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Startup Legal AMA w/ Venturous Counsel

  • 1.  Startup Legal AMA w/ Venturous Counsel

    Posted 11-07-2024 13:03
    Edited by Brent Devey 11-12-2024 09:21

    Hello Carta Community!

    We are the partners of Venturous Counsel, a uniquely mission-driven law firm operating as on-demand general counsel for diverse startups, emerging investors and mission-driven, values-aligned companies. We provide them with seasoned, practical, actionable, bottom-line-oriented and mindful advice, all in a more efficient and responsive manner (and at lower billing rates) than BigLaw.

    We'll be here to answer your questions next Tuesday, November 12 at 11:30am!  From formation to financing strategy, equity compensation, commercial agreements, employee/service provider matters, IP strategy, all the way to exit--ask us anything!*

    More about us below--hope to "see" you there!

    Aravinda Seshadri (Founding Partner) and Michael Young (Managing Partner)

    *****

    Aravinda Seshadri is the Founding Partner of Venturous Counsel, a uniquely mission-driven firm dedicated to representing underestimated startups, investors and values-aligned companies, with over 17 years of experience advising startups like Uber, Lyft, TaskRabbit and investors like Rakuten, Hustle Fund, Felicis and Floodgate.  Aravinda has been named a Super Lawyers Rising Star for 7 years. She was previously a Partner at Silicon Legal Strategy in San Francisco. Before that, she was a corporate associate in the startup practice of Hogan Lovells in Palo Alto. She started her career in Orrick's Emerging Companies Group in Menlo Park.  Aravinda received her law degree with distinction from Stanford Law School and her undergraduate degree with honors in Language and Mind from New York University.

    Michael Young is the Managing Partner at Venturous Counsel.  He specializes in advising emerging companies and their investors at all stages in a company's life cycle-from formation to exit.  Prior to joining Venturous Counsel, Michael represented startups and investors at Silicon Legal Strategy and at Perkins Coie LLP (where he also did a stint as a commercial litigation attorney).  Michael is passionate about empowering clients to realize their vision and navigate the complex startup ecosystem with confidence by offering actionable, bottom-line-oriented advice. 

    *please note that answers given are not legal advice, but our opinions based on general knowledge of certain substantive areas of law; if you require legal advice tailored to your particular circumstances, please discuss with legal counsel retained to represent you.



    ------------------------------
    Michael Young
    ------------------------------



  • 2.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-07-2024 13:16

    I'm so excited for you two to host this AMA! It's great to have such experienced experts in Carta Community. 


    A quick word from Carta's legal team: 

    DISCLOSURE: This event is presented on behalf of eShares, Inc., dba Carta, Inc. ("Carta"). The content of this event is not, and no opinions or comments shared in this event should be treated or construed as, accounting, business, financial, investment, legal, tax, or other professional advice or services​​. This event is for information purposes only. The content of this event is not intended as a recommendation, offer or solicitation for the purchase or sale of any security. Carta does not assume any liability for reliance on the information provided herein and undertakes no obligation to update content. The opinions of the guests and host are their own and do not reflect the view of Carta or Carta's affiliates. All product names, logos, and brands are property of their respective owners in the U.S. and other countries, and are used for identification purposes only. Use of these names, logos, and brands does not imply affiliation or endorsement.



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    Brent Devey
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  • 3.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-07-2024 18:08

    We're stoked!



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    Michael Young
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  • 4.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-08-2024 08:18

    I've seen some information out there about the corporate transparency act. How does the it impact startup founders, especially with the new BOIR requirements? What do these reporting rules mean for privacy and compliance, and what steps should small companies take to stay on top of them?



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    Timothy Dewsnup
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  • 5.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 10:51

    Hi Timothy,

    These requirements are new and the enforcement regime is still somewhat of an unknown, but fortunately compliance is very simple for most companies.  I'm including some instructions below to guide you.  The deadline to complete this is January 1, 2025 for companies formed prior to 1/1/2024.  For companies formed this year, the filing must be made within  90 days of initially registering your company.

    BOIR INSTRUCTIONS:

    1. Go to: FinCEN's website.
    2. Select, "File a report using the BOI E-Filing System"

    1. Select, BOI Reporting "Get Started"

    1. Under, "File Online BOIR", select "Prepare & Submit BOIR"

    1. Complete the highlighted fields as outlined in the attached.
    2. Please download and email us the BOIR transcript summary after submission.


