Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
STATEMENT OF COUNTERCLAIM
HKIAC Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE HKIAC ADMINISTERED ARBITRATION RULES (2024)
BETWEEN
[Claimant's name]
[Claimant's address]
("Claimant," "Counterclaim-Respondent")
— and —
[Respondent's name]
[Respondent's address]
("Respondent," "Counterclaim-Claimant")
Submitted on behalf of the Respondent/Counterclaim-Claimant by: [Representative's title and name]
Date: [date]
This template numbers every paragraph, including optional ones, as though included. Delete any paragraph or clause that does not apply to this filing and renumber sequentially before submission.
Introduction
This Statement of Counterclaim pleads material facts only. The counterclaim is governed by Article 17.3 of the HKIAC Administered Arbitration Rules (2024). This document does not address set-off; where set-off is pleaded, it is addressed in the Statement of Defence.
The Parties
[Cross-reference the Statement of Defence rather than repeat.]
Jurisdiction
Jurisdiction over the Counterclaim arises from the same arbitration agreement pleaded in the Statement of Defence.
Material Facts
[Bare facts supporting the counterclaim — no argument.]
Breach Alleged
[Bare characterisation of the counterclaim's cause of action.]
Loss and Damage
Loss and damage of [amount claimed in the Counterclaim] [quantified].
Interest claimed at [interest rate on the Counterclaim] from [date from which interest is claimed on the Counterclaim].
Relief Sought
The Respondent/Counterclaim-Claimant seeks: (a) [amount claimed in the Counterclaim]; (b) interest as pleaded; (c) costs of the Counterclaim; and (d) further or other relief.
Reservations
The Respondent/Counterclaim-Claimant reserves the right to amend or supplement this Statement of Counterclaim pursuant to Article 18.
Annexure Schedule
Pursuant to Article 17.4, the Respondent/Counterclaim-Claimant shall annex all supporting materials on which it relies.
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent/Counterclaim-Claimant
Date: [date]
5.0 out of 5 on Google
Read reviewsAs seen in
About this template
What is this template?
This is a formal legal pleading used in international arbitration. It establishes the Respondent's own claim against the Claimant, distinct from a mere defence or set-off. It contains specific placeholders for Article 17 and Article 18 compliance and a mandatory annexure schedule for supporting evidence.
When should you use it?
Use this when a respondent in an HKIAC-administered case has an independent cause of action to assert against the claimant. Use the Statement of Defence if you only intend to deny the claimant's allegations without seeking independent relief.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | Invokes Article 17.3 of the HKIAC Rules (2024) and distinguishes the counterclaim from any set-off pleaded in the Defence. |
| 3 | Jurisdiction | Asserts that jurisdiction over the Counterclaim derives from the same arbitration agreement pleaded in the main Statement of Defence. |
| 6 | Loss and Damage | Requires the Counterclaim-Claimant to state a quantified amount of loss and specify the interest rate and commencement date. |
| 7 | Relief Sought | Lists the specific demands including the principal amount, interest, costs of the Counterclaim, and any other further relief. |
| 8 | Reservations | Preserves the Respondent's right to amend or supplement the pleading in accordance with Article 18 of the HKIAC Rules. |
| 9 | Annexure Schedule | Obliges the Respondent to attach all supporting materials relied upon as required by Article 17.4. |
Who it's for
- a respondent in HKIAC arbitration needing to bring a cross-claim against the claimant
- legal counsel drafting formal pleadings under the 2024 HKIAC Administered Arbitration Rules
- a party seeking quantified damages and interest in an active Hong Kong based arbitration
How long it runs and how it's signed
How long
Used once
Signed by
Representative of the Respondent/Counterclaim-Claimant
Witness
Not required
Notarisation
Not required
Also needed
file with HKIAC Secretariat; serve on Claimant
Law it's drafted under
Governed by
HKIAC Administered Arbitration Rules (2024)
Refers to
Article 17.3
Refers to
Article 18
Refers to
Article 17.4
Jurisdiction
Hong Kong
General
Document info
GitLaw document. Document created on Mon Aug 10th, 2026. Last updated on Tue Aug 11th, 2026.
This document is public
Licensed under CC BY 4.0 (Attribution).
Come to agreements faster
Write, review, negotiate, and manage legal contracts
Related documents
FeaturedUnited Nations
Response to Notice of Arbitration (UNCITRAL Rules) by OLL
This formal response template allows a respondent to answer a Notice of Arbitration under UNCITRAL Rules. It provides structured sections for contesting jurisdiction, commenting on arbitrator nominations, and asserting counterclaims for damages.
