DoNotPay: The Robotic Lawyer Fighting For Consumers and Driving Institutional Transparency

Startup Spotlight #6

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Exhibit 1: DoNotPay one page summary

The Problem: Protecting Consumer Rights In A Pay-to-Play game

Consumers lost ~$3.3B due to fraud in 2021. In addition to fraud, individual consumers often face predatory practices from large organization. In 2020, airlines made ~$2.8B from change and cancellation fees, and banks charged consumers $12.4B in overdraft fees. These fees are important revenue generators for institutions, but they often take advantage of consumers when they are most vulnerable.

Corporations, however, are not the only organizations that deploy predatory practices. Governments can be predatory through a variety of practices, including parking and speeding tickets. Non-governmental organizations like Homeowners’ Associations can pressure consumers into a variety of fees and actions. Landlords can unjustifiably withhold security deposits

In summary, there are hundreds of organizations that extract billions from consumers annually, and in many cases, the consumer has the rights to protect themselves, but they do not know it. Why not?

Generally speaking, understanding the legal system is extremely difficult. There is a lack of information access. The industry can be very opaque. The obvious solution would be to hire legal representation, but for many, this economically infeasible.

Exhibit 2: Comparing the Cost Of Fines to Standard Legal Rates (Source #1, Source #2, Source #3, Source #4)

In a 2019 legal trends report, the average hourly rate for a lawyer in the United States was $253 per hour. This would be ~3-7x the actual cost of a change fee, parking ticket, or free trial. For top-tier firms, the firm can be $1,500 per hour!!

Even if the cost of the fine or fee is much greater than Exhibit 3 suggests, it will likely not make much sense for the consumer to hire legal help to fight back. Let’s say the fines are ~$500, and it takes the lawyer only one billable hour (unlikely). There is still a chance the consumer loses. Consider these three examples:

Exhibit 3: Scenario Analysis of Hiring Legal Assistance

In scenario C, the consumer could earn back some of their money, but they could also lose even more (scenario B). There is a risk, especially if the lawyer charges more than one billable hour.

This is certainly an oversimplification of the scenarios, and it does not consider the expected probability of a win, as well as external factors like the organizations response.

Regardless, the main points stand. Consumers are taken advantage of frequently. They have rights, but it is A) difficult to understand and B) expensive to hire someone who does understand it. When they do hire someone, the exorbitant fees can be a risk.

The battle becomes a pay-to-play game, giving large organizations a distinct advantage… until DoNotPay.

The Opportunity: Scaling Consumer Power with Technology

Organizations will almost always have more leverage than a single consumer in the form of time, endemic knowledge, and / or resources. But is that true against 100 consumers? 1,000 consumers? What about 1,000,000 consumers?

Intuitively, as the number of consumers increases, their overall leverage increases. This is the basic concept behind an employees’ union, but for consumers, there really is no equivalent. As a result, it is extremely easy for organizations (e.g., government, corporations) to have power in opacity, driving predatory practices.

Exhibit 4: The Point Of Inflection for Consumer Power

In Exhibit 4, the theory would be that grouping consumers increases leverage. On the far left, there are no consumers organized. The consumer has no power. As consumers organize, however, their power begins to increase.

At some point, there is a steep inflection point. Suddenly, the potential downside for the organization (e.g., class action lawsuit, lost business, internal churn) far exceeds the potential upside (e.g., profits) of the current practice. At this point, the consumer becomes more powerful, forcing transparency. For each organization, that point of inflection is different. For example, 100 consumers could hold their HOA accountable, but it is not likely to impact the power of an airline. That might require one million organized consumers.

Technology makes scaling consumers easy. Mobile applications and online communities reduce much of the complexity of scaling. The most recent example is the organization of a group called Wall Street Bets to gamma squeeze hedge funds shorting GameStop stock.

Now, imagine grouping active consumers, so they can identify predatory practices and push back. Businesses will ignore the single unhappy consumer, but if a material number of consumers (or in the case of government, constituents), push back or threaten to withhold business, they must react.

Exhibit 5: Unifying the consumer with DoNotPay

This is the theory behind scaling the consumer with DoNotPay. Create one company that offers scalable tools for the entire customer base to quickly identify problems and challenge them.

The Challenge: Mobilizing the Consumer

Using technology to unify and scale consumer power provides immediate time and value to consumers, as well as holds organizations accountable long-term, improving overall efficiency.

If there is so much value, however, why has no company done this?

Well, many have tried and are currently trying. There are many examples of companies organizing to fight parking tickets e.g., (Fixed, WinIt) and bank fees (e.g., Cushion, Recoup), among many others.

