Satoshi Nakamoto Sued? $83.7 Billion in BTC Up for "Legal Claiming"

Original article fromGalaxy

Compiled by / Odaily Golem (@web3_golem)

Who would have thought that Satoshi Nakamoto, the creator of Bitcoin, would one day find himself in a lawsuit, with the "ownership" of his wallet addresses potentially being snatched away. And you, reading this article right now, could also be one of the "defendants" — as long as you have dormant Bitcoin addresses.

In March of this year, the New York State Supreme Court accepted a lawsuit: the plaintiff seeks to establish ownership of over 3.7 million Bitcoin (approximately $274 billion) linked to 39,069 Bitcoin addresses. The plaintiffs are pseudonymously named Noah Doe and two unnamed Wyoming limited liability companies (pseudonymously "ABC Company" and "XYZ Company").

The plaintiffs are asking the New York State Supreme Court to confirm, through a declaratory judgment action under New York's abandoned property law, that they own these dormant assets. More importantly, these 39,069 addresses include those suspected to belong to Bitcoin creator Satoshi Nakamoto (a total of 21,744 addresses holding approximately 1.09 million Bitcoin, worth about $83.7 billion at current prices).

Simply put, an anonymous individual and his Wyoming-registered companies are trying to get a New York court to rule that Satoshi Nakamoto's Bitcoin (and numerous other cryptocurrencies) constitutes lost property, and that they are entitled to legal ownership because they "found" these Bitcoins. Galaxy has analyzed the plaintiffs' potential motives and identities, the impact on Bitcoin, and the likelihood of the plaintiffs prevailing.

Below is Odaily’s condensed translation of the full text. Enjoy~

Case Overview and Breakdown of Plaintiff's Strategy

The plaintiffs have filed a petition with the New York State Supreme Court, requesting a declaration that they own the 39,069 dormant Bitcoin addresses and all assets within them. The legal basis is a declaratory judgment confirming ownership under New York Civil Practice Law & Rules Article 3001, rooted in New York's abandoned property law, Article 7-B of the Personal Property Law. This provision stipulates that a finder of lost property who turns it over to the police and faces no claim from the owner within a specified waiting period can ultimately acquire ownership. The plaintiffs attempt to apply this old framework to Bitcoin.

The specific strategy is as follows: Noah Doe, as the finder, delivers a USB drive containing the addresses (not private keys or proof of address ownership, merely public addresses) to the 17th Precinct of the NYPD, fulfilling the requirement of turning over the lost item to the police. He then initiates OP_RETURN notifications on the Bitcoin blockchain and issues a press release, fulfilling the requirement of attempting to contact the owner. Finally, an expert appraises each address as being worth less than $10, pushing the entire case into the fastest procedure allowed under this provision.

It is necessary to clarify that even if the plaintiffs win completely, they would only receive a piece of paper — a court declaration. That's it. They would not receive any private keys and would not be able to transfer any Bitcoin.

The true value of a New York judgment lies elsewhere. It would act as a "cloud on title": if these Bitcoins ever appear at any regulated venue, the plaintiffs could present this document to challenge the exchange or custodian. This is the potential risk this case poses to Bitcoin holders and why this seemingly outrageous lawsuit is still worth a close look.

Case Timeline

The timeline below consists of two parts: the factual narrative of the plaintiff's discovery of the addresses, and the procedural history of the case in court.

• October 2024: Noah Doe claims he discovered a "security issue" with certain addresses and developed an "algorithm" to mark abandoned addresses. (In reality, no "security issue" existed for these addresses);
• December 26, 2024: Noah Doe first "finds" approximately 1,625 addresses. A USB drive containing the addresses is delivered to the 17th Precinct of the NYPD on January 1, 2025;
• February 2025: Noah Doe retains Salomon Brothers Strategic Advisors as consultants;
• March 31, 2025 and April 14, 2025: Noah Doe "finds" another 546 and then 39,911 addresses respectively, delivering USB drives containing the addresses to the police precinct each time;
• June 30, 2025 – July 10, 2025: Noah Doe sends "abandonment notices" to each address via OP_RETURN;
• August 7, 2025: A press release is issued to global media, covered by CoinDesk, Bitcoinist, Yahoo Finance, Investing.com, and Galaxy Digital's research report;
• August 2025 – February 2026: Salomon Brothers receives threatening emails, including over 50 emails containing only "4 8 15 16 23 42" and demanding $1.5 million and 50 Bitcoin;
• October 10, 2025: The 90-day period for owners to claim the property expires;
• December 2025: Noah Doe transfers these addresses to ABC Company and places 98% of the interest into an irrevocable trust. ABC Company transfers a 17.7% interest to XYZ Company;
• March 11, 2026: The initial summons and complaint are filed. Judge Arlene P. Bruce annotates the original order to appear and testify;
• March 23, 2026: Judge Emily Morales-Minerva recuses herself from the case;
• March 25, 2026 – April 17, 2026: Judge Carlos J. Voltron signs orders allowing appearance under pseudonyms and authorizing alternative service via OP_RETURN (without notification to the opposing party);
• May 1, 2026: The first amended complaint expands the defendant pool to 1-39,069 individuals and includes the complete list of addresses;
• May 21, 2026 – May 22, 2026: On-chain execution service occurs, involving 98 batch transactions within Bitcoin blocks 950,446 to 950,576;
• May 22, 2026: Judge Carlos J. Voltron files an affidavit of service, including verification reports for each batch of transactions and verification details for 39,069 lines (Documents 27-29).

