New York Lawsuit Takes Aim At 3.79 Million Dormant Bitcoin

bitcoinistPublished on 2026-05-25Last updated on 2026-05-25

Abstract

A lawsuit filed in New York by "Noah Doe" and two Wyoming LLCs seeks a court declaration that approximately 39,069 long-dormant Bitcoin wallets, allegedly holding about 3.79 million BTC, are legally abandoned property. The plaintiffs claim to have identified the wallets, reported them to the NYPD, and conducted a notification campaign via blockchain messages and a webpage. They argue this satisfies New York's lost-property laws, transferring ownership rights to them. The claim includes addresses linked to Satoshi Nakamoto and early miners, though the complaint itself does not specify these attributions or the total BTC amount. The case centers on the novel legal argument that inactive self-custodied crypto addresses constitute recoverable abandoned property, despite the practical impossibility of accessing the funds without private keys. The campaign was connected to Salomon Brothers Strategic Advisors, a firm separate from the historic Wall Street entity.

A New York lawsuit is seeking a court declaration over tens of thousands of long-dormant Bitcoin addresses that one outside analysis says collectively hold about 3.79 million BTC. The case, brought by “Noah Doe” and two Wyoming LLCs, attempts to frame inactive self-custodied crypto addresses as abandoned property under New York lost-and-found law.

The filing, submitted in the Supreme Court of the State of New York, County of New York, names ABC Company, XYZ Company and Noah Doe as plaintiffs, with “John Does 1–39,069” listed as respondents. It is not a court order awarding ownership. It is a summons and amended complaint seeking declaratory relief, meaning the plaintiffs are asking the court to recognize their claimed rights to the wallets and their contents.

According to the complaint, Doe allegedly identified three sets of dormant digital wallets between December 2024 and April 2025. The first group included 1,625 wallets, or 1,544 after duplicates were excluded. The second included 546 wallets. The third and largest group included 39,911 wallets. After exclusions and alleged owner responses, the plaintiffs say the case concerns 39,069 remaining wallets they describe as abandoned.

3.79 Million Bitcoin Caught In Bizarre NY Legal Fight

The complaint says Doe reported the wallet lists to the New York City Police Department on three separate occasions using USB drives. The NYPD later returned the drives, according to the filing. The plaintiffs argue that these steps satisfied New York lost-property procedures and that title vested in Doe under New York Personal Property Law § 257 before later assignments moved most of the claimed rights into ABC Company and XYZ Company.

The size of the claim is what has drawn attention across Bitcoin circles. Sani, the operator of TimechainIndex.com, said on X that the addresses listed in the case hold 3,791,121.17697938 BTC and include addresses attributed to Satoshi Nakamoto, early miners, Casascius Coins, lost coins, hackers and unidentified entities. That aggregate BTC figure and those attributions do not appear in the complaint’s body. The filing itself lists addresses and lays out the legal theory, but it does not state “Satoshi Nakamoto,” “Casascius,” or the 3.79 million BTC total.

The legal argument is unusual because it treats dormant Bitcoin addresses as recoverable property, even though the complaint acknowledges that cryptocurrency cannot be withdrawn without the relevant private key. The filing compares wallets to bank accounts, arguing that a digital wallet can be uniquely identified by blockchain protocol, address and transaction history. But that analogy is likely to draw scrutiny from Bitcoin-native observers because ownership of a bank account and control over a self-custodied Bitcoin UTXO operate very differently in practice.

The background to the lawsuit appears to trace back to a broad on-chain notice campaign tied to Salomon Brothers Strategic Advisors. The complaint says Doe retained Salomon Brothers in February 2025 as a strategic consultant to help develop a plan for notifying potential wallet owners and identifying wallets incorrectly included in the allegedly abandoned group. It later says a cyber/blockchain expert sent messages to wallet holders using OP_RETURN, while Salomon Brothers hosted a notice webpage.

