The Call for Evidence seeks to understand how DAOs are structured and operated, how the law might best accommodate different types of DAO structures now and in the future, and how DAOs themselves might integrate into existing legal frameworks. It also seeks evidence on which to base recommendations for any changes or reforms necessary to provide legal certainty and clarity to those using or involved in DAOs.
Questions the Commission is asking include:
how do DAOs work and how do they interact with existing legal frameworks;
what are the benefits and risks of using DAOs;
and how could regulation be structured to support the use of DAOs while protecting against the risks they present.
KlimaDAO has responded to the UK Law Commission’s call for evidence, outlining its experiences with the development and regulation of the DAO.
Based on KlimaDAO's experiences with other jurisdictions, KlimaDAO has proposed an approach which focuses on creating a regulatory framework that provides clarity and certainty while also enabling innovation.
KlimaDAO is committed to honoring current regulations in the jurisdictions in which it operates, and to making sure that our DAO complies with regulations in the future.
2.32 To assist in our understanding of the different crypto-token ecosystem functions performed by various participants, please provide feedback on the high-level descriptions in Chapter 2.
KLIMA aims to become a decentralized, Algorithmic based, reserve token-currency for the Voluntary Carbon Market (VCM). At a high level, the token has four axioms:
Every KLIMA token has a Intrinsic Value (IV) backing the token. While there can be more assets backing the token, there is a minimum value associated with the token. Hence, there is a price floor, but no price ceiling of the protocol. As of today, the Intrinsic Value is 1 carbon tonne. In other words, every KLIMA token is backed by 1 carbon tonne.
The KLIMA token can only be minted or burned by the protocol. The protocol serves as the "decentralized, central bank" of the token, with the ability to expand and contract supply.
When KLIMA is trading above the IV, the protocol expands supply, and sells KLIMA to the market. Because the protocol can create more supply, as long as there is the IV backing the token, it generates excess reserves from the spread between IV and market price.
When KLIMA is trading below IV, the protocol buys and burns KLIMA, contracting supply. Because it buys the token under the intrinsic value, the protocol bolsters reserves per KLIMA from the spread.
To learn more about the role of the KLIMA token within the VCM, please kindly read the here linked article.
2.46 We recognise that there is no singular, authoritative understanding of what a DAO is. However, please explain how you understand each of the individual descriptors of a DAO: (1) decentralised; (2) autonomous; and (3) organisation.
The DAOs descriptors can be detailed as follows:
1) Decentralized: there is no entity with the authority to make and enforce decisions; there is no single, centralized control body but each participant has the same rights and powers as everybody else. The positive aspect is that there is no centralized power in a few people but rather it is a diffuse power. Control is exercised by the community of participants instead of by an individual. There is no hierarchical organisation or several levels of hierarchy, everything works according to simple and democratic economic mechanisms. Rules are decided by the votes of the stakeholders and decisions are made through proposals (in the case of KlimaDAO via its Snapshot voting mechanism of Klima Improvement Proposals (KIPs)).
2) Autonomous: it has the ability to function independently and on its own, without the need for a central authority. The members of the DAO are not bound by any formal contract. On the contrary, they are bound together by a common goal and network incentives linked to consensus rules. These rules are completely transparent and written into the open-source software that governs the organisation. The rules may be modified via token voting; with the direct participation from token holders.
3) Organization: it is a community of interested parties, incentivized through some kind of token mechanism and governed by computer codes and programmes. The DAO allows individuals to collaborate without having to know or trust each other.
Evolution of KlimaDAO
In mid-2021, a team of carbon market professionals and blockchain entrepreneurs (the “founders”) conceived of the KlimaDAO protocol as a mechanism to create transparent, liquid carbon markets, by leveraging DeFi tools.
When laying the foundations of the protocol, the founding team made informed decisions based on their professional experience and expert knowledge of both DeFi (in particular the OlympusDAO protocol), which inspired KlimaDAO, as well as the Voluntary Carbon Market; the market that KlimaDAO aspires to bridge “on-chain”. The shared mental model that was developed is encapsulated in the KlimaDAO project, and this group shepherded the protocol to launch.
