This page was compiled by Blockworks using publicly available information reviewed consistent with the TTF, possibly together with information supplied directly by the project where provided. Project-supplied information may correct, update, or supplement the public record, and may not be independently verifiable; Blockworks presents it as provided and does not verify or warrant its accuracy. Because this page depends on what has been disclosed, it may be incomplete — certain categories are more likely to include undisclosed items (e.g., non-announced fundraisings or material relationships), and the absence of an entry should not be read as confirmation that none exists.
Provide a concise narrative that clearly states each of (a)–(e) below.
Response
Frontier AI labs have exhausted the freely scrapeable internet, and the remaining high-value training data is either proprietary, legally undocumented, or does not yet exist. This leaves labs unable to source data at scale, prove its provenance, or guarantee its quality, and it exposes them to copyright and consent liability. The DATA Foundation addresses this by building onchain rails that source real human data, attach enforceable license terms, generate tamper-proof provenance receipts, and route compensation to contributors. The project originated as Story, an IP layer for the internet, and on June 25, 2026 it focused that mission on AI training data, which it identifies as the most valuable and least solved category of IP.
(Source: DATA Foundation Launch Announcement, Cointelegraph, )
The DATA Foundation supports ongoing development and operations through six governance-defined functions. It provides strategic grants to ecosystem partners, promotes network security by appointing a Security Council, implements approved DATA Foundation DAO proposals, runs educational initiatives and events, advocates for increased decentralization of the DAO, and manages the treasury to fund long-term ecosystem growth. The Foundation maintains a treasury reserve of more than 380 million native tokens that it may sell from time to time to repay outstanding loan balances and fund continued technical development.
(Source: Governance, MiCA White Paper)
The DATA Network is a purpose-built Layer 1 blockchain that combines an EVM execution environment with the Cosmos SDK and CometBFT Proof-of-Stake consensus. It enshrines a Proof-of-Creativity protocol that registers programmable IP Assets, attaches Programmable IP License terms, tracks parent-child derivative relationships through an IP Graph, and routes royalties across contributors. Three application layers sit on top of the chain. Contributor apps including Kled and Numo supply opt-in human data, Trace generates a public tamper-proof receipt for every contributed record, and Poseidon cleans, scores, and packages raw contributions into model-ready datasets.
$DATA is the native token of the DATA Network, migrated 1:1 from the prior $IP token. It pays gas fees for transactions on the Layer 1, is staked by validators and delegators as collateral in the Proof-of-Stake system, settles payment and royalty flows for onchain IP licensing, and carries governance rights over protocol upgrades, parameter decisions, ecosystem grants, and Foundation management as defined in the DAO Constitution. $DATA confers no ownership, profit participation, equity, or redemption rights in the Foundation or any affiliated entity.
(Source: FAQs, MiCA White Paper)
The DATA Network relies on a mixed control surface. Tokenholders submit and vote on DATA Foundation Proposals, the DATA Foundation executes approved governance decisions and supports operations, and the Security Council holds emergency and non-emergency technical authority over upgrades, parameter changes, and incident response. The Security Council operates under a phased membership model. In the first phase Foundation Directors appoint up to seven of the up-to-eleven members and incumbents elect up to four. In the second phase, reached at the later of one year after the Constitution or a transition vote, tokenholders gain the right to elect a majority of Council members through a Constitutional DATA Foundation Proposal.
(Source: Governance, Security Council)
For each existing entity: Labs/DevCo (e.g., Founder, CEO, CTO, COO), Foundation (e.g., President, Executive Director, CFO, COO), and DAO / onchain governance leadership (if applicable) list the: (a) full names, (b) official titles, (c) and prior experience of key team members. For any non-existent entity, explicitly mention it does not exist. External links may be included but they will not factor into the score.