Plaintiffs' Legal Basis and Strategy

Article 7-B of the New York Personal Property Law (Sections 251-258) establishes a concise framework for lost property. It provides two distinct paths for a finder to acquire ownership, and the plaintiffs in this case invoke both simultaneously.

• Path A: Custody (Sections 252, 253/254, 257(1)). Section 252 requires a person finding lost property worth $20 or more to return it to the owner or deliver it to the police within 10 days. Sections 253(7) and 254 dictate police custody periods based on value: 3 months for items under $100, 6 months for $100-$500, 1 year for $500-$5,000, and 3 years for items worth $5,000 or more.
• Path B: Fast Track for Items Under $10 (Section 257(2)). For lost items valued under $10, if the finder has "made reasonable efforts to find the owner and return the property, but failed," ownership vests in the finder after one year, without needing police delivery.

The complaint's (unnamed) "independent expert" values each address at "present value" of under $10, based on the improbability of recovering the items. This valuation dictates the procedural timeline of the entire case by placing each address under the uniform one-year vesting period of Section 257(2). It also makes Path A shorter, as items valued under $100 only need to be held by police for three months under Section 254.

Plaintiffs' Arguments

The complaint lists several arguments by the plaintiffs, each building upon the previous one in a chain of logic.

• The addresses are lost property. Addresses are considered property, akin to bank accounts. In this view, losing a private key doesn't destroy the property; its contents are simply "lost" and can be recovered by a finder.
• Noah Doe is the finder, and custody with the NYPD meets statutory requirements. Article 7-B Section 252 requires the finder to turn over the lost item to the police. The plaintiffs argue that the USB drive containing address information, delivered to the 17th Precinct, satisfies this requirement.
• Title has vested in the finder. For property valued under $10, Section 257(2) states that if the finder has made reasonable efforts to find the owner but failed, title vests in the finder after one year. The OP_RETURN notices, press release, and 90-day claim period are considered reasonable efforts.
• The addresses have been abandoned. Noah Doe's "algorithm" flags addresses held by his own firm, unused for at least five years, and unresponsive during significant price increases. Approximately 424 owners who responded by moving tokens were removed from the list. The remaining 39,069 unresponsive owners became defendants.
• Service via OP_RETURN is legal. Since the alleged owners are unknown and unlocatable, the court authorized alternative service under CPLR Section 308(5), i.e., sending an on-chain notice referring to the complaint to each address.
• The plaintiffs can sue under pseudonyms. Given the risk of kidnapping for known large Bitcoin holders, the plaintiffs were permitted to proceed under pseudonyms.

Who Are the Owners?

Galaxy analyzed the addresses that plaintiff Noah Doe claims to have "found" using their full Bitcoin node and internal research database.

As of May 25, 2026, the 39,069 "Noah Doe addresses" held 3,799,629 Bitcoin, worth approximately $293.5 billion at a price of $77,245 per Bitcoin. This value is not evenly distributed but is concentrated in several distinct groups, each telling a different story.

Composition of Noah Doe Addresses

Patoshi Addresses

Includes 21,923 addresses holding approximately 1,096,134 Bitcoin (≈ $84.7 billion). These are early-mined Bitcoins linked to Bitcoin's creator via the "Patoshi" nonce pattern; they have never been moved.

Mt. Gox Hacker Address

Just 1 address holding approximately 79,957 Bitcoin (≈ $6.2 billion). This is John Doe #1, belonging to the bitcoins stolen from the early Bitcoin exchange Mt. Gox. They have remained untouched since 2011. This is disputed property that investigators have tracked for years.

