There never seems to be a dull day in bitcoin.

This is an action for intentional interference with contractual relations and
injunctive relief arising from Wells Fargo’s interference with plaintiffs’ customer contracts.
Wells Fargo has suspended U.S. dollar wire transfer operations needed to remit to plaintiffs’
customers U.S. dollars that the customers deposited with plaintiffs to purchase digital currency,
causing imminent and irreparable harm to plaintiffs. Plaintiff Bitfinex’s business involves
Virtual Currency, which, as defined in this Complaint, refers to an emerging form of a digital
asset designed to work as a medium of exchange using cryptography to secure the transactions
and to control the creation of additional units of the currency. Tether operates a platform to
store, send, and make purchases with digital tokens called tethers that are backed by U.S. dollars
on deposit from customers. Wells Fargo’s suspension of U.S. dollar wire transfers also is
interfering with plaintiffs’ ability to conduct business, such as their ability to pay employees and
suppliers.

Effect of Wells Fargo’s Decision on Bitfinex’s and Tether’s Businesses
Wells Fargo’s decision to suspend U.S. dollar wire transfer operations from
plaintiffs’ correspondent accounts and its refusal to speak directly to plaintiffs about their
correspondent accounts has substantially interfered with plaintiffs’ ability to operate their
businesses and honor their contractual obligations to their customers, as plaintiffs’ counsel has
repeatedly informed Wells Fargo.
For example, customers have already begun complaining about the delay in wire
transfers.
Indeed, plaintiffs expressly informed Wells Fargo that its decision to suspend
outgoing wire transfers in U.S. dollars from plaintiffs’ correspondent accounts presented an
existential threat to their businesses. They informed Wells Fargo that if plaintiffs could not remit
to customers U.S. dollars that belong to their customers, plaintiffs’ businesses would be crippled
as of Wednesday April 5, 2017. They would be brought to a standstill.
Plaintiffs’ inability to transfer U.S. dollars to their customers also will almost
certainly undermine plaintiffs’ reputation and customer goodwill, resulting in the loss of both
current and prospective customers.