Response
Full Name | Entity | Official Title | Prior Experience |
|---|---|---|---|
Seung Yoon "S.Y." Lee | Labs/DevCo | CEO of PIP Labs and strategic adviser to The DATA Foundation | Founded Radish and sold Radish Fiction to Kakao. Co-founded Story in 2022 and served as its CEO. Founding President of Poseidon. (Source: Poseidon, DATA Foundation Launch Announcement) |
Sandeep Chinchali | Labs/DevCo | Chief AI Officer | Former Stanford AI researcher and lead data scientist at Uhana, which VMware acquired. Co-founder and lead scientist of Poseidon. (Source: Poseidon Seed Round, Poseidon) |
Leo Chen | Labs/DevCo | Chief Technology Officer | PIP Labs has not publicly disclosed Leo Chen's prior roles; the leadership listing records only his current title. (Source: Story Protocol Leadership Team) |
Andrea Muttoni | Labs/DevCo | Chief Product Officer | Served as President of Story Foundation before being named CEO of The DATA Foundation on June 25, 2026. (Source: DATA Foundation Launch Announcement) |
Ben Sternberg | Labs/DevCo | Chief Financial Officer | PIP Labs has not publicly disclosed Ben Sternberg's prior roles; the leadership listing records only his current title. (Source: Story Protocol Leadership Team) |
Julie Jo | Labs/DevCo | General Counsel | PIP Labs has not publicly disclosed Julie Jo's prior roles. |
Raúl Martínez | Labs/DevCo | Head of Security | PIP Labs has not publicly disclosed Raúl Martínez's prior roles; he also sits on the DATA Foundation Security Council. (Source: DATA Foundation Security Council) |
Andrea Muttoni | Foundation | CEO | Served as President of Story Foundation and as Chief Product Officer at PIP Labs before being named CEO of The DATA Foundation on June 25, 2026. (Source: DATA Foundation Launch Announcement) |
Matthew Shaw | Foundation | Director | The DATA Foundation has not publicly disclosed Matthew Shaw's prior roles. |
Marc Piano | Foundation | Director | The DATA Foundation has not publicly disclosed Marc Piano's prior roles. |
Seung Soo Kim | Foundation | Director | The DATA Foundation has not publicly disclosed Seung Soo Kim's prior roles. |
Avi Patel | Foundation | Chief Data Officer (part-time advisory) | Founder and CEO of Kled, the opt-in human data marketplace integrated as the flagship app on DATA Network. (Source: DATA Foundation Launch Announcement) |
Michael Lewellen | DAO/Onchain Governance | Security Council member | The DATA Foundation names Michael Lewellen as a current Security Council member empowered to carry out Emergency and Non-Emergency Actions; no prior roles are disclosed. (Source: DATA Foundation Security Council) |
Vera the Ape | DAO/Onchain Governance | Security Council member | The DATA Foundation names Vera the Ape as a current Security Council member empowered to carry out Emergency and Non-Emergency Actions; no prior roles are disclosed. (Source: DATA Foundation Security Council) |
Anton Astafiev | DAO/Onchain Governance | Security Council member | The DATA Foundation names Anton Astafiev as a current Security Council member empowered to carry out Emergency and Non-Emergency Actions; no prior roles are disclosed. (Source: DATA Foundation Security Council) |
Patrick Collins | DAO/Onchain Governance | Security Council member | The DATA Foundation names Patrick Collins as a current Security Council member empowered to carry out Emergency and Non-Emergency Actions, and links his profile at @PatrickAlphaC. That profile identifies him as a co-founder of the smart contract security firm Cyfrin, a smart contract auditor, and a Web3 developer advocate and educator, associated with the CodeHawks competitive-audit platform, the Solodit audit-findings aggregator and Cyfrin Updraft. (Source: DATA Foundation Security Council) (Source: Patrick Collins on LinkedIn) |
Jason Li | DAO/Onchain Governance | Security Council member | The DATA Foundation names Jason Li as a current Security Council member empowered to carry out Emergency and Non-Emergency Actions; no prior roles are disclosed. (Source: DATA Foundation Security Council) |
Raúl Martínez | DAO/Onchain Governance | Security Council member | The DATA Foundation names Raúl Martínez as a current Security Council member empowered to carry out Emergency and Non-Emergency Actions. He holds the Head of Security role at PIP Labs, the primary development company for the network, alongside his Security Council seat; no earlier roles are disclosed. (Source: DATA Foundation Security Council) |
Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so. Address the lettered items below. Even if there is no DAO, there must be an answer to (d).
