Digital Chamber Files Brief Over Dormant Satoshi Wallets

Digital Chamber Files Brief Over Dormant Satoshi Wallets 

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Digital Chamber Files Brief Over Dormant Satoshi Wallets
  • Noah Doe sued for title to 39,069 dormant Bitcoin wallets he found by algorithm.
  • Digital Chamber says dormancy alone cannot prove abandonment under New York law.
  • Noah Doe never held private keys, so cannot access or move funds from any wallet.

The Digital Chamber, the United States’ oldest and largest digital asset trade association, has filed an amicus brief in the New York State Supreme Court opposing a lawsuit that seeks to claim ownership of tens of thousands of dormant Bitcoin wallets, some of which are believed to be linked to Bitcoin’s pseudonymous creator, Satoshi Nakamoto.

What the Lawsuit Claims

A New York resident identified as Noah Doe developed an algorithm in 2024 to identify dormant Bitcoin wallets and ran it on his personal computer, identifying 42,001 wallet addresses that had seen no on-chain activity for at least five years. He copied those addresses onto USB drives, delivered them to the New York City Police Department, and received property receipts he described as evidence of finding.

Between June and July 2025, his team sent OP_RETURN messages directly on the Bitcoin blockchain to the identified wallets, directing holders to an abandonment notice. Ninety days later, having received no response from 39,069 of the wallets, Noah Doe and his associated companies filed suit claiming title to all of them under New York’s lost property law, arguing that five years of inactivity constitutes abandonment.

Why the Digital Chamber Is Pushing Back

The Digital Chamber’s brief argues the claim fails on every legal ground and would cause serious harm far beyond this case.

First, the brief says the court has no jurisdiction because the wallets have no physical presence in New York and their owners, described by the plaintiffs themselves as unknown and unknowable, have no connection to the state. Second, New York’s Article 7-B personal property law applies to tangible property and certain instruments, not intangible cryptographic wallet addresses compiled from publicly available data. 

Third, abandonment under New York law requires proof of intent to relinquish, which dormancy alone cannot establish. Extended inactivity is consistent with long-term holding strategies, cold storage security practices, estate situations, or simply having no reason to transact.

Critically, the brief points out that Noah Doe never held the private keys to a single wallet in question. Without private keys, no party can move or access the funds. Granting title to someone who cannot control the property would create a cloud over the title of tens of thousands of real owners who could wake their wallets at any time. At least two targeted wallets have already become active after the lawsuit was filed.

The Bigger Threat to Self-Custody

The Digital Chamber warned that the ruling sought would punish holders for using self-custody wallets, one of the foundational features of the digital asset ecosystem. If courts accept inactivity as abandonment, every dormant wallet on the Bitcoin blockchain, representing more than 63% of all Bitcoin that has not moved in over a year, could attract competing claims from private finders.

The brief also flagged international comity concerns, noting that wallet owners may reside anywhere in the world and could be stripped of property without any meaningful opportunity to be heard in their own jurisdiction.

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