As the protocol began to take shape, the founding team enabled early contributors to participate in policy decisions, help manage the community, and set up the DAO’s structure and organization. At this early stage, KIPs were formulated by the Core Team and posted directly on Snapshot since there was not yet a forum for discussion (only Discord). Contributors were incentivised to participate by being remunerated in the KLIMA token in return for the time spent and quality of contributions made on developing and organizing DAO work. A period of self-organization ensued where more skilled contributors took on management and organizational roles within the DAO.
By December of 2021, the DAO was a fluid organization with a number of contributors participating in both short-term project work and longer-term management work. At the time of writing, there are more than 60 contributors on the project. At the peak, there were over 100.
The DAO has expanded the KIP (on-chain voting) process to further emphasize community input by adding a Request for Comment period on the KlimaDAO Forum where everyone can question, criticize, or recommend proposals.
As any new protocol with ambitions of decentralization gets off the ground, the community must take on more responsibility. Gradually the vision of the founding team and the shared mental model of the protocol are internalized by the community, which diminishes the risk of uninformed token votes or a poorly worded proposal damaging the protocol’s ability to achieve its objectives.
3.25 In this question we are interested in the legal treatment of a DAO which has not taken any of the additional steps that we discuss in this call for evidence, for example either structuring itself with a variety of incorporated or unincorporated entities or using decentralising elements.
Please explain whether your answer is based on general knowledge of DAOs or based on specific examples of DAOs of which you have first-hand knowledge or experience. We note that respondents might choose to answer this question more widely in the context of the discussion set out in Chapters 4 and 5 on how DAOs seek to modify the general starting point. In this respect, see also Question 21.
What we write is based on our experience as a DAO, based on the moves taken so far and described above, with a constant focus on embracing the best structures for our operations. So, all the answers provided in this document, are coming from direct experience and multiple legal “experiments”.
In particular, we find it useful to open up the use of foreign trusts or foundations, on the one hand, and to link IP and on-chain decisions to facilitate the integration of multiple factors, as happens for example under Jersey law.
3.26 Do you agree that the general starting point for DAOs might be that they are characterised as an unincorporated association, or a general partnership under the law of England and Wales?
Unincorporated associations are formed when two or more persons come together, usually under a common name, for the realization of one or more common purposes. Looking at this definition, one can certainly say that DAOs in this are similar: several identities gather for a reason other than the achievement of a profit.
However, they cannot fully fit into this definition as DAOs cannot be included in any specific category as they have characteristics that differentiate them. For example, unlike general partnerships there is often no contract, even oral, between the different parties; and in such contexts (GP) general partners have unlimited personal liability for the debts of the business, following their active management and control over the company.
3.27 How common do you think it is for DAOs to meet the criteria to be characterised as an unincorporated association? In particular: (1) Do many DAOs currently in existence or contemplation fulfil the following criteria:
(a) the DAO consists of two or more persons with a common purpose other than making a profit;
Most DAOs and Klima in particular
(b) the DAO is governed by rules, including in relation to how participants can join and leave;
(c) the DAO is non-temporary, so continues to exist even as its participation changes;
(d) the DAO has no distinct legal personality?
Depending on the form utilized. For instance, in the case of a trust fund, there shall be no legal personality. In the case of a foundation or a company with a series of rules that will act similarly like a trust, in that case there would be a legal personality.
(2) Are there any aspects of a DAO’s operations which make it unlikely that it would be characterised as an unincorporated association?
As per above answer
(3) Do you have examples of any other aspects of a DAO’s structure or operations that might suggest the existence of an unincorporated association?
3.28 How common do you think it is for DAOs to meet the criteria to be characterised as general partnerships as described from paragraph 3.17 of this call for evidence? In particular:
(1) Do many DAOs currently in existence or contemplation fulfil the following criteria:
(a) the DAO is a business;
(b) the participants within a DAO are acting together for their mutual benefit;
(c) the participants participate in the DAO with a view of profit?
No - in the case of KlimaDAO the vision is to afford greater accessibility and efficiency within the VCM; successful implementation of this vision may not necessarily bring profit as the ultimate beneficiaries of a functioning VCM should be project developers, not intermediaries.
