Who Is Noah Doe? Inside an Audacious Lawsuit to Claim Satoshi's Bitcoin | Galaxy
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Research •<br>May 27, 2026
‘Salmon Brothers’ Client Sues to Claim Legal Ownership of Satoshi’s Coins
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Insights / Research / ‘Salmon Brothers’ Client Sues to Claim Legal Ownership of Satoshi’s Coins
Research • May 27, 2026
‘Salmon Brothers’ Client Sues to Claim Legal Ownership of Satoshi’s Coins
Anonymous plaintiffs have asked a New York court to declare them owners of 3.8m long-dormant BTC, including coins tied to Bitcoin’s mysterious creator. The case has a dubious legal basis, but the stakes are enormous.
Alex Thorn
Head of Firmwide Research
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‘Salmon Brothers’ Client Sues to Claim Legal Ownership of Satoshi’s Coins
Introduction
Case Overview
Case Timeline
Parties to the Case
Legal Arguments Made by Plaintiffs
Assessment of the Plaintiffs’ Arguments
Onchain Analysis
Coins in the Noah Doe Address Set
The Value of the Coins
Service of Process by OP_RETURN
The Same Operator Ran the 2025 Dusting and Noah Doe Onchain Campaigns
Case Vulnerabilities
Does Article 7-B Even Apply?
The Valuation Is Not Credible
The Defendant Set Is Over-Broad and Self-Contradicting
The Anonymity of the Parties
Questions About the Process-Service Affiant
Conclusions
Potential Timelines
Implications of a Plaintiff Victory
Dormancy Is Not Abandonment
Introduction<br>In October 2025, Galaxy Research published a comprehensive report, “The Great Bitcoin Dusting: A ‘Salomon Brothers’ Client Tries to Claim Dormant Wallets,” in which we identified 39,423 Bitcoin addresses (the “dusted addresses”) that were sent ominous messages. These messages claimed that the sender (the uster) had taken constructive possession of their coins. We speculated then that the messages, contained in Bitcoin’s OP_RETURN arbitrary data field, were sent in an endeavor to establish an evidentiary pattern of notifying address owners prior to a potential legal effort to claim title to the assets as abandoned property. That report, written by Zack Pokorny and Will Owens, was named Best Crypto Research for 2025 by the Association of Cryptocurrency Journalists and Researchers.<br>Our speculation has now proved correct.<br>With little fanfare, a case was filed in New York’s Supreme Court in March seeking to claim quiet title to over 3.7m BTC (~$274b) associated with 39,069 bitcoin addresses (New York County Supreme Court, Index No. 153119/2026). The plaintiffs in the case are listed as “Noah Doe” and two unnamed Wyoming LLCs (“ABC Company” and “XYZ Company,” the “Wyoming LLCs”). These 39,069 bitcoin addresses (the “Noah Doe addresses”) are wholly a subset of the dusted addresses analyzed in our October report.<br>The pseudonymous plaintiffs ask the New York County Supreme Court to declare that they own these dormant Noah Doe addresses and their contents under New York’s lost-and-found property statute (Pers. Prop. Law Art. 7-B) via a declaratory judgment action (CPLR § 3001). Crucially, the plaintiffs are seeking legal title over the entirety of addresses suspected of belonging to Bitcoin creator Satoshi Nakamoto (21,744 addresses holding ~1.09m BTC worth ~$83.7b at current prices).<br>Put simply: an anonymous individual and his Wyoming LLCs are seeking to have a New York court rule that Bitcoin creator Satoshi Nakamoto’s coins (and a lot of other coins) are lost property that they deserve to legally own by virtue of “finding” them. This report combines onchain data and court documents to examine the scope of affected coins, potential motivations and identities of the plaintiffs, implications for Bitcoin, and likelihood that the plaintiffs are successful.
Case Overview<br>Three...