Battery Passport Readiness Desk
Thesis: Sell EV, LMT, and industrial battery manufacturers and importers a done-for-you EU Battery Passport readiness packet: supplier evidence collected, product data normalized, Annex XIII fields mapped, QR/access-policy requirements checked, carbon/recycled-content evidence linked, exceptions triaged, and a platform-ready passport data room delivered before the 18 February 2027 passport mandate. The pain exists because the obligation is not just software setup; it is cross-supplier evidence collection, product-lifecycle data reconciliation, confidentiality tiering, and compliance signoff. AI-native operations create leverage by extracting and reconciling messy BOMs, certificates, supplier emails, PLM exports, carbon-footprint files, and test reports while human battery/compliance reviewers approve chokepoints. This is not a customer-facing co-pilot; customers buy an accepted readiness packet and evidence binder, not a tool they must operate.
2. Discovery rationale
The scan covered battery passports and digital product passports, EU AI Act readiness, DSCSA dispenser stabilization, OSHA ITA late/correction submissions, UK Companies House identity verification, and NIS2 evidence readiness. Battery passport readiness won because the regulatory date is fixed and near, the data problem is multi-party and document-heavy, platform vendors already validate budget, and the service wedge sits upstream of software implementation: make the messy product and supplier evidence fit for whichever DPP platform the buyer chooses.
Rejected candidates either had weaker willingness-to-pay evidence, a higher risk of becoming pure advisory, or overlap with prior blueprints. This winner is materially different from prior EUDR, CBAM, packaging EPR, PFAS, and California climate outputs: the buyer is a battery/vehicle/industrial-equipment economic operator, the workflow centers product passport data assembly, the trigger is EU Regulation 2023/1542 Article 77, and the deliverable is a platform-ready passport evidence package.
3. Candidate comparison
| Candidate | Buyer | Outcome | Score | Evidence | Dynasty type | Decision |
|---|---|---|---|---|---|---|
| Battery Passport Readiness Desk | Battery makers, EV OEMs, importers, ESS suppliers | Passport-ready product data room and evidence binder | 82/90 | Strong verified regulatory and vendor evidence | Dynasty vertical blueprint | Selected |
| EU AI Act High-Risk Evidence Desk | AI providers/deployers | Technical documentation and risk-management file | 73/90 | Verified AI Act timeline; uncertainty around final implementation details | Capability expansion | Rejected: legal ambiguity and commoditization by GRC platforms |
| DSCSA Small Dispenser Stabilization Desk | Pharmacy groups and small dispensers | Enhanced security readiness and exemption evidence file | 70/90 | Verified FDA exemption timing | Vertical blueprint | Rejected: smaller buyer budgets and pharmacy-system dependency |
| OSHA ITA Correction Desk | Multi-site employers | Late/corrected OSHA injury data submission packet | 62/90 | Verified annual deadline | Module bundle | Rejected: low complexity and seasonal commodity risk |
| UK Companies House IDV Completion Desk | Accountants, law firms, company secretaries | Director/PSC verification completion queue | 65/90 | Verified transition period and ACSP route | Module bundle | Rejected: free direct path weakens managed-service pricing |
| NIS2 Supplier Evidence Desk | Essential/important entities and suppliers | Audit-ready cybersecurity governance evidence pack | 69/90 | Verified directive scope; national variance high | Vertical blueprint | Rejected: crowded cyber-GRC services market |
4. Hard disqualifier check
| Disqualifier | Status | Reason |
|---|---|---|
| Customer-facing co-pilot or SaaS | Pass | The service delivers a completed readiness packet and evidence binder. |
| Physical labor dependency | Pass | Remote document, data, supplier, and compliance workflow. |
| Hourly pricing dependency | Pass | Priced per product family/passport readiness packet. |
| Cannot plausibly reach 50%+ gross margin | Pass | Repeated supplier/document patterns and automation support 55%+ mature target. |
| Unclear buyer | Pass | Economic operator placing in-scope batteries on the EU market. |
| Workflow not decomposable | Pass | Intake, mapping, evidence chase, validation, review, delivery are modular. |
| Unsafe regulated judgment automation | Pass | Regulatory interpretation and signoff stay with qualified reviewers/counsel. |
| Duplicative of prior blueprint or Dynasty | Pass | Distinct buyer, trigger, object model, and outcome. |
| Illegal/licensing impractical | Pass | Compliance operations service with legal advice excluded or separately reviewed. |
| Core demand unverified | Pass | Regulatory mandate and vendor category verified; willingness to pay inferred. |
| Model progress commoditizes service | Unclear | Generic models help extraction, but supplier network, evidence history, and QA can compound. |
| No bounded pilot | Pass | Pilot can cover 3 product families and 10 suppliers without live filing. |
| Customer must operate AI | Pass | AI is internal only. |
5. Rubric scorecard
Compliance data prep and assurance are already outsourced to consultants, test labs, and platform implementers.
