Qooore is an SEC registered investment adviser formed in January 2022. The Firm is principally owned by Stanislav Khudiakov, Igor Sheremet, Timofey Tkachenko, and Kowa Capital Limited, each through their ownership of the Firm’s parent company, Qooore Corp. (“Qooore Parent”) Qooore offers its investment advisory services through a mobile application (“the Mobile App”) which is available through the App Store (Apple) and Google Play (Android). The Firm provides personal and impersonal investment advice exclusively through a software application that is available in the Mobile App and does not generally provide investment advice in person, over the phone, in live chat, or in any manner other than through the Mobile App. The Firm maintains an online presence through www.qooore.com, primarily for informational purposes. The Mobile App is operated by both Qooore and its parent company, Qooore Parent. Through the Mobile App, Qooore Parent allows persons to subscribe to the content of “Content Creators,” users of the Mobile App who regularly create and publish investment-related commentary to subscribers, as described in further detail later in this Brochure. This subscription service is provided by Qooore Parent only, and is not provided by Qooore. The subscription process is described in this Brochure solely for the purpose of providing background information regarding Qooore’s advisory services, which operate in conjunction with, but are separate from, the publishing services provided by Qooore Parent. Neither the Content Creators nor Qooore Parent provide investment advice, and neither are registered investment advisers. Once a person subscribes to one or more Content Creators through the Mobile App, they may then choose to also create a securities portfolio derived from the portfolios of certain Content Creators to which the person has subscribed, provided that they meet Qooore’s advisory Client-screening criteria, as discussed further herein. A person becomes an advisory Client of Qooore (“Client”), and will receive its advisory services, only once they (1) indicate a desire to create a Content Creator-derived portfolio and (2) Qooore determines that the person meets its screening criteria, and (3) the person enters into an investment advisory agreement (“Advisory Agreement”) with Qooore. For the avoidance of doubt, Clients include only those persons who receive Qooore’s advisory services. Individuals who subscribe to one or more Content Creators through the Mobile App (a “Subscriber”) may or may not also be a Client of Qooore, depending upon whether or not the individual Subscriber wants to engage Qooore’s advisory services and subsequently satisfies Qooore’s criteria to become a Client, as discussed above. When an individual first seeks to subscribe to a Content Creator’s content, they will be asked to create an account with Qooore Parent through the Mobile App. If a subscriber also wishes to receive Qooore’s advisory services, they will then have to apply to create a separate account with Qooore, known as the advisory account. As part of the application process for the advisory account, individuals will be asked to provide certain information about themselves. Specifically, when a person applies for an advisory account, he or she is prompted to complete a series of questions and provide certain information, including (but not limited to) information relevant to his or herinvestment interests and objectives, risk profile and tolerance and investment experience, in order to establish their individual profile (the “Client Profile”). Qooore provides Clients with a classification of their investment profile that is intended to reflect the Client’s risk tolerance and their investment goals, and is intended to help individuals decide whether they wish to establish a portfolio derived from a certain Content Creator. This “investor classification” is based on the Client Profile, as discussed above. Although Clients may choose to establish a Content Creator-derived portfolio from any Content Creator to which they subscribe, if there is substantial divergence between a Client’s investor classification and a certain Content Creator’s “risk score,” Qooore will notify the Client of this divergence via a dialogue box in the Mobile App, and the Client is notified of this risk before the Client creates a portfolio derived from that Content Creator Once a Client has determined to follow one or more Content Creators through the Mobile App, Qooore’s advice to Clients consists of developing an investment portfolio for Clients derived from certain holdings of certain Content Creators to which they subscribe. Qooore Clients’ portfolios are maintained in brokerage accounts in each Client’s name at an unaffiliated custodian, Alpaca Securities LLC (“Alpaca”). Alpaca is a SEC-registered brokerage firm that is also a member of, and regulated by, the Financial Industry Regulatory Authority, Inc. (“FINRA”) and a member of the Securities Investor Protection Corporation (“SIPC”). Qooore is not affiliated with Alpaca. Qooore has entered into an agreement with Alpaca that permits Qooore’s Clients to trade securities as provided above. As part of the process of opening an account with the Alpaca, a Client must instruct the Alpaca, in writing, to allow Qooore the ability to submit trade orders and instructions on behalf of its Clients. On each trading day, Qooore takes the following steps to create and maintain each Client’s securities portfolio:
• Qooore identifies the securities holdings in the relevant Content Creator’s portfolio, which are referred to as the Content Creator’s “Raw Holdings.” Each time a Content Creator adds or removes a security in its Raw Holdings, Qooore will receive this trade information and the updated Raw Holdings shortly thereafter.
