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Aggregate Liability Cap

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Document Record

What it is

The agreement caps each party's total liability for any claim at the greater of fees paid in the six months preceding the claim or USD $100. This cap applies to all legal theories including contract breach and tort.

This analysis describes what Windsurf'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes a financial ceiling on recoverable damages that, for low-spend or free-tier customers, defaults to USD $100 regardless of the nature or magnitude of the underlying claim. The cap applies to both parties but is operationally most significant for customers seeking recovery from Cognition.

Interpretive note: Enforceability of the USD $100 minimum cap may vary by jurisdiction, particularly in the EU for consumer users and in states that restrict liability limitations covering gross negligence.

Recent Activity

This document changed recently

Medium Jul 1, 2026

The updated terms indicate that Windsurf is now operating as the Cognition Platform under Cognition AI, Inc., replacing the prior Exafunction, Inc. structure. The revised terms state that prior terms continue to govern use for 30 days from the posting date (July 1, 2026), and that continued access after that period constitutes acceptance of the updated terms. Users who do not agree with the new terms are instructed to stop using or accessing the Services. The specific substantive changes to user rights, data collection, fees, or service functionality are not detailed in the provided change summary.

View change record →

Consumer impact (what this means for users)

Under this clause, any financial recovery from Cognition for claims arising under the agreement is capped at either six months of fees paid or USD $100, whichever is greater. For free-tier users or customers with limited spend, the effective cap defaults to USD $100.

Cross-platform context

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Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THIS AGREEMENT, IN NO EVENT WILL EITHER PARTY'S AGGREGATE LIABILITY ARISING OUT OF OR RELATED TO ANY CLAIM ARISING IN CONNECTION WITH THIS AGREEMENT UNDER ANY LEGAL OR EQUITABLE THEORY, INCLUDING BREACH OF CONTRACT, TORT (INCLUDING NEGLIGENCE) AND STRICT LIABILITY, EXCEED THE GREATER OF (A) THE TOTAL AMOUNTS PAID TO COGNITION UNDER THIS AGREEMENT IN THE SIX MONTH PERIOD PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED DOLLARS (US$100).

Excerpt from Windsurf's Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: Liability limitation clauses in consumer-facing contracts are subject to scrutiny under the FTC Act's unfair or deceptive practices standards and under state consumer protection laws. In the EU, limitation of liability clauses in consumer contracts may be subject to the Unfair Contract Terms Directive. California courts have occasionally assessed whether liability caps in consumer agreements are enforceable depending on context and whether they cover gross negligence or willful misconduct. (2) GOVERNANCE EXPOSURE: Medium. The USD $100 floor is notably low for an enterprise software platform and may be commercially insufficient to cover meaningful losses arising from data loss, service disruption, or security incidents. The exclusion of consequential, indirect, and punitive damages in Section 10.1 compounds this limitation. However, liability caps are a standard feature of commercial software agreements, and enforceability depends on jurisdiction and whether the cap covers gross negligence or intentional misconduct. (3) JURISDICTION FLAGS: EU consumer protection law may limit enforceability of this cap for individual users qualifying as consumers. Some U.S. states do not permit liability limitations that cover gross negligence or willful misconduct. Enterprise customers in regulated industries (financial services, healthcare) should assess whether this cap conflicts with their own vendor contract standards. (4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams negotiating enterprise agreements should assess whether this cap is commercially acceptable relative to the volume and sensitivity of data processed. Standard enterprise software contracts often negotiate higher caps tied to annual contract value. The mutual application of the cap (applying equally to both parties) should be noted. (5) COMPLIANCE CONSIDERATIONS: Legal teams should document the financial exposure ceiling created by this cap in vendor risk assessments. For customers in regulated industries where vendor liability adequacy is assessed by regulators, this cap may require disclosure or mitigation.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive practices in consumer contracts, including liability limitations that may affect consumer remedies.
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Provision details

Document information
Document
Windsurf Terms of Service
Entity
Windsurf
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014093
Document ID
CA-D-00487
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
f6e8d9d0bd5f9547549794c5f7e89d7dbd456e727e5d9c631d8366f1a48c326f
Analysis generated
July 9, 2026 04:42 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Windsurf
Document: Windsurf Terms of Service
Record ID: CA-P-014093
Captured: 2026-07-09 04:42:52 UTC
SHA-256: f6e8d9d0bd5f9547…
URL: https://conductatlas.com/platform/windsurf/windsurf-terms-of-service/provision/CA-P-014093/aggregate-liability-cap/
Accessed: July 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does Windsurf's Aggregate Liability Cap clause do?

This provision establishes a financial ceiling on recoverable damages that, for low-spend or free-tier customers, defaults to USD $100 regardless of the nature or magnitude of the underlying claim. The cap applies to both parties but is operationally most significant for customers seeking recovery from Cognition.

How does this clause affect you?

Under this clause, any financial recovery from Cognition for claims arising under the agreement is capped at either six months of fees paid or USD $100, whichever is greater. For free-tier users or customers with limited spend, the effective cap defaults to USD $100.

Is ConductAtlas affiliated with Windsurf?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Windsurf.