DRAFT / INTERNAL / NOT FOR PUBLICATION / NO COLLECTION

Applicable laws and business stances

Operator: Emperor Livingstone. Seoul. Blue Book brief 26. DRAFT. Not licensed advice. Collection stays off.

DRAFTINTERNALNOT FOR PUBLICATIONNO COLLECTIONNot licensed adviceCollection stop ruleNot a public offerAds stay closed

Applicable laws and business stances from legal/26-applicable-laws-and-business-stances.md. Facing name: Emperor Livingstone. This is not licensed legal advice. No lawyer has been hired yet. These are the working stances already written on disk. Collection stays off.

DRAFT. Not licensed advice. No collection. No lawyer has marked this up. Do not collect names, emails, or sleep answers. Do not run ads. Do not treat this page as a public offer or a place to take money.

Source on disk: /workspace/sleep-coaching-business/legal/26-applicable-laws-and-business-stances.md

Applicable laws and business stances

For Emperor Livingstone

Blue Book brief 26

This is not licensed legal advice. No lawyer has been hired yet. These are the working stances for this practice, written so you can see which laws likely touch us, why, and what we do about them this week.

FieldValue
Document26-applicable-laws-and-business-stances
PackageBlue Book v0.1-DOMAIN-DRAFT
Date20 August 2026 (KST)
AuthorLieutenant General Steuben of Legal Compliance and Privacy
Operator이성재, Seoul, Republic of Korea
Facing nameEmperor Livingstone
StatusInternal brief. No lawyer has marked this up. We do not collect names, emails, or sleep answers yet. We do not run ads yet.

Who this is about

The Practice is behavioral sleep improvement coaching only. Three actions: verified sleep information; a program that fits lifestyle and needs; daily-habit accountability. It does not diagnose, treat, or claim to cure.

The operator is 이성재, a natural person in Seoul. Public English first person may say Livingstone. Legal papers stay in 이성재's name until a new registration with coaching-appropriate codes exists, or a lawyer says otherwise.

Intelligent Solutions is the other Korean sole proprietorship. It is registered for software development and AI consulting. Keep that name. Sleep coaching does not go on that registration. The two practices stay apart.

The Practice is fully online, English only, high-ticket, paid by the client, adults 18 and over. Later sale countries, if we sell: United States, Canada, Australia, New Zealand, Singapore, and Korea in English. The United Kingdom, the European Union, the European Economic Area, and Switzerland stay out until a separate privacy and claims pack exists.

We do not collect client data, run ads, put up forms, or fire pixels until a real lawyer is hired, or you sign a dated note that you accept the leftover risk after seeing a written quote.


How to read each law

Attaches means we treat it as binding on this practice now, even before the first client.

Maybe attaches means a conservative business treats it as if it might apply, and does not bet the practice on a loophole.

Does not attach means we do not build the practice around it, and we do not wear it as a badge.

For each law: why it hits this practice, what we do this week, what we refuse.


1. Korean Medical Service Act (의료법)

Attaches to the speech and the conduct, because the founder lives in Seoul and the work is sleep-adjacent.

This is the Korean law on who may practice medicine and who may advertise medical acts. It does not care that the website is in English. A Seoul person talking about sleep, apnea, insomnia, or "treatment" can look like unlicensed medical practice or unlicensed medical advertising. White-coat photos, clinic language, diagnostic scores, and "we treat insomnia" are the usual tripwires.

This week we do: keep the three coaching actions only. If someone reports loud snoring, breathing stops, restless legs, or other red flags, we stop the sale and point them to a somnologist or a licensed doctor. We do not name a hospital for a fee.

We refuse: diagnosis, treatment, cure claims, official sleep questionnaires used as scores, wearable-as-diagnosis, white-coat imagery, and any line that says we are a clinic.


2. Korean Personal Information Protection Act (PIPA / 개인정보 보호법)

Attaches the moment we collect a name, an email, a booking, or a sleep story, because the person who decides is in Seoul.

PIPA is Korea's personal-information law. Sleep-symptom answers are sensitive information. A Seoul controller cannot hide behind an English page or a US tool. Intelligent Solutions is a different registration and is not the privacy controller for this practice.

This week we do: collect nothing. No lead magnet, no intake form, no quiz, no pixel, no community join. Spoken fit questions, if any, are not stored.

We refuse: storing health answers before a separate consent form exists, putting sleep notes in personal WhatsApp or KakaoTalk, and calling ourselves "HIPAA compliant" as if that replaced PIPA.


3. Korean fair labeling and advertising / KFTC

Attaches to any public sentence about results, scarcity, or testimonials, because a Seoul operator advertising to people is still a Korean advertiser.

The Fair Labeling and Advertising Act (표시·광고의 공정화에 관한 법률) and the Fair Trade Act sit behind it. "Fall asleep in 7 days," fake leftover seats, and "results not typical" as a cure-all are the usual failures. English copy does not exempt the founder.

This week we do: write claims against the banned-claims list first. Guarantees, if any, are about sessions delivered and unused-session money, never about hours slept. Scarcity is real calendar capacity only.

We refuse: outcome guarantees, invented deadlines, paid doctor referrals, and publishing testimonials before a license and a substantiation file exist.


4. Korean e-commerce act (전자상거래법)

Maybe attaches, even on English-only sales from Seoul.

This is the Act on Consumer Protection in Electronic Commerce. It can require business-identity disclosure, a cooling-off window, and clear withdrawal rules for online sales. We do not have a written exemption that English-only coaching is outside the Act. Betting the first invoice on that exemption is a bad trade.