Most work is extraction, mapping, completeness checking, and evidence chasing; judgment concentrates in exceptions.
Requires synthesis across PLM/BOM/test/carbon/supplier documents and confidentiality tiers.
EU Battery Regulation creates specific deadlines, data obligations, and market-access consequences.
Delivery is digital and remote.
Better models reduce extraction/reconciliation cost; the moat must move to data history, QA, and reviewer workflows.
6. Opportunity
The wedge is not to become another passport software platform. It is to become the operator that turns messy product, supplier, test, and lifecycle evidence into a platform-ready, reviewer-approved passport package. Platform vendors benefit if the service feeds cleaner data into Siemens, AVL, Circularise, Minespider, Spherity, Catena-X, or internal systems.
7. Evidence quality and source-claim matrix
| Claim | Label | Source or basis | Confidence | Business impact |
|---|---|---|---|---|
| Battery passport becomes mandatory for relevant battery categories on 18 Feb 2027. | Verified | European Commission batteries page; Battery Pass; EU Regulation 2023/1542 | High | Creates deadline-driven buying trigger. |
| Passport applies to EV, LMT, and industrial batteries above 2 kWh. | Verified | Battery Pass guidance and vendor summaries aligned to regulation. | High | Defines ICP and scope. |
| EV battery passports involve around 80 mandatory data attributes. | Verified | Battery Pass content guidance. | High | Validates document-heavy workflow. |
| Required work includes QR access, selective data sharing, carbon footprint, recycled content, due diligence, labels, and performance data. | Verified | Circularise, GBA, TUV, Regulation 2023/1542. | High | Defines modules and QA checks. |
| Battery market scale is large enough for a specialist service wedge. | Verified | IEA 2026 battery market and EV battery deployment data. | High | Supports market size, not PMF. |
| Economic operators will pay for managed readiness packages. | Inferred | Vendor category plus compliance urgency; no direct buyer interviews in this run. | Medium | Requires paid pilot validation. |
| Per-product-family readiness packets can reach 55%+ mature gross margin. | Inferred | Workflow automation assumptions and reviewer minutes model. | Medium | Core unit economics risk. |
| Noncompliance can restrict market access and create penalties. | Verified | Article 93 penalty requirement and compliance vendor summaries. | Medium | Raises urgency; penalties vary by member state. |
| Platform vendors create channel opportunities. | Inferred | Visible platform/consulting offerings from Siemens, AVL, Minespider, Circularise, Spherity. | Medium | GTM channel hypothesis. |
8. Why now
Verified market/regulatory changes
EU Battery Regulation 2023/1542 is in force. The European Commission lists February 2027 as the battery passport mandate and notes 2026-2027 implementation work, including the DPP registry legal deadline. Battery Pass and multiple DPP providers align on the 18 February 2027 operational date.
Inferred AI capability changes
Modern multimodal/document models can extract structured fields from product sheets, certificates, test reports, supplier emails, and spreadsheet exports with human review. This makes a packet factory plausible where consultants previously had to reconcile everything manually.
Unverified hypotheses
The market may prefer internal platform implementation over an independent readiness desk. Willingness to pay needs direct validation with battery OEMs, LMT manufacturers, ESS suppliers, and EU importers.
9. Customer and PMF
| ICP | Buyer | User | Trigger | Alternative | JTBD |
|---|---|---|---|---|---|
| Mid-market battery pack maker selling industrial, ESS, e-bike, or EV packs into EU | COO, compliance director, head of quality, sustainability lead | Product compliance, supply-chain, quality, engineering documentation teams | 2027 passport deadline, customer RFQ, EU distributor pressure | DPP software, consultants, internal spreadsheet project | Get passport data assembled and defensible before platform go-live. |
| EU importer/private-label equipment brand with batteries over 2 kWh | General manager, procurement leader, legal/compliance | Supplier management and product compliance | Supplier cannot provide structured passport data | Wait for supplier, switch vendor, consultant | Prove each SKU has enough evidence to keep selling. |
Willingness to pay is Inferred: the deadline and platform market are verified, but this run did not retrieve direct buyer interviews. Early PMF requires paid pilots, not survey interest.
