On a second thought, you are right because those Bitcoin were not product of investment so they will not really count it as a loss. The Bitcoins were products of seizures made by the German government so there was no point considering them.as investment. In another perspective, and like you rightly said, the Bitcoin sales were permitted by their legislation which made it binding on anyone in control of them to sell them as required by law. I think everything followed their laws and process hence no point calling this a loss to them. However, should they had known that Bitcoin will reach this high within that short interval, they would have still held because they were never facing any austerity measures.
So you say they don't have the idea that October, November are the bullish months even the first 10 to 15 days of December are also bullish and they sold their assets? They would not have sold if they had the more profit making mindset as many of the members including you also said they did not planned to make profit and underestimated the idea that they could have gain 2 more billions by just this selling and welcoming only 2 billion is seems to me a bit idiotic. That's just I wanted to express, but as you and me said in the start that it's their funds, whatever they do, I know they are seized from the start even if you check the last topic I created it was on the same topic. So I know much about it and just wonder why they sold it all. But some members pointed out here that they have to liquidate the seizure funds of crypto within a year, and they seized it in Jan CMIIW and still they had 1 year so they could have sold now, but their selling gave many investors a good entry price and it was healthy for the market too.
But they could have made more profit don't get what's the hurry to sell them. 
