Original ｜Odaily Planet Daily（@OdailyChina）
Author｜Golem（@web3_golem）
Do you remember the "legal claiming" lawsuit regarding Satoshi Nakamoto's Bitcoin address that stirred up a lot of discussions online back in June this year?
A plaintiff using the pseudonym Noah Doe is trying to legally confirm her ownership of about 3.799 million bitcoins (worth approximately $23.9 billion) associated with 39,069 dormant Bitcoin addresses under New York state lost and found laws. This includes 21,744 addresses belonging to Satoshi Nakamoto, which total approximately 1.09 million bitcoins (worth about $68.6 billion). This absurd lawsuit is noteworthy not only for its unprecedented scale but also because the outcome could have implications for the legal protection of digital asset holders in the United States. （Related reading:Satoshi Nakamoto in a lawsuit? A value of $83.7 billion BTC is about to be "legally claimed"）
Fortunately, the case has been suspended, with the latest hearing scheduled for September 8. However, since June, the case has not stalled; its progress can be described as "interesting," and more importantly, the success or failure of the Clarity bill advancing in the Senate will play a crucial role in the direction of this case.
Case Progress: Large Amounts of Dormant Bitcoin Transferred, Address Owners Forced to Surface
According to New York state law, after the finder submits a delivery confirmation within 30 days, if the defendant address owner does not appear, a default judgment will occur, and the ownership of these 39,069 dormant bitcoins will belong to Noah Doe. But on June 4, Judge Kathy J. King issued a suspension order, pausing all further procedures and scheduling an oral argument on July 14 to discuss whether lost and found laws apply to blockchain assets.
Over $2.1 Billion in Dormant Bitcoin Transferred
Meanwhile, as the case gained traction on social media, Bitcoin whales who seldom "surf the internet" finally learned that someone was paying attention to their addresses and began transferring bitcoins.
On June 2, the first address among the defendant's Bitcoin addresses triggered a transfer, moving 35.55 bitcoins, worth approximately $2.2 million, from a dormant independent address that had been inactive since March 2011. Then, on June 6, the address numbered 37923 transferred 47.26 bitcoins, worth nearly $3 million; on June 19, address number 1504, dormant since 2012, transferred 199.216 bitcoins.
According to statistics from Galaxy Research, since the lawsuit was filed, 52 of the defendant addresses have transferred 34,335 bitcoins (approximately $2.163 billion) on-chain, with 29 addresses transferring 12,302 bitcoins shortly after "receiving subpoenas."
Noticing the unusual activity, plaintiff's attorney David D. Lin applied to the New York court on June 18 to lift the suspension of the lawsuit, eager to expedite the proceedings out of fear that assets in the defendant's Bitcoin addresses might be completely transferred away.
Defendant Number 33 Appears in Court
However, unexpectedly for everyone, before the court made a decision, a previously unresponsive defendant voluntarily submitted an appearance application.
On June 30, the owner of the Bitcoin address numbered 33 submitted a notice of appearance and a motion to dismiss to the New York Supreme Court, becoming the first actual owner to object to Noah Doe's lawsuit. The documents filed by defendant 33 not only refuted the theory of Bitcoin address ownership but also launched attacks on the foundational structure of the lawsuit.
Firstly, they claimed that Bitcoin addresses are neither natural persons nor legal entities and cannot be subjected to court jurisdiction; the real holders are "natural persons with property rights protected by the Constitution." Secondly, according to Section 7-B of the Personal Property Law, publicly visible on-chain addresses cannot be "picked up"; this provision is aimed at tangible items that have actual locations and are held by the police, and Noah Doe's operation of the Bitcoin public ledger algorithm does not equate to finding lost property.
Additionally, “Defendant Number 33” pointed out that the case is very unfriendly to defendants because while the plaintiff can choose to remain anonymous, the defendant is required to disclose their identity when appearing in court, and publicly holding large amounts of Bitcoin could expose the holder to personal safety threats.
After the Hearing, the Case Remains Suspended, Focusing on the September 8 Hearing
Seeing the situation deteriorate, on July 7, plaintiff Noah Doe voluntarily withdrew the lawsuit against 44 already active addresses, which had held about 21,443 bitcoins at the time of filing but later transferred over 46,000 bitcoins, valued at over $2.9 billion. This also meant that only 39,025 addresses remain among the defendants.
Among the 44 addresses removed from the lawsuit, the address numbered 106 held the most bitcoins, approximately 2,100 bitcoins at the start of the case, but transferred over 20,000 bitcoins through multiple transactions between March and July.
After the July 14 hearing, the court issued multiple “Order to Show Cause” on July 16 and scheduled the next hearing for September 8, also fully suspending the case's progress and prohibiting the plaintiff from advancing any applications for default judgment.
CLARITY Latest Draft Provisions
Since the case was filed in March, the actual debate has long ceased to be simply whether Satoshi Nakamoto's Bitcoin addresses can be legally claimed; it also involves how the American law interprets digital property—whether ownership is proven through cryptographic private keys or through holding physical assets or accounts at designated intermediary institutions.
The US Digital Chamber of Commerce has even expanded concerns beyond the crypto market; if the court considers a long period of inactivity as a relinquishment of ownership, then holders of other tokenized assets or blockchain-based real assets may also face uncertainty as to whether "quiet ownership" can be protected in the absence of activity.
In a nation that prides itself on the "sacred and inviolable" nature of private property, if this case is not handled properly, it could have a significant adverse impact on the future of the American crypto economy.
Essentially, the reason Noah Doe was able to file the lawsuit was due to exploiting a loophole in American law. Therefore, to fundamentally prevent such incidents from happening, the law must keep pace with the times and provide clear legal grounds for court rulings.
The latest version of the CLARITY draft released on July 22 responds to this need.
The latest version of the CLARITY draft, Section 20216, defines self-custodied digital assets as those over which the owner maintains exclusive control of the private key necessary for authorized transactions. It also stipulates that legitimately held self-custodied digital assets cannot be deemed abandoned, unclaimed, or subject to forfeiture, return, acquired by prescription, ownership by finders, or any similar property claims solely because of inactivity, dormancy, or the owner's failure to express ongoing interest, and this provision supersedes any state or local political subdivision’s laws or regulations.
If based on the latest regulations of the CLARITY Act, the lawsuit initiated by Noah Doe would directly crumble, as the entire premise of her lawsuit is built on the assumption that the dormancy of these Bitcoin addresses equates to abandonment or being unclaimed. Noah Doe would directly lose the case.
However, the provisions also state that courts must distinguish between two categories of digital assets: one being cryptocurrencies that individuals directly control via private keys, and the other being cryptocurrencies stored on exchanges or custodial institutions. The new CLARITY Act protects the first category of digital assets, while state unclaimed property rules still apply to the second category of assets.
In short, this means that if users deposit digital assets into exchanges or custodial institutions, if the deposit address of the exchange or custodial institution becomes inactive for a long time or ceases to exist, then finders can claim and own these addresses and assets via lost and found laws.
It appears that if one desires to hold a digital asset for the long term, the best approach from the perspective of American law is still to transfer it to an independent wallet where they control the private keys.
In summary, if the new version of the CLARITY Act is passed, such lawsuits will have legal precedent in the future, meaning that the U.S. will officially recognize the legal ownership of dormant address asset holders from a legal standpoint. However, the problem is that due to the bipartisan differences on moral clauses, the current CLARITY Act seems to be facing difficulties in advancing through the Senate, （Related reading:So close yet so far, what is holding back the Clarity Act?）
If the CLARITY Act cannot be passed before the summer recess of Congress, then the final ruling outcome of this case still holds great uncertainty...
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