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app-aozora — Operator Record

Last updated: 2026-07-28

Owner instruction on 2026-07-28: AWAI Network, L.L.C. is the Service operator and contracting party for app-aozora (`aozora.app`) and its messenger companion app-aozora-yoro, replacing Gftd Japan 株式会社. This document records the operator identity; it does not resolve the registration, tax, or consumer-law items listed under "Known gaps" below.

Service operator

  • Legal name: AWAI Network, L.L.C.
  • Entity type: Delaware limited liability company
  • Formed through: Stripe Atlas
  • Formation date: July 20, 2026
  • Delaware file number: 10704996
  • EIN: pending; not published
  • Same entity as cloud-murakumo's and cloud-itonami's operator (see those repositories' own legal/company.md / public/legal/company.md) — no separate LLC was formed for app-aozora. AWAI Network, L.L.C. now operates all three services.

Delaware registered agent

  • Registered agent: Legalinc Corporate Services Inc.
  • Registered office: 131 Continental Dr, Suite 305, Newark, DE 19713, United States
  • Registered-agent service term supplied by the company owner: active through July 20, 2027

The registered office is maintained for statutory registered-agent and service of process purposes. It is not recorded here as the Operator's principal place of business, mailing address or customer-support office.

Operating relationship

AWAI Network, L.L.C. is the operator of app-aozora and aozora.app, including the atproto Personal Data Server (PDS), AppView, XRPC adapters and public Workers this repository deploys, and the yoro messenger surface served under the same domain. Gftd Japan 株式会社 supplies infrastructure and software (Cloudflare Workers/Pages hosting, kotobase persistence, development) but is not the Service operator unless a separate agreement expressly says otherwise.

Operational contact pending a dedicated AWAI address: hello@gftd.co.jp.

Known gaps — items requiring counsel/owner completion

app-aozora differs from the two prior AWAI operator changes in one way that matters: cloud-murakumo had no live paid transactions and cloud-itonami is a B2B service whose ToS states it "is not intended for consumers." app-aozora is a consumer-facing social network with a Japanese-language surface, Japan governing law, and Tokyo court jurisdiction. Consumer-protection and data-protection questions therefore land harder here than in either precedent, even though app-aozora has no paid surface at all today (no Stripe integration, no subscription or price terms anywhere in legal/terms.md), which keeps the payment-related gaps that dominate cloud-itonami's record inapplicable for now.

The items below are real and unresolved. None has been reviewed by counsel.

  • Foreign-company registration in Japan — likely required. Companies Act Article 818(1) requires a foreign company that continuously conducts transactional activities in Japan to register and appoint at least one Japan-resident representative; physical presence in Japan is explicitly not a precondition, and soliciting Japanese customers through an easily-accessible Japanese-language website is the paradigm case (the same research cited in cloud-itonami's legal/company.md, including the Ministry of Justice's March 2022 notices to 48 foreign IT providers). app-aozora's ToS elects Japanese law and Tokyo jurisdiction and the service is offered in Japanese, so the same analysis applies here. Whether a free consumer service constitutes "transactional activities" (取引を継続してしようとする) is the open sub-question that distinguishes this from cloud-itonami's paid-subscription case — it is a genuine question, not a reason to assume the requirement does not apply. Registration also raises a Japan permanent-establishment tax question. Counsel engagement is the correct next step.
  • Consumer contracts under a foreign operator. legal/terms.md §16 still elects Japanese law and the Tokyo District Court "subject to any mandatory consumer-protection rules that grant you a different forum." That carve-out was drafted when the Operator was a Japanese company. With a Delaware LLC as Operator, the interaction between the chosen forum, Japan's 消費者契約法 / Act on General Rules for Application of Laws Art. 11, and any US-side consumer rules has not been assessed. The governing-law clause was not changed by this operator change — changing it is a counsel decision.
  • APPI extraterritorial application (Art. 171). APPI binds a foreign business handling the personal information of individuals in Japan in connection with providing services to them, regardless of where the business is organized. AWAI Network, L.L.C. as the new (foreign) controller is therefore directly bound by the obligations legal/privacy.md already describes — this is not a cross-border-transfer consent problem. Whether the Privacy Policy's existing APPI section fully covers a foreign-organized controller has not been reviewed.
  • DMCA designated agent — newly concrete, previously abstract. legal/terms.md §8 carries a standing [DECISION NEEDED] for the copyright/DMCA agent. A US-organized operator makes 17 U.S.C. §512 safe harbour concretely relevant, and §512(c)(2) conditions it on designating an agent with the US Copyright Office (a filing with a fee, plus the same contact published on the service). This gap did not change status because of the operator change, but its answer did: it is now a US filing question with a real benefit attached, not just a contact-address question.
  • GDPR Art. 27 representative remains "not designated" in both privacy policies. The Operator was already outside the EU/UK before this change, so the obligation is unchanged — but the change does not resolve it either.
  • Age gate. Both privacy policies record that no age gate exists anywhere in account creation. COPPA (US) exposure is more directly relevant with a US operator. Unchanged by this ADR, still open, still an engineering follow-up once decided.
  • Principal place of business and customer notice address (same open item as cloud-murakumo's and cloud-itonami's operator records).
  • US federal/state tax registrations after EIN issuance.
  • Replacement of the temporary operational contact (hello@gftd.co.jp) with an AWAI-controlled email/domain.

Explicitly out of scope

  • gftd.co.jp / gftd.ai and Gftd Japan 株式会社's own operations are unaffected by this change. Gftd Japan remains the infrastructure/software supplier for app-aozora.
  • No change is made to account identity, DIDs, atproto federation, or data location by this record. It changes who the legal operator is, not how the service runs.