10. The outcome we sell
Paid outcome: a Battery Passport Readiness Packet for one battery product family or SKU cluster.
- Deliverable: structured passport field map, source-linked evidence binder, missing-evidence queue, supplier chase log, access-tier matrix, QR/platform handoff file, reviewer signoff, and executive readiness memo.
- Acceptance criteria: all required known fields marked complete, incomplete, not applicable, or counsel/reviewer decision needed; every completed field has a source link; every unfilled field has owner and remediation path.
- Customer promise: reduce time and rework between raw supplier/product data and platform-ready passport records.
- Exclusions: legal opinion, conformity assessment certification, final regulatory submission authority, carbon-footprint verification unless separately contracted with qualified verifier.
- Rework policy: one correction pass included for source documents supplied before handoff.
- Success metric: 95%+ fields have evidence-backed status and fewer than 5% unresolved unknown-owner exceptions at delivery.
11. Internal AI engine architecture
Secure upload/API/email intake for BOMs, PLM exports, ERP item masters, supplier declarations, test reports, carbon-footprint files, certificates, QR/label specs, and platform templates.
Deduplicate SKUs, map product families, canonicalize suppliers, version files, classify evidence type, and create battery/passport objects.
Index Regulation 2023/1542, Annex XIII, Battery Pass content guidance, customer policies, DPP platform schema, and reviewer playbooks.
Extract fields, summarize evidence, detect conflicts, draft supplier chasers, propose access tiers, and assemble reviewer packets.
Deadline, category, capacity, required-field, source-link, owner, version, and completeness checks are rules-based.
Battery compliance reviewer resolves applicability, field sufficiency, confidentiality, supplier disputes, and customer-ready promises.
Second-pass evidence sampling, contradiction checks, PDF/CSV/JSON handoff package, and customer acceptance log.
Corrections become extraction examples; model layer is portable across OCR, LLM, embedding, and rules engines.
12. AI-vs-human operations pipeline
Classify documents, extract attributes, draft supplier requests, summarize gaps.
Battery category, capacity threshold, required-field matrix, source-link completeness.
Supplier chase, ambiguous files, duplicate SKUs, customer data mapping.
Regulatory applicability, confidentiality access tiers, carbon/due-diligence caveats.
Readiness memo, exception queue, platform handoff, acceptance signoff.
13. Operations as product
The production system uses a fixed intake checklist, required-evidence list by battery category, supplier request templates, versioned field map, exception queues, reviewer assignment logic by chemistry/category, confidence scores per field, audit trails, gold-standard examples, and postmortems for rejected fields. Operators do not improvise the packet; they move units through a controlled line where every field ends in complete, incomplete, not applicable, or expert decision required.
14. No-holes quality engine
- Every AI-extracted field must cite a source file, page, cell, or supplier statement.
- Contradiction detector flags mismatches across BOM, certificate, test report, and supplier declaration.
- Required-field rule engine blocks delivery if any mandatory known field lacks status.
- Reviewer cannot approve a field without evidence sufficiency and access-tier choice.
- Hallucination control: AI never invents missing data; it creates a chase task.
- Customer-harm prevention: legal claims, compliance status, and carbon-footprint assertions are caveated unless verified.
- Red-team check samples 10% of completed fields and all high-risk fields.
15. Pricing, pricing legality, and unit economics
Primary pricing: fixed fee per battery product family/readiness packet: $12,000 launch pilot for up to 3 product families and 10 suppliers; $6,000-$18,000 per additional product family depending on supplier count and document volume; optional $1,500/month monitoring for supplier updates and evidence refresh.
Why not hourly: hourly pricing rewards data messiness and caps AI leverage. Per-packet pricing aligns to the customer outcome: platform-ready evidence.
