Anonymous Claimant Claims Legal Title to $293 Billion in Dormant Bitcoin, Without Holding Any Private Keys

An anonymous individual calling himself “Noah Doe,” along with two Wyoming LLCs, filed a lawsuit in New York Supreme Court seeking a court declaration that they are the legal owners of 39,069 inactive Bitcoin addresses that hold approximately 3.8 million BTC – worth about $293 billion at current rates.

The lawsuit, filed on March 11, 2026, and amended on May 1, 2026 (Reference No. 153119/2026), is believed to be the first attempt in US history to claim title to Bitcoin under local lost and found laws.

The legal vehicle is New York Personal Property Law Article 7-B, a statute designed for lost tangible items – a wallet found on the side of the road, say, or jewelry left in a cab. The law states that a finder who reports lost property to the police, makes reasonable efforts to find its owner, and does not receive an answer within a set time can end up taking title to that property.

Noah Doe’s complaint alleges that inactive Bitcoin addresses are “lost property” under that framework, that his address data USB drives delivered to the NYPD 17th Precinct satisfy the deposit requirement, and that title for all 39,069 addresses provided to him over three days: December 26, 2025, April 26, April 26, 31, April 20 26, 26

The law has never been applied to cryptocurrency. Article 7-B was written for material possessions taken by the receiver and handed over to the authorities. The complainant never held the private keys to any of these addresses and would not have been able to hand over the coins to the police or any owner who came forward.

A Bitcoin address, unlike a lost wallet, is always fully accessible to its original owner regardless of whether someone has identified it – the coins don’t leave unless the owner of the true key signs the transaction.

That’s what the bitcoin case is all about

The 39,069 addresses named as defendants are not a random sample of dormant Bitcoin.

According to the blockchain research company, Galaxy Digital, which published a detailed analysis of the case in May 2026, the addresses of approximately 21,923 defendants carry what the researchers call the “Patoshi” nonce pattern – the onchain fingerprint widely attributed to the anonymous creator of Bitcoin, Satoshi Nakamoto. Those addresses alone hold about 1.096 million BTC, worth about $84.7 billion.

Also on the list of defendants: one address holding the 79,957 BTC stolen in the hack of Mt. Gox of 2011 – coins that have been actively tracked by investigators for more than a decade – and one address that is a Counterparty “burn” address, which means that it is virtually unusable and has never been controlled by anyone. Coins of Mt. Gox are the subject of ongoing recovery processes and are not abandoned, by any standard definition.

The defendant’s middle address holds 50 BTC, currently worth about $3.86 million. The average holds 97.25 BTC, which is worth about $7.5 million.

According to Galaxy’s onchain data, 99.9% of the defendant’s addresses hold BTC worth more than $10.

That $10 figure is the basis of the construction of the case. The appeal hinges on an unnamed expert’s opinion that each address was worth less than $10 “as is” at the time of discovery, on the basis that returning the content is uncertain.

That single estimate puts all 39,069 addresses in Section 257(2) of Article 7-B — the fastest track of the law, which gives the title to the finder just one year after it is found, without the need for years of police detention.

The $10 figure is the legal key to the case, because it’s the number plaintiffs are using to argue that the coins qualify for New York’s instant lost property title method, even though the coins themselves are worth more in the market.

If the addresses were considered to be worth close to market prices, they could fall into the upper bracket of the law, which comes with a three-year police hold requirement. The one-year shortcut relied on by the appeal will not be available.

The three-day appeal to grant title coincides exactly with the three-day receipt and one year — a timeline that only applies if the amount is less than $10. The expert for that valuation was not named anywhere in the filing.

Connecting to the 2025 dust campaign

The defendant’s addresses did not appear anywhere. Galaxy Research identified all but one in the October 2025 report about the blockchain campaign “dusting” – a practice where small amounts of BTC are sent to addresses, usually to track the activity of the fund.

Between June and July 2025, more than 39,000 addresses received OP_RETURN messages – a Bitcoin data field used to embed text – saying that the sender had taken the coins they were building.

Galaxy research has shown that those messages appear to be the basis for a legal abandonment claim. That report won Best Crypto Research of 2025 from the Association of Cryptocurrency Journalists and Researchers.

A May 2026 Galaxy analysis traced funding for the 2025 dust campaign and the 2026 court-ordered onchain service to a single Bitcoin address, which Galaxy calls the “Bankroll” address. The company found that 99.6% of the 2025 dust jobs were funded between the two hops from that address, while the same address funded the 2026 service job.

Because the defendants are anonymous Bitcoin addresses, the court authorized another service under CPLR § 308(5): each address received a 546-satoshi payment (about 4 cents) carrying an OP_RETURN message that links to the website hosting the requests. Galaxy confirmed 98 batch transactions across Bitcoin blocks 950,446 to 950,576, reaching all 39,069 addresses between May 21-22, 2026.

Whether that constitutes adequate legal notice is an open question. The Onchain service has a precedent in the case of Ethereum, where wallets are account-based and tokens falling on an address are often visible in the wallet’s software.

Bitcoin works differently — wallets are built around unspent outputs, and most Bitcoin wallet software doesn’t expose OP_RETURN loads at all. Most bags automatically filter incoming dust transactions as spam.

What victory would – and wouldn’t – mean

Crypto legal observers across the industry agree that even a complete victory for the plaintiff would not allow Noah Doe to move a single coin. Without private keys, the court ruling does not provide the ability to use the Bitcoin network. The law does not respect court orders; the only valid cryptographic signature that transfers BTC.

Functional concerns, as Galaxy and legal analysts have noted, are different. A court order can act as a “cloud on title” – a legal document that plaintiffs can present to a regulated exchange or custodian if any listed currencies appear in the middle ground.

That could trigger a freeze on assets and force original owners to reveal and prove ownership, possibly at the cost of their anonymity. It is this benefit over regulated intermediaries, rather than any ability to hold coins directly, that gives the case its potential value.

Because the defendants are anonymous addresses that will not appear in court, the technical failure may occur in late June 2026, approximately 30 days after service. A motion for default judgment may follow.

The court retains the discretion to hold a hearing before issuing a ruling on the subject, and legal observers note that the novelty of the theory and the scale of the claim are factors that often invite judicial review.