities We Research below.


Neither Mr. Kam nor any other of our officers, directors, partners, managers, employees and contractors are registered as research analysts with any securities authority or self-regulatory organization. Neither Mr. Kam nor any other our officers, directors, partners, managers, employees and contractors named in any of our research makes any certifications in connection with any law, rule or regulation with respect to his or her views expressed in any of our research. We have not submitted our research for approval for publication or dissemination by any registered broker-dealer, securities authority or self-regulatory organization in any jurisdiction.


Conflicts of Interests, Including Trading Securities We Research

Because neither Parent nor MDS is an investment adviser or broker-dealer, neither engages in, or receives any compensation from, the business of investment banking. Our research is not, and under no circumstances should be construed as, a solicitation by us to act as investment adviser or broker-dealer in any jurisdiction.


The person(s) responsible for preparing our research receive compensation that is based upon various factors, including our revenues and profits, a portion of which is generated by the publication or other dissemination of our research. It is our policy, however, that no part of the compensation of Mr. Kam nor any of our officers, directors, partners, managers, employees and contractors named in any of our research is, or will be, directly or indirectly, related to the specific recommendations or views expressed such person(s) in our research, i.e., whether the specific recommendations or views are favorable toward the securities referenced in the research.


Further, MCM, our registered investment adviser affiliate, actively manages its clients portfolios based primarily on our research, both published and unpublished. In addition, Mr. Kam, Editor in Chief of MDS Research, and primary drafter of all MDS published research, also serves as President and Chief Compliance Officer of MCM and as well as MCMs Portfolio Manager for all MCM clients portfolios.


In serving as MCMs Portfolio Manager, Mr. Kam bases his investment decisions for MCM clients portfolios primarily, but not exclusively, on our research, both published and unpublished, including research of which he is the primary drafter. In making those investment decisions, however, Mr. Kam always must consider the portfolio and its owners various investment goals, objectives, policies, restrictions and limitations as well as all other relevant facts and circumstances.


Also, Mr. Kam and other of our affiliates, including certain of our officers, directors, partners, managers, employees and contractors (Our Other Affiliates), also manage certain other personal and proprietary portfolios, including portfolios of investment vehicles and accounts in which Mr. Kam or Our Other Affiliates have material personal financial interests, including without limitation material personal financial interests in securities that are the subject of our research (Research Securities).


In managing these portfolios and accounts, Mr. Kam and Our Other Affiliates base his or their investment decisions primarily, but not exclusively, on our research. Similarly to MCM, Mr. Kam or Our Other Affiliates must consider the portfolio and account owners various investment goals, objectives, polices, restrictions, limitations, business and personal liquidity needs and financial and estate planning requirements as well as all other relevant facts and circumstances.


Although Mr. Kam and certain of our officers, directors, partners, managers, employees and contractors are subject to a code of ethics that impose restrictions on personal securities trading, the foregoing still means that MCM, and Mr. Kam as its Portfolio Manager, may be actively trading, Research Securities that may be or are held in MCM clients portfolios. This also still means that Mr. Kam and Our Other affiliates may be actively trading Research Securities that are held in these other portfolios and accounts.


Thus, whenever you are evaluating our research, you always should assume that MCM and Mr. Kam as its Portfolio Manager, and Mr. Kam and Our Other Affiliates, have material financial interests in Research Securities, and may and will be either holding or actively trading, i.e., either buying or selling, Research Securities in a manner that is exactly contrary to or inconsistent with the opinions (including those of Mr. Kam, any of Our Other Affiliates, or any of our officers, directors, partners, managers, employees and contractors named in any of our research), recommendations or general tenor of our published research, without any notice or disclosure of any particular contrary or inconsistent holding or trading decision.


If you believe or feel that such actions by MCM, Mr. Kam, Our Other Affiliates and any of our officers, directors, partners, managers, employees and contractors named in any of our research in any way undermine or otherwise diminish the validity, accuracy completeness, correctness or credibility of our research, DO NOT RELY ON OUR RESEARCH FOR ANY PURPOSE!


To the maximum extent permitted by law neither we, MCM, any of our affiliates, including without limitation Mr. Kam, Our Other Affiliates or any of our officers, directors, partners, managers, employees and contractors named in any of our research, nor any other person, shall have any liability whatsoever to any person for any loss or expense, whether direct, indirect, consequential, incidental or otherwise, arising from or relating in any way to any use of, or reliance on, our research or the information contained therein and any holding or active trading of any Research Securities by us, Mr. Kam, any of Our Other Affiliates or any of our officers, directors, partners, managers, employees and contractors named in any of our research.


Copyright 2010. Marketocracy. All rights reserved. Any photocopying, reproduction or quotation of this Policy or any of our research is strictly prohibited without our prior written consent.

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