ChassisTrue Clear

Executive summary

Final decision: Blueprint. ChassisTrue Clear sells a done-for-you Chassis Pool Per Diem Dispute Pack to independent intermodal / drayage motor carriers who are billed chassis use and per diem charges by equipment providers (IEPs / chassis pools such as TRAC, Flexi-Van, DCLI, and cooperatives) under the Uniform Intermodal Interchange & Facilities Access Agreement (UIIA).

The customer does not operate a dispute dashboard. They forward invoices, gate/EIR records, appointment screenshots, and free-time clocks. ChassisTrue extracts, matches, scores disputability under UIIA Section E.6 and provider addenda, drafts the written dispute with an evidence index, and a specialist releases a submission-ready pack before the 30-calendar-day UIIA clock dies.

This is not ocean-container demurrage/detention under 46 CFR Part 541 (PortRecoup) and not UIIA M&R damage invoicing (existing M&R desk). It is the chassis-pool use / per diem charge type — a distinct counterparty class, tariff stack, and evidence bundle — with a hard April 28, 2025 UIIA revision clarifying provider invoice support and motor-carrier dispute documentation duties.

Thesis

Independent drayage carriers already pay chassis pool fees every week, already lose interchange privileges when invoices go unpaid, and already miss the UIIA 30-day written dispute window because office staff are buried in gates, EDI, and cash-flow fire drills. AI can turn chaotic invoice PDFs + gate/EIR dumps into a specialist-released dispute pack faster than hiring a full-time accessorial clerk — while a human chokepoint prevents filing frivolous or counterparty-toxic disputes that get the SCAC suspended.

Discovery rationale

This run deliberately steered away from the saturated regulatory-filing “engine” pattern and from OFF-LIMITS terrain (DigTrue, ScoreClear, StormCredit, PACATrue, I983True, BindFile, etc.). Fresh searches across FOG/hood (already blueprinted), HVAC warranty (trade-contractor OEM recovery exists), STR damage (exists), C&D diversion (exists), SADC encounter docs (HCBS pack exists), fire impairment (physical fire-watch labor risk), and utility power-factor (commercial-utility-bill-recovery exists) left chassis-pool per diem as the strongest evidence-backed wedge still open: active FMC complaints citing chassis/return friction, a live UIIA E.6 revision effective April 28, 2025, published fee ranges, and ~13,000 UIIA motor carriers with existing budget for accessorial leakage.

Candidate comparison

CODE validation

• Consumer/buyer trend: Intermodal volumes and chassis pooling remain core to US freight; UIIA covers ~95% of North American intermodal equipment interchanges; IEPs tightened invoice-support language effective April 28, 2025.
• Opportunity: Small/mid drayage offices systematically under-dispute chassis per diem when free time is consumed by terminal congestion, missing appointments, weather, or unavailable returns — then either pay, get suspended, or escalate too late.
• Demand: FMC Docket 24-20 (IXT v. COSCO) alleges $75,725 in per diem with chassis availability / return appointment / congestion facts; industry guides urge line-by-line chassis invoice audits; O Trucking 2026 fee guide documents $75–$150/day per diem and $1,500–$4,000+/mo chassis spend for 5–10 loads/week carriers.
• Economic sizing (range): ~13,000 UIIA motor carriers × assumed $6k–$40k/yr disputable chassis per diem leakage for beachhead fleets (2–40 power units) → illustrative SAM $80M–$520M/yr of leakage; capturing 0.5–2% as managed dispute fees supports a multi-million ARR path. Uncertainty: leakage rates vary sharply by port/rail ramp and pool mix — treat as range, not point estimate.

Rubric scorecard

Total gates: 27/30. Gate 1: accessorial dispute packs are already outsourced informally to billing clerks/consultants; buyer wants waived dollars, not software. Gate 2: OCR + free-time arithmetic + deterministic UIIA clocks; judgment limited to dispute theory selection and “do not file” calls. Gate 3: synthesis across invoices, EIRs, appointment systems, weather/congestion notices, and provider addenda. Gate 4: UIIA contract + potential FMC theories create willingness to pay and deter casual DIY. Gate 5: fully remote document ops. Gate 6: better multimodal extraction and retrieval strengthens packs as models improve; anti-commoditization = provider-specific playbooks, SCAC reputation risk scoring, and closed-loop win/loss learning.