Response
The DATA Foundation DAO does not directly hold the protocol's intellectual property. The core protocol smart contracts live in the public repositories github.com/storyprotocol/protocol-core-v1 and github.com/storyprotocol/protocol-periphery-v1 and are released under a permissive open-source license (MIT or Apache 2.0). The Programmable IP License framework is a proprietary licensing framework developed by Story Foundation. The DAO's control over this IP runs through governance, because tokenholders vote on protocol upgrades and parameter decisions that govern the deployed contracts.
(Source: MiCA White Paper, Governance)
Tokenholders who hold at least 10,000 votes may submit proposals. All tokens are eligible to vote, unstaked tokens carry one vote each, and staked tokens carry 1.25 votes each. The DATA Foundation executes tokenholder governance decisions that pass under the Constitution. The Security Council may propose parameter adjustments, veto network upgrades or parameter changes, and take emergency actions that include pausing or freezing contracts, revoking or changing admin keys, and scheduling upgrades, patches, and parameter changes before full DAO approval. Each emergency action requires a full transparency report once disclosure is safe.
(Source: DAO Constitution, Governance, Security Council)
Staked tokens receive enhanced governance weight of 1.25 votes per token against one vote for unstaked tokens. For consensus and rewards, staked locked tokens and staked unlocked tokens carry the same voting power, while locked tokens earn staking rewards at half the rate of unlocked tokens. Locked tokens cannot be transferred or traded and release on an unlock schedule, and they may only be staked in the flexible period. Tokenholders may delegate voting power where delegation is technically available.
(Source: DAO Constitution, Staking Design)
$DATA confers no rights to revenue distribution, profit participation, dividends, or equity in the DATA Foundation or any affiliated entity, and it grants no redemption or reimbursement right. Tokenholder rights are limited to governance participation, namely voting on protocol upgrades, parameter decisions, ecosystem grants, and Foundation management matters as defined in the DAO Constitution. Newly minted tokens flow to block rewards and to a community pool, and the Foundation determines the use of the community pool, subject to a maximum community pool share of 20% of per-block emissions.
(Source: MiCA White Paper, Staking Design)
The Foundation, named in the DAO Constitution as Story Foundation, is a Cayman Islands foundation company, and its winding up is governed by Cayman Islands Law together with the Foundation Documents, being the Foundation Articles and the Foundation Bylaws. Tokenholders hold no dissolution authority whatsoever: the Constitution expressly lists voting to wind up and dissolve the Foundation itself among the Tokenholder Restricted Activities that tokenholders may neither propose nor approve, alongside voting to remove any Foundation Directors and voting to amend that restriction itself. Authority accordingly rests with the Foundation Directors and the Foundation Supervisor, each of whom holds powers and duties under Cayman Islands Law and as further described in the Foundation Documents. No onchain vote threshold for dissolution, and no mechanism for winding up the DAO as an entity distinct from the Foundation, has been publicly disclosed.
(Source: DAO Constitution, MiCA White Paper)
For the Primary Foundation do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
Story Foundation is a Cayman Islands foundation company, registered on April 19, 2024 at 3119 9 Forum Lane, Camana Bay, P.O. Box 144, Grand Cayman, KY1-9006, Cayman Islands, with Legal Entity Identifier 254900FX6QADHTOLX316. Its management body consists of three Directors, Matthew Shaw, Marc Piano, and Seung Soo Kim. Story Foundation operates under the "The DATA Foundation" brand following the June 25, 2026 rebrand. A separate entity, Narrative Universe Ltd., a Panama foundation registered on September 30, 2022, served as the genesis entity for the token, with the token generation event occurring on January 19, 2025. Narrative Universe Ltd. does not engage in commercial activity and holds no assets.
(Source: MiCA White Paper, DATA Foundation Launch Announcement)
Story Foundation developed the Programmable IP License, the proprietary licensing framework that encodes legal and economic license terms and enforces them onchain. The protocol's production smart contracts are open-sourced under a permissive license and deployed through multi-signature wallets with time-locked upgrade contracts.
