Legal & Disclaimers
Disclaimer, Editorial Standards & Notice-of-Concern Policy
Effective date: June 19, 2026
Who we are. PAG Project, LLC is a Texas limited liability company producing investigative journalism, petitioning, and commentary on matters of public concern. We are not a law firm, investment adviser, broker-dealer, accountant, or tax advisor. Nothing on this publication or our channels is legal, investment, accounting, or tax advice, and nothing creates an attorney-client, advisor-client, fiduciary, confidential, or other special relationship.
We are a news and public-commentary medium. PAG Project is an alternative medium of news, reporting, and public comment whose purpose is the free dissemination of information on matters of public concern. We publish for, and hold ourselves out as entitled to, the protections afforded to news media and journalists under applicable law, including the pre-suit notice and retraction provisions described in Section 4 below.
Where this applies. This Policy applies to all content we publish on this Substack publication and on any official PAG Project channels — email newsletters, website pages, social accounts (X, YouTube, Instagram, Rumble, TikTok, LinkedIn), podcasts, videos, and community spaces such as comments, Chat, and Notes (collectively, the “Channels”). Platform terms (e.g., Substack’s Terms and Privacy Policy) also apply to your use of platform features. This Policy supplements, and should be read with, our Terms of Use.
1) Nature of our content: reporting, analysis, and opinion
Opinion vs. fact. Unless a statement is expressly identified as an established fact drawn from an official record, statements concerning wrongdoing, motive, or culpability are allegations and/or statements of opinion based on our analysis and interpretation of disclosed or cited sources. Reasonable readers should understand them as such.
Disclosed-facts opinion. Where we express conclusions, characterizations, or beliefs, they are our opinions based on facts we disclose or link to, so that readers may review the underlying material and draw their own conclusions.
Official records. Where we rely on public records or official proceedings (court dockets, agency filings and hearings, regulatory submissions, public testimony, and similar), we cite or link to those materials where feasible.
Fair report / official-proceedings privilege. We reserve and assert, where applicable, the fair-report and official-proceedings privilege for fair, true, and impartial accounts of governmental and official proceedings, including under Tex. Civ. Prac. & Rem. Code § 73.002 and analogous Florida and common-law privileges.
Opinion & rhetorical-hyperbole defenses. We reserve the constitutional and common-law protections for opinion, fair comment, and rhetorical hyperbole.
Petitioning. We reserve and assert protections for petitioning the government, including under the Noerr-Pennington doctrine and the Petition Clauses of the U.S. and Texas Constitutions, for our communications that constitute or are made as part of petitioning legislative, executive, judicial, or administrative bodies.
Whistleblower posture. The principal author is pursuing a multi-agency whistleblower effort concerning investor harm and market practices, including formal submissions to U.S. authorities (e.g., the SEC and IRS) and a petition for rulemaking filed with the U.S. Securities and Exchange Commission. Nothing here asserts affiliation with any government agency or discloses confidential or non-public information obtained improperly. Our reporting on those filings is part of our protected petitioning and newsgathering activity.
2) Public-interest mission & anti-SLAPP notice (Texas and Florida)
Our work concerns investor protection, market integrity, government oversight, and systemic practices — issues at the core of public concern and public participation. We reserve and assert all rights, immunities, defenses, and remedies under applicable anti-SLAPP laws, including both the Texas Citizens Participation Act (Tex. Civ. Prac. & Rem. Code Ch. 27) and the Florida anti-SLAPP statute (Fla. Stat. § 768.295), and any other analogous statute of any jurisdiction in which a claim is brought. These include early dismissal, stays of discovery, mandatory fee-shifting and costs, sanctions, and expedited/interlocutory appeal rights, to the fullest extent available.
Prior restraint. We oppose prior restraints on speech as presumptively unconstitutional. Any party seeking a temporary restraining order, injunction, or other relief affecting our publication or speech must, to the maximum extent permitted by law, post a bond or security adequate to secure our damages, costs, and attorneys’ fees if that relief is later dissolved or vacated.
3) Editorial standards & good-faith basis
Evidence-first. We favor primary documents, data, official proceedings, and on-the-record sources, and we link or cite to source material so readers can independently evaluate the basis for our statements.
Good faith. We publish in good faith on matters of public concern, based on sources we reasonably believe to be reliable, and without knowledge of falsity or reckless disregard for the truth. This reflects our editorial practice; it is not a warranty of accuracy and creates no duty enforceable by any person.
Labeling. Posts may be labeled Reporting, Analysis, or Opinion, and individual items may be marked Allegation or From the Record where relevant.
Context & updates. We strive for accuracy and context and will correct or update the record when warranted. Content can become outdated as proceedings evolve; statements speak as of their publication date. Links to third-party materials are provided for context and do not imply endorsement.
Community conduct. We moderate comments, Chat, and Notes to maintain safety and civility. Harassment, doxxing, threats, and illegal content are prohibited.
