‘Salmon Brothers’ Client Sues to Claim Legal Ownership of Satoshi’s Coins

Introduction

In October 2025, Galaxy Research published a comprehensive report, “The Great Bitcoin Dusting: A ‘Salomon Brothers’ Client Tries to Claim Dormant Wallets,” in which we identified 39,423 Bitcoin addresses (the “dusted addresses”) that were sent ominous messages. These messages claimed that the sender (the uster) had taken constructive possession of their coins. We speculated then that the messages, contained in Bitcoin’s OP_RETURN arbitrary data field, were sent in an endeavor to establish an evidentiary pattern of notifying address owners prior to a potential legal effort to claim title to the assets as abandoned property. That report, written by Zack Pokorny and Will Owens, was named Best Crypto Research for 2025 by the Association of Cryptocurrency Journalists and Researchers.

Our speculation has now proved correct.

With little fanfare, a case was filed in New York’s Supreme Court in March seeking to claim quiet title to over 3.7m BTC (~$274b) associated with 39,069 bitcoin addresses (New York County Supreme Court, Index No. 153119/2026). The plaintiffs in the case are listed as “Noah Doe” and two unnamed Wyoming LLCs (“ABC Company” and “XYZ Company,” the “Wyoming LLCs”). These 39,069 bitcoin addresses (the “Noah Doe addresses”) are wholly a subset of the dusted addresses analyzed in our October report.

The pseudonymous plaintiffs ask the New York County Supreme Court to declare that they own these dormant Noah Doe addresses and their contents under New York’s lost-and-found property statute (Pers. Prop. Law Art. 7-B) via a declaratory judgment action (CPLR § 3001). Crucially, the plaintiffs are seeking legal title over the entirety of addresses suspected of belonging to Bitcoin creator Satoshi Nakamoto (21,744 addresses holding ~1.09m BTC worth ~$83.7b at current prices).

Put simply: an anonymous individual and his Wyoming LLCs are seeking to have a New York court rule that Bitcoin creator Satoshi Nakamoto’s coins (and a lot of other coins) are lost property that they deserve to legally own by virtue of “finding” them. This report combines onchain data and court documents to examine the scope of affected coins, potential motivations and identities of the plaintiffs, implications for Bitcoin, and likelihood that the plaintiffs are successful.

Case Overview

Three pseudonymous plaintiffs have asked the New York County Supreme Court to declare that they own 39,069 dormant Bitcoin addresses and everything in them. The legal vehicle is a declaratory judgment to quiet title under CPLR § 3001. The engine underneath it is New York's lost-and-found statute, Article 7-B of the Personal Property Law. That statute lets a person who finds lost property, turns it over to the police, and is not contradicted by an owner within a set waiting period eventually to take title to it. The plaintiffs attempt to map that old framework onto Bitcoin like this:

• Noah Doe is the finder;

• USB drives of addresses (not private keys or proof of possessing them, just the publicly known addresses) delivered to the NYPD 17th Precinct stand in for handing the property to the police;

• An OP_RETURN notice campaign and a press release stand in for the effort to reach the owners;

• And an expert's opinion that each address was worth less than $10 drops the whole matter into the statute's fastest track.

The trouble starts with who is on the defendant list. It is the same set of addresses that a client of “Salomon Brothers Strategic Advisors,” the plaintiffs' own consultant, dusted in 2025, and it sweeps in coins that no valid theory of abandonment can hold. John Doe #1 is the Mt. Gox hacker address, which holds about 79,957 BTC of stolen and hotly contested coins. Roughly 21,923 of the defendants are Satoshi-era “Patoshi” addresses that together hold about 1.10 million BTC. John Doe #104 is the Counterparty burn address, an address that is provably unspendable and that no one has ever controlled or could control.

It is worth being clear about what a win would and would not give the plaintiffs. Even a complete victory hands them a piece of paper, a court declaration, and nothing more. They would not receive a single private key, and they could not move a single coin.