• The Content Creator’s Raw

Holdings are then filtered to eliminate all positions other than cash positions, long-only positions in stocks and exchange-traded funds (also known as “ETFs,” which term is inclusive of exchange-traded notes) listed on the New York Stock Exchange, the Nasdaq, or other U.S. securities exchanges that also (1) meet a certain market capitalization threshold and (2) are available for fractional trading through Alpaca. The resulting positions are referred to as the “Filtered Holdings.”
• The resulting portfolio consisting of the Filtered Holdings is referred to as the Target Portfolio. In order to more closely approximate the Content Creator’s portfolio, the Target Portfolio is priced using then-current market prices each time trade instructions are issued for an individual Client’s account and takes place shortly before Qooore issues trade instructions for that individual Client account. However, Qooore cannot guarantee that this process may not be delayed for a variety of reasons, whether within its control or otherwise.
• Qooore then issues trading orders for Clients’ securities portfolio accounts for execution and alignment with the Target Portfolio such that Clients’ portfolios hold securities in approximately the same ratios as that of the Target Portfolio. Additionally, prior to the issuance of trade execution orders for each specific Client account, Qooore will re-price the Target Portfolio to then current market prices in order to maintain the securities weight ratios established in the initial Target Portfolio. It is anticipated that trade execution orders will be issued as close in time as practicable to the pricing process and the creation of the relevant Target Portfolio. However, Qooore will not initiate a position in a Client account derived from the Target Portfolio if the ratio applied to the Client account results in the position being valued by the Alpaca as less than 10 cents. Qooore issues Client trade execution orders on a randomized basis; at the time of each execution cycle, the process randomly assigns a trading order to all Clients’ trades so that no Client is any more likely than another to have a favored execution position. Clients should understand that, to the extent Clients’ trades are executed sequentially, the lack of order aggregation means that some Clients are likely to get more favorable trade prices and some less favorable. However, it is expected that, over time, the random assignment process should address some of the variability in pricing among Clients. Qooore will monitor the dispersion between the Proxy Account and corresponding Client accounts and periodically rebalance to account for items that were not accounted for during daily trading operations. It should be understood that no trade execution orders will be issued for a Client’s securities portfolio unless one or more of the following conditions are met (or other conditions are met supporting a need for trade execution in the relevant account):
• The Filtered Holdings (other than cash positions) have changed from the immediately prior Filtered Holdings;
• The Client is allocating additional funds to the Client’s securities portfolio;
• The Client seeks to liquidate some, or all funds currently allocated to the Client’s securities portfolio; or
• The Client’s portfolio has not been re-aligned for a specified period of time determined by Qooore. Upon termination of a Client’s subscription with a Content Creator, Qooore Parent will notify Qooore, and Qooore will cause the Client’s account to cease tracking the Content Creator-derived portfolio associated with that Content Creator. The Client’s holdings related to that Content Creator-derived portfolio will be sold and the cash proceeds will be returned to the Client for reengagement in the app or for transfer to their linked banking account. Likewise, upon termination of a Client’s advisory relationship with Qooore (including termination due to the Client’s decision or non-payment of subscription fees), Qooore will no longer issue trading instructions on the Client’s behalf to the Alpaca, and the Client’s holdings related to that Content Creator-derived portfolio will be sold and the cash proceeds will be returned to the Client for reengagement in the app or for transfer to their linked banking account. Terminated advisory Clients, or individuals who are otherwise not active subscribers, will not be able to trade in their brokerage accounts at will through the Mobile App. In such an event, Clients will receive an electronic notification from Qooore or Qooore Parent, as appropriate, describing this change in the operation of their account. However, if a Client no longer wishes to maintain a portfolio derived from a certain Content Creator, provided that the Client has remained current on its subscription fees the Client may terminate securities trading derived from that Content Creator, but retain the Client’s subscription to that Content Creators’ content through Qooore Parent. Qooore’s investment advice is highly dependent on receiving accurate information from Clients, as the Firm’s recommendations to Clients are solely based on information provided by the Client though the App Profile in the Mobile App. If Clients provide Qooore with inaccurate information or fail to update promptly information provided to Qooore when it becomes inaccurate, the suitability of Qooore’s advice could be materially impacted. Clients are advised that Qooore does not provide comprehensive financial or tax planning or legal advice. Clients should seek the advice and counsel of their own tax, financial, and legal advisers. Clients are further advised that Qooore does not offer a complete investment program and Clients should not use it recommendations as the sole component of their investment plan. Qooore does not participate in wrap fee programs. Qooore does not have assets under management as of the date of this Brochure.