There are two main challenges to organizing consumers in this space:

1. Frequency – Consumers typically do not face issues like these (e.g., parking tickets, HOA fees) more than a few times a year. For this reason, it is difficult for any single company to acquire and retain customers. A consumer may use an app to fight a parking ticket, but if they do not get another parking ticket within the next year, they are very likely to churn.

2. Value – This ties directly to frequency. Many of these fees are both low frequency and low $ value (e.g., parking ticket). These fees are a nuisance, but they may not be at a threshold of concern to cause the consumer to continuously fight. If the event is a higher dollar impact event, then a service to fight would be more valuable, but it could also make lawyers more cost-effective.

To succeed in organizing consumers, a company needs to be able to build and scale a profitable product within a space that heavily benefits consumers. Basically, they need to find a way to build a product that makes money in a low frequency, low value space. For this reason, many companies have tried and failed.

The Solution: DoNotPay

DoNotPay, however, has found some ways to succeed. It is working. In June, DoNotPay has 3.09M users!

Here are five reasons DoNotPay will succeed:

1. Subscription model

2. Long-tail of products

3. Hacker Agility

4. Go-to-Market approach

5. Future Product Roadmap

Exhibit 6: Five Reasons DoNotPay Will Succeed in Unifying the Consumer

Subscription Model

First, DoNotPay charges based on a subscription model. A traditional approach may charge per action (e.g., parking ticket). The problem, however, is that these actions can be extremely spaced apart (e.g., once a year), and each might have a very different willingness to pay.

From the DoNotPay perspective, it is a challenge to reacquire a customer every time they need assistance (e.g., every six months).

From a customer perspective, it is not ideal either. Every few months, they have a different issue, and each time, they need to A) identify someone who can help them and B) do a cost-benefit exercise on whether it is worth spending the money.

Exhibit 7: Retaining Consumers Through Various Events in their Journey

The subscription model, however, removes all of this friction. By signing up for the DoNotPay subscription, consumers essentially have a robotic lawyer on retainer. At ~$12 per month (listed as $36 per three months), it is less than a Netflix subscription, and founder, Josh Browder, says that they save the average customer ~$200 per year.

Basically, this subscription can protect your consumer rights for less than a Netflix subscription… and save you money! It is a very strong value proposition that addresses both value and frequency challenges.

Long-tail of products

A consumer will only subscribe if they need the product frequently, and they see the value.

DoNotPay is addressing this by building a massive set of products. Some companies ship 1-2 new products a quarter. DoNotPay ships 1-2 products A WEEK. Ultimately, the goal is to have THOUSANDS of DoNotPay products.

This may seem absurd, but it makes sense. Consider the Netflix Long-tail content strategy.

Exhibit 8: The Netflix Long-tail Content Strategy

DoNotPay will acquire customers with the feature products. These could include fighting spam calls, cancelling free trials or memberships, or fighting fines. All of these features address sizable pain points for the consumer. These top 10-20 products are most likely to lead customers to purchase assistance. DoNotPay will use these products to compete for customer acquisition.

There are, however, then hundreds of long-tail products that other competitors will not bother to do. They are, however, individually valuable to the customer, and they provide the product portfolio breadth required to be able to assist the consumer with their weekly needs. (See Exhibit 12-14 for the list of all products)

To close the loop on the analogy, you come for Peaky Blinders (e.g., fighting parking tickets), and you stay for the super niche documentary you find (e.g., inflight wifi protection).

If you do not believe me, just look at the data. DoNotPay has a revenue churn of <5%. At Netflix price point levels, they are already retaining customers because of their value proposition.

Hacker Agility

Producing 2,000 products will not be easy. Many of these products directly challenge massive institutions, including wealthy corporations and large government organizations, and compete directly with legal competitors (e.g., large law firms).

In summary, DoNotPay needs to ship products faster than any company out there while directly challenging some of the most powerful entities in the world. How do you even begin to do that?

This is where the hacker agility of DoNotPay is exceptional.

The hacker mentality is critical to being the internet Robin Hood. Their ethos derives from founder Josh Browder’s creativity and conviction in helping consumers and battling the opacity of institutions. This is not a hobby for DoNotPay, but rather, it is a mission.

The entire team has a level of agility that is required to ship hundreds of products. From inception to release, DoNotPay can ideate and create an app / bot in <1 month. It is important to understand that these institutions do fight back, so their agility is critical to constantly react and innovate to new obstacles.

Here are three examples of this agility.

First, DoNotPay creates dummy credit cards for consumers to use when signing up for free trials. This removes any risk from the consumer getting billed beyond the trial. Companies like Netflix constantly block DoNotPay credit card numbers, but they continue to spin up new ones to serve their customers.

