Some example,
1. Anyone (such as exchange) who become victim of their double-spend attack.
2. If the attack performed by company who own mining pool, miner theoretically can sue them for misuse of their hashrate.
This are good examples but we all know how law suits stand against Chinese owned companies, they will not care.
I think we can agree that 51% attack (on any of the network) would be only possible if hashrate drastically dropped due to some reasons like profitability collapse and then it would make financial sense to attack it by smaller attackers.