Target buyer

ICP: Independent US intermodal/drayage motor carriers, 2–40 power units, UIIA signatory, active at 1–3 ports or rail ramps (beachhead: Savannah, Houston, LA/LB, NY/NJ, Chicago), receiving chassis pool invoices from TRAC / Flexi-Van / DCLI / cooperatives, with an owner-operator or office manager handling billing (no dedicated accessorial desk).

Economic buyer: Owner / GM / Controller. Champion: Billing coordinator / dispatcher who already screens invoices. Anti-ICP: Mega-fleets with in-house claims teams; pure over-the-road dry-van carriers without intermodal; non-UIIA carriers.

Jobs-to-be-Done

• When a chassis per diem invoice arrives, help me decide in <48 hours whether to pay, dispute, or escalate — without missing the 30-day UIIA clock.
• When free time burned because of terminal/appointment failure, assemble evidence the provider’s addendum and UIIA require so interchange privileges stay intact.
• When cash is tight, convert disputable chassis leakage into credits/waivers without hiring a full-time clerk or outside counsel for every invoice.

Painful problem

Chassis fees stack as daily usage ($20–$50/day), per diem after free time ($75–$150/day), flips, and splits. For a carrier doing 5–10 intermodal loads/week, chassis costs can reach $1,500–$4,000+/month — often invoiced weeks later, buried in accessorials, and enforced via Gate Control / interchange suspension. The painful failure mode is not “I don’t know chassis exist”; it is “I paid (or got suspended) on charges that accrued while return was impossible or free time was miscalculated, because nobody built a dispute file in 30 days.”

The outcome we sell

Outcome sold: A specialist-released Chassis Per Diem Dispute Pack — written dispute letter + free-time arithmetic worksheet + evidence index (invoice, EIR/gate records, appointment proofs, congestion/weather notices, provider addendum cites) + submission checklist — ready for the motor carrier to send to the equipment provider within the UIIA window.

We do not sell a guaranteed waiver amount, legal representation before the FMC/IANA arbitration panel as the core product, or a customer-operated dispute SaaS co-pilot.

First one-feature MVP wedge

Evidence summary

• Verified UIIA E.6 revised April 28, 2025: provider must supply reasonably necessary invoice support (e.g., EIRs); motor carrier must respond in writing within 30 calendar days with appropriate evidence.
• Verified IANA: 13,000+ motor carriers and ~65 equipment providers on UIIA; ~95% of N.A. intermodal interchanges.
• Verified Published chassis fee ranges (O Trucking 2026): usage $20–$50/day; per diem $75–$150/day; small-fleet monthly chassis spend $1,500–$4,000+.
• Verified FMC Docket 24-20 complaint alleges $75,725 per diem with chassis availability / appointment / congestion facts (active buyer pain signal; not a win judgment).
• Inferred Many 2–40 truck drayage offices miss dispute windows due to staffing — consistent with industry process guides urging audits, but not surveyed by us this run.
• Unverified Exact average recoverability % of chassis per diem across pools — treat pilot measurement as required before scale.

Claim table

Source-claim matrix

Market and demand evidence

US intermodal freight transportation demand is estimated around $13.8B in 2025 with double-digit CAGR forecasts through 2035 (analyst estimates; ranges vary by firm). The operational beachhead is the UIIA motor-carrier population (~13,000) rather than all 580,000 FMCSA tractor carriers. Chassis pools (TRAC, Flexi-Van, DCLI, cooperatives) monetize usage and per diem; Gate Control Systems and interchange holds create acute payment pressure. Demand is evidenced by published dispute playbooks, FMC complaints citing chassis/return friction, and the 2025 UIIA clarification that both sides must document invoices/disputes — which raises the documentation bar for small offices.

Active buyer conversations

• FMC Docket 24-20: motor carrier alleges unjust per diem practices including chassis availability and unavailable return appointments — public complaint text is a primary demand artifact.
• Industry operator guides (2026) explicitly instruct carriers to audit chassis invoices line-by-line and dispute per diem caused by congestion/closures/holds with timestamped evidence.
• IANA arbitration pages and UIIA notices continuously surface process questions from signatories about clocks and documentation.

Competitive landscape

• DIY / office clerk: Status quo; fails on volume and clock discipline.
• General freight audit / accessorial recovery firms: Often ocean D&D or broker detention focused; weak chassis-pool addendum libraries.
• TMS / pool portals: Customer-operated visibility tools — not done-for-you dispute packs.
• Maritime counsel / FMC litigators: Correct for large contested matters; overkill and slow for $800–$8,000 invoice batches.
• PortRecoup / ocean D&D desks: Adjacent; different counterparty and Part 541 regime.
• UIIA M&R dispute desks: Adjacent; damage invoices, not use/per diem.

