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Legal Consultation Memo

Performance Program Agreement — Risk Assessment & Strategy
January 3, 2026
Re: Texas E-Commerce Brand Dispute

Executive Summary

Your contract has strong defensive provisions (no-refund, Danish venue) but contains performance-sounding promises that create vulnerability. The primary risk is chargebacks, not litigation.

HIGH
Chargeback Risk
MEDIUM-LOW
Litigation Risk (if delivered)

Key Issues Overview

Core Problem: The contract simultaneously says "no refunds" while also marketing ROI/ROAS/profitability. This contradiction is exactly what opponents exploit.
Critical Performance Promises in Contract

Your agreement includes language that can be characterized as performance guarantees:

Section 4(E) — "Free Until Profitability"
"If the Client is not profitable within 90 days, the Company will continue working with them free of charge until profitability is achieved."

This creates an open-ended obligation tied to undefined "profitability" — potentially indefinite.

Section 4(F) — ROAS Representations
"Expected ROAS ranges from 3-8X" ... "Typical performance data suggests 60 orders per video."

Even with caveats, these are exactly what dissatisfied clients cite as implied performance guarantees.

Page 2 — "Perfect Fit" Promise
"Within one week you'll have pre-negotiated influencers who are a perfect fit."

Factual promise that can frame a "not as described" claim.

High Chargeback Vulnerability

Card networks don't adjudicate Danish law. They ask: "Did the merchant provide what was purchased, as described?"

Why This Contract is a Chargeback Magnet:

  • Requires credit card payment with "no credit card transaction fees" (Section 4(A))
  • Large B2B invoices on card = high dispute exposure
  • ROAS/profitability language gives issuers ammunition for "not as described"
  • No formal acceptance mechanics = ambiguous "services provided"
Medium Scope Vagueness

The "Work to be performed" list is broad and lacks:

  • Tight deliverables schedule with dates
  • Acceptance/rejection mechanics
  • Cure provisions
  • "Deemed accepted" triggers

This vagueness increases chargeback risk because issuers look for clear proof of "services provided as described."

Contract Strengths

You have three strong "first line" defenses on paper:

Strong No-Refund / Final Payment

Section 4(C)
"All payment is final and no refunds... under any circumstances."

This is unambiguous and enforceable in contract law. However, it doesn't bind card network dispute processes.

Strong Exclusive Danish Forum + Law

Section 10(C)
"Any suit... must be instituted in Glostrup District Court, under Danish law."

Effect: Meaningful deterrent and strong basis to seek dismissal/stay of a Texas action via forum-selection + forum non conveniens.

Helpful Chargeback Waiver Language

Signature Block
Express waiver of "any rights to charge-back."

Limitations: Won't stop an issuer from processing a chargeback, but helpful for:

  • Representment narrative to processor
  • Later collection if chargeback succeeds

Contract Vulnerabilities

These are the "plaintiff lawyer paragraphs" — the hooks a Texas client will use:

Issue Location Risk Level Plaintiff's Argument
"Free until profitability" Section 4(E) Critical "You promised profitability as part of the service"
ROAS 3-8X representation Section 4(F) Critical "You represented specific ROI expectations"
"60 orders per video" Section 4(F) Critical "You set specific performance benchmarks"
"Perfect fit" influencers Page 2 High "Influencers were not a fit for our brand"
Vague deliverables Work Description High "Services not provided as described"
No acceptance mechanics Entire Agreement Medium "We never approved the deliverables"
The Core Contradiction: Your contract markets ROI/ROAS/profitability while also saying "no refunds." This internal inconsistency is exploitable.

Chargeback Defense Strategy

Understanding Chargeback Reality

Key insight: Winning in court and winning a chargeback are different games. You can be 100% right contractually and still lose a chargeback if your evidence trail is sloppy.

Common Chargeback Reason Codes They'll Try:

  • Services not provided / not received
  • Not as described / defective (most likely)
  • Canceled recurring / continued billing
  • Misrepresentation (functionally "not as described")

Card networks don't apply Danish law. They apply network/processor rules, and issuer bias often favors the cardholder.