Counterparty Burn Address

Just 1 address holding approximately 2,131 Bitcoin (≈ $160 million). This is John Doe #104, a provably unspendable "burn" address. No one ever held its keys because, by design, no such key exists.

Other Dormant Addresses

7,144 addresses holding approximately 2,621,407 Bitcoin (≈ $202.5 billion). These addresses contain substantial Bitcoin from early adopters and the exchange era, untouched for many years.

This dormancy is long-standing. If we sort each address by the year of its last on-chain Bitcoin transfer, we find that most Bitcoin transfers are concentrated in Bitcoin's early years. The vast majority of these Bitcoins were last transacted between 2009 and 2013, a period when Bitcoin's price surged from nearly zero to a few hundred dollars.

But many of these addresses have been claimed before. In the Kleiman v. Wright case (Southern District of Florida, 2018), Australian businessman Craig Wright filed a list of 16,404 early block addresses he claimed belonged to him, as part of his (later dismissed) claim to be Satoshi Nakamoto.

We compared the Bitcoin addresses Craig Wright claimed ownership of in the Kleiman lawsuit with the Noah Doe addresses to see the overlap.

Overlap between Noah Doe and Craig Wright Addresses

The overlap is nearly complete: 16,350 out of Wright’s 16,404 claimed addresses (99.7%) are also claimed by Noah Doe’s defendants, holding approximately 817,513 Bitcoin. We cannot determine if Craig Wright has any connection to the Noah Doe case, but the overlap remains noteworthy. Craig Wright spent years trying to claim these Bitcoins through litigation but was found in contempt of court by a UK court in 2024.

Suspicious Points in the Case

While we are not lawyers, looking purely at the docket records and relevant statutes, this case presents several red flags.

Does Abandoned Property Law Apply?

Before any valuation or service issues, there is a more fundamental question: the abandoned property law is designed for physical items that a finder picks up, holds, and delivers to the police. Noah Doe never held the coins or the keys. He merely looked at public addresses on a public ledger that anyone can read. Looking at a public address is far from holding lost property. Turning over a USB drive with a list of addresses to the police is not the same as physically surrendering the lost item.

The statute envisions a finder who can return the item if the owner shows up. In this case, the finder never held the coins and couldn't possibly hand them over to anyone, whether to the police acting as custodian or to an owner who comes to claim them. The crux of the issue goes far beyond ownership; losing a private key does not deprive the true owner of any rights whatsoever. The Bitcoin remains on the chain. The true key holder can move them at any time, and hundreds of Bitcoin owners who had lost their keys have done exactly that.

It is axiomatic that ownership cannot be effectively transferred to a finder who can never access the asset.

Valuation is Unreliable

The average holding in Noah Doe's addresses is 97.25 Bitcoin, worth approximately $7.5 million; the median is 50.00 Bitcoin, worth approximately $3.86 million. Compared to these figures, the claim that each address is worth under $10 is fundamentally untenable and appears to be a tactic to push these assets through the legal process at the fastest possible speed.

Two additional details further undermine this valuation. The expert who provided the "under $10" figure is unnamed in the documents. Therefore, this single figure that dictates the entire timeline cannot be scrutinized or challenged. If the logic of "recoverability as-is" were applied universally, the value of almost all self-custodied Bitcoin would be near zero, which entirely contradicts how any user treats their Bitcoin, especially plaintiffs who go to such lengths to file a lawsuit.

Anonymity of the Parties

The use of anonymity by Noah Doe in this case is also highly suspicious. They request anonymity to avoid being tracked as large holders, yet they seek an interest that would force the holders of the actual addresses to reveal their identities to defend their crypto. The plaintiffs seek protection for themselves that they want to deny all defendants.

Even if an individual can present a legitimate personal safety theory, that theory exists to protect natural persons. ABC Company and XYZ Company are shell LLCs. A company has no physical entity that can be threatened and no privacy that can be exposed, so the fear of extortion logic doesn't apply. It is preposterous to allow two companies to claim hundreds of billions of dollars in property under shell company names.

Moreover, New York State does not favor anonymous entities. New York courts rarely permit the use of pseudonyms. While New York historically allowed anonymous LLC ownership, the state's LLC Transparency Act now mandates beneficial ownership disclosure, although federal regulations have narrowed its scope to foreign-formed LLCs.

Potential Directions for the Lawsuit

Even setting aside these details, the sheer audacity of this lawsuit is stark