Competitor and budget validation

Budget already exists as (1) paid chassis invoices, (2) office labor hours on accessorials, (3) occasional counsel for suspensions/arbitration, and (4) factoring/cash-flow costs when interchange is held. ChassisTrue redirects a slice of leakage + labor into a per-pack or continuity fee. Win thesis: faster clock compliance + provider-specific evidence packs beat generic “we’ll look at your detention” shops and beat SaaS that still leaves the clerk assembling the letter.

Pricing evidence and proposed pricing

Primary model is flat per-pack / retainer. Success bonus is optional and capped. Never hourly. Not a contingency lawsuit shop; not legal representation unless separately engaged counsel.

Regulatory and compliance considerations

• UIIA contract law: Private industry agreement administered by IANA; E.6 free days/per diem/use charges; H default dispute + Exhibit D arbitration.
• Shipping Act / FMC: May be relevant when ocean common carriers’ practices intertwine with per diem — ChassisTrue drafts commercial UIIA disputes; FMC complaints require counsel.
• OSRA 2022 invoice rules: Inform ocean D&D context; do not redefine chassis pool private invoices — keep theories labeled.
• FMCSA / interchange suspension: Operational consequence of unpaid invoices — packs must avoid reckless nonpayment advice.

Licensing boundary

Disclaimers on every pack: documentation assistance for the motor carrier’s own UIIA dispute rights; not legal advice; carrier remains the disputing party of record.

AI-native advantage

AI changes unit economics by OCR’ing heterogeneous IEP invoices, aligning container/chassis IDs to EIR/gate events, reconstructing free-time clocks, retrieving provider-addendum clauses, and drafting structured dispute letters in minutes. Humans stay on SCAC-risk judgment and theory selection. As multimodal models improve photo/PDF extraction and long-context addendum retrieval, COGS per pack falls without rewriting the customer offer.

Internal AI engine architecture

1. Intake: Secure upload (invoice, EIR/gate, appointments, emails, addendum PDF).
2. Normalization: Chassis/container IDs, dates, SCAC, IEP entity resolution.
3. Retrieval/knowledge: Provider addendum library + UIIA E.6/H/Exhibit D snippets + port calendars.
4. AI workbench: Line extraction, free-time reconstruction, dispute theory tagging.
5. Deterministic rules: 30-day clock, invoice age, required evidence checklist, max claim math.
6. Human chokepoint: Specialist release / kill switch.
7. QA: Second-pass ID match, citation check, tone/risk score.
8. Delivery: Pack PDF + email draft + portal checklist.
9. Learning loop: Win/loss codes → prompt/rules updates.
10. Model-portability: Swap LLM/OCR vendors behind schema contracts.

AI-vs-human operations pipeline

Dynasty translation layer

• Buyer: Drayage owner paying chassis per diem and fearing interchange holds.
• Service: Done-for-you dispute pack; optional continuity desk.
• Workflow: Intake → extract → clock → draft → specialist release → carrier submits → outcome capture.
• Tooling: Secure drive + OCR + addendum KB + Notion/Airtable case board + Doc generator (no custom platform day one).
• Sales: “We’ll beat the 30-day clock with a provider-ready evidence pack — or tell you to pay.”
• Delivery: Manual specialist + AI drafts for first 20 packs; automate extraction next.
• Expansion: Flip/split audits; multi-IEP desks; arbitration binders; port-specific playbooks.

Anti-duplication analysis

Checked manifest (738 runs restored from bindfile tip) and filenames. Closest priors: portrecoup-demurrage-detention-overbilling-recovery-desk (ocean D&D / Part 541) and drayage-uiia-mr-damage-invoice-dispute-desk (M&R damage). ChassisTrue’s counterparty is the chassis IEP / pool, charge type is UIIA E.6 use/per diem, evidence centers on free-time clocks + return impossibility, not container demurrage invoices or repair estimates. Not a duplicate of DigTrue, ScoreClear, ocean D&D engines, or carrier facility detention recovery.

Anti-commoditization analysis

If general models let clerks draft letters, ChassisTrue still wins on (1) maintained provider-addendum libraries, (2) SCAC suspension risk scoring, (3) measured win/loss playbooks by IEP/port, (4) specialist release that keeps carriers from filing self-harming disputes, and (5) Continuity Desk SLAs against the 30-day clock. The product is operational reliability, not a prompt.