The real value of a New York judgment lies elsewhere. It would function as a cloud on title, a document the plaintiffs could wave at an exchange or a custodian if any of these coins ever surfaced at a regulated venue. That is the potential risk this case carries for Bitcoin holders, and it is the reason a lawsuit that sounds far-fetched still deserves a careful look.

Case Timeline

Two stories run in parallel: a factual narrative the plaintiffs tell about finding the addresses, and the procedural history of the case as it moved through the courthouse. The table below threads them together.

Parties to the Case

The filings name dozens of people and companies. The ones who matter to this investigation, and the role each one plays, are set out below.

Legal Arguments Made by Plaintiffs

N.Y. Personal Property Law Article 7-B (§§ 251–258) is a short lost-and-found regime. It offers two different routes to a finder’s title, and the plaintiffs in this case plead both.

Path A: Deposit-and-Hold (§§ 252, 253/254, 257(1))

• § 252: a finder of lost property worth $20 or more must, within 10 days, return it to the owner or deposit it with the police.

• § 253(7), § 254: the police then hold it for a value-keyed period:

Path B: The Sub-$10 Shortcut (§ 257(2))

For lost property worth under $10, if the finder “has made reasonable effort to find the owner and restore it to him, and has been unable to do so,” title vests in the finder one year after the finding with no police-delivery step required.

How the $10 Valuation Fits

The complaint’s (unnamed) “independent expert” pegged each address’s “as-is” value at under $10, on the theory that recovering the contents is uncertain. That single number drives the entire timeline:

• It drops every address into § 257(2)’s flat one-year vesting clock. The three “finds” (Dec. 26, 2024; March 31, 2025; and April 14, 2025) + one year = the exact “title vested by” dates the complaint pleads (Dec. 26, 2025; March 31, 2026; and April 14, 2026). The “reasonable effort to find the owner” prong appears to be precisely what the OP_RETURN notices, the global press release, and the 90-day claim window were built to satisfy.

• It also keeps Path A short: under $100 means only a three-month police hold under § 254.

• And it sits below the $20 § 252 deposit threshold, so depositing the USB drives with the NYPD was arguably more than the statute required for purportedly sub-$20 property (maybe good for optics and an attempt at record-building).

We discuss this valuation methodology in more detail later in the report.

Assessment of the Plaintiffs’ Arguments

The complaint stacks several arguments on top of one another. Each one must hold for the next to matter, which is useful to keep in mind, because the chain is only as strong as its weakest link.

• The addresses are lost property. An address is treated as property much like a bank account. On this view, losing the private key does not destroy the property, so the contents are merely “lost,” and a finder can take custody of them.

• Noah Doe is the finder, and the NYPD deposit satisfies the statute. Article 7-B § 252 requires a finder to turn lost property over to the police. The plaintiffs treat the USB drives of addresses they handed to the 17th Precinct as meeting that requirement.

• Title has already vested. For property worth less than $10, § 257(2) vests title in the finder one year after the find, provided the finder made a reasonable effort to locate the owner and could not. The OP_RETURN notices, the press release, and the 90-day claim window are offered as that reasonable effort.

• The addresses are abandoned. Noah Doe's “Algorithm” flags addresses that are self-custodied, dormant for at least five years, and untouched through major price run-ups. About 424 owners who reacted by moving coins were dropped from the list, leaving the 39,069 who did not respond as the defendants.

• Service by OP_RETURN is proper. Because the owners are said to be unknown and unlocatable, the court authorized alternative service under CPLR § 308(5) by sending each address an onchain notice that links to the pleadings.

• The plaintiffs may proceed anonymously. Pointing to the risk of “wrench attacks” and kidnapping faced by known large holders of BTC, the plaintiffs obtained leave to caption the case under pseudonyms, meaning the title of the case lists the pseudonyms.

Onchain Analysis

We utilize our own Bitcoin full node and internal research databases to examine the onchain footprint of the addresses the Noah Doe plaintiffs claimed to have “found.”