(2) Are there any aspects of a DAO’s operations which make it unlikely that it would be characterised as a general partnership?
(3) Do you have examples of any other aspects of a DAO’s structure or operations that might suggest the existence of a general partnership?
In our opinion it should be said generically that it cannot fall into any category - this is connected with question 4.40
As a premise, we have to keep in mind that, under the applicable law, “unincorporated associations” are “set up through an agreement between a group of people who come together for a reason other than to make a profit (for example, a voluntary group or a sports club)” and “general partnerships” are “made up of two or more general partners who are responsible for the business. General partnerships are formed via a general partnership agreement—either verbal or written—made between two or more partners who all agree to share in the company’s profits, losses, and assets”. [See below to support the belief]
4.37 Why would a DAO choose not to use incorporation as part of its organisational structuring (in England and Wales, or elsewhere)?
At the moment we don’t see any legal instrument as the right one for DAOs.
4.38 Where a DAO does choose to use incorporation as part of its organisational structuring, are there any requirements or ongoing obligations, such as reporting, that are challenging for the incorporated entity to comply with as part of a DAO?
Choosing incorporation involves greater controls and a more structured and defined organization that moves away from the idea of decentralization typical of a DAO.
The below table (available here) discusses these two concepts based on the factors: ease of formation; level of external control; and methods of raising funds.
4.40 Please explain whether any or all of the available existing legal forms are unsuitable or unattractive for those DAOs that wish to use them as part of their organisational structuring.
The DAOs should survive external events, therefore there should be a way of structure that can make the DAO live even if the founders will disappear or stop working for the DAO.
4.56 Are there jurisdictions other than England and Wales that provide a legislative approach to legal forms that is more effective or attractive for use by DAOs?
Considering the legal research that we carried out, we find that Jersey Trust Law and the new Foundation model of Cayman allows a good framework for DAOs. Please review this document for insights into KlimaDAO’s legal research.
4.57 What are the advantages and disadvantages of those other jurisdictions, legal regimes or legal forms for DAOs in arranging their organisational structuring? Please include practical examples in your response to the extent possible. If there are advantages, please explain how the structure led to the choice of that jurisdiction.
The advantages are:
a malleable structure that can easily change the bylaws and rules of governance;
the creation of a bond/obligation/restriction between the assets that are in the DAO (or the fund) and the people participating in the DAO;
For instance, should I want a specific smart contract on Ethereum to be deployed only after the positive vote of at least 60% of the token holders, with absolute majority, this cannot be done in a C-corp, while on the other hand, can be done through a trust or through a foundation that will set the rules for the deployment of future contracts (or modification, or similar events).
4.60 Do you consider that England and Wales could or should introduce a new form of entity or recognition specifically tailored to DAOs? If so, please explain why this would be helpful for DAOs and how such an entity could be structured (including the potential trade-offs of formalising such an entity).
For us, it must be said that the government would be better off regulating them and, of course, incorporating safeguards that provide incentives to set them up in England and Wales.
5.15 Do you think that the concept of decentralisation (and / or sufficient decentralisation) could usefully be refined, clarified or applied under the law of England and Wales? If so, please explain why and how, and give examples.
Greater specification of the concept of decentralization may be a challenging process today, as DAOs in and of themselves remain a novel and immature concept with much experimentation and innovation still underway. In other words the ‘end state’ of many DAOs may not have yet been realized. That said, as the DAO model matures, it will become increasingly easy to categorize different types of DAOs and approaches to decentralization.
Within the context of KlimaDAO, the process of decentralization has been iterative, and is in some respects tied to the development of wider market conditions (including that of the Voluntary Carbon Market). For example, in March last year, KlimaDAO ceased much of its market activity due to an embargo placed on the tokenization of carbon credits (i.e. KlimaDAO’s growth was curtailed). A direct response of this from the DAO is to focus on re-enabling the ability to tokenize carbon credits by working with registries in the VCM, with other development activities de-prioritized; ultimately this has reduced the ‘permeability’ of the DAO until full operations resume; although this (likely temporary) condition may not be representative of the DAOs final state of, or trajectory towards, decentralization. Understanding how DAO’s react and develop in varying market activities will require time, and exploration throughout market cycles.