Exhibit 9: Leveraging Consumers As Nodes to Evade IP Blocking

Second, companies would continue to block DoNotPay IP addresses to reject DoNotPay efforts (Exhibit 9). As a solution, the DoNotPay app uses each customers’ phone as a node to send, disguising the request with the customers’ IP address. This is a brilliant way to disguise unified action. DoNotPay is scaling the consumers’ power, but from the institutions perspective, it looks like thousands of individual actions.

Third, scam callers can be sued, but they are difficult to track. If they bill your credit card, however, you can often trace the business, but there is risk. DoNotPay’s Robo Revenge product will give a credit card number to provide, so they can gather enough information to automatically sue the organization. This can award the customer with a $4K payout, as well as reduce the number of scammers.

Go-to-market approach

In my opinion, one of the most subtly brilliant parts of DoNotPay is their go-to-market approach. Some estimate that consumer startups spend 40% of their money on acquisition costs. Companies like Uber have spent billions on customer acquisition.

DoNotPay, however, is taking the search engine optimization (SEO) approach. SEO can be thankless, but long-term, it is the most efficient customer acquisition engine. Zapier mastered this approach, and as a result, they receive greater than 3.5M organic search visits per month.

For those unfamiliar, Zapier offers thousands of automated “Zaps.” They use miniature pages to rank each one with based on the keywords you are looking for. Paid media can be challenging because you would need hundreds of micro-campaigns, resulting in significant inefficiencies.

DoNotPay is similar. With hundreds of products, it would be difficult to do a concentrated marketing approach. They can, however, create hundreds of miniature pages that appropriately direct a consumer to the exact product they need given their pain point.

For this reason, DoNotPay is creating 1,000 articles per month. They spend ~$100 per article, and as a result, they create a miniature page to match every customer’s pain point down to the state and regulation level. Long-term, this will create an incredibly efficient and sustainable customer acquisition engine.

Future product Roadmap

Finally, I think the future product roadmap will elevate DoNotPay. Today, they generate hundreds of products, many of which are automated tools via their website / app. Long-term, however, DoNotPay will be the legal assistant for every American consumer.

As they continue to advance, Browder discusses opportunities like computer pop-ups (e.g., prompts on the screen with advice) to guide customers through online processes or virtual hearings. In addition, DoNotPay may eventually be able to apply artificial intelligence capabilities to preemptively recognize customer value (e.g., free trial scams) and proactively fight them.

Overall, Browder’s vision is incredibly striking, and the continuous digitization of legal procedures will create more opportunity for someone like DoNotPay to scale consumer power.

Conclusion

Scaling consumer rights against institutions has been a never ending challenge. Unions and class action lawsuits are examples of success, but they are isolated, and they are fragmented. DoNotPay has the chance to be the first to create a unified consumer front. We have clearly stated why and how they are the people to do it, but in closing, I think you should consider why this is so important.

Institutions are getting larger and more opaque. There are multiple trillion dollar companies, and many of them generate revenue through monopolistic marketplaces and privacy-infringing ad-based models. Meanwhile, our government has never been larger, and I would argue it has never been less effective.

Scaling the consumer will have two massive impacts on society: 1) Transparency and 2) Efficiency.

The consumer will force transparency by holding institutions accountable with the dollar vote. If an institution tries to hide fees, take advantage of vulnerable customers, or misrepresent value, then there will be a swath of consumers quickly prepared to push back.

These consumer swings will drive efficiency. Bureaucracies will be unable to handle pushback (e.g., appeals) if their processes are inefficient. In addition, an empowered consumer will demand more value, forcing corporations to fight for market share with enhanced value propositions and efficiency gains.

Overall, you have the private sector, the public sector, and the consumer. For years, the private and public sector have battled for leverage, often at the cost of the consumer. DoNotPay has the chance to change that.

Appendix

Investment score

Exhibit 10: Investment score

Problem Statement

Today, vulnerable consumers are consistently targeted with predatory fees (e.g., flight change fees, overdraft fees, HOA fines).

Challenging these predatory and opaque practices requires legal support. This creates a pay-to-play scenario, immediately placing the consumer at a disadvantage to the institution (e.g., government, corporation).

Market Drivers

Growth

• COVID digitization – COVID forced years of digital transformation on these institutions. For the first time, court hearings were moved online. DMVs allowed more services online than ever before. Many of these industries previously believed teleconference was an impossible substitute, but things worked better than most would ever imagine. Many of these switches to remote, teleconference, or online will likely be forever maintained. The increase in online share of processes presents new opportunities for DoNotPay to build supporting apps & bots.