(Source: MiCA White Paper)
The DATA Foundation supports the DATA Foundation DAO operationally, executes tokenholder governance decisions, promotes network security by creating the Security Council and appointing its members, and manages the treasury for long-term ecosystem growth. The Foundation may directly or indirectly purchase and sell $DATA at its sole discretion through open market transactions, OTC trades, block trades, privately negotiated transactions, or other means for market stability, operations, and ecosystem growth, and it has previously engaged in such transactions. The Foundation makes the final delegation decisions for the Foundation Delegation Program after receiving research and recommendations from the PIP Labs team.
(Source: Governance, DATA Foundation Disclaimer)
The PIP Labs team conducts research, diligence, and evaluation for the Foundation Delegation Program and presents recommendations to the DATA Foundation, while final decisions on delegation amounts and recipients rest with the Foundation. The available public sources show Foundation decision authority within that delegation program and do not describe broader corporate control rights of the Foundation over PIP Labs.
(Source: Governance)
The Foundation promotes network security by creating the Security Council and appointing members to it. The Security Council may pause or freeze contracts, revoke or change admin access, schedule upgrades, patches, and parameter changes before full DAO approval, coordinate fund recovery with governance where feasible, and veto network upgrades or parameter changes. The Council seats up to eleven members and currently seats six.
(Source: Security Council, Governance)
The DATA Foundation may buy or sell $DATA through open market, OTC, block, privately negotiated, or other transactions for market stability, operations, or ecosystem growth, and it may enter programmatic purchase or sale plans, on a proprietary basis for its own account. In the August 11, 2025 Heritage Distilling private placement, Story Foundation sold $IP to Heritage at a fixed price of $3.40 per token, and the issuer stated that 100% of the Foundation's net cash proceeds from that sale would be used to repurchase $IP in the open market within up to 90 days. The Foundation also discloses that it may purchase and sell securities of Heritage Distilling Holding Company, Inc. d/b/a IP Strategy at its sole discretion.
(Source: DATA Foundation Disclaimer, Heritage Distilling $360M Reserve)
For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
The DevCo is Story Protocol, Inc. d/b/a PIP Labs, located at 248 Homer Avenue, Palo Alto, California 94301, USA. The MiCA white paper names it as the initial core contributor to the network. It is a United States corporation operating from California.
(Source: MiCA White Paper)
PIP Labs builds and patches the protocol and distributes security releases to validators as the initial core contributor. The protocol smart contracts are open-sourced under a permissive license.
(Source: MiCA White Paper)
The PIP Labs team conducts research, diligence, and evaluation of validator submissions and presents recommendations to the DATA Foundation for delegation allocations. The available public sources do not show broader PIP Labs authority over the DAO, the treasury, or token administration beyond that recommendation role. (Source: Governance)
PIP Labs provides diligence and recommendations to the DATA Foundation for the Foundation Delegation Program, and final delegation decisions rest with the Foundation. The available public sources do not show that PIP Labs can compel or direct Foundation decisions.
(Source: Governance)
PIP Labs patches protocol issues and distributes security releases to validators. The available public sources do not specify a standalone PIP Labs pause, upgrade, or governance-executor threshold separate from the Security Council and DAO process.
(Source: Release Notes)
The disclosed economic arrangements are genesis token allocations rather than fee or revenue streams. The genesis distribution of 1,000,000,000 tokens assigns 20% to Core Contributors, described as compensation for hiring and retaining team members who have contributed to the development of the Story blockchain, and 21.6% to Early Backers, described as stakes for early investors and advisors; both categories remained locked at launch with unlocks occurring over 48 months, against 25% of total supply unlocked at launch. A further 10% is allocated to the Foundation for Foundation employees and services that grow the blockchain, and 38.4% to Ecosystem and Community. The published distribution does not name Story Protocol, Inc. d/b/a PIP Labs as the recipient of the Core Contributors allocation, and the project has not disclosed how much of that allocation is held by the entity as distinct from individual contributors. Neither the MiCA white paper nor the governance documentation discloses any protocol fee share, revenue-sharing arrangement, service agreement or ongoing treasury funding directed from the network or the Foundation to PIP Labs, and no distribution policy governing the Core Contributors allocation beyond the 48-month unlock has been published.