    ------------------------------
    Michael Young
    ------------------------------



  • 6.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:29

    Hi, 

    I have a CTA question as well. Are you seeing all board members included in the BOI Report?

    Scott



    ------------------------------
    Scott Robinson
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  • 7.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:34

    Hi Scott,

    Yes, typically we'd include all board members since arguably they all "exercise substantial control" over the entity, tripping up one of the requirements.



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    Michael Young
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  • 8.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 09:47

    How should I determine the right amount of equity to offer advisors? Are there best practices or common benchmarks that can help me structure these agreements fairly and attract the right expertise?



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    Isabella Trejo
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  • 9.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:21

    Great question Isabella! The typical offer for advisors depends a bit on the Company's stage and industry, but for the most part, especially for early-stage companies, the range is between 0.1% to 0.25% of the fully-diluted capitalization of the company (which includes all issued shares and shares reserved for issuance under your option pools). Typical vesting is 1-2 years monthly with 100% single trigger change of control acceleration (if the company gets acquired, unvested shares accelerate). A really important or industry-specific advisor could receive 0.5%, but a larger amount than that should be reserved for someone like Beyonce but in your industry, someone who can really open all of the doors for you.



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    Aravinda Seshadri
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  • 10.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 10:42
    Edited by Robert Leer 11-12-2024 10:42

    Thanks for hosting this. Would love a 2nd opinion regarding this. What is the right way to legally set up a case interview / work trial? Currently, I have a standard Ind Contractor agreement I am asking the person to sign (IP etc). How long can the work trial last? Should I be paying for this work? What are the absolute must-haves and what should I avoid doing? Thank you!



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    Robbie
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  • 11.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:40

    Hi Robert, great question. Your question hits at the core of this concept called "employer/consultant classification." The topic could itself be its own AMA, but here are some links that help you understand the difference: https://www.dol.gov/agencies/whd/fact-sheets/13-flsa-employment-relationship and https://www.irs.gov/newsroom/worker-classification-101-employee-or-independent-contractor. To clarify: if the service provider is hired for a specific project or simultaneously working for other companies, those are important factors weighing in favor of the service provider being an actual consultant, but it's an overall many-factor analysis.

    In reality, many startups actually are misclassifying consultants in the early days. They may decide the risk of doing so for sophisticated service providers over a short period of time is an acceptable amount of risk compared to the cost of hiring employees who must be paid a minimum amount of cash (especially before they have any investment/cash available). Later on some companies continue this practice with an arrangement like what it seems you're describing above Robbie--more of a "try before you buy" approach. While these folks may actually be employees, if it's for a short period of time, working with sophisticated service providers, the risk is probably low, but it increases the more evaluations done and the longer each trial period lasts.

    The lowest risk approach would be to work with a PEO (professional employment organization) who can employ and handle state-by-state registration, payroll, etc. so you are not at risk of misclassifying these folks during their "trial" period. Of course, this costs more.

    I would definitely strongly recommend compensating service providers during their evaluation period (a consultant/contractor agreement is likely not enforceable if you didn't provide some consideration for the IP assignment). Even if they have signed the consulting agreement, if you pay a minimal amount and then end up using their work in your product or especially outward facing communications, the service provider may feel they have been treated unfairly. So while it's a common practice, there is some risk so the way you handle this process really relates to your level of risk. Ultimately, you're trying to avoid threats of or actual litigation by someone who feels hard done by AND visibility to regulators who could bring an enforcement action. 

    You may be able to get to a better outcome by hiring folks as employees and letting them know that the initial X period is a "trial" period--even in the many "at will" jurisdictions where employees may be terminated at any time without cause, this aligns expectations with the employee and reduces the likelihood someone would sue, while removing the misclassification issue from the table altogether.



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    Aravinda Seshadri
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  • 12.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:08

    I'm starting up two Delaware C-Corps. One will be a Venture Studio (Planet 9 Ventures Inc.) helping founders launch new businesses leveraging AI and automation and 2nd company will be an Operational/Industrial Technology Cyber Security solutions company (Nexus 9 Inc.). We're interested in complying with IRC Section 1202 (QSBS) for both companies, but I'm wondering if that's a possibility for the Venture Studio.

