Murphy v. Department of Homeland Security, No. 1:25-cv-01025 (D.D.C.), ECF 1 — FOIA complaint (DHS agent's 2019 statement about interviewing "Satoshi")
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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.
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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JAMES A. MURPHY,
4990 Sadler Place
Unit 5604
Glen Allen, VA 23058
Plaintiff,
v. Civil Action No.: 25-1025
DEPARTMENT OF HOMELAND
SECURITY,
2707 Martin Luther King Jr. Ave., SE
Washington, DC 20528
Defendant.
COMPLAINT
1. Plaintiff James A. Murphy brings this action against Defendant
Department of Homeland Security (“DHS”) and its component, Immigration and
Customs Enforcement (“ICE”), to compel compliance with the Freedom of Information
Act (“FOIA”), 5 U.S.C. § 552.
2. The requested records relate to an interview DHS conducted of someone
named, or using the pseudonym, Satoshi Nakamoto, which is the name often used for
the person(s) who claims to have created the digital asset Bitcoin. See Ex. A.
3. These records are immensely important, as federal and state officials
are currently taking steps to investigate potential investment in Bitcoin. For
instance, on March 6, 2025, President Trump issued an Executive Order establishing
a “Strategic Bitcoin Reserve.” The Order directs that all Bitcoin held by the federal
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government be placed in a Strategic Bitcoin Reserve, and it authorizes the Secretaries
of the Treasury and Commerce to develop budget-neutral strategies for acquiring
additional Bitcoin for the Reserve. See Exec. Order No. 14,233, § 3, 90 Fed. Reg.
11,789, 11,789–90 (Mar. 6, 2025).
4. Similarly, the U.S. Senate is considering legislation that would establish
a Bitcoin reserve operated by the U.S. Treasury. 1
5. Additionally, nearly 20 states are currently considering legislation that
would authorize investing public funds in Bitcoin. 2
6. Beyond these government actions, many public and private companies
also currently hold Bitcoin on their balance sheets as treasury assets. The largest of
these in the United States is Strategy (NASDAQ: MSTR), which holds over 500,000
Bitcoin worth more than $4.25 billion. 3
7. Over $100 billion is currently invested in U.S. exchange-traded products
that hold only Bitcoin. 4 These products trade on U.S. securities exchanges and are
held and traded by individuals, retirement accounts, college and university
endowments, pension funds, and a variety of institutions.
1 SeePress Release, Sen. Cynthia Lummis, Lummis Introduces Strategic Bitcoin
Reserve Legislation (July 31, 2024), https://tinyurl.com/3u35bu9k.
2 See Jesse Hamilton, North Carolina Joins Growing Number of States Pursuing
Crypto Investments, CoinDesk (Feb. 10, 2025), https://tinyurl.com/4tafya8v.
3 See Mehab Qureshi, MicroStrategy now holds over 500,000 Bitcoin after $584M
purchase, The Street Roundtable (Mar. 24, 2025), https://tinyurl.com/yyadekeu.
4 See Bob Pisani, ETFs holding bitcoin are now the crypto’s largest holders, surpassing
creator Satoshi Nakamoto, CNBC (Dec. 12, 2024), https://tinyurl.com/ysvj9dh9.
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8. Given the massive public and private investment in Bitcoin, it is
important for Mr. Murphy and the public to understand better what the federal
government knows about the identity of the actor(s) responsible for creating Bitcoin.
9. To better understand these issues, Mr. Murphy submitted a FOIA
Request to DHS on February 12, 2025. See Ex. A.
10. To date, DHS has failed to comply with its statutory obligation to
respond to Mr. Murphy’s FOIA request.
11. DHS is thus depriving Mr. Murphy and the public of vital information.
JURISDICTION AND VENUE
12. This Court has jurisdiction over this action pursuant to 5 U.S.C.
§ 552(a)(4)(B) and 28 U.S.C. § 1331. Additionally, it may grant declaratory relief
pursuant to 28 U.S.C. § 2201 et seq.
13. Venue is proper in this District pursuant to 5 U.S.C. § 552(a)(4)(B) and
28 U.S.C. § 1391(e).
PARTIES
14. Mr. Murphy is an attorney licensed to practice law in New York and
Virginia. He is a resident of the Commonwealth of Virginia. He regularly publishes
information to thousands of people through the social media platform X (formerly
known as Twitter) where he posts using the handle @MetaLawMan. Through these
posts, Mr. Murphy primarily focuses on news and commentary on legal issues related
to digital assets, including cryptocurrencies such as Bitcoin. Mr. Murphy has also
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been an investor in Bitcoin and other cryptocurrencies for several years, and he also
engaged in Bitcoin mining for several years.