Coins in the Noah Doe Address Set

As of May 25, 2026, the 39,069 Noah Doe addresses hold 3,799,629 BTC, worth about $293.5 billion at $77,245 per coin. That value is not spread evenly, but exists in a handful of buckets, each of which tells its own part of the story.

• Satoshi-pattern (Patoshi) addresses: 21,923 addresses, about 1,096,134 BTC (~$84.7 billion). These are the early-mined coins tied to Bitcoin's creator through the well-documented “Patoshi” nonce pattern. They have never moved.

• The Mt. Gox hacker address: 1 address, 79,957 BTC (~6.2 billion dollars). This is John Doe #1. The coins were stolen from Mt. Gox, an early bitcoin exchange, and have sat untouched since 2011. They are contested property that investigators have tracked for years.

• The Counterparty burn address: 1 address, 2,131 BTC (~$0.16 billion). This is John Doe #104, a provably unspendable “burn” address. No person has ever held its keys, because by design no such keys exist.

• Other dormant addresses: 17,144 addresses, about 2,621,407 BTC (~$202.5 billion). A long tail of early holders and exchange-era coins that simply have not moved in years.

The dormancy runs deep. When we chart each address by the year its coins last moved onchain, the weight of the set sits firmly in Bitcoin’s earliest years. The overwhelming majority of these coins last moved between 2009 and 2013, a stretch when Bitcoin went from having no price at all to trading at a few hundred dollars.

The Noah Doe Set Is a Subset of the 2025 Dusting Set

Every address named in the lawsuit was first dusted in the 2025 dusting campaign that we covered in our award-winning report from October 2025. Of the 39,069 defendant addresses, 39,068 sit in our 2025 dusting address set, and the lone exception is a single bech32 address that has never spent. The two campaigns are aimed at the same coins, a year apart.

The 348 addresses that fell out of the set between 2025 and 2026 are comprised mostly of addresses that moved their coins subsequent to the 2025 Dusting campaign and prior to the initiation of the Noah Doe case: 339 of them spent coins onchain after the dusting. Presumably, the remaining nine addresses dropped from the 2025 Dusting set proved their ownership to the plaintiffs another way, such as through the salomonbros.com online form. The plaintiffs watched the chain, saw which owners answered the notices by moving their coins, and removed exactly those addresses from the lawsuit. The complaint says as much, describing how addresses that “took onchain action” were taken off the list.

Overlap With Craig Wright’s Claimed Coins

Many of these particular coins have been claimed before. In Kleiman v. Wright (S.D. Fla., 2018), Australian businessman Craig Wright produced a list of 16,404 early-block addresses he swore were his, as part of his since-rejected effort to be recognized as Satoshi Nakamoto. We compared the coins claimed by Wright in the Kleiman litigation to the Noah Doe addresses to see how much they overlap. (Notably, one of the real owners of coins claimed by Wright signed a cryptographic message proving their ownership – not Wright’s – and the message denounced Wright and his effort).

The overlap is almost total: 16,350 of Wright's 16,404 claimed addresses, or 99.7%, are also claimed by the Noah Doe defendants, and they hold about 817,513 BTC. A nearly identical share were in the set of addresses from the 2025 Dusting, and 13,657 of them, or 83.3%, carry the Patoshi pattern. Only 46 addresses are unique to Wright. We can’t know if Craig Wright is somehow connected to the Noah Doe case (Salomon Brothers denied to CoinDesk in 2025 that Wright was its client), but the overlap is nonetheless notable. Craig Wright tried for years to claim the coins through litigation before being found in contempt by a U.K. court in 2024; two years later, Noah Doe is trying to claim the coins through a New York abandoned-property action.

Through all of it, Satoshi’s coins themselves have not moved onchain.

The Value of the Coins

The plaintiffs' case timeline hangs on a single number: an unnamed expert's opinion that each address was worth less than $10 at the time it was “found.” That figure is doing an enormous amount of work, and it may be the place where the case is most exposed, because it is the one claim that onchain data, combined with market prices, can test directly.

