Dormant Bitcoin Wallets Move as $238B Noah Doe Lawsuit Hits Court Stay

Noah Doe Bitcoin Case Hits A Stay

The NYSCEF docket shows Cohen filed a proposed order to show cause and a proposed amicus curiae brief on May 29. It then lists a June 5 decision and order on Motion No. 001, identified as an injunction and restraining order, and a June 5 order to show cause on Cohen’s Motion No. 004.

Bitcoin.com reported that Judge Kathy J. King stayed the proceedings and halted any push toward default judgment pending further hearing. The publicly available order image in NYSCEF did not extract into readable text in our review, so the docket and the secondary court-reporting record are both relevant.

The stay matters because the defendants are not people named in the usual way. They are Bitcoin addresses, and the court had allowed alternative service through OP_RETURN transactions, a Bitcoin field that can carry short text or links.

Galaxy said on-chain service was executed in 98 batch transactions across Bitcoin blocks 950,446 to 950,576 on May 21 and May 22. The docket separately lists an affirmation of service and verification exhibits filed May 22.

That process is a new kind of procedural stress test. A normal defendant can appear, hire counsel and contest ownership. A Bitcoin address cannot read a complaint, and a careful long-term holder may avoid any action that links an address to a real-world identity.

That same privacy problem sits behind earlier Bitcoin debates over Satoshi-era coins and quantum migration. In both cases, dormant coins create a public-policy temptation: outsiders want the network or a court to infer something from silence.

Dormant 2011 Wallets Move Onchain

The strongest factual blow to the abandonment claim came from the chain itself. CoinDesk reported that address 1LwWtSs7tMCwcRczQd5kVMv3xpWw6w4Sxe, which had held 35.55 BTC since March 2011, spent coins on June 2 in transaction b90755bf11506e120aafdb7058bf9dcc1ef251041b7c9d0de688a67421f40206.

The mempool.space address page shows that transaction confirmed in block 952,104 and spent an input of 35.546714 BTC, with outputs of 15 BTC and 20.546709 BTC. At $62,615 per BTC, that input was worth about $2.23 million.

A second address intensified the signal. Bitcoin.com reported that address 18sLgPeB9wQVrE8JoWqtKtnucbsx3Lw1m7, identified in coverage as defendant address No. 37923, moved 47.26 BTC on June 6 after sitting dormant since 2011. Its mempool.space record shows the old 47.25710519 BTC output feeding a June transaction.

Those two movements do not resolve the whole case. They do not prove every other listed address has an active owner, and they do not identify the people behind the keys.

They do make the plaintiffs’ broad premise harder to state cleanly. If an address can stay quiet for 14 or 15 years and then spend, inactivity alone is weak evidence that the owner abandoned the property.

The timing also lands during a fragile market backdrop. Bitcoin has been under pressure from ETF outflows and liquidations, including the recent drop below $62,000 during forced selling, so an old-wallet movement can quickly become both a legal headline and a trading headline.

Lost Property Theory Faces Bitcoin Test

Cohen’s brief attacks the case on several fronts: whether New York’s lost-property statute applies to self-custodied crypto, whether the court has jurisdiction over borderless Bitcoin, whether OP_RETURN service gives adequate notice and whether dormant wallets can be treated as abandoned at all.

The brief also warns that the defendant list includes historically sensitive coins. Galaxy’s analysis said the set includes Satoshi-pattern Patoshi addresses, a Mt. Gox hacker address and the Counterparty burn address, which is designed to be unspendable.

That mix is why the case is bigger than one unusual complaint. If a private party can scan a public ledger, send notice to addresses and ask a state court for title when no one appears, every large dormant wallet becomes a potential target for copycat litigation.

The court does not have to accept that theory for the case to matter. A partial ruling, a narrowed hearing, or even a rejection could still become a reference point for how judges think about Bitcoin ownership, notice and inactivity.

The same issue is already visible in technical debates over whether old coins should ever face network-level restrictions, including the proposal we covered when Bitcoin developers discussed freezing early wallets. Courts and protocol developers are dealing with different tools, but both are being asked whether silence should change property rights.

For U.S. crypto policy, the case also sits beside a broader move from improvisation toward formal rules. Daily Crypto Briefs has tracked that shift in our 2026 U.S. crypto regulation guide, where custody, wallet control, broker reporting and court-recognized property rights increasingly overlap.

What remains unknown is the next hearing schedule, whether any actual address owner will intervene and whether the court will address the lost-property theory on the merits or dispose of the case on narrower procedural grounds. The next verifiable signals are new NYSCEF docket entries, further old-wallet movements and any order explaining how far New York law can reach into self-custodied Bitcoin.