the letter, TFH US indicated that they had ceased all orb sign-ups. However, that TFH US indicated that it had decided not to block the Worldcoin Mobile App or operator portal claiming that the 60-day delay was disproportionate. 45.That on 22nd August 2022, following the implementation of the Data Protection (Registration of Data Controllers and Data Processors) Regulations, TFH GmbH and TFH US applied for registration as a data controller and an invoice for payment on 24th August, 2022 was generated. That consequently, upon being prompted through the online systems, TFH GmbH was requested to submit proof of its annual turnover. However, that on 2nd September 2022, Bowmans is said to have informed the ODPC via email that TFH GmbH was a venture capital backed entity in its pre-revenue stage and that no revenue was being generated by it. 46.Similarly, that TFH US submitted its application for registration as a data controller on 29th August 2022 and was issued with an invoice for payment on the same day. However, that TFH US had not submitted its Profit & loss account information alongside its establishment documents as required by the Registration Regulations. The submission criteria, according to the 6th Respondent, is sequentially elaborate in ODPC’s system and as such, an applicant can establish the required documentation from the successive prompts in the application system. Consequently, that TFH US’s application process was Page 18 of 84

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