Ornn Data LLC, a Delaware limited liability company and wholly-owned subsidiary of Ornn AI Inc., serves as the administrator and index creator of the Ornn Compute Price Index (OCPI) and Ornn Token Price Index (OTPI). This statement is issued by Ornn Data LLC in its capacity as the indices' creator and administrator. It is intended to inform market participants, licensees, and any party referencing OCPI or OTPI in a financial instrument, data product, commercial contract, or investment decision of the material risks, limitations, and regulatory considerations associated with the benchmarks.
Ornn Data LLC retains primary and exclusive responsibility for the development, determination, dissemination, operation, and governance of OCPI and OTPI. The indices are calculated and published by Ornn Data LLC. No other entity, including any licensee, exchange partner, distribution platform, or Bloomberg Terminal subscriber, holds determination authority over either index. The published methodologies and official documentation made available by Ornn Data LLC constitute the authoritative specifications of how the indices are constructed.
OCPI Construction and Market Coverage
OCPI is anchored in anonymized executed transactions sourced from a global network of GPU compute providers. The index reflects the weighted mean of arm's-length spot rental prices for GPU compute capacity by GPU type, geographic region, and contract duration, calculated across an observation window and published on a regular settlement schedule. Because the index reflects actual executed trades rather than indicative quotes or voluntary submissions, the methodology is designed to resist manipulation.
Filtering procedures include verified counterparty checks, anti-wash-trade controls, minimum notional thresholds, and provider reliability controls. Statistical fitting and distributional procedures may be applied before computing the daily settlement value, as described in Ornn Data LLC's applicable methodology.
OTPI Construction and Market Coverage
OTPI is a family of transaction-based token price indices that track the realized market price of frontier-lab language-model tokens in U.S. dollars per million tokens. OTPI is organized by lab and currently tracks paid token usage across major lab model families, including OpenAI, Anthropic, and Google, as reflected in Ornn Data LLC's published data products.
Each OTPI value is designed to represent the token-volume-weighted average price actually paid across a lab's priced models over a completed daily observation window. The index incorporates same-day transacted prices, provider weights pooled across intraday routing samples, and same-day token volumes drawn from executed on-demand inference traffic. Cache discounts, model mix, input and output composition, and reasoning-token economics may be reflected in the transacted prices because OTPI is built from realized paid usage rather than posted rate cards.
Free variants, zero-price models, and open-weight models served by third-party hosts may be excluded where they do not represent paid lab token transactions within the relevant methodology. New models, labs, serving providers, and token classes may be added or removed under Ornn Data LLC's methodology and eligibility procedures.
Methodology Risk
Notwithstanding the design controls described above, OCPI and OTPI are subject to significant methodology risk. The accuracy, completeness, timeliness, and fitness for any particular purpose of either index are not guaranteed by Ornn Data LLC. Any index that summarizes a complex, evolving market in a single settlement figure necessarily involves methodological judgments that introduce model risk.
GPU compute markets are characterized by rapid structural change driven by new hardware generations, shifts in workload composition between training and inference, changes in energy pricing, export controls and geopolitical constraints on chip supply, and evolving market concentration among providers. The distribution of observed transaction prices may be multimodal or discontinuous under certain market conditions.
Token markets are also subject to structural change. OTPI may be affected by new model launches, migration between premium and lower-cost models, changes in lab pricing, shifts in serving-provider routing, cache-discount economics, reasoning intensity, input-output mix, changes in tokenization, and the relative volume of paid traffic across labs and models. Because OTPI measures realized token prices rather than posted rates, changes in buyer behavior and workload composition may move the index even when published rate cards do not change.
The construction methodologies for OCPI and OTPI are subject to revision in accordance with methodology change procedures published by Ornn Data LLC. Ornn Data LLC does not guarantee that either index will continue to be published, or that either index will continue to reflect the economic reality of its underlying market without amendment.
Market and Volatility Risk
The underlying market for GPU compute capacity is nascent, illiquid in certain regional and contract-duration segments, and subject to rapid and substantial price movements. OCPI values have in the past exhibited, and may in the future exhibit, significant intraday and inter-period volatility. Factors that have driven and may continue to drive material price changes include aggregate demand from large-scale model training and inference deployment, hardware supply constraints arising from production delays or export restrictions, the introduction of new GPU architectures that displace demand from existing GPU classes, and changes in the competitive landscape among cloud and neocloud compute providers.
The underlying market for paid language-model tokens is also evolving. OTPI values may be affected by model launches, lab pricing changes, token throughput, routing across providers, cache utilization, reasoning-token intensity, buyer migration between model tiers, changes in demand for inference, and changes in provider or lab availability. Observed price movements in either OCPI or OTPI may lag underlying supply-and-demand shifts because price discovery in emerging compute and token markets is imperfect and transaction timing is irregular.
