Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
STATEMENT OF REPLY [AND DEFENCE TO COUNTERCLAIM]
["AND DEFENCE TO COUNTERCLAIM" appears in the title, and Sections 3–6 below apply, only where the Respondent has raised a Counterclaim in its Statement of Defence and this filing also serves as the Claimant's Defence to Counterclaim, pursuant to Art. 15.4.]
LCIA Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE LCIA ARBITRATION RULES (2020)
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 Claimant by: [Representative's title and name]
Date: [date]
Introduction
This Statement of Reply is submitted pursuant to Art. 15.4 of the LCIA Arbitration Rules (2020), pleading material facts only in response to new matters raised in the Statement of Defence[, and in defence of the Counterclaim], within 28 days of the Claimant's receipt of the Respondent's Statement of Defence[/Counterclaim] or of the Respondent's election under Art. 15.3(i).
Reply to the Statement of Defence
(Material Facts Only)
[Bare facts addressing new matters raised in the Statement of Defence — no argument.]
Defence to Counterclaim —
General Traverse[Include Sections 3–6 only where this filing also serves as the Defence to Counterclaim.]
Save as expressly admitted below, the Claimant/Counterclaim-Respondent denies each allegation in the Counterclaim.
Defence to Counterclaim — Paragraph-by-Paragraph Reply
Counterclaim ¶ | Allegation (summary) | Response |
Defence to Counterclaim — Material Facts and Bare Defences
[Bare facts only, no argument.]
Affirmative Defence 1 (bare): [basis, if applicable].
[Include the following paragraph only where the Claimant/Counterclaim-Respondent pleads a set-off against the Counterclaim: "Set-Off. Pleaded in the amount of [set-off amount] — bare characterisation only. The LCIA Rules do not provide a distinct set-off mechanism; not the same as LCIA's 'cross-claim' concept (inter-respondent claims only, Art. 2.1(iii))."]
Quantum Response on the Counterclaim
Position on [counterclaim quantum amount]: [admit / dispute].
Relief Sought
The Claimant seeks:
the relief sought in the Statement of Case;
[where a Counterclaim is pleaded] dismissal of the Counterclaim;
[where a set-off is pleaded against the Counterclaim] effect given to the set-off of [set-off amount];
[where a Counterclaim is pleaded] costs of the Counterclaim;
costs of this arbitration; and
further or other relief.
Reservations
The Claimant reserves the right to amend or supplement this Statement of Reply at the appropriate stage of the proceedings.
Annexure Schedule
All documents relied upon by the Claimant accompany this Statement of Reply, in accordance with Art. 15.4, as follows:
Exhibit No. | Description | Referenced at ¶ |
Respectfully submitted,
[Representative's title and name]
On behalf of the Claimant[/Counterclaim-Respondent]
Date: [date]
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About this template
What is this template?
This is a formal arbitral pleading used to respond to a respondent's defense or counterclaim in LCIA proceedings. It is not an initial Statement of Case or a Request for Arbitration. It contains a general traverse, a specific quantum response table, and an annexure schedule for exhibits.
When should you use it?
Use this document when you are the claimant in an LCIA arbitration and need to reply to new material facts or defend a counterclaim. Use a Statement of Case instead if you are initiating the primary claim details for the first time.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | Confirms submission pursuant to Art. 15.4 of the LCIA Rules within 28 days of receiving the Statement of Defence. |
| 3 | Defence to Counterclaim — General Traverse | Denies every allegation in the Counterclaim except for those expressly admitted in the filing. |
| 5 | Set-Off | Pleads a specific set-off amount against the Counterclaim, noting the absence of a distinct set-off mechanism in the LCIA Rules. |
| 7 | Relief Sought | Requests the dismissal of the Counterclaim, specific costs of the arbitration, and the relief sought in the Statement of Case. |
| 8 | Reservations | Reserves the Claimant's right to amend or supplement this Statement of Reply at any appropriate stage of the proceedings. |
| 9 | Annexure Schedule | Requires an exhibit table listing all documents relied upon by the Claimant in accordance with Art. 15.4 requirements. |
Who it's for
- a claimant in LCIA arbitration responding to new matters in a statement of defence
- a party defending against a counterclaim brought under the LCIA Rules 2020
- legal representatives filing a paragraph-by-paragraph reply to arbitral pleadings
How long it runs and how it's signed
How long
Used once
Signed by
Representative of the Claimant
Witness
Not required
Notarisation
Not required
Also needed
Submit to LCIA within 28 days of receipt
Law it's drafted under
Governed by
LCIA Arbitration Rules (2020)
Refers to
Art. 15.4
Refers to
Art. 15.3(i)
Refers to
Art. 2.1(iii)
England & Wales note
This version is drafted for England & Wales. Scotland and Northern Ireland differ on some points — for example notice periods and tribunal procedure. Tell GitLaw where you hire and it adjusts the draft.
Jurisdiction
England & Wales
General
Document info
GitLaw document. Document created on Sun Aug 9th, 2026. Last updated on Tue Aug 11th, 2026.
This document is public
Licensed under CC BY-SA 4.0 (Attribution-ShareAlike).
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