Noah Doe Claims Title to 39,069 Dormant Addresses via New York Lost-and-Found Statute
A pseudonymous plaintiff calling himself “Noah Doe,” alongside two Wyoming LLCs, filed suit in New York Supreme Court on March 11, 2026, seeking legal recognition as the rightful owner of 39,069 dormant Bitcoin addresses containing approximately 3.8 million BTC, valued at roughly $293 billion.
The case marks the first known attempt in U.S. history to claim title to cryptocurrency under a lost-and-found property statute. The plaintiff invoked New York Personal Property Law Article 7-B, a statute designed for tangible objects such as wallets and jewelry found in public spaces. The law requires a finder to report lost property to police, make reasonable efforts to locate the owner, and receive no response within a set period before taking legal title.
The defendant addresses span multiple categories of historical significance. Roughly 21,923 addresses carry the “Patoshi” nonce pattern, an onchain fingerprint widely attributed to Bitcoin creator Satoshi Nakamoto, holding approximately 1.096 million BTC valued at $84.7 billion. One defendant address holds 79,957 BTC stolen in the 2011 Mt. Gox hack, coins that have been actively tracked by investigators for over a decade and remain subject to ongoing recovery proceedings. A Counterparty “burn” address, provably unspendable and never controlled by any person, is also named as a defendant.
The complaint’s legal strategy hinges on valuation. According to the filing, an unnamed expert opined that each address was worth less than $10 “as is” at the time of finding, based on uncertain recovery prospects. This $10 threshold places all addresses into Section 257(2) of Article 7-B, the fastest title-vesting track, under which the plaintiff could claim ownership one year after the find date with no extended police holding period. If valued at current market prices instead, the addresses would fall into the statute’s top bracket, requiring a three-year police holding period.
The dusting campaign that preceded the lawsuit began between June and July 2025, when over 39,000 addresses received OP_RETURN messages claiming constructive possession. Galaxy Digital, a blockchain research firm, identified all but one defendant address in an October 2025 report on the dusting campaign. Galaxy published a detailed analysis of the case in May 2026.
On May 21 and 22, 2026, the court ordered onchain service of the complaint via OP_RETURN messages to all 39,069 addresses across Bitcoin blocks 950,446 to 950,576. The service included 98 batch transactions, each carrying a 546-satoshi payment worth approximately $0.04. Galaxy’s analysis traced funding for both the 2025 dusting campaign and the 2026 court-ordered service to a common source, with 99.6% of the 2025 dusting transactions funded within two hops of an address labeled “Bankroll.”
The complaint was filed on March 11, 2026, and amended on May 1, 2026. The filing lists three alleged title-vesting dates: December 26, 2025, March 31, 2026, and April 14, 2026. A technical default is possible approximately 30 days after service.
A Bitcoin address remains fully accessible to its original owner regardless of whether someone else has identified it. Coins do not move unless the true keyholder signs a transaction. The plaintiff never held private keys to any of the 39,069 addresses. The median defendant address holds 50 BTC, valued at approximately $3.86 million; the average address holds 97.25 BTC, worth roughly $7.5 million.