Salomon Brothers publicly framed the campaign as an effort to address risks around abandoned wallets. In an August 2025 press release, the firm said abandoned wallets could become vulnerable to better-resourced attackers and argued that “securing wallets protects” other wallet holders. The release said notices had been inserted into long-dormant wallets and gave owners at least 90 days to respond, either by conducting an on-chain transaction with the private key or by using a form on a Salomon Brothers webpage.

That Salomon Brothers connection requires careful context. Galaxy Research described the entity involved as not the historic Wall Street firm that became part of Citigroup, but a newer organization that acquired the Salomon name. Salomon Brothers’ current website describes the firm as an “alliance of professional practices” providing services including financial advisory, real estate finance and research.

Galaxy’s analysis of the related OP_RETURN campaign described it as the “Great Bitcoin Dusting.” According to Galaxy, an unknown actor sent 41,523 OP_RETURN messages from 3,738 sender addresses to 39,423 recipient addresses, which together held 2,334,482.52 BTC when the messages were transmitted. Galaxy said the campaign had two phases: initial trial messages without Salomon links, followed by waves of messages that included links to Salomon’s website.

Galaxy also found that 98.82% of the notified addresses were legacy P2PKH addresses and that the average adjusted dormancy was about 2,171 days, or roughly 5.95 years. That detail matters because Sani separately argued that, for many old coin holders, including wallets attributed to Satoshi Nakamoto, notices were sent to P2PKH versions of addresses with no or only dust balances, while the real balances sit in older P2PK outputs. If accurate, that distinction could become central to the crypto community’s assessment of whether meaningful notice was ever delivered to the relevant holders.

The case now sits at the intersection of legal doctrine and protocol reality. The plaintiffs are asking a New York court to treat inactivity as abandonment and to recognize claimed ownership over wallets that have not moved for years. Bitcoin users, meanwhile, are likely to focus on a narrower but more fundamental issue: an address can be dormant because its owner is gone, because keys are lost, or because the holder has no intention of moving coins. On-chain, those cases can look identical.

At press time, BTC traded at $77,441.

Bitcoin hovers below the 20-week EMA, 1-week chart | Source: BTCUSDT on TradingView.com

Related Questions

QWhat is the core legal claim in the 'Noah Doe' New York lawsuit regarding dormant Bitcoin addresses?

AThe lawsuit argues that tens of thousands of long-dormant, self-custodied Bitcoin addresses constitute 'abandoned property' under New York lost-and-found law. The plaintiffs seek a court declaration recognizing their claimed ownership rights to these wallets after allegedly following state procedures for reporting found property.

QApproximately how much Bitcoin is implicated in the lawsuit according to an outside analysis, and what notable addresses are mentioned?

AAccording to an analysis by Sani of TimechainIndex.com, the addresses listed in the complaint collectively hold approximately 3.79 million BTC. The analysis states these include addresses attributed to Satoshi Nakamoto, early miners, Casascius Coins, lost coins, hackers, and other unidentified entities.

QWhat entity was involved in the notification campaign to the dormant wallet owners, and what method was used?

AThe plaintiffs retained Salomon Brothers Strategic Advisors to help develop a notification plan. A cyber/blockchain expert sent messages to wallet holders using OP_RETURN transactions on the Bitcoin blockchain, and Salomon Brothers hosted a webpage for owners to respond.

QWhat key distinction did the analysis from Galaxy Research make about the notification campaign's effectiveness?

AGalaxy Research noted that 98.82% of the notified addresses were legacy P2PKH addresses. Sani further argued that for many old coin holders (including those attributed to Satoshi), notices were sent to P2PKH versions of addresses with little to no balance, while the real balances resided in older, non-standard P2PK outputs, questioning whether meaningful notice was delivered.

QWhat is a fundamental practical challenge to the lawsuit's claim of ownership over these dormant wallets?

AA fundamental challenge is that ownership/control of a self-custodied Bitcoin wallet is cryptographically secured by a private key. The complaint acknowledges the coins cannot be withdrawn without the key. Therefore, a court order granting ownership does not inherently grant the ability to spend the coins, unlike with a traditional bank account.

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