(Source: Introducing $IP, MiCA White Paper, Staking Design)
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
The genesis supply was 1,000,000,000 tokens, and the initial unlocked supply at launch was 25% of that total, or 250,000,000 tokens. The remaining 75% was subject to the lock and vesting arrangements described in (f). (Source: Introducing $IP, Staking Design)
No fixed initial offering price was set. The token entered the market through centralized exchange listings on February 13, 2025 rather than through a fixed-price public offering, so the launch price was market-set at listing rather than set by the issuer. (Source: MiCA White Paper, Data Network on CoinGecko)
The native token trades under the ticker DATA. It migrated 1:1 from the prior IP ticker on June 25, 2026, so filings and market data published before that date refer to the same asset as IP. (Source: FAQs, Data Network on CoinGecko)
The supply is not fixed and is mildly inflationary. Genesis supply was 1,000,000,000 tokens. The protocol emits a fixed quantity in the first year, set by the Foundation, with roughly 20,000,000 inflationary tokens per year flowing to block rewards and a community pool; annual emission in later periods is set by an emissions algorithm that is adjustable through governance or a hard fork. Gas fees are burned under EIP-1559, providing a partial offset. Current total supply stands at approximately 1,030,000,000 tokens. (Source: Staking Design, MiCA White Paper, Data Network on CoinGecko)
The community allocation unlocked on Day 1 of public mainnet through the Initial Incentives claim, and 25% of genesis supply was unlocked at launch overall. Early Backers and Core Contributors unlock over 48 months. The initial unlock date for locked team and investor tokens was February 13, 2026 and was delayed by six months to August 13, 2026. The DATA Foundation has not publicly disclosed a cliff-and-linear breakdown within the 48-month period or a release schedule specific to the Ecosystem and Community or Foundation allocations. (Source: Introducing $IP, The DATA Foundation)
Address each of the following sub-items based on the project's airdrop status. If a sub-item does not apply to the project's situation, state that explicitly.
Response
Planned but not yet executed airdrop
Not applicable. The Day 1 Initial Incentives claims program opened on February 13, 2025 and was distributed through the rewards portal rather than held back for a later date, so there is no pending tranche whose recipient wallet list could be committed to quarterly publication. The project has announced no further airdrop beyond the Initial Incentives program. (Source: Introducing $IP, MiCA White Paper)
Executed airdrop
This is the applicable branch. The Day 1 Initial Incentives claims program opened on February 13, 2025 through the rewards portal and distributed against pre-existing eligibility rather than against a purchase. Initial Incentives consist of 10% of the supply, split into 5% Direct Claims and 5% Ecosystem Projects.
Per-address source. No per-address source has been published. The rewards portal was built as a connected-wallet claim interface, which returns a single wallet's own eligibility and amount to the person holding that wallet and does not expose the recipient set; the project has published no CSV, TSV or JSON allocation file, no Dune table, no full Merkle dump, no GitHub repository file embedding per-address allocations, and no RPC endpoint exposing claim or amount data for the Day 1 Initial Incentives. The published record therefore establishes the size of each claim group as a share of supply but does not allow the recipient list or any individual allocation to be reconstructed from public data.
Projects must disclose all material terms of market-making arrangements that affect token liquidity. If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. For each market maker, include in a table:
If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for this item.
Response
The DATA Foundation discloses that it may execute token transactions through open market transactions, OTC trades, block trades, privately negotiated transactions, or other means, and that it may enter programmatic purchase or sale plans, on a proprietary basis for its own account. Story has not publicly disclosed any specific market-maker agreement, token allocation, loan, or structure. (Source: DATA Foundation Disclaimer)
Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:
If the project has no agreements or deals with CEX or DEX, state that explicitly; doing so earns full credit; cash/fiat fee amounts are not required for this item.
Response
The token is publicly listed and traded across multiple centralized exchanges. The MiCA white paper names OKX, Bitvavo, Coinbase, and Bithumb as admission-to-trading venues. Story has not publicly disclosed private listing agreements, token allocations supplied by the project for listing, or native-token listing fees for any of these venues. (Source: MiCA White Paper, Data Network on CoinGecko)
Disclose all prior token sales by the Project — including fundraising rounds, any material OTC sales to investors, and any discounted market-maker sales. For each sale, provide:
If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").