This week we do: keep paid checkout closed. When a lawyer is hired, ask this question first: does the Act apply to this English-only, fully online coaching sale by a Seoul natural person?

We refuse: publishing a site that pretends Korean consumer rules cannot reach an English page, and printing Intelligent Solutions' software registration as if it were this practice's business identity.


5. Korean tax on a Seoul resident

Attaches to the founder's worldwide income, because 이성재 lives in Seoul.

A Korean tax resident reports worldwide income. Selling coaching in dollars to a US client does not make that money invisible in Korea. Intelligent Solutions already exists for software and AI consulting. Sleep income must not be booked through that registration. We do not have the certificate or the business-code numbers in hand. We still do not invent them, and we still do not use that paper for sleep.

This week we do: keep sleep invoices unissued. If money is later taken, it is taken as 이성재 the natural person, or under a later coaching-coded registration that you have ordered in a dated writing. VAT words on a USD invoice stay options only until a tax person writes them.

We refuse: putting sleep fees through Intelligent Solutions, forming a US LLC to "hide" Korean tax, and printing VAT copy we have not been told to print.


6. US FTC Act §5 and health-coaching claims

Attaches before the first US person pays, if an English health-adjacent offer is on the open web.

The US Federal Trade Commission polices unfair or deceptive acts. It does not need a US company. The test is the net impression of the page, the ad, and the call: what would a reasonable person think we promised about their sleep? Health-related claims need competent evidence. Process claims need to be true. "I will show up and you will do the work" is a different sentence from "you will sleep 8 hours."

This week we do: keep the public offer unpublished. Draft copy against the claims lexicon. The only money path we will later allow is Protocol Completion Guarantee v1: effort gates, then extra sessions or unused-session refund, never a physiological result.

We refuse: "clinically proven coaching," before-and-after sleep-hour promises, and running US ads before a US lawyer has seen the aggressive version of the copy.


7. US state unlicensed-practice lines

Maybe attaches, state by state, if we coach a person who lives in that state.

Some US states treat certain sleep or health advice as the practice of medicine. There is no single fifty-state clearance. Coaching from Seoul does not erase that. The safer pattern is the same as 의료법: information, fit, habits; screen and refer when a medical problem is in the room.

This week we do: stay behavioral. Do not interpret a sleep-study PDF as a medical act. Do not tell a US person they have apnea.

We refuse: a quiz that scores apnea risk as a diagnosis, and any plan that treats "we are only a coach" as a magic shield in every US state.


8. Why the UK and the EU stay out

GDPR / UK GDPR would attach if we offered to, or collected from, people in the UK, EU, or EEA. UK CAP / ASA health-claim rules would attach to ads in those places.

Those systems want a lawful basis, extra health-data rules, a representative in some cases, and a tighter claims regime. We do not have that pack. Switzerland sits with them for this practice's default.

This week we do: leave those countries off the allowed list. Do not take their money. Do not collect their email "just in case."

We refuse: a footer that says "not available in the EU" while a form still accepts an EU address, and any plan to "add Europe later" without a separate privacy and claims set.


9. HIPAA (US health-privacy law)

Does not attach as a default, and we do not wear it as a badge.

HIPAA covers US covered entities and their business associates (clinics, insurers, and people they hire). A Seoul behavioral coach selling to a private adult is not that, unless a later US clinic relationship appears. Saying "HIPAA compliant coaching" is usually false or empty.

This week we do: ignore HIPAA as a marketing line.

We refuse: a HIPAA badge on the site.


10. Later countries (Canada, Australia, New Zealand, Singapore, Korea-English)

Maybe attach their consumer, spam, and privacy rules once we actually sell there.

We do not need a full pack for each of them this week. We do need to remember that English-only does not exempt us, and that Korea-English buyers can still trigger Korean consumer and tax rules.

This week we do: keep those countries as the later-sale list only. No checkout.

We refuse: building a Canada or Singapore funnel before the first allowed-country sale path is designed and a lawyer has seen it.


What we do this week

  1. Keep the practice as coaching only. Three actions. No medical acts.
  2. Keep the legal party as 이성재, a natural person in Seoul.
  3. Leave Intelligent Solutions on software and AI consulting. Do not mix sleep into it. Do not rename it.
  4. Collect nothing. No ads, no forms, no pixels, no community joins.
  5. Do not form a new business unless you write that order with a date.
  6. If a red-flag story appears in conversation, stop and refer. Do not store the answers.
  7. Let other teams draft internally against the Blue Book. They do not publish.

What we refuse this week

  1. Sleep coaching on the Intelligent Solutions registration.
  2. A new company or a new sole proprietorship without your dated writing.
  3. Any public claim that we diagnose, treat, or cure.
  4. Any guarantee about hours slept or a symptom disappearing.
  5. UK, EU, EEA, or Swiss buyers.
  6. Official ISI, STOP-Bang, IRLS, ESS, or official sleep-diary forms.
  7. Personal chat apps as the place we keep health notes.

What a lawyer still has to confirm

Hire Korean counsel first (의료법, PIPA, labeling, e-commerce, tax), then US counsel before any US person is in scope (FTC and state practice lines). Ask the e-commerce question in writing. Ask whether a later coaching-coded 개인사업자 is the right paper, and which codes. Do not treat this brief as that answer.


Leftover uncertainty

We do not have the Intelligent Solutions certificate, tax ID, or business-code numbers. Sleep still must not use that registration.

Whether the Korean e-commerce Act applies to English-only coaching from Seoul is open. We act as if it might.

Whether a given US state would call this coaching the practice of medicine is fact-specific. We stay on the coaching side of the line.

This brief does not choose a venue, bind insurance, or open collection.