Perhaps I wasn’t clear

I dont think the concern is loss in market value. The concern is a forced sale generating less than market value—essentially penalizing the appellant beyond the judgment value for pursuing an appeal.

My assumption (and he’d have to submit evidence for it) is that an injunction would adequately guard recovery — i.e. that he has assets multiple times the judgment such that there is not a real chance of failure to pay should it be affirmed, and that an injunction preventing the transfer of assets, recovery would be ensured.

If that’s true, and a court finds it could fashion a remedy that both ensures recovery and makes a potentially wasteful fire sale unnecessary, that seems like the best way to avoid irreparable harm and balance the interests of justice (2/3 of the factors). But its an equitable question and courts have wide discretion to fashion remedy here (perhaps combining an injunction on real estate assets with say a 200 million dollar bond)

Of course the other factor is likelihood of success on the appeal, and so it also depends in large part on the facial reaction to the merits of the appeal. If they think there’s a good chance they reverse or modify, that would weigh in favor of not forcing the fire sale (and vice versa).