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Intel· June 9, 2026· 5 min read

NY Court Halts Bid for 39,069 Dormant Bitcoin Wallets

On June 5, a New York Supreme Court judge stayed a lawsuit filed by a pseudonymous plaintiff who claims that 39,069 dormant Bitcoin wallets holding approximately 3.7 million BTC are legally abandoned property under New York's lost-and-found statute and that he owns them. On June 6, a 2011-era wallet listed in the case moved 47 BTC after 15 years of dormancy, undercutting the abandonment theory in real time. Attorney Ian R. Cohen's amicus brief invoked 'not your keys, not your coins' as a legal proposition. A July 14 hearing will decide whether New York's century-old lost-property statute can reach a public blockchain.

Key takeaways

  1. On March 11, 2026, a pseudonymous plaintiff identified as Noah Doe filed suit in New York Supreme Court under Index No. 153119/2026, claiming ownership of 39,069 Bitcoin wallets dormant for at least six years. The legal basis is Article 7-B of New York's Personal Property Law, a lost-and-found statute written for physical objects. The 39,069 wallets collectively hold approximately 3.7 million BTC worth roughly $234 billion at current prices. The list includes addresses attributed to Satoshi Nakamoto and addresses associated with the Mt. Gox hacker.
  2. Noah Doe claims to have identified the wallets using an algorithm that detects a claimed 'security vulnerability' preventing owners from accessing funds, leading to abandonment. He sent OP_RETURN messages to 42,001 candidate wallets between October 2024 and April 2025 directing holders to a webpage with a 90-day response window. Only 424 wallets took on-chain action. The remaining 39,069 became the basis for a declaratory judgment claim that Noah Doe and two Wyoming LLCs own them outright.
  3. On June 5, 2026, Judge Kathy J. King of New York Supreme Court issued a Decision and Order staying the case and blocking any push toward a default judgment pending further hearing. The stay followed an amicus brief filed May 29 by attorney Ian R. Cohen on behalf of unnamed Bitcoin holders. Cohen argued that Article 7-B was written for physical objects, not blockchain entries, and invoked 'not your keys, not your coins' as a legal proposition: private key control is the standard of Bitcoin ownership, and Noah Doe holds no private keys.
  4. On June 6, 2026, Galaxy Research analyst Alex Thorn flagged a transaction where 47.26 BTC moved from defendant wallet address 37923 in the case, a wallet that had been inactive since June 17, 2011. The movement undercuts the lawsuit's central premise: at least one wallet listed as abandoned has an active owner who can access funds. A July 14, 2026 hearing at New York County courthouse is scheduled to address the amicus motion and set the case's procedural path.
  5. The case is the private-sector legal parallel to BIP-361, which proposes that the Bitcoin network freeze coins in quantum-vulnerable addresses. Both raise the same foundational question: does dormancy constitute forfeiture of Bitcoin ownership, and who gets to decide? The dormant wallet case answers through New York property law. BIP-361 would answer through protocol governance. Bitcoin's foundational answer to both has been consistent: the private key is the proof of ownership.

What Happened

On March 11, 2026, a pseudonymous plaintiff identified only as Noah Doe filed suit in New York Supreme Court under Index No. 153119/2026. The complaint, assembled by Brooklyn-based Lewis & Lin LLC and amended May 1, claims that 39,069 Bitcoin wallets dormant for at least six years have been legally abandoned and that Noah Doe, by virtue of having 'found' them under New York's Personal Property Law Article 7-B, holds legal title. The wallets collectively hold approximately 3.7 million BTC worth roughly $234 billion at current prices. The list includes addresses attributed to Satoshi Nakamoto and addresses associated with the Mt. Gox hacker.

On June 5, 2026, New York Supreme Court Judge Kathy J. King issued a Decision and Order staying the case. The stay followed an amicus brief filed May 29 by New York attorney Ian R. Cohen, who intervened on behalf of Bitcoin wallet holders arguing that the case should not proceed toward a default judgment without first addressing whether Article 7-B of New York's Personal Property Law applies to Bitcoin at all. A hearing is set for July 14, 2026 at New York County courthouse. On June 6, the case gained a new on-chain data point: Galaxy Research analyst Alex Thorn flagged 47.26 BTC moving from defendant address 37923, a wallet that had not moved funds since June 17, 2011, directly undercutting the abandonment premise.

The Lost Property Theory and Why It Has Not Been Tested

New York Personal Property Law Article 7-B establishes a legal framework for property found by private individuals. Under the statute, a finder of lost property of sufficient value is required to deposit it with the appropriate authority and, after a waiting period without the owner coming forward, may claim title. The statute is approximately a century old and was designed for tangible physical objects: wallets, jewelry, electronics. Noah Doe's complaint stretches this framework to argue that he is a 'finder' under Article 7-B, that the dormant Bitcoin wallets are 'lost property' under the statute, and that his notification process (OP_RETURN blockchain messages directing wallet holders to a webpage) is the functional equivalent of depositing found property with police. The 90-day response window he gave wallet holders, until October 10, 2025, was the required waiting period. The 39,069 wallets that did not respond have been abandoned.

The claimed factual basis for dormancy is significant. Noah Doe does not argue that wallets are dormant because holders chose not to transact. He argues the 39,069 wallets have a 'security vulnerability' preventing owners from accessing or withdrawing funds. This claim serves a specific legal purpose: if wallets are dormant because owners chose not to transact, they may not be 'abandoned' under the statute. If they are dormant because owners cannot access them due to a technical flaw, the abandonment argument is stronger. The June 6 on-chain movement of a claimed-abandoned wallet directly challenges the technical-access premise: at least one wallet the lawsuit claims is inaccessible moved 47.26 BTC after 15 years, showing a live owner who was monitoring the case and could access funds.

