The digital currency community has been closely tracking a case involving a pseudonymous plaintiff known as “Noah Doe,” who filed suit in the New York Supreme Court claiming he developed a proprietary algorithm capable of identifying 39,069 dormant bitcoin addresses.

The wallets included addresses associated with Satoshi Nakamoto, Mt Gox, the Counterparty burn address, and others. After cataloging the addresses onto USB drives, Doe delivered them to the NYPD as allegedly found property and invoked New York’s lost-and-found statute (Article 7-B), arguing that legal title to roughly 3.8 million BTC, valued at approximately $293 billion, has vested in him.

While the case recently drew widespread attention and a technical default was expected by late June, approximately 30 days after service, several bitcoin wallets created in 2011 and tied to Noah Doe’s list of 39,069 addresses he claims to have found shifted to new addresses. Meanwhile, at the end of May, New York attorney Ian R. Cohen filed a Proposed Order to Show Cause along with a proposed amicus curiae brief, prompting the judge to issue a stay and setting the stage for a hearing.

Then, on Sunday at block height 952,767, a wallet listed as No. 137 on Noah Doe’s roster of addresses shifted a sizable trove of bitcoin. Galaxy Research spotted the transfer, which moved 1,878.5711 BTC, worth $114.16 million. The source wallet was originally funded on Dec. 18, 2019, roughly 6.5 years ago. In its X post, Galaxy Research further noted that the bitcoin came from an address labeled “Salomon Client Dusted.”

Alex Thorn, head of firmwide research at Galaxy, speaking on the latest 1,878.5711 BTC move.

“Salomon-dusted” is Galaxy Research’s shorthand for any wallet that received one of the tiny “dust” transactions dispatched by Salomon Brothers Strategic Advisors on behalf of Noah Doe. The transfers consisted of 546 satoshis, worth less than a dollar, and were distributed across thousands of addresses identified in the lawsuit. In bitcoin parlance, “dusting” refers to sending minuscule amounts of BTC to an address; here, the practice served as a legal notification mechanism, embedding an OP_RETURN notice directly into the transaction history of each targeted wallet.

The OP_RETURN notice begins with the declaration: “This digital wallet appears to be lost or abandoned. Our client has taken constructive possession of it and is [sic] seeks to determine if there is a bona fide owner.” The latest activity from several 2011-era wallets and Sunday’s transfer of 1,878.5711 BTC weakens one of the central assumptions underlying Noah Doe’s theory.

If addresses identified as “lost” or “abandoned” continue to demonstrate signs of control years later, the premise that inactivity alone establishes abandonment becomes increasingly difficult to sustain. What happens next depends on the hearing. Whether the judge views the recent wallet activity as legally significant remains to be seen. But for anyone watching this case, the blockchain has already delivered its own answer, recorded permanently at the protocol level.

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