Average and Median Value Today

Even if we grant plaintiffs’ argument that they actually “found” the property held in the addresses, the coins’ value is substantially higher than $10 at the time of “finding.” The average Noah Doe address holds 97.25 BTC (worth about $7.5 million at the time of writing), while the median address holds 50 BTC (worth about $3.86 million). The 50 BTC median is no accident. Fifty BTC was the block reward in Bitcoin's earliest years, so the typical defendant is a single early coinbase address (a mining payout transaction, not the exchange Coinbase, which is named after that transaction type), one block's worth of mining reward, frozen in time. Of the 39,069 addresses, 39,046, or 99.9%, are worth considerably more than $10 today. The full distribution stretches from roughly $100,000 to over $1 billion per address.

Value at the Time the Coins Last Moved

Even if we valued the “found” addresses at the time they last moved onchain rather than today’s objective market value, a huge portion of the addresses would be worth more than $10. In our view, this is not an appropriate way to value assets because any liquid asset, if found on the street, is valued by the market at its current exchange rate, not what it may have been worth 15 years ago. If you own a painting and it is stolen or you lose it, your loss is the current assessed value, not the value when the painter first put brush to canvas. Nonetheless, even by that standard, the Noah Doe address set is substantially overbroad.

Summary of Coin Value

Put the whole set together and the gap becomes almost difficult to state with a straight face. The defendant addresses hold 3,799,629 BTC, worth roughly $293.5 billion at current prices. This is the property the plaintiffs describe as lost goods worth less than $10 per address. The distance between “under $10” and $293.5 billion is a gap of nine orders of magnitude.

It might seem easy to treat the $10 figure as harmless, but it is structurally essential to the plaintiffs’ case. Their coin valuation of <$10 is the lever that drops the property into Article 7-B § 257(2), the sub-$10 track that vests title in the finder just one year after the find. The complaint’s pleaded vesting dates line up precisely with the find dates plus one year, which is exactly what you would expect if the $10 figure were chosen to unlock that track. Value these addresses at anything close to their real worth and they fall into the statute’s top bracket, which carries a three-year police holding period, and the one-year shortcut simply disappears. A court that values this property accurately could not, in our opinion, reach the result the plaintiffs want on the schedule they have built for it. Asking to take title to nearly $300 billion of property on an accelerated, sub-$10 lost-and-found track is not a close call, and no amount of expert framing makes it one, especially from an unnamed expert.

Even if we give the most charitable value to the coins by valuing them on the date they last moved onchain, 7,108 individual addresses cleared $10 on that basis. The 28,962 addresses that failed to clear $10 on this basis fail solely because their coins last moved in 2009 and 2010, before BTC had any market price at all. Those same addresses were worth millions or billions of dollars on the dates that plaintiffs pleaded as their finds.

Service of Process by OP_RETURN

With the legal theory and the valuation in place, the plaintiffs still had to serve 39,069 defendants who are, by their own account, anonymous and unreachable. Their solution was to serve everyone onchain.

Each address received a tiny payment of 546 satoshis (about 4.1 cents) carrying an OP_RETURN message that links to a web page hosting the pleadings. We reconstructed the entire operation from our own node and confirmed every claim in the affidavit of service. There were 98 batch transactions sent across Bitcoin blocks 950,446 to 950,576, with all 39,069 recipients “present” onchain and none missing, a single identical message in every batch, and a uniform 546-satoshi dust amount throughout. The message reads: COURT-ORDERED LEGAL NOTICE: https://www.ilawconotices.com/153119-2026.

The service ran through a chain of six rotating server addresses, every one of them funded by the Bankroll address (more on that address in the next section). The map below isolates the service operation on its own, with the separate 2025 dusting set aside, so the shape of the 2026 campaign is easy to follow.

Is OP_RETURN Dusting Sufficient for Service of Process?

Grant that the transactions happened exactly as the affidavit says. There is still a serious question about whether this method puts the owners on notice at all, and notice is the point of serving someone.