Pricing legality: fixed-fee compliance operations is generally lower risk than contingency pricing. The service must avoid unauthorized legal practice and certification claims; legal opinions, conformity assessment, and carbon verification require qualified professionals or customer counsel.
| Unit economics item | Pilot | Mature target |
|---|---|---|
| Revenue per packet | $12,000 | $9,000 blended |
| Operator time | 28 hrs @ $55 = $1,540 | 10 hrs @ $60 = $600 |
| Expert review | 8 hrs @ $175 = $1,400 | 3 hrs @ $190 = $570 |
| Model/OCR/storage | $180 | $75 |
| Software/security/admin | $900 | $650 |
| Gross margin | 66% before sales overhead | 79% before sales overhead; 55-62% fully loaded target |
| Revenue per FTE target | $350k | $650k-$850k |
16. Nonlinear scaling plan
At launch, one operator handles 4-6 packets per month with expert support. By month 9, extraction templates, supplier chasers, platform schema mappers, and reviewer rubrics should let one operator handle 12-16 packets per month, with expert review limited to 15-25% of fields. Margin expands as repeated suppliers, chemistries, and platform templates reduce manual reconciliation. Escalation rate target moves from 35% of fields in pilot to below 12% after 50 packets.
17. Moat and Sam Altman test
Model improvement strengthens the company if it owns the packet workflow, not just prompts: source-linked extraction history, supplier response library, schema mappers for major DPP platforms, reviewer gold standards, benchmark exception rates, and trusted partner channels. The strongest commoditization threat is that passport platforms add managed onboarding and supplier evidence automation. The counter is to be platform-neutral, faster for messy mid-market suppliers, and better at reviewer-ready evidence than software implementation teams.
18. Buyer-specific go-to-market
Selected GTM: founder-led outbound plus channel partnerships with DPP platforms, battery test labs, product-compliance consultants, Catena-X implementers, and EU import/compliance advisors.
- First 50 prospects: LMT/e-bike battery makers, ESS pack suppliers, industrial battery importers, and mid-market EV component suppliers selling into EU.
- Trigger events: 2027 passport project kickoff, customer RFQ asks for passport readiness, platform implementation stalls due to supplier data gaps.
- Outreach wedge: free one-product field-gap scan using the buyer's existing product sheet and supplier declaration.
- Credibility asset: sample anonymized readiness packet mapped to Annex XIII and a DPP platform export.
- Conversion path: field-gap scan -> paid 3-product pilot -> monitoring retainer -> platform partner referral.
- Expected sales cycle: 30-75 days for pilot; longer for large OEM procurement.
- Acquisition metric: qualified gap scans booked. Activation metric: complete source-file upload within 10 days.
- Proof before scaling: 5 paid pilots, 80% source-field acceptance, under 20 reviewer hours per packet.
19. Pilot design and early-demand trap mitigation
Pilot cap: 5 customers, 3 product families each, 10 suppliers each. Success criteria: paid engagement, complete source upload, at least 85% required-field status completion, customer acceptance, and documented time saved versus internal baseline. Manual workarounds are logged as defects, not hidden margin. Kill criteria: buyers will not pay fixed fees, supplier data access remains blocked beyond 30 days, reviewer hours exceed 35 per packet after the third pilot, or platform vendors close the service gap faster than expected.
20. Competitive landscape
| Category | Examples | Positioning |
|---|---|---|
| DPP/battery passport platforms | Siemens, AVL, Minespider, Circularise, Spherity, Catena-X solutions | Partners or competitors; they host/manage passports but still need clean evidence. |
| Compliance consultants | TUV, product compliance firms, sustainability consultants | High trust, less scalable packet factory unless digitized. |
| Internal teams | Quality, regulatory, engineering documentation, supply chain | Know source systems but overloaded and fragmented. |
| Do nothing | Wait for supplier/platform | Risk increases as deadline approaches and RFQs require readiness proof. |
21. Regulation, compliance, and licensing boundary
The service operates inside EU Battery Regulation readiness, not legal representation. It can collect evidence, map required fields, maintain audit trails, identify missing data, prepare platform-ready exports, and coordinate reviewer approval. It cannot certify conformity, issue legal opinions, verify carbon footprints, or guarantee regulatory acceptance unless a qualified body or counsel does that work. Privacy and trade-secret controls are central because passport data has public, regulator, and restricted access tiers. Customer contracts must prohibit claims that the desk replaces notified-body, verifier, legal, or final economic-operator responsibilities.
