Reg FD position

Mediaberry does not generate, distribute, or facilitate the selective disclosure of material non-public information. We ingest only publicly available retail-investor conversation, we deliver analysis to a single subscribing IRO (and their team), and we do not transmit information from the issuer's account to the public.

The information flow is one-directional and inbound: public retail commentary → Mediaberry analysis → the IRO's inbox. There is no path from Mediaberry to a securities analyst, shareholder, or media outlet that the IRO does not personally control.

Regulation Fair Disclosure (17 CFR 243.100-103) prohibits a public company, or a person acting on its behalf, from intentionally selectively disclosing material non-public information to securities-market professionals or to shareholders likely to trade on it, without simultaneously making it public. The trigger is selective disclosure of MNPI, by the issuer, to specified recipients.

Mediaberry is not the issuer. Reg FD applies to the company and persons acting on its behalf. Mediaberry is a third-party analysis vendor; we do not speak for the issuer to the market.

We do not transmit issuer information out of the IRO's account. Briefs, alerts, and other deliverables go only to the subscribing IRO and the team members they invite. There is no newsletter, public feed, or third-party syndication of any customer's data.

Inputs are public. Mediaberry ingests posts from X / Twitter, Reddit, Stocktwits, and Seeking Alpha — all public commentary. We do not ingest internal documents, draft press releases, transcripts before they are published, or any other source the issuer would consider non-public.

AI synthesis of public data is not, on its own, MNPI. Our outputs (sentiment scores, topic clusters, threat-vector analyses, etc.) are derived from public posts. The synthesis can be useful, but it does not introduce material information that the issuer hasn't disclosed; it interprets information that is already public.

IROs using Mediaberry should still apply their standard Reg FD discipline when forwarding or quoting Mediaberry output to outside parties. Specifically:

• Treat the IRO's own internal context — supplied to talking points or vulnerability assessments — as MNPI if it would be MNPI in any other channel. Don't paste material non-public information into the “Context” field of any Mediaberry feature and then forward the output.
• When forwarding a brief or talking-point memo to your CEO or CFO, treat it as internal preparation material. Do not redistribute to analysts or shareholders.
• If a brief surfaces an active rumor about your company, follow your standard Reg FD response procedure (no comment / public clarification) — the brief itself doesn't change that calculus.

Customer accounts are isolated by design via Postgres row-level security. One IRO cannot see another IRO's tickers, mentions, briefs, talking points, or assessments. Mediaberry employees access customer data only when needed to deliver the service or respond to a support request, and access is logged.

For specific Reg FD or compliance questions, email legal@mediaberry.com and we'll connect you with the right person.