Updated 13 Aug 2026
Singapore
Statement of Counterclaim (Pleading) (SIAC Rules) by OLL
This template provides a formal structure for a Statement of Counterclaim under the SIAC Rules (2025, 7th Edition). It is used in international arbitration when a respondent files a standalone claim against the claimant rather than merging it with the Statement of Defence.
Updated 13 Aug 2026
Hong Kong
Notice of Arbitration (HKIAC Rules) by OLL
This Notice of Arbitration initiates a formal dispute resolution process under the HKIAC Administered Arbitration Rules. It requires the Claimant to identify the Respondent, state the legal basis for the claim, and provide a non-refundable registration fee of HKD 8,000.
Updated 13 Aug 2026
FeaturedEngland & Wales
Request for Arbitration (LCIA Rules) by OLL
This document is a formal request to initiate arbitration under the London Court of International Arbitration (LCIA) rules. It enables a claimant to define the dispute, nominate arbitrators, and state the specific financial relief and legal declarations sought from the tribunal. The template includes required sections for party details, the factual background of the breach, and proof of registration fee payment.
Updated 13 Aug 2026
United Nations
Statement of Claim (Memorial) (UNCITRAL Rules) by OLL
This template is a formal response for a respondent in an international arbitration governed by the 2021 UNCITRAL Arbitration Rules. It provides a structured framework for submitting a Statement of Defence, including factual backgrounds, legal grounds, and optional counterclaims.
Updated 13 Aug 2026
Frequently asked questions
A template isn't binding on its own - like any contract, it becomes binding once it's properly completed and signed. Templates in our curated library are professionally drafted for US or UK law; review any template before you sign it.
Yes. Chat with GitLaw to edit any section, or make changes directly in the editor.
Yes, read about team plans here.
Describe what you need in the chat and GitLaw will draft it for you.
Templates in our curated library are professionally drafted for US or UK law. The wider library comes from the GitLaw community and public sources - a solid starting point, but check any template fits your situation before you rely on it.
Mostly US and UK law. Some templates use general commercial terms that work across jurisdictions, and many note which law they're written for.
It depends on the situation. Templates work well for routine business agreements. For anything involving significant money, complex IP, employment, or areas you're unsure about, it's worth getting professional advice before you sign. GitLaw provides templates and tools, not legal advice.
Open any template in GitLaw and describe the change you want in the chat — 'make clause 4 mutual' or 'add a 30-day notice period', for example. GitLaw drafts the revised language and shows it as a suggested edit. You accept, reject, or keep editing from there.
Yes. Upload a Word, PDF, or Markdown file and GitLaw will open it in the editor. You can review, edit, or chat with GitLaw about it the same way you would with any template from the library.
Trusted by 5,000+ businesses
From template to signed, in one place
Every template opens in an editor with an AI agent alongside it.
1
Open
Pick a template and open it. Nothing to download, and no credit card to start.
Free to open
2
Edit with AI
Describe your situation in chat and the agent adapts the wording, clause by clause.
Tracked changes you can review
3
Send and sign
Share it for negotiation, then collect signatures without leaving GitLaw.
eSign included
Built for your legal work,
with practicing lawyers
Trained on 5,500+ clauses and specialist areas of law. Built with a standards committee of independent lawyers.
Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
Juliana Calil
Principal Counsel · Technology & Entertainment
20+ years in-house at Google, Intel, Disney and Looker
Adam Wardel
General Counsel, Data Privacy Officer & AI Advisor
12+ years leading legal & privacy for SaaS and AI companies
John Hoffman
Associate Director, Corporate Counsel · Life Sciences & Technology
20+ years in corporate counsel, incl. senior counsel at Certara
Richard Nohe
General Counsel · Telecom, Cloud & Data Centers
20+ years in-house, regional General Counsel at BT across 30+ countries
Joe Al-Khayat
General Counsel · Technology & High-Growth Companies
Cross-jurisdictional M&A and SaaS contracting across the UK, US & Australia
Joshua Woo
Technology, AI & Privacy Counsel · APAC
Former Goldman Sachs Executive Director for AI, cybersecurity & privacy in APAC
Sahil Verma
International Business & Investment Lawyer
13+ years in business law, investment law & dispute resolution
Matthew Willis
CRO & General Counsel · SaaS
Former President of the ACC's 2,200-attorney Chicago Chapter · JD + Kellogg MBA
Mayowa Ogunrinola
Legal Consultant · Fintech & AI Compliance
Regulatory strategy, AI governance & data protection for fintech and AI
Steven J. Shanker
Partner and Chair of Corporate and Employment Law
25+ years as a corporate & employment attorney in New York
As seen in
Ready to get started?
No sales calls, no credit card. Just chat with GitLaw.
GitLaw provides templates and tools, not legal advice. Templates are a starting point, not a substitute for advice on your situation - for anything significant, speak to a qualified lawyer.