Measuring Damages In Avoidance Actions That Target Cryptocurrency Transfers

Celsius Network, LLC operated as a cryptocurrency lending and yield platform. At its peak, Celsius had roughly 1.7 million customers and nearly $12 billion in assets under management. In June 2022, however, Celsius froze withdrawals, and by July 2022, Celsius and its affiliates filed voluntary petitions for relief in the Bankruptcy Court for the Southern District of New York (the Court) under Chapter 11 of the Bankruptcy Code. After the Court confirmed the Celsius Chapter 11 plan, Mohsin Y. Meghji, as the litigation administrator for the Celsius post-confirmation estate (the Litigation Administrator), commenced thousands of avoidance actions against former Celsius customers to recover preferential transfers made in the 90 days before the bankruptcy petition date.