Building Your Winning Evidence Packet

Create a single PDF bundle with index containing:

1
Executed Agreement + Onboarding

Full signed contract, any scope confirmation emails

2
Deliverables Table

Contract item mapped to: Delivered Date | Evidence Reference

3
Proof of Delivery

Influencer lists, outreach logs, campaign briefs, content links, posts live (screenshots), ad setup, optimization notes

4
Client Approvals & Instructions

"Looks good," "approved," "go live," "increase budget" — any continued direction

5
Short Narrative

Deliverables delivered; results depend on market conditions; no refund per Section 4(C)

Future Prevention: Payment Architecture

The Single Biggest Risk Reducer:

Move away from card funding for large invoices.

Do This

  • Prefer wire/ACH for main fee
  • If card: cap to small onboarding fee only
  • Add processing fee for card payments
  • Require 3DS authentication
  • Add chargeback cost reimbursement clause

Avoid This

  • Full program fees on credit card
  • "No credit card transaction fees" (current contract)
  • Large B2B invoices without wire option

Litigation Strategy

Can They Sue in Texas?

Yes, they can file. The question is whether they can keep it there.

Your Procedural Response:

  1. Motion to dismiss/stay based on mandatory exclusive Danish forum clause
  2. Forum non conveniens argument
  3. Personal jurisdiction defense if DK agency didn't purposefully avail itself in TX
Section 10(C) — Your Shield
"Any suit... must be instituted in Glostrup District Court"

US courts (including Texas federal courts) often enforce forum-selection clauses in commercial contracts absent fraud/overreaching/public policy issues.

Claims They'll Threaten
Claim Type Their Argument Your Defense
Breach of Contract "You didn't deliver X / Y" Deliverables table + proof of delivery
Misrepresentation / Fraud "You promised ROI / ROAS" Performance disclaimers; marketing puffery
Deceptive Trade Practices Texas DTPA claims B2B exemption; Danish law governs
Unjust Enrichment Dodge contract terms Contract governs; no quasi-contract claim

Your Best Defense Posture:

Box the case into contract performance:

  • Deliverables were provided as specified
  • Contract disclaimed performance guarantees
  • Outcomes depend on variables outside your control
  • Client had approval/acceptance opportunities
  • Any "marketing puffery" is non-actionable
Practical Reality Check
The Real Risk: Not "losing on the merits" (if you truly delivered) but cost/friction: early motion practice, potential discovery fights, and reputational pressure.

Your Danish venue clause is a strong deterrent, but assume a motivated Texas client can still force you to spend money on an early procedural response unless you settle.

Contract Fixes for Future Agreements

If you want "deliverables-based, not performance-guaranteed," the agreement must be internally consistent.

Priority 1 Delete/Rewrite Section 4(E)

Current Language (Problematic):

"If the Client is not profitable within 90 days, the Company will continue working with them free of charge until profitability is achieved."

Recommended Replacement:

"If Client does not achieve [specific metric] within 90 days of campaign launch, Company will provide up to [X] additional optimization hours at no charge. This make-good is Client's sole remedy and is expressly not tied to any guarantee of profitability, revenue, or ROI."

Priority 1 Remove ROAS/Order Representations

Current Language (Problematic):

"Expected ROAS ranges from 3-8X" ... "Typical performance data suggests 60 orders per video."

Options:

Option A: Remove Entirely

Delete all specific performance projections from the contract.