The precedent for onchain service is almost all from Ethereum, where a handful of courts have allowed service by onchain message or by airdropping an NFT into an address. Some examples include LCX AG v. John Does Nos. 1-25 (N.Y. Sup. Ct., June 2, 2022), D'Aloia v. Persons Unknown & Binance Holdings Ltd. et al. (EWHC, June 2022), and In re Celsius Network LLC (Bankr. S.D.N.Y., Oct. 24, 2024). Another example with substantial precedential value regarding service on a decentralized autonomous organization, though different because the recipient was a DAO and the method of service was posting to its online help chat box, is the CFTC v. Ooki DAO (N.D. Cal., Dec. 20, 2022) case.

The onchain service approach works on Ethereum for a concrete technical reason: Ethereum is account-based and addresses are persistent, reused, and built to receive and display new tokens, so a token dropped into an Ethereum address tends to surface in front of the person who holds it when they open their wallet software.

Bitcoin behaves in almost the opposite way: rather than accounts, Bitcoin is built around unspent transaction outputs (UTXOs), and tiny unsolicited payments are the standard vehicle for spam and for address-poisoning attacks. Most Bitcoin wallet software does not display OP_RETURN payloads at all, and many wallets hide or filter incoming dust by default. A legal notice delivered as a mass dust airdrop of roughly 400 recipients per transaction looks, to the software and to the user, exactly like the spam the wallet is designed to suppress. The odds that any given owner saw the 2026 notice are low. The same doubt hangs over the original 2025 Dusting. Borrowing an Ethereum NFT-service theory and bolting it onto Bitcoin dust takes the outward form of onchain service without delivering the thing service is supposed to do, which is reach the person being served.

The Same Operator Ran the 2025 Dusting and Noah Doe Onchain Campaigns

On the surface, the 2025 dusting and the 2026 service look like the work of two different operations. The 2025 campaign was a sprawling fan-out, roughly 3,797 throwaway “duster” addresses firing off 41,669 single-recipient transactions. The 2026 service was a tidy, professional run of 98 batched transactions through six rotating addresses using the MAYDROP tool. The execution could hardly look more different. The money behind them, however, comes from one place.

Starting from the change address that paid for all 98 service batches, we traced the funding upstream until it converged on a single hub, what we now call the Bankroll (bc1q2f60twvuwftp50dz4hmjphyw9ntwaeyhpqul99). A full-population trace of all 39,416 dusted addresses shows that 99.6% of the 41,669 dusting transactions were sent by addresses the Bankroll funded within two hops. That same address then funded the 2026 service with a single 0.636 BTC payment into the server-address chain. It was active from April 2025 through May 2026, straddling both campaigns. Its own coins arrived through a chain of fresh single-use addresses and an older 2020-era address, with no regulated exchange deposit observable by Galaxy Research anywhere in the trail, which is the signature of an operation that took great care to stay anonymous.

Two independent lines of evidence point in the same direction. Onchain, one address bankrolled both operations, and common funding is strong evidence of common control. In the filings, the complaint says Noah Doe engaged a “cyber/blockchain expert” in early 2025 to send the original abandonment notices, and the person who signed the 2026 Affirmation of Service, the self-described blockchain engineer Carlos J. Voltron, is by the filing's own description that same expert. Put the two together and a reasonable conclusion comes into focus: one person ran both the 2025 Dusting and the 2026 court-ordered service and paid for both out of the Bankroll address. Over the intervening year the operator cleaned up their onchain tradecraft, moving from a chaotic self-help blast to a court-sanctioned batch service, while the address writing the proverbial checks never changed.

Case Vulnerabilities

While we are not lawyers, a plain reading of the docket items and the statute suggests the case is highly dubious.

Does Article 7-B Even Apply?