The Amicus Brief and the 'Not Your Keys' Legal Argument

Ian R. Cohen's May 29 amicus brief is the procedural intervention that stopped the case from proceeding toward a default judgment. Cohen argues three structural points. First, Article 7-B was written for physical objects that can be deposited with police. Bitcoin exists on a globally distributed ledger that is not physically located anywhere in New York. The concept of 'depositing' a public blockchain address with the NYPD is incoherent under the statute's original framework. Second, dormancy on a public ledger is not abandonment. A person scanning a public ledger with an algorithm is not a 'finder' under the statute because Bitcoin does not need to be physically found: its entire transaction history is publicly visible to anyone with a network connection. Third, Cohen invoked 'not your keys, not your coins' as a legal proposition. Bitcoin ownership is defined by control of the private key. Noah Doe holds no private key corresponding to any of the 39,069 wallets. He has run an algorithm over a public ledger and asserted title.

The counter-argument Cohen addresses: what if the security vulnerability claim is factual? If wallet owners genuinely cannot access funds because of a technical flaw, and those funds have been sitting untouched through multiple cycles of price appreciation, does the law offer any remedy? Cohen's answer is structural: involuntary deprivation of access is not abandonment. If anything, the security-vulnerability claim supports an investigation into the alleged flaw, not a declaratory judgment transferring title to the person who identified inactive addresses. This is why July 14 matters: the court needs to establish whether any factual predicate allows Article 7-B to reach a public blockchain address before any other question can proceed. The June 6 dormant wallet movement strengthens Cohen's position: the case's own on-chain evidence record is evolving against the plaintiff's abandonment theory in real time.

What This Means for You

If you self-custody Bitcoin in your own keys on the Bitcoin network, this case does not threaten your holdings today. Judge King's June 5 stay blocks any default judgment, and Cohen's amicus brief has framed the legal questions in a way that makes a plaintiff victory at the July 14 hearing unlikely without a substantially stronger factual record. But the case establishes that the theory of applying lost-property law to dormant Bitcoin wallets has been filed, has reached a New York Supreme Court hearing, and will now receive a judicial answer. If the court finds Article 7-B can apply to public blockchain addresses, the ruling would reshape what dormancy means for every long-inactive Bitcoin holder.

The specific security vulnerability Noah Doe claims as the basis for abandonment has not been named or independently verified in public filings as of this writing. If it exists and affects the 39,069 wallets, it would be a security finding warranting immediate disclosure rather than a lawsuit seeking title transfer. The June 6 dormant wallet movement is relevant: a wallet listed in the case moved 47 BTC after 15 years, meaning at least one wallet owner was actively monitoring the situation and could access funds. That is directly inconsistent with the claim that the wallets are technically inaccessible.

Self-custody of Bitcoin means holding private keys to addresses you control. No one can claim legal title to those addresses by scanning the public blockchain, however creative the property-law theory. A public blockchain address is not lost in any geographic sense. The ledger is the ownership record. The private key is the title document. Noah Doe has not found anything. He has searched a public database and filed a lawsuit. Whether a New York court agrees that these are different things is what July 14 will answer.

What to Watch

Watch the July 14, 2026 hearing at New York County courthouse. The critical legal question is whether Judge King will accept Cohen's argument that Article 7-B of the Personal Property Law cannot apply to public blockchain addresses, which would effectively end the case. If the court rules that Article 7-B is facially applicable and sets a path toward discovery, the case enters a much longer phase. Whether Noah Doe's attorneys can identify and describe the specific security vulnerability they claim prevents the 39,069 wallet owners from accessing funds is pivotal, because the entire abandonment theory depends on that factual claim holding. Any movement of additional named-defendant-wallet addresses on-chain before July 14 would matter, because each movement undermines the abandonment premise and strengthens the dormancy-by-choice argument. The broader Bitcoin community's legal response is the next thing to track: the case is now in a posture where amicus filings carry weight, and additional technical experts testifying about how Bitcoin private key ownership works could affect the court's foundational understanding of the property theory. And watch whether this case influences the BIP-361 debate about network-level freezing of quantum-vulnerable addresses, because both proceedings share the same underlying question: what does dormancy mean for Bitcoin ownership, and who decides when the answer is no?

Private key control is Bitcoin ownership. The court's answer on whether New York lost-property law disagrees is due July 14.

Sources

  1. [1]The Block — 'NY judge stays lawsuit seeking ownership of nearly 40,000 bitcoin wallets, sets July hearing on proposed amicus brief', June 8, 2026
  2. [2]The Crypto Times — 'New York Judge Halts Bid to Claim 39,000 Dormant Bitcoin Wallets', June 8, 2026
  3. [3]CoinDesk — 'Satoshi-era BTC at center of $285 billion bitcoin lawsuit moves after 14 years', June 6, 2026
  4. [4]Bitcoin.com News — 'NY Court Pauses Default Judgment After Lawyer Argues 39,069 Bitcoin Wallets Were Not Abandoned', June 2026
  5. [5]Bitcoin Magazine — 'Anonymous Plaintiff Seeks Legal Title To $293 Billion In Dormant Bitcoin, Without Holding Any Private Keys', May/June 2026
  6. [6]CCN — 'Who Owns Inactive Bitcoin? New York Lawsuit Tests Dormant BTC Wallets as Lost Property', June 2026
  7. [7]BeInCrypto — 'NY Judge Halts Lawsuit Claiming 39,069 Dormant Bitcoin Wallets Until July Hearing', June 2026

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