Response
The project completed corporate equity financings for PIP Labs and one public-company transaction that included a sale of tokens by Story Foundation. PIP Labs raised an $80M Series B led by a16z crypto, and total funding raised to date is reported at roughly $136M to $140M with participation from a16z crypto, Polychain, Samsung Ventures, and earlier backers including 11:11 Media. On August 11, 2025, Heritage Distilling Holding Company priced a $220M private placement, made of $100M in cash and $120M in tokens, and allocated $82M of proceeds to purchase tokens from Story Foundation at a fixed price of $3.40 per token. Story Foundation stated it would use 100% of the net cash proceeds to repurchase tokens in the open market within up to 90 days. At close, the Heritage treasury was expected to hold approximately 52.5 million tokens valued at approximately $361M based on the August 10, 2025 market price. A related ecosystem company, Poseidon, raised a $15M seed led by a16z crypto on July 22, 2025.
(Source: Messari Story Profile, Heritage Distilling $360M Reserve, Poseidon Seed Round)
If any, list prior exploits or incidents that directly affected the token, token supply, tokenholder balances, token contract, minting controls, burn mechanics, or custody of token supply. This question is not asking about general protocol, application, or smart contract exploits unless the incident directly affected the native token itself. If no prior incidents, state this explicitly (e.g., "No exploits affecting tokenholders or protocol funds as of YYYY-MM-DD").
Response
As of 2026-09-28, no exploit or security incident has been publicly reported that affected the DATA token (issued under its former ticker IP), its token contract, total supply, tokenholder balances, minting controls, burn mechanics, or the custody of token supply. Neither the DATA Foundation's own disclosures nor the public client release history records any such incident, and the MiCA white paper's audit-outcome section reports that every issue raised in the independent audits was addressed by the core development team rather than exploited in production.
Five dated security releases to the Layer 1 client software are on the public record. None of them affected the token itself; each is listed here for completeness, because each concerns the chain that issues and settles the token.
x/evmengine module, the block-size consensus parameters, and the validator CLI key handling. (Source: Story v1.2.0 “Ovid” release notes)Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.
(a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:
Impact of Regulatory Change on TGE and Listings: (If applicable) How could evolving or conflicting laws and regulations affect your ability to complete the TGE, deliver tokens to purchasers, and list or maintain the token on trading venues in key jurisdictions?
Entity-Level Regulatory Impact: (If applicable) How could regulatory or legal changes impact your core entities (Foundation, DevCo, DAO, affiliated service providers), including enforcement actions, licensing requirements, or forced changes to structure or operations?
Tokenholder Tax Treatment: (If applicable) What uncertainties exist around how tokenholders may be taxed, and make clear that tokenholders are responsible for understanding their own tax obligations?
Jurisdictional & User Access Restrictions: (If applicable) If the project restricts access for certain jurisdictions or user types (e.g., U.S. persons, sanctioned countries, retail vs. professional), what are those restrictions and what risks do they create for users and for the project?
(b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:
Bugs and Design Flaws: (If applicable) What bugs, design flaws, or implementation errors could exist in your core protocol code, smart contracts, and any bridges, rollups, or oracles that you depend on, and how could these lead to loss of funds or disruption of the protocol?
Security Measures & Their Limitations: (If applicable) What security measures have you taken (audits, formal verification, bug bounties), and what types of failures might these measures still fail to detect or prevent?
(c) Token Economics, Unlocks & Incentive Risks — Describe how the token's economic design and supply schedule could affect holders by answering, at a minimum, questions like:
Critical Economic Assumptions: (If applicable) Which economic assumptions (e.g., staking yields, fee revenue, liquidity incentives, MEV capture, demand for blockspace) are critical for protocol security, utility, and governance, and what happens if those assumptions fail?
