A New York lawsuit is testing whether dormant Bitcoin wallets can be treated as abandoned property under traditional lost-and-found rules, even when the claimant does not hold the private keys needed to move the coins. The suit, filed in the Supreme Court of the State of New York, County of New York, under Index No. 153119/2026, is a summons and first amended complaint for declaratory relief, not a final order granting ownership.
Plaintiffs Seek Title to Dormant Bitcoin Wallets
The plaintiffs are Noah Doe, described in the filing as a New York citizen and resident, and two Wyoming LLCs, ABC Company and XYZ Company. They are seeking a judicial declaration that they own 39,069 allegedly abandoned digital wallets listed as John Does 1–39,069. The complaint says the wallets come from three groups of records found between late December 2024 and April 2025, then submitted to the NYPD before being returned months later.
Crypto researcher Sani of TimechainIndex.com described the scale of the claim in an X post, writing: “A New York suit by ‘Noah Doe’ and two Wyoming LLCs seeks a court order confirming their ownership of 39,069 long-dormant Bitcoin wallets, arguing the wallets are legally ‘abandoned’ property they found, reported to NYPD, noticed on-chain and in the press, and then claimed under NY lost-and-found statutes. The total holdings of these addresses are 3,791,121.17697938 BTC, with addresses attributed to Satoshi Nakamoto, early miners, Casascius Coins, lost coins, hackers and unidentified entities. Note that for majority of old coin holders like Satoshi Nakamoto, the notice was sent to the P2PKH version of the addresses which hold no to dust value, while the real balances are held the P2PK version.”
The 3.79 million BTC figure comes from the X analysis, not from the complaint text itself. The filing says Doe found a net 42,001 digital wallets and removed 2,932 addresses for various reasons, including 424 that took on-chain action to show they were not abandoned. The remaining 39,069 wallets are the focus of the suit, with the plaintiffs claiming title vested under New York Personal Property Law § 257 on different dates tied to the three wallet groups.
Court Fight Turns on Abandonment and Keys
The complaint’s legal theory rests heavily on dormancy, self-custody and notice. It claims Doe developed an “Algorithm” in fall 2024 to identify abandoned wallets after identifying a “security issue” involving wallets whose owners had lost withdrawal ability. The filing says wallets inactive for five years or longer are “highly likely” to have been abandoned, and that custodial wallets such as exchange addresses were excluded from the pool.
The plaintiffs also describe a broad notice campaign. Doe retained Salomon Brothers Strategic Advisors Inc. in February 2025 to help contact potential owners, host a notice webpage and identify wallets that may have been incorrectly included. From June 30 through July 10, 2025, a cyber/blockchain expert sent OP_RETURN messages directing wallet holders to an abandonment notice page, giving them until October 10, 2025, to show the wallets were not abandoned.
Salomon Brothers’ August 7 press release framed the campaign as a protective effort, with representative R. Adam Smith stating, “Securing wallets protects the millions of wallets that are not abandoned.” Galaxy Research later analyzed what it called the “Great Bitcoin Dusting,” writing that an unknown actor sent 41,523 OP_RETURN messages from 3,738 sender addresses to 39,423 recipient addresses holding 2,334,482.52 BTC at the time. Galaxy also found that “98.82% of addresses receiving messages were legacy P2PKH addresses” and that the average adjusted dormancy was 2,171 days, or about 5.95 years.
The central unresolved issue is practical as much as legal. The complaint itself states that a private key is required to withdraw cryptocurrency and that without the private key, withdrawal is impossible. That leaves the court to consider whether traditional abandoned-property concepts can establish legal title to dormant self-custodied crypto addresses, while the Bitcoin system still requires cryptographic control before any coins can move.
The case places a novel property-law claim in direct contact with Bitcoin’s key-based ownership model. Even if the plaintiffs obtain the declaratory relief they seek, the filing acknowledges that legal title and technical control are not the same thing. For crypto markets and legal observers, the suit is likely to be watched less for immediate coin movement than for how a court addresses dormancy, notice, abandonment and private-key possession in self-custodied digital assets.
AI Transparency Note: This article was prepared with the assistance of an AI system based on the sources listed and was reviewed, edited, and approved by a human editor before publication. All quotes, data points, and factual claims are intended to be grounded in the cited source material; however, errors cannot be ruled out entirely.