A Bitcoin address identified as Noah Doe #38097 transferred 40 BTC in block 965,330 on Sept. 3, after remaining inactive since Nov. 5, 2011. Galaxy Research valued the transaction at approximately $3.1 million and calculated price appreciation of about 2,571,899% from Bitcoin's roughly $3 price when the coins were received. The address is among 39,069 listed in a New York County Supreme Court lawsuit, ABC Company, XYZ Company and Noah Doe v. John Does 1–39,069, which seeks legal title to coins allegedly abandoned under Article 7-B of New York's Personal Property Law. The movement proves that someone controls the address's private key, but it does not identify that person, establish lawful ownership or show that the Bitcoin was sold. The transfer may affect the address's inclusion in the case, while the broader dispute over jurisdiction, ownership and the application of lost-property law to self-custodied Bitcoin remains unresolved.