In addition, many DAOs do not yet have firm perspectives on where their decentralization journey ends (with the exception of MakerDAO, perhaps). There are very few examples of DAOs which have specified a ‘decentralization’ roadmap where parameters about the DAOs objectives and safeguards are defined. KlimaDAO for example is in the process of developing a Decentralization Roadmap (via its Decentralization Working Group), with a number of reports due to be released throughout 2023 to inform the Community of potential avenues towards decentralization, as well as the costs and benefits of such strategies (note the working of the Decentralization Working Group can be shared with the Law Commission if of interest).
The obvious risk is trying to interpret DAOs and full decentralization before the full set of conditions and practices around decentralization are understood is that legal frameworks may then not be fit-for-purpose.
Note, CeliumDAO may provide an interesting framework for further research here.
5.28 To assist in our understanding of the use of crypto-tokens by DAOs, please provide further information on whether software protocol-specified tokens are designed to confer similar rights on holders to the holding of share capital in a business, or equivalent to the holding of a partnership interest in a business.
Depending on how the DAO is set up, the rights can be similar but not the same. The rights they have are the voting rights and the possibility to participate directly in the governance of the system. Through the permissionless and highly public nature of decentralized governance, token holders have the ability to have a direct influence on the project on single issues, or over a prolonged period of time (i.e. it is easy to accrue or dispose of assets in order to participate in governance).
5.46 Please describe how you characterise the relationship between (i) DAOs; (ii) developers and / or incorporated companies (or other legal forms or incorporated entities) involved in software development; (ii) software protocols based on opensource code.
The relationships are taken care of such as in normal companies / business / association / foundations.
5.47 What are the legal uncertainties and / or risks that you consider are inherent in this Characterisation?
5.48 Do you consider that it is ever appropriate (and if so, in what circumstances) for developers of open-source code for software protocols / blockchain protocols to owe of duties of care and / or fiduciary duties to users of those software protocols?
5.49 How important is legal certainty with respect to the scope of duties of care and / or fiduciary duties of developers of open-source code for software protocols / blockchain protocols for DAOs and their participants?
Legal clarity is very important especially when a DAO wants to scale and to participate in “real world” markets, as is the case with KlimaDAO. Without clarity it makes it challenging to integrate with markets and/or services, inhibiting the potential benefit that decentralized, open-source projects can have on market (in the case of KlimaDAO to improve the transparency and experience of the VCM for the benefit of carbon project developers and consumers within the market).
5.50 Do you consider that greater legal clarity could be provided on these issues? If so, in what areas or respects?
It is important for the project to be clear on how the voting rules are, and how the founders and the DAO should act in the case that the voting happens.
5.56 Please provide further input on whether, and if so how, DAOs use smart legal contracts.
Depending on how the on-chain governance is done, DAOs can either automatically implement smart legal contracts, or just be a voting protocol that then will require a manual trigger of the smart contract modification.
5.57 Please describe your view on the nature of the relationship between a user and an (open-source) smart contract / software protocol that can be interacted with by anyone in the public market. In particular, please provide your view on whether such relationships can be properly regarded as constituting smart legal contracts as between a user and (i) a DAO; and / or (ii) a software protocol.
Depending on how the on-chain governance is implemented, in some cases there can be a smart legal contract between the user and the DAO. Some DAOs, for instance, set up a foundation and nominate, as beneficiary of the foundation, the token holders.
5.60 How do you consider that the privacy of users and participants could or should be protected where organisational structures and market systems rely on open-source code and publicly accessible transactional data?
The privacy of the users should be taken into consideration in case the DAO wants to keep in touch with a various group of persons; to make it permissionless. In case the DAO would like to proceed with a different solution, a gated DAO can be implemented.
The blockchain allows privacy in the way that a wallet can be created without documents (i.e. it can be pseudonymous / not ‘claimed’), but transactions can never be deleted from the blockchain; hence transactions can theoretically be traced to a ‘real world’ identity. With greater on-chain analytical tools, and increased regulation around so-called ‘mixer’ contracts it is assumed likely that absolute ‘anonymity’ will be challenging in the future.