22. Compact founding team and expert map
| Role | Why needed | Timing |
|---|---|---|
| Domain expert | Battery regulation, quality, product compliance playbook | Fractional at launch |
| Operations lead | Runs packet factory, supplier chase, acceptance workflow | In-house from day 1 |
| Automation/AI engineer | Extraction, schema mapper, evidence binder, QA tooling | In-house or dedicated contractor |
| Compliance/legal reviewer | Boundary, disclaimers, applicability review | Fractional |
| Sales/channel lead | DPP platform and test-lab partnerships | Founder initially |
| QA owner | Sampling, red-team, postmortems | Ops lead initially |
23. Exhaustive risk register
1. Buyers prefer platform vendor managed services
Likelihood: Medium. Impact: High. Label: Inferred. Mitigation: partner with vendors and specialize in pre-platform evidence cleanup. Owner: Founder. Indicator: partner referrals below 2/month.
2. Supplier data remains unavailable
Likelihood: High. Impact: High. Label: Inferred. Mitigation: supplier escalation templates, customer executive sponsor, missing-data classification. Owner: Ops. Indicator: more than 25% fields unknown-owner after 14 days.
3. Regulatory requirements shift
Likelihood: Medium. Impact: Medium. Label: Verified for ongoing implementation work. Mitigation: versioned rule library and reviewer updates. Owner: Domain expert. Indicator: new delegated act or standard update.
4. Unauthorized legal practice boundary
Likelihood: Medium. Impact: High. Label: Inferred. Mitigation: counsel-reviewed engagement language and referral for legal opinions. Owner: Compliance reviewer. Indicator: customer asks for legal certification.
5. Carbon-footprint evidence needs qualified verification
Likelihood: Medium. Impact: High. Label: Verified. Mitigation: exclude verification or partner with qualified verifier. Owner: Domain expert. Indicator: carbon fields block acceptance.
6. AI extraction creates false confidence
Likelihood: Medium. Impact: High. Label: Inferred. Mitigation: source citation required, deterministic completeness checks, reviewer sampling. Owner: QA. Indicator: sampled field error rate above 3%.
7. Data security concerns slow sales
Likelihood: High. Impact: Medium. Label: Inferred. Mitigation: SOC2-ready controls, EU data processing terms, least-privilege access. Owner: Automation engineer. Indicator: security review exceeds 30 days.
8. Gross margin misses target
Likelihood: Medium. Impact: High. Label: Inferred. Mitigation: cap pilot scope and measure reviewer minutes. Owner: Ops. Indicator: COGS above 45% after fifth packet.
9. Platform schemas diverge
Likelihood: Medium. Impact: Medium. Label: Verified vendor diversity. Mitigation: neutral canonical schema plus adapters. Owner: AI engineer. Indicator: custom mapping per customer.
10. Deadline delay reduces urgency
Likelihood: Low-Medium. Impact: Medium. Label: Unverified. Mitigation: sell customer RFQ readiness and supplier data cleanup independent of deadline. Owner: Founder. Indicator: prospects cite delay to defer.
11. Enterprise procurement too slow
Likelihood: Medium. Impact: Medium. Label: Inferred. Mitigation: target mid-market and supplier-tier pilots first. Owner: Sales. Indicator: sales cycle over 90 days.
12. Duplicate consultant offering underprices service
Likelihood: Medium. Impact: Medium. Label: Inferred. Mitigation: compete on packet speed, audit trail, platform export, and fixed outcome. Owner: Founder. Indicator: discount requests above 30%.
24. Tech stack and build plan
Use a secure tenant workspace with object storage, Postgres, document OCR, structured extraction queues, embeddings over source documents, a canonical battery-passport schema, deterministic rule engine, reviewer UI, supplier request tracker, evidence-binder renderer, and export adapters for CSV/JSON/platform templates. Build sequence: intake and object model, source-linked extraction, Annex XIII field map, completeness rules, reviewer queue, supplier chase automation, PDF/ZIP evidence binder, platform export adapters, monitoring retainer workflow.
