This analysis describes what Coinbase's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This liability structure allocates financial risk between the platform and users by establishing the maximum amount Coinbase can be required to pay in dispute resolution. The three-month fee cap creates a defined boundary for the company's aggregate exposure across claim categories.
Interpretive note: The enforceability of the liability cap may be limited in jurisdictions with non-waivable consumer protection duties or where courts find the cap unconscionable given the potential scale of user losses.
The updated terms establish a new arrangement for USDC designated as 'Secured USDC' in connection with the Coinbase One Card. Under the revised language, if you designate USDC in your wallet as Secured USDC, you agree that Coinbase may transfer that amount to a third party designated as the secured party, and you will be restricted from withdrawing or transferring those funds. Additionally, the secured party's instructions to Coinbase regarding those assets take priority over any conflicting instructions you provide. The agreement states that you consent to all such permitted transfers. This arrangement operates independently of amounts owed to Coinbase, meaning Secured USDC will not be debited to satisfy debts you owe to Coinbase.
View change record →The updated terms eliminate language that previously allowed Coinbase to restrict your withdrawals if you designated USDC as Secured USDC and to comply with third-party secured party instructions without your consent. Under the revised agreement, Coinbase will not transfer, loan, or otherwise handle your Supported Digital Assets except as required by law or as you instruct. This means the One Card Secured USDC mechanism is no longer integrated into the core asset protection clause, and users no longer face withdrawal restrictions or loss of instruction authority tied to that designation. If you currently hold Secured USDC under a separate One Card cardholder agreement, that agreement remains in effect but is no longer cross-referenced in the main User Agreement's asset protection section.
View change record →The updated terms establish a new exception to the prior prohibition on transferring user digital assets. Previously, Coinbase stated it would not transfer assets except as required by law or per user instruction. The revised language now permits Coinbase to transfer USDC designated as 'Secured USDC' to third parties pursuant to a Coinbase One Card cardholder agreement. Users who elect to use this feature agree they will be restricted from withdrawing or transferring the secured portion, and they consent to Coinbase following instructions from a designated secured party without further user approval, even if those instructions conflict with the user's own orders to Coinbase. The full terms of this arrangement are stated to be in Appendix 4, which is not included in this summary.
View change record →Users' recoverable damages in disputes with Coinbase are restricted to direct damages only, with total recovery capped at fees paid during the three-month period preceding the claim. This means losses categorized as indirect, consequential, or exemplary—such as lost profits or business interruption—are excluded from potential recovery.
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"TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, AND EXCEPT AS OTHERWISE SPECIFIED IN A WRITING BY US, COINBASE AND ITS AFFILIATES SHALL NOT BE LIABLE FOR ANY INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES, INCLUDING DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA, OR OTHER INTANGIBLE LOSSES. FURTHER, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, COINBASE'S TOTAL LIABILITY TO YOU IS LIMITED TO THE FEES PAID BY YOU TO COINBASE IN THE THREE MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM.— Excerpt from Coinbase's Coinbase User Agreement
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This liability structure allocates financial risk between the platform and users by establishing the maximum amount Coinbase can be required to pay in dispute resolution. The three-month fee cap creates a defined boundary for the company's aggregate exposure across claim categories.
Users' recoverable damages in disputes with Coinbase are restricted to direct damages only, with total recovery capped at fees paid during the three-month period preceding the claim. This means losses categorized as indirect, consequential, or exemplary—such as lost profits or business interruption—are excluded from potential recovery.
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