Ping Fai Yuen v Fun Yung Li & Anor
Claims in conversion are struck out as English law does not permit conversion of intangible property such as Bitcoin; trespass to goods is not struck out at this stage pending possible amendment; security for costs is refused due to overwhelming evidence, assets within jurisdiction, and unreliable cost estimates; substituted service is granted for Second Defendant.
- Parties
- Claimant: Ping Fai Yuen; First Defendant: Fun Yung Li; Second Defendant: Lai Yung Li
- Jurisdiction
- England and Wales
- Judgment Date
- 03 October 2026
- Procedural Posture
- Civil / Interlocutory Judgment on Amendment, Strike Out, Security for Costs, and Substituted Service Applications
- Outcome
- Claim in conversion struck out; trespass to goods claim not struck out pending amendment; security for costs application dismissed; substituted service granted.
- Legal Topics
- Digital Assets, Conversion, Trespass to Goods, Unjust Enrichment, Breach of Confidence, Misuse of Private Information, Proprietary Restitution, Constructive Trust, Security for Costs, Substituted Service
Case Brief
Summary, issues, holding and outcome
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Parties
Ping Fai Yuen
Claimant
Fun Yung Li
First Defendant
Lai Yung Li
Second Defendant
Procedural Posture
Civil / Interlocutory Judgment on Amendment, Strike Out, Security for Costs, and Substituted Service Applications
Legal Issues
- 1 Whether Bitcoin is capable of being converted under English law
- 2 Applicability of trespass to goods to digital assets
- 3 Availability of proprietary restitution and constructive trust remedies for misappropriated Bitcoin
Ratio Decidendi
Claims in conversion are struck out as English law does not permit conversion of intangible property such as Bitcoin; trespass to goods is not struck out at this stage pending possible amendment; security for costs is refused due to overwhelming evidence, assets within jurisdiction, and unreliable cost estimates; substituted service is granted for Second Defendant.
Court Disposition
Claim in conversion struck out; trespass to goods claim not struck out pending amendment; security for costs application dismissed; substituted service granted.
Orders
- Claim in conversion struck out.
- Claimant given seven days to apply to amend trespass to goods claim.
Full Case Text
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