25. Dynasty translation layer
Classification: Dynasty vertical blueprint.
| Check | Translation |
|---|---|
| Buyer and outcome fit | Clear buyer: economic operator placing in-scope batteries on EU market. Outcome: passport-ready evidence packet with acceptance criteria. |
| Module decomposition | Intake, battery object registry, supplier evidence chaser, Annex XIII mapper, access-tier policy, reviewer queue, evidence binder, platform export, monitoring. |
| Activation path | Guided activation. Instant activation is unrealistic until source-system and supplier connectors are standardized. |
| Capability gaps | Secure product-data intake, supplier portal/email adapter, regulated field-rule engine, confidential data access controls, reviewer audit trail. |
| Tenant objects | Tenant, battery_product, product_family, supplier, source_document, passport_field, evidence_link, exception, reviewer_decision, access_tier, platform_export. |
| Warranted claims | Can promise evidence-backed readiness packet; cannot promise legal compliance, certification, carbon verification, or regulator acceptance. |
| Anti-duplication | Not a generic launcher, HVAC suite, or automation marketplace. It is a regulated battery-passport packet factory for a specific EU product-data obligation. |
| Deployability status guess | Spec. Move to validated after 5 paid pilots with measured acceptance and reviewer-minute data. |
| Recommendation | Pilot, then platformize as a governed vertical pack if paid pilots prove data access and margin. |
26. Metrics and KPIs
27. What could kill this
The business dies fastest if DPP platforms absorb evidence cleanup as bundled onboarding, buyers refuse fixed-fee managed packets, supplier data stays too incomplete for scalable delivery, legal/compliance reviewers require bespoke advice on every field, or deadline changes reduce urgency before the service has partner channels. The other sharp failure mode is confusing a service business with a software implementation project; the service must sell accepted readiness packets, not hours of platform configuration.
28. 90-day validation and launch plan
| Weeks | Actions | Proof/kill gate |
|---|---|---|
| 1-2 | Build sample packet from public battery docs; counsel-review engagement boundary; interview 10 battery/DPP experts. | At least 5 confirm evidence-prep pain; no fatal legal boundary. |
| 3-4 | Outbound to 50 prospects; offer paid field-gap scan; secure two platform/test-lab conversations. | 5+ qualified calls and 2 paid pilots or park. |
| 5-7 | Deliver first two pilots manually with instrumentation; measure field completion, reviewer minutes, supplier latency. | Under 35 reviewer hours and 80% acceptance. |
| 8-10 | Automate recurring extractors, supplier chasers, and evidence binder; add platform export adapter. | COGS path below 45% visible. |
| 11-13 | Run three more pilots; negotiate channel referral; decide Dynasty vertical pack status. | 5 paid pilots, 3 accepted packets, clear repeatable schema. |
29. Sources
- European Commission - Batteries
- Regulation (EU) 2023/1542 on batteries and waste batteries
- Battery Pass - Battery passport readiness
- Battery Pass - Content guidance Q&A
- Global Battery Alliance - Battery Passport and EU Battery Regulation whitepaper
- IEA - Global EV Outlook 2026, electric vehicle batteries
- IEA - Global battery markets are growing strongly
- Circularise - EU battery passport regulation requirements
- Siemens - Battery Passport
- AVL - Digital Battery Passport
- Minespider - Battery Passports
- Spherity - Digital Product Passport
- European Commission - AI Act timeline
- FDA - DSCSA waivers and exemptions beyond stabilization period
- OSHA - Injury Tracking Application
- Companies House - Identity verification
- European Commission - NIS2 Directive
Final validation
Machine-checkable: exactly one 05:00 output produced; HTML exists; PDF exists and is non-empty; filename uses 20260629 and hour 05; manifest updated; all 29 sections included; five-plus candidates considered; source-claim matrix exists; 12 risks included; real hyperlinks included; PDF generated from expanded-details print copy; no remote scripts, remote fonts, frameworks, CSS nesting, or experimental CSS; Dynasty reference and addendum found and read; Dynasty translation layer included; manifest includes Dynasty fields.
Judgment: the business is not substantially duplicative of prior runs or Dynasty Launcher; winner selected through evidence and scoring; pricing is fixed per outcome, not hourly; pricing legality and licensing boundary are explicit; major claims are labeled; service sells a done-for-you packet, not a co-pilot; internal AI engine and human chokepoints are clear; COGS and revenue/headcount scaling are addressed; early-demand trap and Sam Altman test are answered; credible but unproven path to 50%+ gross margin and governed Dynasty activation.