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
Covered user segments and allocation method. The covered segments were Odyssey Badge Holders, Chronicles NFT holders who were also Odyssey Badge Holders, the Active Story Community, Social Rewards recipients, Exchange Based Program participants, validators, and ecosystem program participants; Core Contributors were not eligible to claim Initial Incentives. Eligibility in each case was earned before the claim opened: badge and NFT holdings were established by onchain ownership, community and social rewards by recorded participation, exchange-based programs by participation in the relevant venue's campaign, and validator rewards by operating validation infrastructure. The allocation was sized at the program level, with Direct Claims drawing on 5% of supply and Ecosystem Projects on the other 5%; the project has not published the per-segment split within Direct Claims or the formula converting a participant's recorded activity into a token amount. (Source: Introducing $IP, MiCA White Paper)
No airdrop planned or conducted
Not applicable, because an airdrop was conducted. The Day 1 Initial Incentives claims program described above was executed on February 13, 2025, so the project cannot state that it has never conducted one. (Source: Introducing $IP)
(Source: MiCA White Paper, Release Notes)
No exploit vector against the token is on the public record, because no incident against the token is on the public record. The vectors closed by the five client releases above were as follows.
MaxBytes block parameter in consensus params, closing an oversized-payload path into the execution engine; it also disallowed unexported fields in Cosmos transactions, and removed the --private-key flag from the validator CLI, which the release notes describe as a breaking change made “to prevent private key exposure,” replacing it with an encrypted key file. (Source: Story v1.2.0 “Ovid” release notes)DATADIR/geth/nodekey and regenerate the p2p node key after upgrading. (Source: Story-Geth v1.2.1 “Yasunari” release notes)(Source: Release Notes)
No loss of funds. Across all five releases, no DATA (formerly IP) tokens were lost, no tokenholder balance was altered, no unauthorized mint or burn occurred, and total supply was unchanged. Specifically:
The DATA Foundation has published no post-mortem quantifying any loss, and no chain halt, reorg, or balance correction is recorded against any of these releases.
(Source: Release Notes, MiCA White Paper)
The remediation pattern is consistent across the incidents and is documented in the release notes themselves.
MaxBytes consensus parameter changed, unexported fields in Cosmos transactions disallowed, and validator private-key encryption introduced in place of the removed CLI flag. (Source: Story v1.2.0 “Ovid” release notes)Alongside per-incident remediation, the Foundation states that Story and its Proof-of-Creativity smart contract protocol have undergone independent audits for every major release by Slowmist, FuzzingLabs, Halborn, and Trust Security, covering consensus, staking and slashing, execution, registration, and licensing; that all issues were addressed by the initial core development team; that it ran a timeboxed public security competition for independent auditors with a total prize pool of US$1 million; and that it maintains an ongoing bug bounty for responsible disclosure. The audit reports are published. (Source: MiCA White Paper, published audit reports)
All five are resolved. Each was closed by a shipped client release rather than left open, and no litigation, regulatory investigation, refund, or compensation event is associated with any of them.
No incident affecting the DATA token, its supply, or tokenholder balances is open, under investigation, or in litigation as of 2026-09-28.
Governance Control over Monetary Policy & Rewards: (If applicable) To what extent can governance change monetary policy, fee parameters, or reward allocations (e.g., inflation rate, treasury flows, incentive programs), and how could such changes adversely affect tokenholders?
