A new development has emerged in a New York lawsuit concerning the ownership of numerous dormant Bitcoin addresses. One wallet listed in the lawsuit transferred 40 Bitcoin on September 3, after being inactive for nearly 15 years, amounting to approximately $3.1 million at the time. This transaction indicates that the corresponding private key is still in someone’s possession, but it does not directly prove legal ownership.
40 BTC transferred from a dormant wallet
On-chain data shows that this transaction was confirmed in Bitcoin block 965,330. Galaxy Research labeled the outgoing address as “Noah Doe #38097” and stated it is related to a Bitcoin ownership case currently under review in New York.
The last activity on this address dates back to November 5, 2011, when the price of Bitcoin was around $3. This transfer only indicates that someone has access to the private key of this address; it is not possible to determine the identity of the operator or confirm whether these bitcoins have been sold, based solely on on-chain data.
The lawsuit involves 39,069 addresses.
This case has been filed in the Supreme Court of New York County, with plaintiffs ABC Company, XYZ Company, and Noah Doe suing anonymous defendants numbered 1 through 39,069. The plaintiffs seek a court ruling affirming their legal rights to the bitcoins associated with these addresses.
Previously, researchers reviewing the complaint found that these addresses collectively held approximately 3.7 to 3.8 million bitcoins. Based on earlier prices, the total value was estimated at around $293 billion. The list allegedly includes wallets associated with Satoshi Nakamoto, the Mt. Gox theft, and burn addresses, but these labels are primarily derived from on-chain analysis and do not constitute legal proof of ownership.
Address movements undermine the plaintiff's claim
The plaintiffs assert that the assets associated with these addresses constitute "lost or abandoned property" as defined under Article 7-B of the New York Personal Property Law. They state that these wallets were identified by algorithm, reported to law enforcement, and notified via small on-chain transfers containing messages.
However, the reactivation of wallets listed in the lawsuit contradicts the claim that “private keys are uncontrollable.” Reports indicate that the plaintiffs had previously removed certain addresses from their claims after activity resumed on those addresses. In July of this year, Alex Thorn of Galaxy Research stated that 44 addresses had been removed from the lawsuit due to renewed on-chain activity.
The dispute centers on the classification of self-custody.
Opponents argue that an address remaining inactive for a long time is not sufficient evidence that the assets have been abandoned. Lawyers Ian Cohen, the Digital Chamber, and the Bitcoin Policy Institute have all challenged the plaintiff’s legal reasoning, stating that an address on a public blockchain cannot be claimed as property simply because someone “saw” it.
Previously, a New York judge temporarily halted the proceedings to prevent the plaintiff from immediately obtaining a default judgment. To date, the court has not determined that these addresses constitute abandoned property, nor has it awarded the associated bitcoins to Noah Doe or the two companies. Even if the plaintiff ultimately obtains a favorable ruling, the judgment itself will not automatically grant them access to the private keys.