Indicative Values, Fallbacks, and Publication Risk
Under certain low-liquidity, low-coverage, data-quality, or operational conditions, OCPI or OTPI may be designated as indicative rather than settlement-grade, may be delayed, or may be unavailable. For OCPI, such conditions may include insufficient eligible provider transactions in the observation window. For OTPI, such conditions may include incomplete same-day token volumes, unavailable provider routing samples, insufficient paid traffic for a lab or model family, or upstream settlement delays.
In the event of a severe operational outage that prevents a new determination, Ornn Data LLC may republish a prior fully-informed settlement value, delay publication, publish an indicative value, or take another action described in the applicable methodology. Any financial instrument or commercial contract that references OCPI or OTPI should include fallback provisions that address indicative designations, delayed publication, methodology changes, and publication outages. Counterparties are encouraged to confirm that such provisions are present in their agreements.
No Advice or Recommendation
Nothing in OCPI, OTPI, any publication of OCPI or OTPI values, any API or data feed distributing OCPI or OTPI, or any communication from Ornn Data LLC or Ornn AI Inc. constitutes investment advice, financial advice, trading advice, legal advice, tax advice, or a recommendation to buy, sell, or hold any security, commodity, financial instrument, token, derivative, or other asset.
OCPI and OTPI are pricing benchmarks designed to reflect transaction activity in their respective markets. They do not express a view on future prices. No representation is made that reliance on OCPI or OTPI is appropriate for any investment objective, risk tolerance, commercial use, or financial situation. Persons considering any financial product, commercial contract, data product, or investment decision that references OCPI or OTPI should seek independent professional advice.
Conflicts of Interest
Ornn Data LLC is the benchmark administrator and a wholly-owned subsidiary of Ornn AI Inc. Ornn AI Inc. operates affiliated entities that reference or transact in OCPI-indexed products, including Ornn Exchange LLC, which aggregates capacity and offtake transactions, and OrnnX LLC, which operates as a de minimis swap dealer and riskless principal. Ornn affiliated entities may also have commercial interests in token data, token-market infrastructure, OTPI licensing, or products that reference OTPI as those markets develop.
The existence of affiliated entities that have commercial interests in GPU compute markets, token markets, and index-referenced instruments constitutes a structural conflict of interest between the index administration function and the affiliated businesses of the parent group. Ornn Data LLC is in the process of adopting formal conflicts procedures to document information barriers between the determination function and affiliated trading and commercial entities, to define compensation practices that sever any link between index determination personnel and benchmark levels or derivatives profit and loss, and to make public the scope of affiliated-business relationships as required by the IOSCO Principles for Financial Benchmarks. Until those procedures are published, market participants should be aware that the conflict exists and is structural.
Outside counsel for derivatives and registration matters is Katten Muchin Rosenman LLP. Outside counsel for corporate matters is Orrick, Herrington and Sutcliffe LLP.
Regulatory and IOSCO Considerations
Ornn Data LLC conducts its benchmark administration activities with reference to the IOSCO Principles for Financial Benchmarks, FR07/13, July 2013. IOSCO compliance is voluntary at the international level. Ornn Data LLC has assessed its current governance and methodology against the IOSCO framework and has identified areas where implementation is complete, partial, or in progress.
In the interim, Ornn Data LLC is not in a position to represent full compliance with all nineteen IOSCO principles, and market participants and licensees should not treat reference to the IOSCO framework as a representation of complete compliance. OCPI is currently distributed on Bloomberg Terminal and may be referenced in licensed products and financial instruments. OTPI is currently published on the Ornn Data platform and may be licensed or referenced in data products, commercial contracts, or future financial instruments as token markets mature.
Ornn Data LLC is not registered as a benchmark administrator in any jurisdiction as of the date of this statement. Certain jurisdictions require or may in the future require registration, authorization, or recognition of benchmark administrators, and Ornn Data LLC intends to engage with applicable regulatory frameworks as its licensing, distribution, and reference use expands.
Forward-Looking Information
This statement contains forward-looking information, including statements regarding planned regulatory steps, methodology revisions, governance actions, index coverage, token-market development, and exchange or distribution partnerships. Forward-looking statements reflect current intentions and expectations and are subject to risks and uncertainties that could cause actual outcomes to differ materially from those described.
These risks include, without limitation, changes in applicable law or regulatory requirements, changes in the structure of GPU compute markets, changes in the structure of paid token markets, changes in the commercial or technical viability of maintaining OCPI or OTPI, and changes in Ornn Data LLC's organizational capacity. No forward-looking statement in this disclosure should be read as a guarantee or commitment that the described action will be completed within any specified timeframe or at all.
Informational Purpose
This statement is issued for informational purposes only. It does not form part of any licensing agreement, financial contract, commercial contract, or instrument specification. The terms of any licensing agreement between Ornn Data LLC and a licensee govern the rights and obligations of the parties to that agreement and are not modified or superseded by this statement. This statement will be reviewed and updated periodically.
Ornn Data LLC
New York, New York
June 18, 2026