Service delivery workflow

1. Carrier enrolls; signs MSA + UIIA-dispute authorization.
2. Uploads invoice batch + supporting files.
3. AI completeness score; request missing EIRs/appointments.
4. Workbench builds free-time worksheet + draft.
5. Specialist release (or pay recommendation).
6. Carrier submits via provider portal/email; ChassisTrue tracks.
7. Outcome coded; playbook updated.

Operations as product

SOPs for each major IEP; required evidence checklists; automated clock countdowns; exception queues (missing EIR, dual-party invoice, third-party rate conflict under E.6.d); reviewer assignment by port; confidence scoring; full audit trail; gold-standard packs; red-team “frivolous dispute” checks; root-cause tags on losses.

No-holes quality engine

• No pack ships without matched chassis/container IDs or an explicit unmatched exception.
• No pack ships past day 27 of the 30-day clock without rush protocol.
• Every citation must resolve to addendum clause or UIIA section.
• Random 10% second-specialist review through pilot 20.

What the human expert actually does

Minimum viable offer

Free Chassis Leak Scan on one recent invoice → disputability score + missing-evidence list → paid Single Dispute Pack within 5 business days (rush 48h +$250). Beachhead IEPs: TRAC + Flexi-Van at Savannah/Houston.

Fulfillment process

First 3 customers: Google Drive intake, Claude/GPT extraction into structured JSON, Airtable case board, Google Docs letter templates, specialist on Zoom/async review, carrier sends the pack. No custom app. Do not automate provider portal login until after 10 packs (credential/ToS risk).

Tools and systems

• Day 1: Secure shared drive, OCR (Document AI / Textract), LLM workbench, Airtable, Doc templates, calendar clocks, Stripe invoicing.
• Day 90: Addendum retrieval index, auto-clock, outcome CRM, provider portal macros where ToS-safe.
• Year 1: Lightweight case app only after SOP freeze.

Human-in-the-loop quality control

Every pack requires specialist RELEASE. Auto-fail if confidence <0.7 on ID match or clock math. Counsel queue if carrier requests FMC/arbitration language beyond template. Monthly red-team of 5 random packs.

Nonlinear scaling and unit economics

COGS stack: model inference, storage, specialist minutes, QA sample, payment processing, rework, sales follow-up. CAC payback target ≤2 Continuity months or ≤4 paid packs. Assumptions: scan→paid 8–15%; pilot→Continuity 30%; monthly retention 85%+.

Distribution proof table

Sales and outreach plan

Lead with diagnosis memo (“3 lines look disputable; 2 need EIR; clock day 11”), not a demo. Offer Free Leak Scan → paid pack → Continuity. No hourly scoping calls.

Founder-led content plan

Teach free-time math, E.6.e/f duties, suspension economics, and “when to pay vs dispute vs call counsel.” Publish anonymized teardowns from public FMC patterns and redacted packs.

First 30 days of content

1. UIIA E.6.f in plain English (30-day clock)
2. What “reasonably necessary evidence” means after Apr 28, 2025
3. Chassis usage vs per diem vs flip vs split — fee map
4. Savannah appointment failure teardown template
5. Houston weather/return refusal checklist
6. How Gate Control suspensions really start
7. EIR vs invoice ID mismatch — top 5 fails
8. When chassis availability kills free-time math
9. Pay vs dispute decision tree
10. Arbitration Exhibit D — when packs aren’t enough
11. Diagnostic teardown A: 12-line TRAC invoice
12. Diagnostic teardown B: Flexi-Van dual SCAC mixup
13. Diagnostic teardown C: cooperative pool free-time calendar
14. Lead magnet: Chassis Leak Scorecard (PDF)
15. Lead magnet: 30-Day Dispute Clock Checklist
16. Webinar: Live invoice redteam for Savannah/Houston carriers
17. Outbound diagnosis template (personalized 5-bullet memo)

Lead magnet and waitlist plan

Lead magnet: Chassis Leak Scorecard — upload one invoice, receive disputability score + missing evidence list + clock day. Waitlist CTA: “Get packs before your next suspension.” Follow-up in 24h with offer; sales-ready if ≥$500 disputable lines or active suspension threat.

Warm GTM plan

Scan users, prior ocean D&D relationships (refer-out/refer-in with PortRecoup-style shops), factor partners, and port breakfast contacts. Offer founding Continuity pricing for first 10 SCACs.

