Nettavisen stilte Incruises disse spørsmålene:

Do you know the number of Norwegian citizens enrolled in the inCruises scheme?

How many Norwegians have achieved leadership ranks?

One of the active promoters in Norway is Mr. Reidar Furuholmen. Could you say anything specific about his leadership role in Norway?

How do you define the products/services sold by inCruises?

What's the major source of income for the company?

Does the company have sources of income besides enrollment fees, and if so, how are the sources of income balanced (by percentage)?

How many of your 200.000+ (?) paying members have as yet been awarded a free cruise such as the ones heavily promoted in your promo videos?

The Norwegian Gaming and Foundation Authority finds several similarities between inCruises and World Ventures. The latter was classified as a pyramid scheme and judged illegal by Norwegian courts in 2016. To what degree is or isn't Incruises a pyramid scheme, in your opinion?

Her er svaret i sin helhet, gjengitt uendret:

«Dear Mr. Solli:

inCruises has adopted a proactive, transparent, and committed policy in our obligation to be an excellent corporate citizen wherever we conduct business.

We expect the same journalistic integrity from you and your publication.

We would appreciate you sharing your article before publication to verify that the information you portray is true and accurate. Please confirm, thank you.

You should know that we protect our reputation at every cost. We have filed lawsuits against six different media personalities or publications for defamation in various courts worldwide. These publishers have published false and defamatory information about inCruises by calling us a “scam," a "pyramid scheme," or "Ponzi scheme.”

Two of these lawsuits have already resulted in a favorable court ruling for inCruises. The courts ruled that the publication defamed in Cruises by writing that it is a “scam" and a "pyramid scheme," and one of the publications has been removed from the internet. We expect the second one to also be removed. The other court proceedings are pending.

Mr. Solli, in Cruises is a subscription-based cruise travel membership club. We operate a legal Membership club, and we save Members money. inCruises is not a pyramid scheme, nor is it a Ponzi scheme. Nor do we share similarities with these illegal schemes. Pyramids and Ponzi plans are unlawful because people get hurt and lose money.

These are two different types of illegal schemes. I will address them separately because these terms are often used interchangeably.

Morten Solli

April 23, 2021 Page 2

A Ponzi scheme is a fraudulent investment scheme in which investors are solicited based on representations of artificially high rates of return with very little or no risk. Early investors (and the perpetrator of the scheme) often receive high rates of return, but those returns are funded by the later investors and not from any legitimate business activity. Thus, once the pool of investors is exhausted, the later investors not only do not earn any returns, but they are unable to withdraw their investments, and the scheme collapses.

We sell our membership through a network of independent distributors that we call "Partners." The persons who buy our membership and participate in the benefits of the club membership are called "Members.” Some Partners also choose to be Members, and they are called "Partner Members."

A pyramid scheme is typically characterized by the payment by participants of money to the company in return for which they receive (1) the right to sell a product and (2) the right to receive in return for recruiting other participants into the program rewards which are unrelated to the sale of the product to ultimate users.

Participants in the inCruises marketing program are the Partners mentioned above. While it is true that Partners pay money to in Cruises in exchange for which they receive the right to sell a product (inCruises Memberships), they do not receive the right to receive rewards (compensation) for recruiting other Partners into the program. No Partners are ever paid a commission for recruiting other Partners.

Instead, they receive the right to receive compensation for the sale of Memberships to Members. The payment that Partners earn through participation in the inCruises marketing program is based on the sale of the Memberships to ultimate users—the Members.

Partners join in Cruises by signing our Independent Business Partner Agreement and pay a one-time activation fee of $195. They can renew their Partner account each year by paying $95 on their initial registration anniversary date. In return for their $195, they receive access to thousands of dollars worth of training aids, software including a complete email marketing system, mobile apps, leadership courses, and materials. No commissions are paid on the activation fee or renewal fee.

Neither the $195 initial fee nor the $95 annual renewal fee for Partners is an investment that funds a Ponzi scheme. Those fees, as noted above, are service fees used to cover the costs of the marketing, business assistance, software, marketing tools, and training services that in Cruises provides to Partners. No part of these fees is paid to other Partners or Members.

For these reasons, inCruises respectfully submits that again, we are not a pyramid nor a Ponzi scheme. Nor do we share similarities with these illegal schemes.

Morten Solli April 23, 2021 Page 3

Concerning Members, they too pay money to the company. The $100 monthly membership fee is not an investment, and Members are not induced to pay that monthly fee by the promise of a return of any sort. Instead, they are paying a monthly subscription fee in exchange for the benefits of inCruises Membership.

in Cruises' Membership is no more a Ponzi scheme than is your local gym, Disney Plus, Netflix, Dollar Shave Club, Peloton, ADAC, or Amazon Prime, all of which charge membership fees for consumers to access their benefits. No portion of the monthly inCruises Membership fee is paid to other Members. However, according to our compensation structure, an amount is paid to the Partner who sold the Membership and “sponsoring" Partners.