Response
Impact of regulatory change on TGE and listings
The token generation event is complete and the token has been listed since February 13, 2025, so the live exposure is to continued venue availability rather than to completing a TGE. The MiCA white paper sets Malta as the home member state and all EU and EEA states as host member states, which means admission to and continuation of EU trading depends on continued MiCA compliance. Evolving or conflicting regulation in key jurisdictions could therefore restrict the project's ability to list or maintain the token on trading venues, both through MiCA compliance failure and through individual exchange listing terms. The DATA Foundation has not published a project-specific contingency plan for loss of venue availability. (Source: MiCA White Paper, Terms of Use)
Entity-level regulatory impact
The DATA Foundation is a Cayman Islands foundation company, the MiCA white paper sets applicable law as Malta, and disputes fall to the courts of the Cayman Islands. Regulatory or legal change could therefore reach the Foundation through Cayman, Maltese, or EU law, and could reach PIP Labs and affiliated service providers through their own jurisdictions. Such change could impose licensing requirements, enforcement actions, fines, or forced structural changes on the Foundation or its affiliates. Separately, copyright and patent infringement claims tied to AI training data carry direct litigation exposure for the project, given that the network's purpose is the sourcing and licensing of data for AI. The DATA Foundation has not disclosed a contingency plan for entity restructuring under such change. (Source: MiCA White Paper, Terms of Use)
Tokenholder tax treatment
Tokenholders bear their own tax obligations, and the published terms place responsibility on the holder for understanding and meeting them. Changes in tax rates or tax law could create additional liabilities for holders. The DATA Foundation has not published guidance on how staking rewards, claim receipts, or disposals are treated in any particular jurisdiction, and digital-asset tax treatment continues to differ between jurisdictions. (Source: MiCA White Paper, Terms of Use)
Jurisdictional and user access restrictions
The token is classified in the white paper as a utility token, and acquiring it grants no equity, ownership, profit participation, or revenue-sharing interest in the Foundation or its affiliates, and no redemption right. The token is not available for purchase or use in sanctioned or restricted territories, so access is jurisdictionally gated and some users are excluded outright. Future regulatory change could extend those restrictions to further jurisdictions. The DATA Foundation has not published the full list of restricted territories or the screening mechanism applied. (Source: MiCA White Paper, Terms of Use)
Bugs and design flaws
DATA Network runs on CometBFT Byzantine Fault Tolerant Proof-of-Stake consensus with roughly five-second block times and deterministic finality once a supermajority of more than two-thirds of validator voting power signs a block, so the network progresses only while that supermajority remains active and a coordinated failure or collusion among the active set can halt it. The active validator set holds the top 64 validators ranked by stake, which is a small set by comparison with larger Proof-of-Stake networks. The project documented post-launch critical issues involving possible chain halts, validator crashes, and malicious unstake edge cases, and responded with private validator releases followed by public patched releases — evidence that material implementation defects reached production. Confidential Data Rails, the threshold-encrypted confidential data layer, runs on the Aeneid testnet and carries the technical and operational risk of any pre-mainnet system. (Source: Staking Design, Security Council, CDR Overview)
Security measures and their limitations
The project ran audits with Slowmist, FuzzingLabs, Halborn, and Trust Security, ran a public security competition with a US$1,000,000 prize pool, and maintains an ongoing bug bounty. The Security Council holds emergency and non-emergency authority over technical governance, upgrade review, and incident response. Validators face slashing of 5% and permanent tombstoning for double-signing, and 0.02% with jailing for extended downtime, with delegators sharing the penalty of a slashed validator. These measures did not prevent the post-launch critical issues described in (a), which is the clearest disclosed limit on their coverage: audits and competitions test the code as submitted and do not detect defects introduced later or edge cases outside the tested surface, and the Security Council's emergency authority is itself a concentration of power that depends on the Council acting correctly and promptly. (Source: MiCA White Paper, Staking Design, Security Council)
Critical economic assumptions
The economic design assumes that staking yields remain sufficient to retain validators and delegators, and that demand for data on the network converts into recurring revenue. Locked tokens earn staking rewards at half the rate of unlocked tokens, and staking multipliers range from 0.5 for locked flexible staking to 2.0 for a 540-day fixed period, so security depends on holders continuing to accept long lock periods in exchange for yield. Concentration risk applies on the demand side because a large share of contributed data volume on the network runs through a single flagship marketplace, Kled, so failure or decline of that one venue would materially reduce network activity. Demand-side conversion into recurring lab revenue remains the central unresolved commercial question for the data thesis, and if it does not materialize the inflationary emission described in (b) is not offset by fee burn. (Source: Staking Design, DATA Foundation Launch Announcement, The DATA Foundation)
Governance control over monetary policy and rewards
Governance control over monetary policy is material. The protocol emits a fixed quantity in the first year, set by the Foundation, at roughly 20,000,000 inflationary tokens per year flowing to block rewards and a community pool; the annual emission in later periods is set by an emissions algorithm that is adjustable through governance or a hard fork. Governance can therefore raise the inflation rate and change reward allocation, diluting existing holders. Unlock timing is likewise subject to change by the project: the initial unlock for locked team and investor tokens moved from February 13, 2026 to August 13, 2026, which demonstrates that supply-overhang timing is a discretionary variable and remains material to holders. (Source: Staking Design, Introducing $IP, The DATA Foundation, MiCA White Paper)