Targeted outbound plan

Build list of UIIA SCACs at beachhead ports (FMCSA + DrayLocator-style directories). Personalized opener references their IEP mix if visible. Attach mini diagnosis if public suspension chatter exists. Cadence: day 0 note, day 3 value teardown, day 7 scan offer.

Answer-engine/search visibility plan

Target queries: “UIIA per diem dispute 30 days,” “chassis pool invoice dispute evidence,” “TRAC chassis per diem waiver,” “Flexi-Van free time dispute.” Publish clause-cited explainers; avoid claiming legal advice.

Pilot design and early-demand-trap mitigation

Pilot cap: 8 SCACs / 40 packs. Incentive: founding pack price $395. Feedback: win/loss + missing-evidence tags weekly. Custom one-off portal scraping = custom work (defer). Expand only after COGS, cycle time, and ≥35% productive outcome rate measured.

Early-access feedback flywheel

Every denial code updates the addendum playbook. Product feedback = reusable rules; custom work = single-carrier portal quirks. Corrections become SOPs, prompts, and QA checks within 7 days.

Build-before-scale checkpoints

• After 5 pilots: freeze intake checklist + evidence requirements.
• After 10 pilots: freeze SOPs, exception queues, reviewer checklist, delivery templates.
• After 20 pilots: pause new logos until COGS, rework, escalation, cycle time dashboards are green.

7-day / 30-day / 90-day launch plans

7 days: Addendum library v0 (TRAC/Flexi-Van), templates, scorecard landing page, 20 outbound notes, 3 warm intros.

30 days: 25 scans, 8 paid packs, first Continuity LOI, public E.6 explainer, webinar scheduled.

90 days: 10 Continuity logos or 60 packs, day-90 COGS ≤60 min specialist, Houston expansion, counsel referral panel live.

Metrics and KPIs

• Clock compliance: % packs released with ≥3 days remaining
• Scan→paid conversion
• Pack productive outcome rate (credit/waiver/extension)
• Specialist minutes, rework %, escalation %
• Gross margin, revenue/FTE, Continuity churn

Risks and mitigations

Key risks: provider retaliation/suspension politics; UPL creep; overlap confusion with ocean D&D sellers; low win rates; evidence gaps; model hallucination of clause cites. Mitigations: specialist kill switch, counsel boundary, hard anti-dup messaging, pilot measurement, citation verifier, no guaranteed recovery marketing.

Exhaustive risk register

What could kill this

• Major IEPs unilaterally collapse dispute rights or auto-waive in ways that erase paid demand.
• Pilot productive outcome rate stays <15% at n≥40.
• Specialist minutes stuck >100 after automation pass.
• UPL/E&O finding on dispute letters.
• Inability to hard-diff from ocean D&D shops in buyer minds after 90 days of GTM.

Go/no-go reasoning

Clears evidence threshold: identified buyer, painful clocked problem, spend/labor evidence, active demand artifacts, competitor/budget validation, narrow MVP, service-first delivery, 50%+ margin path, distribution path, no fatal licensing blocker if counsel boundary held. Stronger than ImpairClear (physical labor edge) and DayLog (duplicate risk). Proceed to blueprint.

Final recommendation

Build ChassisTrue Clear. Launch Savannah/Houston beachhead with Free Chassis Leak Scan → $495–$795 Dispute Pack → Continuity Desk. Cap pilots at 8 SCACs / 40 packs. Measure win rate and specialist minutes before expanding IEPs or ports. Keep flat pack primary; optional capped success bonus only; never hourly; never customer-operated co-pilot as the product.

Source list

1. UIIA Revision Notice — E.6 / H changes effective April 28, 2025
2. UIIA legal text (E.6 Per Diem / use charges)
3. IANA UIIA program homepage
4. IANA Intermodal Information Services Overview
5. UIIA Binding Arbitration Process
6. O Trucking — Chassis Fees Explained (2026)
7. FMC Docket 24-20 — IXT v. COSCO Complaint
8. D.C. Circuit — Evergreen v. FMC (2026)
9. SNS Insider — Intermodal Freight Transportation Market
10. Fact.MR — US Intermodal Freight Demand
11. American Trucking Associations — Economics & Industry Data
12. Transport Topics — 2025 Top Intermodal/Drayage Carriers
13. TRAC Intermodal — Motor Carrier
14. FlexiVan — Pool Chassis
15. DrayLocator — UIIA Drayage Carriers directory