A pseudonymous individual, identifying himself as "Noah Doe," in conjunction with two Wyoming LLCs, has initiated a novel lawsuit in New York Supreme Court. The legal action seeks a court declaration of their ownership over 39,069 dormant Bitcoin addresses, collectively holding approximately 3.8 million BTC, valued at an estimated $293 billion at current market prices. Filed on March 11, 2026, and later amended on May 1, 2026 (Index No. 153119/2026), this case marks the first known attempt in U.S. legal history to claim title to Bitcoin under a lost-and-found property statute.

The plaintiffs are leveraging New York Personal Property Law Article 7-B, a statute traditionally designed for tangible lost objects such as a wallet or jewelry. This law allows a finder who reports lost property to the police, makes reasonable efforts to locate the owner, and receives no response within a specified period, to eventually acquire legal title to the item. Noah Doe's complaint asserts that dormant Bitcoin addresses qualify as "lost property" under this framework. He further contends that his delivery of USB drives containing address data to the NYPD 17th Precinct fulfills the statute's deposit requirement, and that title to all 39,069 addresses legally vested in him on three specific dates: December 26, 2025, March 31, 2026, and April 14, 2026.

Legal observers widely acknowledge that Article 7-B was crafted for physical items that a finder could physically pick up and surrender to authorities. A critical challenge to Doe's claim is the fact that he has never possessed the private keys for any of these addresses, meaning he could not have transferred the bitcoins to the police or to any original owner who might come forward. Unlike a physical lost item, a Bitcoin address remains entirely accessible to its original owner, regardless of whether its public address has been identified by others; the coins only move when the true keyholder signs a transaction.

The lawsuit specifically targets a non-random selection of dormant Bitcoin addresses. According to a detailed analysis published in May 2026 by blockchain research firm Galaxy Digital, approximately 21,923 of the defendant addresses exhibit the distinctive "Patoshi" nonce pattern. This onchain fingerprint is widely attributed to Bitcoin's pseudonymous creator, Satoshi Nakamoto, and these addresses alone hold about 1.096 million BTC, worth roughly $84.7 billion. The defendant list also includes an address containing 79,957 BTC stolen in the 2011 Mt. Gox hack, coins that have been under active investigation for over a decade and are not conventionally considered abandoned. Additionally, a Counterparty "burn" address, which is provably unspendable and was never controlled by any person, is listed.

The financial scale of the claim is substantial, with the median defendant address holding 50 BTC (approximately $3.86 million) and the average holding 97.25 BTC (around $7.5 million). Galaxy's onchain data indicates that 99.9% of these addresses hold BTC worth significantly more than $10. This $10 valuation is a crucial linchpin of the lawsuit. The complaint relies on an unnamed expert's opinion stating that each address was worth less than $10 "as is" at the time of finding, on the premise that recovering their contents is uncertain. This specific valuation strategically places all 39,069 addresses under Section 257(2) of Article 7-B, the statute's fastest track, which grants title to the finder just one year after the find date, bypassing a multi-year police holding period. If the addresses were valued closer to their actual market prices, they would fall into a higher statutory bracket requiring a three-year police holding period, rendering the one-year shortcut unavailable. The complaint's three title-vesting dates precisely correspond to the three "found dates" plus one year, a timeline only valid if the sub-$10 valuation is accepted.

The origins of these defendant addresses are linked to a blockchain "dusting" campaign. Galaxy Research identified all but one of these addresses in an October 2025 report detailing this practice, where minuscule amounts of BTC are sent to addresses, often to track wallet activity. Between June and July 2025, over 39,000 addresses received OP_RETURN messages—a Bitcoin data field used to embed text—claiming the sender had taken constructive possession of the coins. Galaxy's research at the time suggested these messages were laying the groundwork for a legal abandonment claim, a report that earned Best Crypto Research for 2025 from the Association of Cryptocurrency Journalists and Researchers.

Galaxy's May 2026 analysis further traced the funding for both the 2025 dusting campaign and the 2026 court-ordered onchain service to a single Bitcoin address, which Galaxy refers to as the "Bankroll" address. The firm found that 99.6% of the 2025 dusting transactions were funded within two hops from this address, which subsequently also funded the 2026 service operation. Due to the anonymous nature of Bitcoin addresses, the court authorized alternative service under CPLR § 308(5): each defendant address received a 546-satoshi payment (approximately 4 cents) containing an OP_RETURN message linking to a website hosting the legal pleadings. Galaxy confirmed 98 batch transactions across Bitcoin blocks 950,446 to 950,576, reaching all 39,069 addresses between May 21–22, 2026. However, the adequacy of such onchain legal notice remains an open question, as Bitcoin operates differently from account-based systems like Ethereum; most Bitcoin wallet software does not display OP_RETURN payloads and often filters incoming dust transactions as spam.

Despite the potential for a complete plaintiff victory, crypto legal observers across the industry concur that such an outcome would not enable Noah Doe to move a single coin. Without private keys, a court declaration of title confers no ability to transact on the Bitcoin network, as the protocol does not recognize court orders; only a valid cryptographic signature can move BTC. The primary practical concern, as noted by Galaxy and legal commentators, is the creation of a "cloud on title." This legal document could be presented by the plaintiffs to regulated exchanges or custodians if any of the listed bitcoins were to appear at a centralized venue. Such an action could trigger asset freezes and compel original owners to surface and prove ownership, potentially at the cost of their anonymity. This leverage over regulated intermediaries, rather than any direct ability to seize coins, is what gives the case its significant potential impact.

Given that the defendants are pseudonymous Bitcoin addresses, a technical default is anticipated around late June 2026, roughly 30 days after the service. A motion for default judgment would likely ensue. The court, however, retains discretion to hold a hearing before issuing a declaration of title, and legal observers highlight that the profound novelty of the legal theory and the immense scale of the claim are factors that typically invite rigorous judicial scrutiny.