Before any of the valuation or service questions matter, there is a more basic problem. The lost-and-found statute was written for physical objects that a finder picks up, takes into possession, and hands to the police. Noah Doe never possessed these coins or their keys. He looked at public addresses on a ledger that anyone in the world can read. Looking at a visible address is a long way from taking custody of lost property, and handing the police a USB stick that lists addresses is not the same as depositing the property itself. The statute imagines a finder who could give the item back if the owner walked in the door. Here the finder never held the coins and could not have delivered them to anyone, not to the police who supposedly held them, and not to an owner who showed up to claim them. The point cuts even deeper than possession. Losing a private key does not strip the real owner of anything. The coins stay onchain, and the true keyholder can move them whenever they like, which is exactly what hundreds of dusted owners did. It stands to reason that title cannot meaningfully pass to a finder who can never touch the asset.

The Valuation Is Not Credible

As our onchain analysis section lays out, the average Noah Doe address holds 97.25 BTC, worth about $7.5 million, and the median holds 50.00 BTC, worth about $3.86 million. Against those numbers, the claim that each address is worth less than $10 is not a defensible appraisal of valuable property. It is a device for fitting that property into the statute's fastest track.

Two other details further undermine the valuation. The expert who produced the under-$10 figure is not named anywhere in the filings, so the single number that drives the entire timeline cannot be examined or challenged. And the “as-is recoverability” reasoning behind it would, if applied evenly, value essentially all self-custodied BTC at close to zero, which is not how any user treats these coins, least of all the plaintiffs, who went to the trouble of suing for them.

The Defendant Set Is Over-Broad and Self-Contradicting

The list does not just include a few awkward entries. It is built around them.

The Mt. Gox hacker stash at John Doe #1 is stolen property that is actively contested and has been tracked by investigators for years, which is not abandoned property by any definition. The roughly 21,923 Satoshi-era addresses are the most closely watched coins in all of Bitcoin, the very opposite of forgotten. The Counterparty burn address at John Doe #104 is provably unspendable and was never owned by anyone at all. A statute meant for genuinely lost objects cannot comfortably swallow a set that is defined to include stolen coins, the most famous coins in the asset’s history, and an address that by construction has no owner to lose it.

The Anonymity of the Parties

The pseudonyms in this case are not a side issue, and they do not all stand on the same footing. There are several distinct problems here.

• The pseudonym is self-defeating. Noah Doe asks to stay anonymous so that he is not targeted as a large holder, while the relief he seeks would force the actual address owners to identify themselves in public in order to defend their coins. The plaintiff wants for himself precisely the protection he would strip from every defendant.

• The companies have no safety interest at all. Even if an individual can plead a genuine physical-safety theory, that theory exists to protect natural persons. ABC Company and XYZ Company are LLC shells. A company has no body to threaten and no private life to expose, so the wrench-attack rationale does not reach it. Letting two corporations claim hundreds of billions of dollars of property under placeholder names would be extraordinary.

• New York disfavors anonymous entities. New York courts permit pseudonyms only sparingly. While the New York historically allowed anonymous LLC ownership, the state's LLC Transparency Act now imposes beneficial-ownership disclosure, although federal rulemaking has narrowed its application to foreign-formed LLCs. ABC and XYZ are Wyoming LLCs, formed in an anonymity-friendly jurisdiction, now reaching into New York to assert property rights. The corporate anonymity is definitely exposed to challenge.

Questions About the Process-Service Affiant

The Affirmation of Service was signed by “Carlos J. Voltron,” who describes himself as a blockchain engineer with more than 10 years of experience. We went looking for him and came up empty. The only meaningful result for that name is a 2008 satirical article in The Onion, “Struggling Mets Combine To Form Carlos Voltron.”

A real blockchain professional named Charles Voltron does exist, so the surname is genuine in the field. But the affiant uses the exact Onion spelling, Carlos, and web and database searches located no real Carlos Voltron anywhere, at least one who is active in crypto. If the affiant’s identity is not genuine, the consequences are significant because the affidavit of service is the document on which the court’s personal jurisdiction over the defendants rests. If the affidavit were determined to be false, it would be facially defective and could be challenged with no time limit, which means any default or declaratory judgment built on top of it could later be vacated. The underlying transactions did happen, and we verified them. But the lack of any Google, LinkedIn, X, or other online results for Carlos Voltron, let alone our deep experience in crypto markets and blockchain technology and accompanying lack of knowledge of such a figure, could lead one to question the veracity of his identity.