5.78 Do you consider that there is a real risk that a DAO that is structured to ensure that the features described in paragraph 5.72 are not present could be characterised (or re-characterised) as a general partnership under the law of England and Wales? Please explain your reasoning.
We have said that the DAO is not comparable to a general partnership.
5.83 Please explain any other practical and legal structuring tools that DAOs use in both their blockchain based and non-blockchain based activities. If possible, please explain how you see these techniques interacting with principles of private law (including those discussed in Chapter 5).
Per introductory links: KlimaDAO Forum, Discord and Snapshot.
6.10 How do DAOs (or the constituent parts thereof) structure their governance and decision-making processes? Please provide examples, including (if possible) where such processes have worked and have not worked.
Each DAO can choose a different governance process, KlimaDAO’s is based on a fair and democratic voting system that respects the will of the DAO users, proportional to their holdings and voter turnout of the vote – the Snapshot platform publishes voter turnout and voting intentions, tied to users’ wallet addresses.
Before each vote, the proposal must be discussed on the forum. It must reach soft consensus prior to being moved to a formal token vote, per the below image (read more here).
Within the conferment of the forum and the keys to access it, will also confer the “Space” on “Snapshot”, and the relative Domain. The “Controller” of the Space will be able to change the settings of the space, including administrators.
All holders of the KLIMA token will be able to vote for any modification to the Platform itself, or to make a new proposal on the Forum, published on the Space soon after this, subject to the users’ vote. The voting power for each voter is calculated using a strategy selected in the proposal. Depending on the type of vote, the voting power for each voter can be distributed over several options. The “Controller” may also allow only certain members to vote using the whitelist strategy or calculate voting power from multiple chains with multi chain strategy. Each vote is signed by the voter in an easily verifiable way online.
Different strategies can be used to calculate the result of a proposal and each proposal can also have multiple strategies. The voting process used by the platform is flexible and easy to use. It is also carried out outside the blockchain and therefore does not cost a gas fee.
The result of the votes cast through the voting system is almost certain and therefore very difficult to dispute, although the system designed by Klima DAO is very user-friendly and allows for easy voting and verification.
Once a discussion has taken place and a ballot has been cast, the Controller must act according to the parameters that have emerged and ensure that the results reflect the wishes of the voters.
Some other DAOs have a more sophisticated system of voting that will allow people to vote, and should the quorum be reached, the modification or deployment of the smart contract will happen right after, in the next blocks.
In terms of “success”, KlimaDAO’s proposed votes have all passed thus far and this may be interpreted as ‘successful’. The KlimaDAO protocol has a clear vision to provide infrastructure to the VCM, and it is assumed that a high degree of individuals/entities who hold the token are aligned with the vision, and therefore the governance mechanism is effective in ratifying the direction of travel of the DAO.
6.16 How do DAOs (or the constituent parts thereof) assess their tax obligations and (if relevant) residence for tax purposes? Are there any particular areas of uncertainty for DAOs currently operating in the market?
Any entity that has a group of different participants working together and dividing profits can be taxed, but there is no specific information on this in other jurisdictions, even the US IRS is not clear on this point. The real problem is that since DAOs do not have a centralized authority, they cannot file taxes as traditional corporations can. From a tax perspective, a DAO LLC, being registered under State law, may be treated as a domestic partnership for tax purposes. This may be detrimental for the US partners, who must report their share of the DAO’s income and losses, regardless of whether the DAO makes a distribution, but it may be possible for a DAO LLC to elect to be treated as a domestic corporation for tax purposes. Also, it is deemed essential to evaluate if the company actually creates profit or not.
6.17 Are there any ways in which the taxation regime and tax consequences for DAOs (or the constituent parts thereof) could be simplified and / or improved? Please explain whether your answer is based on general knowledge of DAOs or based on specific examples of DAOs of which you have first-hand knowledge or experience.
Providing tax benefits or, at the very least, being clear from the beginning as far as the classification of the DAOs (i) corporation or partnership or (ii) as domestic or foreign company, would help to improve the framework. Such an answer is based on general knowledge about the DAOs and especially on the US tax framework for DAOs. For further reference, please see the FriedFrank newsletter (July 29, 2022).
