Gideon, the Oathsworn has a +2 loyalty ability that reads:
+2: Until end of turn, Gideon, the Oathsworn becomes a 5/5 white Soldier creature that's still a planeswalker. Prevent all damage that would be dealt to him this turn. (He can't attack if he was cast this turn.)
In the card rulings, it states:
If damage that can’t be prevented is dealt to Gideon after his first loyalty ability has resolved, that damage will have all applicable results: specifically, the damage is marked on Gideon (since he’s a creature) and that damage causes that many loyalty counters to be removed from him (since he’s a planeswalker). Even though he’s also a creature, if Gideon has no loyalty counters on him, he’s put into his owner’s graveyard.
What is a scenario that could cause non-preventable damage after this ability has resolved, which states that it will "prevent all damage"?