In a recent legal opinion delivered by Judge Colm Connolly in the case of Sun v. Bloomberg, L.P. (D. Del.), significant issues regarding the disclosure of cryptocurrency holdings have emerged. On August 11, 2025, after an extensive verification process concerning the assets of Justin Sun, Bloomberg included his profile in its Billionaires Index, a comprehensive ranking of the wealthiest individuals globally. The profile in question included two key statements: it claimed that Sun possesses over 60 billion Tronix (commonly known as TRON or TRX), the cryptocurrency associated with the Tron network, based on financial information supplied by Sun’s representatives in February 2025. Additionally, the profile stated that Sun holds approximately 17,000 Bitcoin, 224,000 Ether, and 700 million Tether, as per the same analysis.
Sun contends that the publication of the “alleged specific amounts of cryptocurrencies” he controls is a violation of his privacy, asserting that Bloomberg is barred from releasing “financial information regarding the value of specific assets and details related to [his] ownership of those assets.” He claims Bloomberg had assured him that it would not disclose “the amounts of specific cryptocurrency” he owns and that it would implement measures to safeguard his confidential financial information. After Bloomberg released the profile, Sun promptly filed an initial complaint and sought a temporary restraining order and preliminary injunction. However, he retracted his motion three days later, citing ongoing discussions that might have rendered the motion unnecessary. Unfortunately, these negotiations appear to have faltered, leading Sun to file a new motion on September 11, demanding that Bloomberg (1) “remove the amounts of any specific cryptocurrency owned by Mr. Sun from any of its online publication,” (2) “retract its claim that Mr. Sun owns 60 billion Tronix and controls the majority of its supply,” and (3) “refrain from publishing the amounts of any specific cryptocurrency owned by Mr. Sun in any future publication.”
When evaluating Sun’s claims, the court found that he has not convincingly demonstrated that he is likely to prevail on his promissory estoppel claim. To succeed in this legal argument, Sun must prove through clear and convincing evidence that (1) Bloomberg made a promise; (2) it was reasonable for Bloomberg to expect that this promise would induce some action or inaction from Sun; (3) Sun reasonably relied on this promise, resulting in detrimental actions on his part; and (4) enforcing the promise is necessary to prevent injustice. Sun attempts to establish the first aspect of his claim by asserting that Bloomberg made explicit promises regarding the confidentiality of the information he provided before deciding to participate in the Billionaires Index. He references his own declaration, which states that a Bloomberg reporter, Muyao Shen, assured him that any information shared would remain confidential and solely used for verifying his personal assets for the Index profile. However, Bloomberg counters this assertion with its own declarations, stating that Shen did not make any promises of confidentiality concerning the information related to Sun’s coverage. Two additional members of Bloomberg’s Billionaires Index team also affirm that they never guaranteed confidentiality regarding the data shared by Sun and his team. Based on the evidence presented, the court concluded that Sun has not satisfactorily demonstrated that Bloomberg made explicit promises regarding the confidentiality of the information provided.
Consequently, Sun’s assertion that he is likely to succeed on the merits of his promissory estoppel claim remains unsubstantiated. Moving on to Sun’s claim concerning public disclosure of private facts, for him to succeed, he would need to establish that (1) there was public disclosure, (2) of a private fact that would be deemed offensive and objectionable by a reasonable person, and (3) this fact is not of legitimate public concern. Sun argues that Bloomberg’s dissemination of his cryptocurrency holdings to millions of online readers, along with threats of further publicizing this information in another article, would be deeply offensive to a reasonable individual. He believes that revealing his cryptocurrency ownership increases his vulnerability to threats such as hacking, phishing, kidnapping, or even bodily harm. However, prior to Bloomberg’s publication, other organizations, including Nansen, had already offered similar, if not more detailed, assessments of Sun’s assets. Furthermore, Sun himself has previously disclosed far more detailed information about his Bitcoin holdings than what Bloomberg reported. Given these circumstances, the court finds that Bloomberg’s publication of estimates regarding Sun’s cryptocurrency holdings—information that is arguably less specific than what has already been made public—does not rise to the level of being objectively offensive to a reasonable person. Thus, Sun has failed to convincingly demonstrate that he is likely to succeed on his public disclosure claim regarding private facts.
Bloomberg is represented by a team of legal professionals, including Jeffrey J. Lyons, Isabelle Corbett Sterling, Teresa Goody Guillen, and Katherine L. McKnight from Baker & Hostetler LLP, as well as James M. Yoch, Jr. and Robert M. Vrana from Young Conaway Stargatt & Taylor, LLP.
