It's true that it may be a rather spoilery sub-title to those who are familiar with the comics, but I can kind of understand it. The truth of the matter is, in this day and age, with IMDB listings, studio leaks and eyewitness reports, it would be too hard to keep something like Sebastian Stan's return for the sequel a secret anyway. Fans would immediately guess that they were doing the "Winter Soldier" anyway, so they might as well roll with it and create as much early buzz as they can.