Option B: Separate Exhibit

Move to non-binding "Case Studies" exhibit with bold disclaimer: "NOT TYPICAL / NOT A PROMISE / NOT RELIED UPON"

Priority 2 Add Acceptance Mechanics

Add These Provisions:

  • Milestone Acceptance: "Deemed accepted within 5 business days unless specific written defects are provided"
  • Cure Limitation: "Cure limited to re-performance of the specific nonconforming deliverable"
  • Final Acceptance: "Upon term completion, Client waives claims based on then-known facts"
Priority 2 Tighten SOW into Schedule

Replace Vague "Work to be Performed" with:

Deliverable Due Date Acceptance Period
Influencer Discovery List (X creators) Week 1 3 business days
Campaign Brief Week 2 3 business days
Content Approval Rounds (Y rounds) Weeks 3-4 2 business days each
Campaign Go-Live Week 5 N/A
Performance Reports Weekly Informational only
Priority 3 Strengthen Dispute/Chargeback Clause

Add to Agreement:

Dispute Resolution:

  • Chargeback initiation = material breach
  • Client remains liable for all fees regardless of chargeback outcome
  • Client responsible for collection costs + attorney fees
  • Exclusive forum (Glostrup) applies to collection claims
  • Interest on chargebacked/overdue amounts at [X]% annually

Note: This won't stop Visa/Mastercard from processing a chargeback, but strengthens post-chargeback collection position.

Priority 3 Add Cooperation/Dependency Clause

Make Outcomes Conditioned on Client Inputs:

"Client acknowledges that campaign performance depends on Client's timely provision of:

  • Access to ad accounts, product feeds, landing pages
  • Timely content/creative approvals
  • Adequate inventory and competitive pricing
  • Proper attribution/tracking setup

If Client delays approvals or access, timelines shift and fees remain due."

Immediate Action Items

Right Now: Build the Dispute Packet

This doubles as chargeback representment evidence.

1
Executed agreement + exhibits/SOW
2
Deliverables checklist mapped to contract sections
3
Proof of delivery per deliverable (links/screenshots/timestamps)
4
Client approvals/confirmations (emails, Slack, etc.)
5
Performance-disclaimer language from all communications
6
Invoices + payment confirmations
7
Complete timeline (signing -> kickoff -> milestones -> complaint)

Send Structured Response to Client

Your response should accomplish three things:

  1. Confirm full performance with deliverables table (contract item | delivered date | evidence)
  2. Reject refund demand citing Section 4(C) "all payments final/no refunds"
  3. Put venue on the table — any dispute must be brought in Glostrup under Danish law; TX filing will be met with procedural response

Commercial Off-Ramp (Optional)

If you want to preserve the relationship or avoid chargeback risk:

Offer credit (not refund) conditioned on:

  • Release of all claims
  • Non-disparagement covenant
  • No chargeback covenant
  • Confirmation of delivery/acceptance through end of term

If Chargeback Is Imminent

  • Notify processor now and ask what format they want for representment
  • Gather transaction data: IDs, descriptor, authorization evidence, 3DS/AVS/CVV results
  • Send preservation notice: "Disputes must go through contract mechanism; chargebacks are unauthorized per agreement; client remains liable for fees/costs"
Next Step: If you have the client's actual threat email or summary of their allegations (e.g., "you promised 3-8x ROAS," "not profitable," "influencers weren't a fit"), we can draft a tight response that (i) deters chargeback, (ii) frames performance as "delivered as described," and (iii) tees up venue dismissal if they file in Texas.

Draft Response to Client

Edit the response below as needed, then click "Copy to Clipboard" to paste into your email client.

Sarah, I'm in receipt of your email. We dispute that any amount is owed to you. Under the Performance Program Agreement dated March 6, 2025, Section 10(C) (Governing Law; Forum; Jurisdiction) provides that the agreement is governed by Danish law and that "any legal proceeding relating to this Agreement must be instituted" exclusively in the District Court of Glostrup (Glostrup Byret). Accordingly, Texas Justice Court is an improper venue for any claim arising out of the agreement, and we would promptly challenge any Texas filing based on Section 10(C). Separately, Section 4(C) (No Refunds) states that "all payment is final and no refunds" are available. We delivered the contracted services during the 90-day term. If you contend otherwise, please identify (i) the specific contractual deliverable you claim was not provided, (ii) the relevant contract section(s), and (iii) the facts supporting your claim so we can evaluate and respond substantively. Regards, Tristan