📋 Overview

Your DeFi protocol has received a demand letter from a user claiming losses due to a smart contract exploit, hack, or security vulnerability. These claims typically allege negligence in security practices, failure to protect user funds, or misrepresentation of protocol safety. This guide helps protocol developers and DAOs build an effective defense.

🛡 Security Audits

Multiple independent security audits and remediation records demonstrate reasonable security practices and due diligence.

📄 Risk Disclosures

Clear warnings that DeFi is experimental, smart contracts may contain bugs, and users assume all risk of loss.

🔗 Open Source Defense

Publicly auditable code allows users to verify security themselves, supporting an assumption of risk defense.

Common Exploit Claim Types

Claim Type Allegation Defense Strength
Negligent Security Failed to implement reasonable security measures Strong with multiple audits
Unpatched Vulnerability Known issue not fixed before exploit Weak if audit findings ignored
Oracle Manipulation Failed to protect against oracle attacks Depends on oracle documentation
Flash Loan Attack Protocol vulnerable to economic exploits Depends on risk disclosures

🛡 Defense Strategies

Build your defense around these key legal arguments and factual foundations.

Security Audit Documentation

Multiple independent security audits from reputable firms demonstrate reasonable care. Document all audit reports, findings, and remediation actions taken. Show ongoing security monitoring and bug bounty programs.

Key elements: Audit reports from recognized firms, remediation records, ongoing security practices, bug bounty program.

Risk Disclosure and Assumption of Risk

Clear terms stating that DeFi protocols are experimental, smart contracts may contain undiscovered bugs, and users assume all risk of loss. Documentation that users acknowledged these risks before interacting with the protocol.

Best practice: Prominent risk warnings, required acknowledgment before first interaction, no security guarantees.

Open Source Code Defense

The protocol code is publicly available for anyone to audit. Users could have reviewed the code themselves or hired auditors before depositing funds. This supports assumption of risk and "as-is" software arguments.

Documentation: Public repository, verification on block explorer, documentation of code availability.

Decentralization Defense

If the protocol is truly decentralized and governed by a DAO, individual developers may not have liability. Document the decentralized governance structure, lack of admin keys, and community control over the protocol.

Use when: Protocol is DAO-governed, no admin controls, developers cannot unilaterally modify code.

Third-Party Attack Defense

The exploit was caused by a malicious third-party attacker, not protocol misconduct. The protocol was the victim of criminal activity. Document the attack vector, law enforcement referrals, and efforts to recover funds.

Strategy: Position protocol as victim, show cooperative response, document recovery efforts.

Arbitration and Class Action Waiver

Terms requiring individual arbitration prevent costly class actions from multiple affected users. Motion to compel arbitration addresses claims individually.

Strategy: Enforce arbitration clause, prevent class consolidation, limit discovery exposure.

⚠ Insurance Claim Coordination

If your protocol has smart contract cover or cyber insurance, coordinate with insurers before responding to claims. Insurance policies may require specific procedures and could affect your response strategy. Do not admit liability without insurer consultation.

📄 Key Documentation

Preserve and organize these documents to support your defense.

Security Documentation

  • Audit reports: All security audits with findings and severity ratings
  • Remediation records: Evidence of fixing identified issues
  • Bug bounty program: Program documentation and payouts
  • Security monitoring: Ongoing monitoring tools and alerts
  • Incident response plan: Pre-existing security response procedures

User Agreements and Disclosures

  • Terms of Service with risk disclosures and liability limitations
  • User acknowledgment records before first interaction
  • Risk warnings displayed on the protocol interface
  • Documentation disclaimers in protocol docs

Incident Records

  • Exploit timeline and attack vector analysis
  • Post-mortem report
  • Law enforcement referrals and reports
  • Recovery efforts and fund tracing
  • Communications with affected users
  • DAO governance votes related to incident response

Blockchain Records

  • Claimant's wallet interaction history with the protocol
  • Transaction records showing deposits and losses
  • Attacker wallet analysis and fund flow tracing
  • Smart contract deployment and version history

💡 Litigation Hold Notice

Upon receiving a demand letter, immediately issue a litigation hold notice. Preserve all security-related communications, audit reports, incident response records, and governance discussions. Failure to preserve evidence can result in adverse inference instructions.

📝 Sample Response Letter

DeFi Protocol Response to Exploit Claim
Re: Response to Demand Regarding [PROTOCOL NAME] Exploit Dear [CLAIMANT NAME/COUNSEL]: We have received your demand letter dated [DATE] regarding losses from the [PROTOCOL NAME] security incident of [DATE]. We sympathize with affected users but must address the legal claims in your letter. SECURITY PRACTICES [PROTOCOL NAME] implemented industry-standard security practices: 1. The protocol underwent [NUMBER] independent security audits from [AUDIT FIRMS]. 2. All identified vulnerabilities were remediated prior to deployment. 3. An active bug bounty program with [$X] in payouts has operated since launch. 4. The code is open source and publicly verifiable on [GITHUB/ETHERSCAN]. RISK DISCLOSURES Your client agreed to our Terms of Service, which clearly stated: 1. Section [X]: "DeFi protocols are experimental. Smart contracts may contain bugs or vulnerabilities that could result in total loss of funds." 2. Section [X]: "Users interact with the protocol at their own risk. We make no guarantees regarding security." 3. Section [X]: Disputes are subject to binding individual arbitration. THIRD-PARTY CRIMINAL ATTACK The incident was caused by a sophisticated criminal attack by a malicious third party. [PROTOCOL NAME] was a victim, not a perpetrator. We have: - Referred the matter to law enforcement - Engaged blockchain security firms to trace stolen funds - Cooperated with exchanges to freeze attacker addresses - [DESCRIBE ANY RECOVERY EFFORTS] DECENTRALIZED GOVERNANCE [PROTOCOL NAME] is governed by a decentralized autonomous organization (DAO). No individual developer has unilateral control over the protocol. The DAO has voted to [DESCRIBE GOVERNANCE RESPONSE]. DEMAND FOR ARBITRATION Pursuant to our Terms of Service, any dispute must be resolved through binding arbitration. If your client wishes to proceed, we demand arbitration before [AAA/JAMS]. We reserve all rights and defenses. This letter is for settlement purposes only under FRE 408. Sincerely, [PROTOCOL NAME / DAO REPRESENTATIVE]

💰 Pricing

Professional legal assistance for responding to DeFi exploit claims.

Legal Services

  • 📄 Response letter: Flat fee $450
  • Extended negotiation: $240/hr
  • 📊 Insurance coordination: $240/hr

Initial response letters include review of your security documentation, terms of service, and incident records, plus a customized response letter. Extended negotiation, arbitration defense, and insurance claim coordination billed hourly.

🚀 Next Steps

Day 1: Preserve

Issue litigation hold. Preserve all security documentation, incident records, and communications.

Day 1-3: Insurance

Notify insurers if you have smart contract cover or cyber insurance. Follow policy procedures.

Week 1: Respond

Send initial response letter asserting defenses and demanding arbitration.

Week 2+: Defend

If claimant proceeds, enforce arbitration clause and prepare comprehensive defense.

Protect Your Protocol

Get professional help defending against DeFi exploit claims.

Schedule Consultation - $450

Resources

  • Security auditors: Trail of Bits, OpenZeppelin, Consensys Diligence
  • Insurance: Nexus Mutual, InsurAce, traditional cyber liability carriers
  • Blockchain forensics: Chainalysis, TRM Labs, Elliptic
  • AAA/JAMS: Arbitration providers for dispute resolution