A closely watched New York lawsuit seeking legal ownership of long-dormant Bitcoin wallets has narrowed after dozens of the targeted addresses showed signs of activity on the blockchain.
According to Galaxy Research Head Alex Thorn, the plaintiffs behind the case—identified as “Noah Doe” and two Wyoming-based entities—have removed 44 Bitcoin wallet addresses from the lawsuit after those wallets moved funds on-chain following the filing of the case.
The lawsuit seeks to have thousands of inactive Bitcoin wallets declared abandoned property under New York’s lost-property laws. The original complaint targeted 39,069 wallet addresses holding an estimated 3.7 million BTC, including wallets allegedly linked to Bitcoin creator Satoshi Nakamoto and addresses associated with the Mt. Gox hack.
Thorn stated that each of the 44 removed wallets had recorded on-chain activity since the lawsuit was filed, undermining the argument that the assets had been abandoned. According to his analysis, the wallets held approximately 21,443 BTC when the case began, later moved a combined 46,334 BTC, and currently contain roughly 3,097 BTC.
The development is significant because the lawsuit itself indicated that addresses demonstrating activity would no longer qualify as dormant and would therefore be removed from the list of defendants. The latest filing appears to reflect that requirement.
The case has generated considerable debate within the cryptocurrency industry, where many argue that wallet inactivity alone does not prove that Bitcoin has been abandoned. Long-term holders often store assets in cold wallets for years without making transactions, while still retaining full control of their private keys.
Recent on-chain movements have strengthened that argument. Earlier reports highlighted a 30 BTC wallet that became active after nearly 15 years of inactivity despite being included in the lawsuit, raising questions about whether dormant addresses can reasonably be presumed abandoned.
The legal theory behind the case has also faced growing opposition. Attorney Ian R. Cohen has argued that self-custodied Bitcoin cannot be considered abandoned simply because it remains inactive for an extended period. He contends that New York’s abandoned-property laws were not designed to apply to decentralized digital assets secured by private keys.
In addition, the cryptocurrency advocacy group The Digital Chamber submitted an amicus brief opposing the lawsuit, warning that a favorable ruling for the plaintiffs could create broader legal uncertainty for self-custodied digital assets.
Legal experts have also noted that even if the plaintiffs were successful, a court ruling would not automatically grant access to the Bitcoin itself. Without possession of the private keys, the plaintiffs would only obtain a legal declaration of ownership, potentially creating complications if any of the coins were later transferred to regulated exchanges or custodial platforms.
A major focus of the case remains the inclusion of thousands of early Bitcoin mining addresses. Galaxy Research previously reported that more than 21,000 wallets listed in the complaint display the so-called “Patoshi” mining pattern, which some researchers believe may be associated with Satoshi Nakamoto’s early mining activity.
While the lawsuit still targets thousands of wallets, the removal of 44 active addresses demonstrates that the scope of the case remains fluid. The latest developments have reinforced a central argument of the opposition: inactivity on the Bitcoin blockchain does not necessarily mean that ownership has been lost or abandoned.