15. DHS is an agency of the federal government within the meaning of
5 U.S.C. § 552(f), and DHS, along with its component ICE, has possession and control
of the records Mr. Murphy seeks.
BACKGROUND
A. Bitcoin explained.
16. Bitcoin is a digital currency operating on a peer-to-peer network, which
allows users to send and receive payments without the need for intermediaries like
banks or governments.
17. The Bitcoin network was created in 2009 by an anonymous individual
or group using the pseudonym Satoshi Nakamoto.
18. Bitcoin transactions are recorded on a public ledger called a blockchain,
which ensures transparency and security.
19. Bitcoin is generated through a process called “mining,” where powerful
computers solve complex mathematical problems to validate transactions—the
movement of Bitcoin from one wallet to another on the blockchain.
20. The “miners” earn rewards for running the computational work in the
form of new Bitcoins.
21. Bitcoin has a limited supply—capped at 21 million coins—and it is
considered to be a store of value (like “digital gold”) and a medium of exchange.
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22. The total market value of all Bitcoin in existence is over $1.7 trillion,
and it is estimated that there are more than 100 million owners of Bitcoin worldwide. 5
23. Bitcoin is the only major cryptocurrency whose creator is unknown to
the public.
B. DHS Interviewed Bitcoin Creator Satoshi Nakamoto.
24. On April 29, 2019, DHS Special Agent Rana Saoud gave a presentation
at the OffshoreAlert Conference North America. At the time of her presentation,
Special Agent Saoud served as an Assistant Special Agent in Charge in the Homeland
Security Investigations office in Miami, Florida.
25. Special Agent Saoud was subsequently promoted, and, according to her
LinkedIn profile, she currently serves as Special Agent in Charge of Homeland
Security Investigations in the Nashville, Tennessee office. See Rana Saoud,
LinkedIn, https://tinyurl.com/35ereahv (last visited Apr. 6, 2025).
26. During her April 29, 2019 public presentation, Special Agent Saoud
affirmed that DHS knows the identity of Satoshi Nakamoto.
27. In fact, Special Agent Saoud stated that DHS agents traveled to
California to interview Nakamoto about his creating Bitcoin. According to Special
Agent Saoud, when the agents got to California, there were actually three other
people who had been involved with creating Bitcoin, and the agents met with all four
individuals to discuss how Bitcoin works and why they created it.
5 See Bitcoin’s Market Cap Reaches $1.7 Trillion, Representing 1.3% of Global Money
Supply, Blockchain.news (Mar. 22, 2025), https://tinyurl.com/83jybxuj.
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28. Specifically, during her public presentation, Special Agent Saoud
explained the circumstances surrounding the meeting with Nakamoto:
One of our agents … he was [a] really, really smart, forward-
leaning agent, and he goes “I want to go interview Satoshi
Nakamoto,” and we’re like “What?” He said, “Yeah I want to go
interview this guy.” And at the time, we’re like “Hey, it was a
figment of somebody’s imagination, maybe it’s true, maybe it’s not
true.” So, you know, we had all this push back from our
headquarters and we thought: “Hey, if an agent wants to go talk
to him and we have some money why don’t we send him? Let’s
find out how this works.” So, as it came to be, the agents flew out
to California, and they realized that he wasn’t alone in creating
this. There were 3 other people. And they sat down and met with
them and talked to them to find out how this actually works and
what their reason for it was. 6
29. DHS has never disclosed the identities of these four Satoshi Nakamotos
to the public.
C. Mr. Murphy’s FOIA Request.
30. To learn more about these important events, on February 12, 2025, Mr.
Murphy submitted a FOIA request to DHS. 7 See Ex. A.
6 OffshoreAlert, Regulating Cryptocurrencies & ICOs: Security, Commodity, or
Currency?, YouTube, at 44:21–45:10 (May 24, 2019), https://tinyurl.com/2s92yf9z
(recording of The OffshoreAlert Conference on Financial Intelligence &
Investigations (Apr. 29, 2019)).
7 In January 2025, Mr. Murphy submitted a separate FOIA request to DHS seeking
records about interviews of Satoshi Nakamoto. That request, which DHS referred to
ICE, was assigned tracking number 2025-ICFO-17214. Mr. Murphy does not
challenge ICE’s response to that request through this lawsuit. Rather, through this
lawsuit, Mr. Murphy challenges DHS’s failure to respond to his February 12, 2025
FOIA request.
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31. In that request, Mr. Murphy sought four categories of records:
(1) Any transcript of the public statements made by DHS Special
Agent Rana Saoud at the Off-Short Alert Conference North
America on April 27, 2019.
