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relatively straightforward to identify wallet addresses with distinctive characteristics, such as unusually large balances or unique compositions of cryptoassets. 40. Thus, by disclosing the specific amounts of Plaintiff’s cryptocurrency holdings broken out by cryptocurrency, Bloomberg will provide everyone—including bad actors—with vital information necessary to identify crypto wallets that are owned by Plaintiff. Indeed, even if holdings are split among multiple wallets, bad actors can identify linked wallets through address clustering techniques, which analyze patterns such as common inputs, transaction flows, or behavioral signals, to find multiple addresses controlled by the same individual or entity. 41. As soon as the Plaintiff’s wallets are identified, associated wallets can also be found. 42. Given his significant crypto holdings, once Plaintiff’s wallet numbers are known, Plaintiff will become a considerable target for bad actors who can use the information to determine the methods to carry out an attack, which may include a variety of tools to steal, extort, and attack Plaintiff. 43. For example, attackers can use advanced, tailored, and targeted social engineering and phishing to obtain the seedphrase (which functions similar to a password) which would allow them to steal the funds from Plaintiffs’ wallets. These bad actors might also impersonate a cryptoexchange or wallet provider. It is well known in the industry that these bad actors can craft extremely
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relatively straightforward to identify wallet addresses with distinctive characteristics, such as unusually large balances or unique compositions of cryptoassets. 40. Thus, by disclosing the specific amounts of Plaintiff’s cryptocurrency holdings broken out by cryptocurrency, Bloomberg will provide everyone—including bad actors—with vital information necessary to identify crypto wallets that are owned by Plaintiff. Indeed, even if holdings are split among multiple wallets, bad actors can identify linked wallets through address clustering techniques, which analyze patterns such as common inputs, transaction flows, or behavioral signals, to find multiple addresses controlled by the same individual or entity. 41. As soon as the Plaintiff’s wallets are identified, associated wallets can also be found. 42. Given his significant crypto holdings, once Plaintiff’s wallet numbers are known, Plaintiff will become a considerable target for bad actors who can use the information to determine the methods to carry out an attack, which may include a variety of tools to steal, extort, and attack Plaintiff. 43. For example, attackers can use advanced, tailored, and targeted social engineering and phishing to obtain the seedphrase (which functions similar to a password) which would allow them to steal the funds from Plaintiffs’ wallets. These bad actors might also impersonate a cryptoexchange or wallet provider. It is well known in the industry that these bad actors can craft extremely
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