中本聰攤上官司？價值837億美元BTC要被人「合法招領」了

原文来自Galaxy

编译 / Odaily 星球日报 Golem（@web 3_golem）

Unexpectedly, even Satoshi Nakamoto, the creator of Bitcoin, is facing a lawsuit, with the "ownership" of wallet addresses potentially being taken away. And you, reading this article right now, could also be one of the "defendants," as long as you have a dormant Bitcoin address.

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 Bitcoins (approximately $274 billion) associated with 39,069 Bitcoin addresses. The plaintiff operates under the pseudonym Noah Doe and includes two unnamed Wyoming limited liability companies (pseudonyms "ABC Company" and "XYZ Company").

The plaintiff is requesting the New York State Supreme Court to confirm their ownership of these dormant addresses through a declaratory judgment under New York's lost property law. More importantly, among these 39,069 addresses are those suspected to belong to Bitcoin's creator, Satoshi Nakamoto (totaling 21,744 addresses holding approximately 1.09 million Bitcoins, worth about $83.7 billion at current prices).

Simply put, an anonymous individual and their Wyoming-registered company are trying to get a New York court to rule that Satoshi Nakamoto's Bitcoin (and many other cryptocurrencies) are lost property, entitling them to legal ownership for having "found" these Bitcoins. Galaxy has analyzed the plaintiff's potential motives and identity, the impact on Bitcoin, and the likelihood of the plaintiff's success.

Odaily has compiled and translated the full text below. Enjoy~

Case Overview and Plaintiff's Strategy Deconstructed

The plaintiff has petitioned the New York State Supreme Court to declare them the owners of 39,069 dormant Bitcoin addresses and all assets within them. The legal basis is a declaratory judgment of ownership under Section 3001 of the New York Civil Practice Law and Rules, fundamentally relying on New York's lost property law, Article 7-B of the Personal Property Law. This clause stipulates that a finder who turns lost property over to the police and faces no claim from the owner within a specified waiting period may eventually acquire ownership. The plaintiff attempts to apply this old framework to Bitcoin.

The specific strategy is: Noah Doe, as the finder, submits a USB drive containing the addresses (not private keys or proof of address ownership, but merely the public addresses) to the 17th Precinct of the New York City Police Department, acting as a substitute for turning over the lost item to the police. Subsequently, they issue an OP_RETURN notification on the Bitcoin blockchain and publish a press release to serve as an attempt to contact the owners. Finally, they have an expert appraise each address at a value of less than $10, allowing the entire case to proceed under the fastest procedure stipulated by this clause.

It is important to note that even if the plaintiff wins completely, they will only receive a piece of paper, a court declaration, and nothing more. They will not receive any private keys and cannot transfer any Bitcoin.

The real 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 plaintiff could present this document to contest the exchange or custodian. This is the potential risk this case poses to Bitcoin holders and why this seemingly outlandish lawsuit is still worth a close examination.

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 to have discovered a "security issue" with certain addresses and developed an "algorithm" to mark abandoned addresses (in reality, no such "security issue" existed).
• 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 hires Salomon Brothers Strategic Advisors as consultants.
• March 31 & April 14, 2025: Noah Doe "finds" an additional 546 addresses and 39,911 addresses respectively. After each "find," the USB drive containing the addresses was delivered to the police precinct.
• June 30 - July 10, 2025: Noah Doe sends "abandonment notices" to each address via OP_RETURN.
• August 7, 2025: A press release is sent to global media outlets. CoinDesk, Bitcoinist, Yahoo Finance, Investing.com, and Galaxy Digital's research reports cover the story.
• August 2025 - February 2026: Salomon Brothers receives threatening emails, including over 50 emails containing only "4 8 15 16 23 42," demanding $1.5 million and 50 Bitcoins.
• October 10, 2025: The 90-day claim period for the owners ends.
• December 2025: Noah Doe transfers these addresses to ABC Company and places 98% of the interest into an irrevocable trust. ABC Company transfers 17.7% of the interest to XYZ Company.
• March 11, 2026: The original summons and complaint are filed. Judge Arlene P. Bruce annotates the initial order for deposition.
• March 23, 2026: Judge Emily Morales-Minerva recuses herself from the case.
• March 25 - April 17, 2026: Judge Carlos J. Voltron signs orders for deposition (allowing pseudonyms) and authorizing alternative service via OP_RETURN (without notifying the opposing party).
• May 1, 2026: The first amended complaint expands the defendants from 1 to 39,069 and includes a complete list of addresses.
• May 21-22, 2026: On-chain execution services: 98 batch transactions in 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).

Plaintiff's Legal Basis and Strategy

Article 7-B of the New York Personal Property Law (Sections 251-258) provides a summary lost property system. It offers two different paths for a finder to acquire ownership. The plaintiff in this case invokes both paths.

• Path A: Custody (Sections 252, 253/254, 257(1)). Section 252 requires a person finding lost property valued at $20 or more to return it to the owner or deliver it to the police within 10 days. Sections 253(7) and 254 specify different holding periods by police based on the value of the lost item: 3 months for items under $100, 6 months for items $100-$500, 1 year for items $500-$5000, and 3 years for items $5000 or more.
• Path B: Shortcut for items under $10 (Section 257(2)). For lost items valued under $10, the finder can acquire ownership after one year, without police delivery, if they "have made reasonable efforts to find the owner and restore the same but without success."

The (unnamed) "independent expert" in the complaint values each address at "status quo" under $10, arguing that the possibility of recovering the items is unlikely. This valuation governs the procedural timeline of the entire case by bringing each address under the uniform one-year vesting period of Section 257(2). It also shortens Path A, as items valued under $100 are held by police for only three months under Section 254.