(2) Records of any interview conducted by DHS of someone
named, or using the pseudonym, Satoshi Nakamoto, including
any transcription of the interview, audio or video recording of
the interview, notes taken during the interview, or
correspondence sent or received that reference the interview.
(3) Records of any interview conducted by DHS of an individual
purporting to have created Bitcoin or whom DHS believes
created Bitcoin, including any transcription of the interview,
audio or video recording of the interview, notes taken during
the interview, or correspondence sent or received that
reference the interview.
(4) Records discussing the identity of the creator(s) of Bitcoin.
Ex. A at 1 (footnotes omitted).
32. Mr. Murphy limited responsive records to those created, sent, or
received between January 1, 2009, and the date of the search. See id. at 1.
33. Mr. Murphy also identified the following DHS components as those most
likely to have responsive records: the Office of the Secretary; the Office of the Deputy
Secretary; the Science and Technology Directorate; and Homeland Security
Investigations, which is housed within ICE. See id. at 1–2.
34. Mr. Murphy also requested a fee waiver based on his status as a media
requester and given the significant public interest in the requested records. See id.
at 2.
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35. On February 13, 2025, DHS sent Mr. Murphy a letter acknowledging
receipt of the FOIA request and assigning it tracking number 2025-HQFO-02468. See
Ex. B.
36. Additionally, DHS referred the request to ICE. See id. at 1.
37. On February 19, 2025, ICE sent Mr. Murphy an email acknowledging
receipt of the FOIA request, but stating that “Mr. Murphy has already submitted this
request.” Ex. C. ICE further stated that it would “continue to process this request
under tracking number 2025-ICFO-17214.” Id.
38. On February 19, 2025, Mr. Murphy’s counsel responded to ICE’s email,
acknowledging that “Mr. Murphy previously submitted a FOIA request seeking
records on similar topics,” but noting that “the February 12, 2025 request differs in
several ways from the request ICE assigned tracking number 2025-ICFO-17214.”
Ex. D. Accordingly, Mr. Murphy’s counsel asked that ICE “confirm that [it] is
processing the request submitted on February 12, 2025.” Id.
39. To date, ICE has not responded to that correspondence, and Mr. Murphy
has not received any further correspondence from DHS or ICE regarding his
February 12, 2025 FOIA request. Accordingly, the statutory deadline for DHS to
respond has passed.
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COUNT I
Violation of FOIA, 5 U.S.C. § 552
40. Plaintiff repeats the foregoing paragraphs as if set forth fully herein.
41. DHS is an agency of the federal government within the meaning of 5
U.S.C. § 552(f).
42. By letter dated February 12, 2025, Mr. Murphy submitted a valid FOIA
request to DHS. See Ex. A.
43. That request reasonably described all requested records and complied
with all applicable statutes and regulations.
44. DHS has failed to respond to the request by conducting a search
reasonably calculated to locate responsive records, as FOIA requires. See Weisberg
v. U.S. Dep’t of Just., 705 F.2d 1344, 1351 (D.C. Cir. 1983).
45. And the requested records are not exempt from FOIA pursuant to 5
U.S.C. § 552(b).
46. DHS has also failed to respond to Mr. Murphy’s request within the
statutory time period. See 5 U.S.C. § 552(a)(6).
47. Accordingly, Mr. Murphy has exhausted his administrative remedies.
See 5 U.S.C. § 552(a)(6)(C).
48. By failing to release all responsive, non-exempt records, DHS has
violated FOIA. See 5 U.S.C. § 552(a)(3)(A).
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PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court:
i. Declare that the requested records, as described in the foregoing
paragraphs, must be disclosed pursuant to 5 U.S.C. § 552.
ii. Order DHS to conduct legally sufficient searches immediately for all
records responsive to Plaintiff’s FOIA request and demonstrate that the search
methods were reasonably likely to lead to the discovery of responsive records.
iii. Order DHS to produce by a date certain all non-exempt records
responsive to Plaintiff’s FOIA request.
iv. Award Plaintiff attorneys’ fees and costs incurred in this action
pursuant to 5 U.S.C. § 552(a)(4)(E).
v. Grant Plaintiff such other and further relief as this Court deems proper.
April 7, 2025 Respectfully submitted,
/s/ Brian J. Field
BRIAN J. FIELD
D.C. Bar No. 985577
SCHAERR | JAFFE LLP
1717 K Street NW
Suite 900
Washington, DC 20006
Tel.: (202) 787-1060
Email: [email protected]
Counsel for Plaintiff James A. Murphy
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