    Can you share your experience with QSBS qualification and, in general, can Venture Studios qualify for that tax savings strategy?

    Thanks in advance for any and all help!



    ------------------------------
    Steven Rodgers
    President and CEO
    Planet 9 Ventures Inc.
    Overland Park KS
    ------------------------------



  • 13.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:43

    Hi Scott!

    It's a good question.  As you likely know, if all of the QSBS eligibility requirements are met, a selling stockholder can exclude up to $10M in otherwise taxable capital gains at the federal level--so it's definitely worthwhile to ascertain your eligibility and try to pursue it as a tax savings strategy.  Venture Studios certainly are not categorically prohibited from obtaining this benefit (in this way they are much like any other investor), but eligibility is highly case-specific, so we'd strongly recommend checking in with your tax advisor to go over the particulars.



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    Michael Young
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  • 14.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:39

    Our small business will have an Stock Option Plan. We are not publicly traded. If an employee wants to sell their stock, who buys it? Is the company required to buy back all stock that employees want to sell? 



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    Jennifer Warrillow
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  • 15.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:54

    Hi Jennifer,

    Great questions. I do want to mention that the employee's ability to sell stock of a private company is constrained, not just by securities compliance (if the company is not publicly traded, you need to have an exemption from securities laws for any issuance or sale of securities), but it also be due to contractual restrictions in the company documents, such as transfer restrictions in the bylaws in some cases and almost always with a right of first offer in favor of the company (meaning the employee has to offer the terms they negotiate to the company and often the investors first before selling to anyone else).

    If an employee doesn't have (or is able to get around) those contractual restrictions, they might be able to find someone to purchase their shares--for later stage companies there are event platforms that help facilitate this kind of liquidity like SecondMarket, but it's far from a sure thing. 

    The Company is typically not required to repurchase any employee shares, but the easiest way for Common Stock holders to obtain liquidity is if it's facilitated by the company--generally by selling to existing or new investors. This generally requires the company to have a lot of leverage/numerous investors at the table, because the cash investors pay will not go to progressing the company, but will be lining employees' pockets and actually reducing their equity stake/incentive to excel for the company.

    I do recommend the company repurchase unvested shares--these are usually repurchasable at the lower of current fair market value or the employee's purchase price. It always makes sense for the company to keep more shares in the hands of current service providers.



    ------------------------------
    Aravinda Seshadri
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  • 16.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:42
     posted 10-01-2024 09:14

    Greetings!

    Thanks for listening :-)

    I am trying to figure out how to actually use my ROTH IRA account to purchase Stock Options

    that have vested at the company I work for. I have no other interests in the company other

    then being a devoted employee  :-) .

    Has anyone done this? Upside / downside?

    Any advice would be appreciated.

    Cheers

    Chris 



    ------------------------------
    Christopher Chandler
    ------------------------------



  • 17.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:46

    Hi Christopher,

    Before making any decisions about how to invest retirement funds, I'd recommend talking with your financial advisor to discuss suitability.  Obviously, equity in any individual company can be volatile and while a Roth IRA can yield tax benefits, the underlying investments may or may not be appropriate depending on your age, time horizon, risk tolerance, and retirement goals.



    ------------------------------
    Michael Young
    ------------------------------



  • 18.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:54

    Thanks Michael,

    but this has already been discussed....  it's not an issue... I just need to know how it might be done.

    Where can I go for details/information like this?



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    Christopher Chandler
    ------------------------------



  • 19.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 12:03

    Hi Chris, jumping in here for a bit more info. You're looking for what is called a "self-directed" IRA. Some banks offer this--I believe Charles Schwab may provide it and you can look online for other options. Keep in mind that most stock options aren't issuable to an entity, so this makes more sense if you're receiving shares (restricted stock), transferring shares as you exercise vested options, or investing as an investor in a company. You will then follow the requirements/instructions of the bank or IRA provider to get the shares properly registered under the IRA.



    ------------------------------
    Aravinda Seshadri
    ------------------------------



  • 20.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 12:58

    Thank you for your reply Aravinda,

    I have a self directed Roth IRA with Fidelity.  I'm hoping I'll be able to figure this out eventually.