4) Corrections, Retractions & Notice-of-Concern (mandatory pre-suit request)
This is a required step before any lawsuit. If you contend specific content is inaccurate, misleading, unlawfully defamatory, or unlawfully invasive of privacy, you must first submit a written Notice-of-Concern so we can review it in good faith. This requirement is intended to invoke and operate together with:
Florida’s pre-suit notice statute, Fla. Stat. § 770.01, which requires a person, at least five (5) days before filing any civil action for libel or slander against a newspaper, periodical, or other medium (including online news and public-commentary publishers), to serve written notice specifying the article or broadcast and the statements alleged to be false. PAG Project is a medium of news and public comment within the meaning of that statute;
Florida’s retraction statute, Fla. Stat. § 770.02, under which a good-faith correction or retraction may limit recovery to actual damages; and
The Texas Defamation Mitigation Act, Tex. Civ. Prac. & Rem. Code §§ 73.051–73.062, under which a person who fails to make a timely and sufficient request for correction, clarification, or retraction may not recover exemplary damages.
Send to (preferred): Review@pagproject.com — Subject line: NOTICE OF CONCERN Or by mail: PAG Project, LLC — 5900 Balcones Drive, STE 100, Austin, TX 78731
Your Notice must include:
The exact URL(s) or platform post link(s) and the verbatim quotation(s) at issue;
A particularized explanation of why each statement is false or unlawfully misleading (not merely unflattering);
The supporting facts and documents you believe establish falsity or required context; and
The precise correction, clarification, or retraction you seek, and why.
Our process. We will acknowledge receipt and review compliant Notices in good faith. Remedies, at our sole editorial discretion, may include a correction, clarification, added context, right-of-reply, update, or retraction. On third-party platforms, corrections may appear via an edit (where supported), a follow-up correction/clarification post, or a link to an updated explainer. A correction or clarification is not an admission of liability, fault, or falsity. Notices that omit the required elements may be disregarded or returned for completion.
Transparency. We may publish the substance of your Notice and our response (with limited redactions for safety or legal compliance) to promote transparency about attempts to suppress or correct speech. Submitting a Notice creates no duty beyond our good-faith review, and we reserve all defenses and privileges.
5) User submissions & third-party material
We may host community comments and link to or quote third-party material. Responsibility for third-party statements remains with their authors. Shares, embeds, and links are provided for reporting and commentary and do not imply endorsement. To the fullest extent permitted by law, we claim the protections of 47 U.S.C. § 230 for content provided by others and for good-faith moderation, restriction, or removal decisions.
Tips and documents you submit are non-confidential unless we expressly agree otherwise in a signed writing. Do not send material you are legally barred from sharing or that was illegally obtained. You represent that you have the right to share what you send and that doing so violates no law, court order, or third-party right.
6) No professional advice; reliance & risk
All content is provided for general information and public-interest journalism. You should not rely on it for legal, tax, accounting, or investment decisions, and nothing here is a recommendation to buy, sell, or hold any security. Consult your own licensed professionals who know your specific circumstances. Your use of our content is at your own risk.
7) Intellectual property
© PAG Project, LLC. All rights reserved. Our original content may not be scraped, bulk-downloaded, systematically archived, republished, redistributed, paywall-bypassed, or used to train, fine-tune, or evaluate AI or machine-learning models, or to build derivative or competing datasets, without our prior written consent. “Private Attorney General Project” and “PAG Project” are brand names of PAG Project, LLC. Other logos and trademarks remain the property of their respective owners. All rights not expressly granted are reserved.
8) Governing law; venue; reservation of all defenses
Primary forum and law. To the maximum extent permitted by law, this Policy and any claim or dispute arising out of or relating to our content or the Channels — whether sounding in contract, tort, or statute — are governed by Texas law and applicable U.S. federal law, without regard to conflict-of-laws principles, and our preferred and (as to anyone bound by our Terms of Use) exclusive forum is Travis County, Texas, as further provided in our Terms of Use (including its arbitration agreement, exclusive-forum provision, and the cascade described there). The parties intend Texas’s speech-protective laws, including the Texas Citizens Participation Act (Ch. 27), to apply as substantive law in any forum to the fullest extent permitted.
Fallback (cascade). If a court determines that Texas law or the Texas forum does not govern a particular claim or claimant, then Texas substantive law shall apply to the greatest extent permitted; and to the extent it is held not to apply, the law of the jurisdiction with the most significant relationship governs, and we reserve and will assert every speech-protective law and remedy available there — expressly including, without limitation, Florida’s anti-SLAPP statute (Fla. Stat. § 768.295) and Florida’s pre-suit-notice and retraction statutes (Fla. Stat. §§ 770.01–770.02) — together with applicable federal law. This is a reservation of protections, not a waiver of any of them, and shall never be read to waive any non-waivable right.
Without limiting the foregoing, we reserve and assert all privileges and defenses available to journalists, publishers, and petitioners, including: truth and substantial truth; opinion, fair comment, and rhetorical hyperbole; the fair-report and official-proceedings privilege; the First Amendment and the constitutional actual-malice standard for public officials and public figures; the Noerr-Pennington doctrine and the right to petition; reporter’s privilege; the anti-SLAPP statutes of Texas (Ch. 27) and Florida (§ 768.295) and any analogous law; the pre-suit notice and retraction statutes of Florida (§§ 770.01, 770.02) and Texas (§§ 73.051–73.062); the protections of 47 U.S.C. § 230; applicable statutes of limitations; and all applicable federal and state whistleblower and anti-retaliation protections. No defense, privilege, or immunity is waived, and assertion of one is not a waiver of any other.
Contact: Review@pagproject.com