6.32 Do you consider that anti-money laundering regulations apply to DAOs (or one or more of their constituent elements)? In particular:
(1) Do many DAOs (or one or more of their constituent elements) currently in existence or contemplation fulfil any of the following criteria:
(a) the DAO (or one or more of its constituent elements) is a “cryptoasset exchange provider” or “custodian wallet provider”; and
(b) the DAO (or one or more of its constituent elements) is carrying on business in the United Kingdom?
(2) In relation to the activities undertaken by DAOs, should different interpretative approaches be taken between “making arrangements with a view to” in the context of the RAO and the MLRs 2017?
(3) If “making arrangements with a view to” under the MLRs 2017 is interpreted using the same approach as that under the RAO, what would be the impact on DAOs based in the UK?
(4) Are there any aspects of a DAO (or one or more of its constituent elements) which would make it more or less likely that anti-money laundering regulations would apply?
6.33 To the extent that anti-money laundering regulations do apply, are any of the requirements particularly challenging for a DAO to comply with (for example, whether, given the nature of the entity, how and what they would be able to register)? If so:
(1) Do you have examples, or specific evidence, of those challenges?
(2) What could be done to solve those challenges, including by reference to the use of novel technology to achieve the same policy goals?
(3) Where DAOs replicate the activities of those subject to the MLRs, do you consider that it is appropriate to treat DAOs similarly to other “businesses” subject to the MLRs? If not, please explain why.
(4) What steps do DAOs take to make users and participants aware of any potential risks of interacting with either a DAO or an open-source software protocol and to help inform their decision-making?
Please explain whether your answers are based on general knowledge of DAOs or based on specific examples of DAOs of which you have first-hand knowledge or experience.
Joint answer 6.32-6.33:
As it is widely held, DAOs are anonymous organizations, which leads to some uncertainties but - what is even more - this means that compliance with Anti-Money Laundering (AML) and Know Your Customer (KYC) policies are not difficult to handle, and made even more complex when handling with different jurisdiction.
So, as DAOs prefer tech advantages rather than legal certainties, we can conclude in the sense that AML/KYC do not apply to the DAOs themselves, but rather to the structure and to the entities they use to operate (e.g. trusts). This is precisely the reason why KlimaDAO always carries out all the AML technicalities (and expressly states that) with reference to each and every transaction and contract signed.
Also, the EU GDPR aims at regulating the use of personal data by organizations and businesses, but its scope of application is not limited to the EU companies, as it extends towards all companies and organizations that process data from EU individuals. This is precisely the reason why we cannot neglect it, regardless of the fact that we normally deal with the US regulatory framework and the UK one for the purpose of this consultation.
DAOs must follow the GDPR (and the relevant sanctions are applicable to them too) as long as the data inside the DAO qualifies as personal data (as broadly referred to by EU Courts), and if such data are related to EU citizens, this will trigger the (mandatory) application of such EU laws. Furthermore, DAOs are even more challenging than for traditional organizations, as the absence of a central entity makes some GDPR requirements very difficult to meet.
Lacking a specific legal structure, if the form of the “general partnership” applies to DAOs by default, this entails that each and every member of the partnership itself can be sued for breaching the GDPR, as each is individually responsible for the entire DAO. It is preferable for these DAOs to appoint a Data Protection Officer in charge of the organization’s general compliance with the GDPR.
6.38 Are there any ways in which the applicable regulatory regime and practical consequences for DAOs (or the constituent parts thereof) could be simplified and / or improved?
Should a proper law that explains how the voting system and the DAO rules should be implemented, this certainly will improve the lives of developers and founders.
6.39 How do DAOs currently determine questions at to the jurisdiction applicable to them for regulatory purposes? Please explain whether your answer is based on general knowledge of DAOs or based on specific examples of DAOs of which you have first-hand knowledge or experience.
Some DAOs just elect the jurisdictions that are favorable, and follow those rules. The place of decision making, and the seat where most of the DAO’s decisions are happening, play an important role in the matter.
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