    Cheers

        (I guess I'm just stunned that no one else has brought this up before...? ) :-)



    ------------------------------
    Christopher Chandler
    ------------------------------



  • 21.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 11:44

    For small business with about 8 employees, with 10% set aside for the stock option pool, what is the usual percent offered to early employees of the company at this stage? What is the usual vesting period?



    ------------------------------
    Pritha Bose
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  • 22.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 12:05

    Hi Pritha!

    It really depends on a variety of factors, including what the roles are, what cash compensation you're offering, and the negotiating leverage of the employee.  The 'rule of thumb' range can be fairly wide: anywhere from 0.1%-2% for early employees, but for non c-level hires, you're usually going to be somewhere between 0.1% and 0.25%.  And of course everyone should be subject to standard vesting terms (ideally with a one year cliff, i.e., no shares vest until the 1-year anniverary, so the company doesn't over-allocate equity to folks who are not performing).  There are some resources online that could also help you with benchmarking (Carta, Wellfound, YC, and General Catalyst all regularly produce equity compensation reports).  Hope this helps!



    ------------------------------
    Michael Young
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  • 23.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 12:00

    We are a pre-seed, medical device startup incorporated as a Delaware C corp and operating in Georgia at the moment. We participated in Startup Launch at Georgia Tech, which led us to using Carta for equity management. 

     

    1. Are there any resources available from Venturous Counsel for legal help & IP protection for bootstrapped startups?

     

    1. Do you have advice on legal pitfalls to consider when fundraising from VC, angels, & institutional funds?

     

    1. What is the best way for us to properly distribute equity for contractors as a pre-revenue startup?

     

    1. Aside from Gusto, what are some affordable resources we can use for maintaining legal & tax compliance? 

     

    1. How can we leverage R&D tax credits as we develop our medical device? 

     

    1. What are some legal mistakes to avoid as first-time founders?

     

    1. Will VCs invest if the company does not yet have a patent? 

     

    1. What are best practices for drafting patent claims that are novel and non-obvious? How do we avoid having a "useless" patent?

    2. As a medical device company, we are preparing for our first clinical trials. If we partner with a university to run the trial, how do we ensure that we retain our IP? 



    ------------------------------
    Kareem Elfoulie
    ------------------------------



  • 24.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 12:28

    Hi Kareem,

    A few of these fall outside our wheelhouse and an AMA may not be the best venue for a list of questions like this, but I've tried to respond as best as I can below!

    1. Are there any resources available from Venturous Counsel for legal help & IP protection for bootstrapped startups?

    "IP protection" is a pretty broad umbrella, but certainly one essential element will be making sure that everyone who performs any kind of work for the company enters into an agreement assigning IP they develop to the company.  A common form of such an agreement is the "CIIA" or "Confidential Information and Inventions Assignment Agreement."  Most consulting agreements have language assigning IP to the company as well--however it's documented, this is critical and investors will expect that anyone and everyone who has every performed any kind of work for the company will have such an agreement in place.  To the extent you are developing IP that needs to be registered (patents, generally), there's no substitute for retaining competent patent counsel--in the medical device field, this is likely to be even more important.

     

    1. Do you have advice on legal pitfalls to consider when fundraising from VC, angels, & institutional funds?

     

    Yes, but a lot of it is context-specific.  In general:

    • know your audience (do your homework)
    • ask for references (other founders they've worked with)
    • ensure you share a vision for how you'll be working together (how 'hands on' will the investor be)
    • don't negotiate against yourself; let the investor make the initial offer terms

    1. What is the best way for us to properly distribute equity for contractors as a pre-revenue startup?

     

    Depends on the nature of the services being provided, but we'd generally expect consultant/contractor grants to be in the range of 0.1%-0.25% depending on the cash value/importance of the services being provided.  If contractors are retained to provide specific deliverables, sometimes equity vesting is tied to 'milestones' instead of automatically vesting over time (the default for employees).  If the company is in a position to pay contractors in cash, this can be preferable as it avoids diluting the founding team.

    1. Aside from Gusto, what are some affordable resources we can use for maintaining legal & tax compliance? 

     Gusto seems to be popular in the space; we have clients using Deel and Rippling as well.