The payment of money by Members to inCruises is for the benefits of the inCruises Membership that they receive. They do not have the right to sell any product or service offered by inCruises, and they do not have the right to recruit other Members (or Partners) into the program

Members join our club by signing our Membership Agreement. There is no initiation fee or activation fee for these persons. They pay $100 per month as a membership fee, and in return, they receive 200 Cruise Credits, which we call Cruise Dollars. Cruise Credits do not expire as long as a Member remains active.

Members have access to our proprietary cruise booking technology platform, whereby they can purchase a cruise using their Cruise Dollars/Cruise Credits. The cruises are sold at the price that is regularly advertised. Still, all Members can achieve measurable savings on their cruise purchase because of the Cruise Dollar/Cruise Credit to membership fee differential. in Cruises can profit partly because we make cruise bookings through a wholesaler at a price that allows us to pass on our members' savings. We are also profitable because we have a low and mostly variable operating overhead.

We have many testimonials from our Members who attest to the fact that they have received measurable value and have indeed saved money on their cruise purchases through their club membership.

100% of customers/Members have saved money on every cruise vacation. 100%.

Over 172,000 customers/Members have saved money and sailed without incident since July 2016

All customers/Members were refunded 100%, not vouchers, in 2020 for canceled cruises due to COVID. 100%.

Would you like to review some of these Membership testimonials? Please confirm.

Morten Solli April 23, 2021 Page 4

Mr. Solli, please confirm you are aware that we have a relationship with Trust My Travel,

We at inCruises pay the insurance premiums to Trust My Travel for every Member.

In the unlikely event we were to go out of business, Members' dues would be refunded.

Mr. Solli, please tell me of any other subscription business that pays Membership insurance premiums? There is none.

Please see this statement at the bottom right of our main website:

For your financial protection (INCRUISES INTERNATIONAL LLC) is a member of Trust My Travel, and our membership number is TMT56252. All client payments to INCRUISES INTERNATIONAL LLC acquired through Trust My Travel are protected by Trust My Travel. This means, in the unlikely event of our financial failure, you will receive a refund for any payments made to INCRUISES INTERNATIONAL LLC that were acquired or transacted through Trust My

Travel and were not previously utilized, expired, or applied towards an upcoming cruise booking, for which a confirmation number has been delivered by a Third Party Service Provider (for example, a cruise line).

I trust you agree that Pyramid and Ponzi schemes typically do not offer consumer protection, do they?

Mr. Solli, Pyramid schemes typically do not have a product or service for which there is a market demand outside of the company's distributor sales force. Concerning in Cruises, the market demand for the club membership is tangible and demonstrated by the fact that there are more Members than Partners or Partner Members. We have far more Members than we have Partners or Partner Members around the world.

In Norway, our business is relatively new, and the number of active Members in Norway exceeds the number of active Partners or Partner Members. In Norway, in Cruises has over four hundred active Partners and over six hundred active Members.

We have five Norwegian leaders who have achieved a leadership rank including Mr. Reidar Furuholmen. Mr. Furuholmen is one of our respected independent Partner leaders. Please know that I personally met Mr. Furuholmen in December 2019 when he was investigating our company. I found him to be genuine, articulate, and determined. I am proud that Mr. Furuholmen has worked hard during the pandemic to achieve the rank of Regional Director and maintain his business during this difficult time.

Morten Solli April 23, 2021 Page 5

It is important to note that our Norwegian Partners and Partner Members also build sales organizations outside of Norway by using online marketing methods and technology.

Mr. Solli, please confirm you are aware that customers who have decided to join our Membership offer from Norway did so on our US website under agreements that are based on US law and with entities in the US, not in Norway. The same is true for Partners.

We do not stop anyone from a country that is not restricted by the US State Department (we do not accept customers from Iran, North Korea, Cuba, for example) from joining our website as Members and/or Partners. That decision is up to them, and they must know if our offer is legal or not in their country.

Meaning and to be clear: any Member that joins is buying from our US-based entities and will enjoy cruises that almost all depart from outside of Norway. There is no legal restriction, as far as we know, for Norwegian citizens to do this, and if there were, it would be up to them to understand those restrictions. There are no restrictions, as far as we know, for Partners to engage in entrepreneurial activity. And it's up to those Partners to declare and pay their taxes. We require them by contract to do so.

Finally, a Partner Member is someone who chooses to be both a Partner and a Member. Upon activation in our system, a Partner Member will pay the activation fee of $195 plus a membership fee of $100 for a total of $295. Then, this person will pay $100 per month as a membership fee, along with a $95 annual renewal fee for the Partner account. This person will accumulate Cruise Dollars/Cruise Credits through the membership program and also have the opportunity to participate in the compensation plan by selling memberships and recruiting other Partners who also sell memberships.

Finally, please note we have strong ties with the Cruise Line Industry based on our excellent reputation:

Morten Solli April 23, 2021 Page 6

To ensure that we are fairly represented, we respectfully ask again to review your article before publication. We have been transparent with you regarding our business operations and would appreciate transparency from you and your publication.


Brune R. Mundock

Bruce R. Murdock

General Counsel

in Cruises International, LLC