• Consumer sentiment – Consumers are increasingly demanding transparency from corporations and organizations.The change in consumer preference will be a strong tailwind for DoNotPay. In Exhibit 4, we discussed the inflection point where consumer power begins to overtake the institution. DoNotPay has strong network effects. For each additional user, the overall network increases in buyer. The greater the number of consumers, the greater total power. The consumer sentiment tailwind + a strong network effect will drive both the entire Market and DoNotPay’s individual growth

Uncertain

• Corporate response – We have spoken a lot about DoNotPay’s action, but let’s not forget the corporations will likely fight back. Hidden fees are typically margin contributors, so they will likely be threatened by anyone trying to remove them. Currently, it is a bit uncertain how this impacts the market. Corporations may respond, but ultimately, there may be some that embrace transparency and innovate separate ways to gain margin. Those companies will win. The companies that actively fight will lose long-term. Overall, it is uncertain how a strong corporate response would impact the overall market.

Challenges

• Regulation – While most corporations will not have an extremely strong avenue to respond, two groups will: 1) legal institutions and 2) governments. DoNotPay will directly compete against legal institutions. For the most part, DoNotPay will not fight top-tier firms for market share, but they will compete with lower-level, boutique practices. In addition, DoNotPay fundamentally questions the current pay-to-play state of the legal sector. In many ways, this is likely to draw criticism from regulators (e.g., lawyers) in a regulated field (practicing law). Additionally, some governments may enjoy the efficiency in processes that DoNotPay provides, but many will likely feel challenged as well. Overall, I would expect some push back from traditionalists.

Market sizing

Exhibit 11: DoNotPay estimated market sizing

Bottom-up notes:

• Currently DoNotPay focuses on the United States, so we will focus on the US revenue potential

• ~257M adults in the US as of ~ April 2020

• In Q1 2021, Netflix had 74M paying subscribers in the US; Netflix is the most saturated subscription platform, so it is a decent proxy for identifying the upper bound of # of paid monthly paid subscribers

• Currently, DoNotPay charges $36 per three months (or $12/month)

• The TAM would be ~$37B, but the base case I projected long-term wouldbe ~$7.4B in annual revenue

• Long-term DoNotPay’s expanding product portfolio could easily warrant a larger subscription fee, having a linear effect on revenue potential

As a decent comp for the top-down, Americans spent ~$429B on legal costs five years ago. Shaving off ~$7.4B would actually be a very small slice (~2%) of the entire industry. Given the current subscription model, the $7.4B makes a lot of sense. The market size expands dramatically if they begin tiering products based on associated value. For example:

Exhibit 12: Tiered pricing model

In Exhibit 12, consider the “base case” that originally was sized at $7.4B. For some users, they will use features that far exceed the subscription of $12 per month. For example, businesses could use DoNotPay for business disputes, and it would likely still provide more than $1,200 in value (~$100/month). They could also effectively do this via add-on purchases. Regardless, if the revenue for these top customers amounts to ~$100/month, you can see revenue in the base case jumps to $15.2B (roughly double).

Because of the huge variation in legal fees, the upper bound of potential revenue for DoNotPay is quite high.

Competition

Exhibit 13: Competitive landscape

Direct

• Holistic players - Large players tackling significant pieces of legal work (e.g., lease creation); DoNotPay entered the market with more niche products (e.g., fighting parking tickets), but long-term they will need to directly compete in spaces holistic players currently sit. Within niche products, however, it is very unlikely these companies will have the agility required to ship at the speed DoNotPay does

• Niche players - Individual players that focus on 1-2 of the specific use cases DoNotPay does. Some (like those fighting bank fees), take different approaches, but their products are tangential. Overall, while they offer very similar products to DoNotPay, they will struggle with scale, frequency, and value, making it challenging to compete with DoNotPay at the levels holistic players will

Indirect

• Corporations & Governments - DoNotPay’s products directly challenge these large institutions, so they are likely to react. These large organizations could “compete” by A) providing more transparent processes and digital tools (removing the need for DoNotPay) or B) actively resisting DoNotPay. Both are likely to happen, but as they streamline or push back on certain processes, new opportunities arise. If there is one thing large institutions are good at, it is building bureaucracy.

• Legal institutions - DoNotPay aims to replace the need for lawyers and attorneys in some instances. Legal institutions may try to provide digital tools in response, but this is very unlikely. They do not have the skills, and their business models are fundamentally different.  Top-tier firms may have the resources, but they are unlikely to be threatened by DoNotPay. DoNotPay will replace some revenue for boutique firms, and boutique firms will not have the resources to compete. Most of the “competition” will come simply in the form of the legal world trying to invalidate DoNotPay

Additional Exhibits

Exhibit 14.1: DoNotPay Products (I/III)

Exhibit 14.2: DoNotPay Products (II/III)

Exhibit 14.3: DoNotPay Products (III/III)