    1. How can we leverage R&D tax credits as we develop our medical device? 

     Good question for a tax advisor :)

    1. What are some legal mistakes to avoid as first-time founders?

     We have an entire presentation on this!  High-level:

    • form the right type of entity (DE c-corp)
    • work with attorneys or a trusted platform (i.e. Clerky) to manage equity issuances
    • don't forget to make your 83(b) election!
    • develop open dialog with your co-founder(s) re: expectations
    • loop in attorneys EARLY in the fundraising process
    • hire attorneys who actually do a high volume of venture financing transactions (all-purpose 'corporate' attorneys = no)
    • understand the difference between various fundraising instruments (notes, SAFEs, preferred stock)
    • practice delivering constructive feedback and having difficult conversations

    1. Will VCs invest if the company does not yet have a patent? 

     

    Many startups don't require patents or have patentable inventions, so yes.  For a medical device maker, my instinct is that an investor would want some assurance that the company wouldn't be precluded from bringing its product to market, so it's likely you'll need to consult with an IP specialist before fundraising.

    1. What are best practices for drafting patent claims that are novel and non-obvious? How do we avoid having a "useless" patent?

    Great question for a patent attorney :)  We work with clients who have patented inventions every day, but the actual work of preparing and prosecuting claims is highly specialized and outside our particular wheelhouse.

    1. As a medical device company, we are preparing for our first clinical trials. If we partner with a university to run the trial, how do we ensure that we retain our IP? 

    Would strongly recommend to have experienced attorneys review the agreement with the university to ensure the IP terms are clear and will not imperil your future fundraising efforts.



    ------------------------------
    Michael Young
    ------------------------------



  • 25.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 12:07

    I love this!

    What are the advantages (and disadvantages) to enacting an ESOP (Employee Stock Option Plan) immediately before a fundraise, for the company and for the employee? We are thinking of enacting the ESOP in December and fundraising in Feb/March. The 2 employees joined us in 2024 and have not been issued shares (yet).



    ------------------------------
    Jamie McKee
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  • 26.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 12:55

    Hi Jamie!

    The advantage is that you can perfectly 'right size' your stock plan and avoid unnecessary dilution (since unused pool shares count as part of the 'fully diluted' equity of the company, they cause SAFEs/notes to convert at lower prices than they otherwise would, diluting the founders).

    There are a few [potential] disadvantages:

    • Timing.  As soon as you receive a term sheet, you can no longer issue the shares (because receipt of a term sheet is viewed by the IRS as an event that impacts the fair market value of the shares).  So you'd have to time if perfectly such that the plan is adopted and all grants under the plan approved by the board before a term sheet lands.

    • Holding period.  There can be tax advantages to holding shares for longer periods of time (1 year for federal capital gains; 5 years for QSBS), so by delaying the issuance of shares, you may be shortening the period of time in which your employees have held shares, impacting their ability to qualify for certain tax benefits.

    • Retention.  The optics of hiring someone and not actually granting their equity for months (or longer) can be less than optimal--at a certain point, employees can start to feel as though the company isn't following through.

    On balance, our preference is to see companies issuing equity shortly after employees are onboarded--while waiting to adopt a stock plan can prevent some avoidable dilution, there are other solutions to that particular 'problem' (such as right-sizing the plan immediately before a financing), so we generally recommend companies adopt a 10-15% plan at the time of formation (though this is also context-specific and isn't appropriate for every company).



    ------------------------------
    Michael Young
    ------------------------------



  • 27.  RE: Startup Legal AMA w/ Venturous Counsel

    Posted 11-12-2024 14:17

    Thanks to everyone for the insightful questions and participation! It was a delight to be a resource to this community.

    If you have any other legal questions, you can reach Michael and me by email (michael@venturouscounsel.com and aravinda@venturouscounsel.com)--even if we're not the right fit for what you need, we can point you in the right direction! 

    If you're founder of a mission-driven or diverse-led startup or fund looking for legal support, members of the Carta community can book a free 30 minute consultation with Michael here: https://calendly.com/michael-venturous/30min or me here: https://calendly.com/aravinda-vc/30. We look forward to further supporting you all!

    Best,

    --Aravinda and Michael, partners at Venturous Counsel



    ------------------------------
    Aravinda Seshadri
    ------------------------------