Galaxy Research analyst Alex Thorn confirmed on X that a Bitcoin address dormant since March 27, 2011 transferred 35.55 BTC (about $2.54 million) on June 2 at block height 952104. The address had previously been listed as a defendant in a New York abandoned property lawsuit.
Noah Doe Lawsuit Core Claims: A Legal Loophole in the “Below $10 Valuation” Strategy
Key parameters of the case:
Case number:** 153119/2026, filed March 11, 2026**
Target addresses: 39,069 dormant Bitcoin addresses
Claimed holding amount: about 3,799,629 BTC, valued at about $29.35 billion at market prices
Plaintiff’s valuation strategy: value each address at less than $10, trigger the shortcut for low-value proceedings under Section 257(2), so that ownership can be completed within one year after discovery
Galaxy Research actual data: 39,069 addresses average 97.25 BTC per address (about $7.5 million), with a median of 50 BTC
Gap: Alex Thorn described the gap between the plaintiff’s $10 valuation and the actual total of $29.35 billion as “nine orders of magnitude”
The court authorized 98 batch transactions between Bitcoin blocks 950446 and 950576 via OP_RETURN messages. Each target address received 546 sats and included a link pointing to the case documents.
June 2 Transfer Confirmed: Holders Respond After the “Dust Notice”
(Source: Alex Thorn)
Address 1LwWtSs7tMCwcRczQd5kVMv3xpWw6w4Sxe first received Bitcoin on March 27, 2011, when each coin was about $0.87. After sitting idle for 15.2 years, it made its first outgoing transfer on June 2, 2026.
After Noah Doe sent an on-chain dust transaction (including a link to court documents) to that address, Alex Thorn said on X: “These long-dormant bitcoins were submitted by Noah Doe in the abandoned property case, but apparently they are not abandoned items in practice.” Legally, this transfer affirmed that the holders had active control over the bitcoins, and direct awareness of the lawsuit.
The Real Legal Effect of a Default Judgment
Alex Thorn explained the scope of effect of a default judgment: the court order will produce a legal document that can be used against designated crypto assets appearing at regulated custodians or exchanges, leading to asset freezes and forcing holders to publicly prove ownership. Thorn calls this a “cloud on title.”
Thorn also noted that the likelihood of a court approving a declaration of complete ownership assignment in a default situation is as low as “low to medium.” Private keys will never be transferred through court orders under any circumstance. Based on about 30 days after the service notice, the earliest technical breach would arrive by the end of June 2026.
FAQ
What legal basis did the Noah Doe lawsuit cite?
The plaintiffs relied on New York State’s Personal Property Law, Section 7-B, arguing that long-dormant Bitcoin addresses fit the definition of abandoned property. They used a per-address valuation of less than $10 to initiate the low-value proceedings shortcut under Section 257(2), shortening the time required to establish ownership.
Why can’t private keys be transferred via a court order?
Bitcoin network transfers require private keys to move funds, and a court order cannot override this technical mechanism. Even if the court issues an ownership ruling, the order can only take action on the specified addresses on regulated centralized platforms, and cannot directly affect on-chain control.
What legal impact does the June 2 transfer have on the lawsuit outcome?
This transfer confirmed that at least one listed address holder still actively controls the assets, directly undermining Noah Doe’s abandoned property claim for that address. The plaintiffs’ broader case covering 39,069 addresses remains ongoing; this transfer only has direct impact on the specific address that was transferred.
