# cloud-itonami — Operator Record Last updated: 2026-07-24 ## Service operator - Legal name: **AWAI Network, L.L.C.** - Entity type: Delaware limited liability company - Formation date: July 20, 2026 - Delaware file number: **10704996** - EIN: pending; not published - Same entity as cloud-murakumo's operator (see `cloud-murakumo`'s own `public/legal/company.md`) — no separate LLC was formed for cloud-itonami; AWAI Network, L.L.C. now operates both 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 cloud-itonami and itonami.cloud. Gftd Japan 株式会社 supplies infrastructure and software (Cloudflare Pages/Workers/KV 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 Unlike cloud-murakumo (no live paid transactions at the time AWAI Network was named its operator), cloud-itonami already has a live commercial surface (4 self-registered external tenants, live Stripe Payment Links across the flagship cohort, `hyp/itonami-smb-pay` gate open) at the time this operator change was made. The following are real, unresolved gaps, not template boilerplate. 2026-07-24 update: each item below now carries informational research with cited public sources (NOT legal advice — every item still needs actual counsel sign-off before being relied on) rather than being merely flagged as unassessed. - **Stripe merchant of record — still open, drafting in progress.** The live Stripe account processing itonami's Payment Links remains registered under **Gftd Japan 株式会社**, not AWAI Network, L.L.C. (`docs/deployment-secrets.md`, `src/cloud_itonami/edge/billing.cljc`). This record names AWAI Network as the Service operator/contracting party, but the entity actually receiving and processing customer payment is still Gftd Japan's Stripe account. Do not represent to a prospective paying customer that AWAI Network is the Stripe merchant of record until either (a) the Stripe account is re-papered to AWAI Network (requires real KYC/business-verification documents this repo does not hold — an owner action, not an agent-executable one), or (b) a documented agency/undisclosed-principal arrangement between AWAI Network and Gftd Japan covering payment collection is put in writing. A DRAFT of (b), `legal/payment-collection-agency-agreement.md`, was added 2026-07-24 — it still needs real execution (signature by an authorized person for each party) before it resolves anything; an unsigned draft sitting in a git repo does not itself create a binding agency relationship. - **Foreign-company registration in Japan — likely required, not merely open.** Research (Companies Act Article 818(1); see [Lexology: Regulation of Continuous Transactions by Foreign Companies in Japan](https://www.lexology.com/library/detail.aspx?g=fa397687-880b-490d-bf82-1193b12a9058), [Global Compliance News, 2022 MOJ enforcement notices to foreign IT providers](https://www.globalcompliancenews.com/2022/05/21/japan-the-ministry-of-justices-recent-notice-to-tech-giants-may-affect-tax-and-business-planning-in-japan-for-all-overseas-businesses-02052022/)) indicates registration (and appointment of at least one Japan-resident representative) is required once a foreign company "continuously conducts transactional activities targeting Japanese customers via internet... (e.g. soliciting Japanese customers by creating an easily accessible website in the Japanese language)" — physical presence in Japan is explicitly NOT a precondition. cloud-itonami's own ToS (Japan governing law, Tokyo court jurisdiction, JPY billing, Japanese-language site content) plausibly meets this description as an ongoing subscription business, not a one-off/incidental transaction (the statutory exemption). The Ministry of Justice's March 2022 notices to 48 foreign IT providers signal active (not merely theoretical) enforcement of this requirement. **This is now the single highest-priority open item** — registering also creates a potential Japan permanent-establishment (PE) tax-exposure question that itself needs analysis before appointing a representative, per the same source. Counsel engagement, not further agent research, is the correct next step. - **Consumption tax / invoice-system registration — likely NOT required, narrower than first flagged.** Research ([National Tax Agency guidance on cross-border services](https://www.nta.go.jp/english/taxes/consumption_tax/cross-kokugai-en.pdf); see also the B2B reverse-charge summaries at [Anrok](https://www.anrok.com/vat-software-digital-services/japan) and [Mochizuki & Associates](https://www.mochizuki-associates.com/en/blog/corporation-3/is-there-a-reverse-charge-mechanism-for-cross-border-services-in-japan-33)) indicates Japan's B2B reverse-charge mechanism applies to business-purpose digital services from a foreign provider: the foreign provider does not register for or collect Japanese consumption tax; the Japan-resident business customer self-assesses instead. cloud-itonami's ToS already states the Service is "offered to businesses (\"Customer\") and is not intended for consumers" (Section 1), so this narrower B2B regime — not the B2C foreign-provider registration regime — is the one that plausibly applies. One concrete gap the research surfaced: Japan requires the foreign B2B provider to **notify the customer in advance that the customer, not the provider, is liable for consumption tax** under the reverse-charge mechanism — `legal/terms.md` Section 6 has been updated with a first-pass notice reflecting this (2026-07-24), still DRAFT/counsel-review-required like the rest of this document. - **APPI cross-border provision — citation corrected, and this is a narrower/different question than first flagged.** The 2026-07-24 first pass of this document cited "APPI Article 24 (overseas third-party provision)," which is the WRONG provision for this situation: Article 28 (formerly numbered differently pre-2022 amendment) governs a *domestic* business transferring data TO a foreign third party — that is not what is happening here. The applicable provision is **APPI Article 171** (extraterritorial application): the Act applies directly to a foreign business handling the personal information of individuals located in Japan, where that handling is in connection with providing goods/services to persons in Japan — regardless of whether the business entity is domestic or foreign (source: [Global Investigations Review, Japan data protection in cross-border investigations](https://globalinvestigationsreview.com/guide/the-guide-cyber-investigations/fourth-edition/article/japan-data-protection-in-cross-border-investigations)). Practically this means AWAI Network, as the new (foreign) controller, is directly and substantively bound by APPI's obligations toward cloud-itonami's Japan-based data subjects — the same substantive obligations `legal/privacy.md` already describes under "APPI (Japan)" — rather than needing a separate cross-border-transfer consent flow. This is a genuinely simpler finding than originally flagged, but the extraterritorial-application nuance (and whether the Privacy Policy's existing APPI section fully covers a foreign-organized controller) still has not been reviewed by counsel. - Principal place of business and customer notice address (same open item as murakumo's own operator record). - US federal/state tax registrations after EIN issuance. - Replacement of the temporary operational contact with an AWAI-controlled email/domain. ## Explicitly out of scope / not a gap - **itad.gftd.ai** (Gftd Japan's own regulatory license-tracking application) and the **gftd.ai** site are Gftd Japan 株式会社's own operations, unrelated to cloud-itonami's operator identity, and are unaffected by this change (owner confirmation, 2026-07-24).