Conclusions

When we take a step back from the mechanics, the sheer audacity of the request comes into view. It would be extraordinary for a New York court to hand three anonymous parties legal title to roughly $293 billion worth of BTC, including the coins most closely associated with Satoshi Nakamoto, on a lost-and-found theory propped up by a questionable under-$10 valuation. Courts are generally reluctant to grant novel and sweeping relief of this kind, and that reluctance only grows where the property is contested and where a judgment would echo far beyond the parties in the room.

Because this is a quiet-title action over property, a genuine address owner would have a strong basis to intervene as of right under CPLR § 1012(a)(3), and an interested non-owner can ask for permissive intervention under § 1013. But while the doctrine leaves the door open to intervene, the practical obstacle is severe. To intervene, an owner has to surface and prove control of a listed address, which is the exact deanonymization that careful holders spend their lives avoiding, and which the plaintiff Noah Doe himself cites as justification for himself remaining anonymous in his own case. Furthermore, as we have explained in this report, the odds that a genuine owner of one of the ~39k defendant addresses would even be aware of the 2025 Dusting or Noah Doe service campaigns is extremely low. The structure of the lawsuit quietly discourages the only people with the clearest standing from ever stepping forward.

Potential Timelines

The defendants are pseudonymous addresses that, by design, will not appear, so a technical default is close to certain by roughly late June 2026, about 30 days after service. A motion for default judgment will likely follow over the summer. A clean and fast default judgment granting everything the plaintiffs ask for is still unlikely, for several reasons that tend to pull in the same direction. A declaration of title is not a clerk’s default for a fixed sum; it requires a judicial application, and the court keeps the discretion to demand a hearing and real proof. The theory is novel and the stakes are enormous, conditions that tend to invite judicial skepticism rather than a rubber stamp. The adequacy of OP_RETURN service is itself open to challenge, the questionable affidavit of service gives the court a reason to proceed cautiously, and a single intervening owner would turn an uncontested walkover into a real fight. Our estimate is that the probability the court grants the full title-vesting declaration on default is low to moderate, and that any such ruling, if it comes at all, is more likely to arrive after a hearing, in narrowed form, or not at all.

Implications of a Plaintiff Victory

Even if the plaintiffs win outright, they still cannot seize the BTC. What they would hold is a New York declaration, not a set of private keys. “Not your keys, not your coins” applies to them as squarely as it does to anyone else. So, the danger is not that plaintiffs can seize Satoshi’s coins, or any of the other coins identified in Noah Doe defendant addresses. The danger is that, if any of these coins ever move to a centralized exchange or a custodian, the plaintiffs can present their New York judgment to that venue and try to encumber the coins. Such an action could freeze assets, set off years of litigation, and force a holder who moved coins decades after the fact to come forward and prove ownership, thereby jeopardizing their own anonymity. A paper title is a lever to be used against regulated intermediaries and the holders who depend on them, and that is almost certainly why a judgment that can never reach the coins directly is still worth chasing for the people behind this case.

Dormancy Is Not Abandonment

Underneath all of it sits one premise, and the premise is wrong on both halves.

The premise is that coins which have not moved must be lost, and that lost coins can be found and taken. Dormancy is a feature of Bitcoin, not a sign of abandonment. Long-term holders, estates with lost keys, the Satoshi coins, and burn addresses all sit perfectly still, some on purpose and some by circumstance, and none of that stillness hands ownership to a stranger who happens to be looking. Seeing coins on a public ledger is not “finding” them, and it is certainly not possessing them. A ledger that the whole world can read is not a lost-and-found bin waiting to be emptied. If a New York court accepts otherwise, the precedent would not stop at these 39,069 addresses. It would place every dormant address in Bitcoin within reach of the next party willing to file a complaint.

The coins have not moved. The right response is to leave them alone.