[everfree]

> If Celsius is accepting deposits on existing addresses, they are continuing to accept deposits that they know their customers can't access.

Did you read the affidavit? Your argument is specifically pre-empted and refuted:

> It is important to understand that users transfer their digital assets from external “wallets” to the Celsius platform by recording such transactions on the blockchain. These transfers are entirely user driven with no ability for Celsius to “approve” or “deny” a transfer to its platform. This is a feature of the underlying blockchain infrastructure and cannot be technically changed or otherwise prevented.

It is impossible to create, for example, a Bitcoin address that has an "off switch" that will prevent people from sending additional bitcoins to it. It's a feature that most blockchains simply do not support.

In other words, Celsius did not "design the system without an off switch." Satoshi Nakamoto designed Bitcoin without an off switch.

[tromp]

> It's a feature that most blockchains simply do not support.

Notably, the feature of requiring receiver approval is inherent in blockchains using the Mimblewimble protocol.