Plaintiff's Arguments

The complaint lists several arguments by the plaintiff, each building upon the previous one.

• The addresses are lost property. The addresses are treated as property, akin to bank accounts. Under this view, losing the private keys does not destroy the property; its contents are merely "lost" and can be reclaimed by a finder.
• Noah Doe is the finder, and custody by the NYPD satisfies statutory requirements. Section 252 of Article 7-B requires the finder to deliver the lost item to the police. The plaintiff argues that delivering a USB drive containing the address list to the 17th Precinct satisfies this requirement.
• Ownership has vested with 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, ownership vests after one year. The OP_RETURN notifications, press release, and the 90-day claim period are considered reasonable efforts.
• The addresses have been abandoned. Noah Doe's "algorithm" identified addresses that had been inactive for at least five years, were untouched during major price rallies, and held by their owners. Approximately 424 owners who responded by moving tokens were removed from the list. The remaining 39,069 who did not respond are the defendants.
• The OP_RETURN notification is legal. Since the alleged owners are unidentified and unlocatable, the court authorized alternative service under CPLR Section 308(5), which is the on-chain notice sent to each address pointing to the complaint.
• The plaintiff can sue anonymously. Given the known risks of kidnapping for large Bitcoin holders, the plaintiff was permitted to proceed under a pseudonym.

Who are the Owners?

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

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

Composition of addresses found by Noah Doe

Patoshi Addresses

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

Mt. Gox Hacker Address

Just 1 address, approximately 79,957 Bitcoins (approx. $6.2 billion). This is John Doe #1. These Bitcoins were stolen from the early Bitcoin exchange Mt. Gox and have remained untouched since 2011. They are disputed property that investigators have tracked for years.

Counterparty Burn Address

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

Other Dormant Addresses

7,144 addresses, approximately 2,621,407 Bitcoins (approx. $202.5 billion). These addresses contain Bitcoin from a large group of early adopters and the exchange era, which have not been moved for years.

This dormancy is longstanding. Sorting addresses by the year of their last on-chain movement shows that most Bitcoin movement was 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 rose from near zero to a few hundred dollars.

But many of these addresses have been claimed before. In the Kleiman v. Wright case (S.D. Fla., 2018), Australian businessman Craig Wright submitted a list of 16,404 early block addresses, claiming they belonged to him as part of his (later discredited) claim to be Satoshi Nakamoto.

We compared the Bitcoin addresses Wright claimed ownership of in the Kleiman suit with Noah Doe's addresses to see their overlap.

Overlap between Noah Doe and Craig Wright addresses

The overlap is almost exact: 16,350 out of 16,404 addresses (99.7%) claimed by Wright are also claimed by Noah Doe's defendants, holding approximately 817,513 Bitcoins. We cannot confirm if Craig Wright is connected to the Noah Doe case, but the overlap is noteworthy. Wright has spent years trying to claim these Bitcoins through litigation but was found in contempt of court by a British court in 2024.

Suspicious Points in the Case

While we are not lawyers, looking solely at the case record and relevant statutes, several aspects of this case are questionable.

Does the Lost Property Law Apply?

Before any valuation or service issues, there is a more fundamental problem. The lost property law was designed for physical items a finder picks up, holds, and delivers to the police. Noah Doe never held these coins or their keys. He merely looked at a public ledger of addresses, readable by anyone. Looking at a public address is far from possessing a lost item. Delivering a USB drive with addresses to the police is also different from actually handing over the lost item.

The statute envisions a finder who can return the item if the owner appears. But in this case, the finder never held the coins and cannot hand them to anyone, whether to the police acting as custodian or to an owner who comes to claim them. The core issue goes beyond ownership: losing a private key does not deprive the true owner of any rights. The Bitcoin remains on the chain. The true key holder can transfer them at any time, and hundreds of owners who lost their Bitcoin have done just that.

It seems clear that ownership cannot be validly transferred to a finder who can never access the asset.

Unreliable Valuation

The average holding in a Noah Doe address is 97.25 Bitcoins, worth approximately $7.5 million; the median is 50.00 Bitcoins, worth about $3.86 million. Compared to these figures, the claim that each address is worth less than $10 is untenable. It is merely a tactic to push these assets through the legal process as quickly as possible.

Two more details further undermine this valuation. The expert who provided the "under $10" figure is not named in the filings, making this single number that drives the entire timeline unscrutinizable and unchallengeable. Applying the "recoverable as-is" logic universally would mean almost all self-custodied Bitcoin has near-zero value, which contradicts how any user treats their Bitcoin, especially plaintiffs who go to great lengths to sue.

Anonymity of the Parties

Noah Doe's anonymity in this case is highly suspicious. They request anonymity to avoid being tracked as a large holder. Yet, the rights they seek would force actual address holders to reveal their identities to defend their cryptocurrency. The plaintiff wants protection for themselves that they are seeking to deny all defendants.

Even if an individual can present a genuine personal safety theory, that theory exists to protect natural persons. ABC Company and XYZ Company are shell LLCs. A company has no physical entity to threaten or privacy to expose, so the logic of fearing extortion does not apply to it. Allowing two companies to claim hundreds of billions of dollars in property through shell companies is preposterous.

Furthermore, New York State does not favor anonymous entities. New York courts rarely allow pseudonyms. While historically allowing 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.

Future Legal Developments

Even setting aside these details, the "audacity" of this lawsuit is clear. It is almost unthinkable that a New York court would award legal ownership of approximately $293 billion worth of Bitcoin (including some belonging to Satoshi Nakamoto) to anonymous individuals based on a dubious "lost property" theory with an under $10 valuation.

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