From:                                         Matthew Hoyle <MHoyle@oeclaw.co.uk>

Sent:                                           Thursday 13 February 2025 11:46

To:                                               'Kelvin F.K. Low'; Gerard McMeel KC; Lucas Clover Alcolea

Cc:                                               Wilde, Mark; Steve Hedley; obligations@uwo.ca; Daniel Seng

Subject:                                     RE: Bitcoin and Restitution

 

A1P1 is usually a pure point of law, so an appeal court would generally – but not inevitably – let you take it. Only if, for example, further evidence was needed in order to ascertain facts necessary to decide whether the thing claimed amounted to a “possession” within the Strasbourg case law would you have a problem.

 

Also, A1P1 generally imposes low thresholds for state interference. Even if this was a deprivation case, rather than a “control of use” case (and it seems much more likely to be the latter), there is a clear lawful basis for the deprivation, and an obvious justification: the state needs to be able to effectively manage waste disposal in the general interest. It cannot have people clogging up the system suing for their property back (or worse, getting injunctions preventing disposal of collected rubbish) or much worse going round trying to dig up and recapture things they have thrown away accidentally (or intentionally but with later regret).

 

That has the potential to paralyse local waste management, which clearly has huge public health and safety implications. I can’t see how this is a disproportionate measure given that public interest.

 

Best,

 

Matthew

 

Matthew Hoyle

Barrister

One Essex Court

 

This message is confidential and may be privileged. If you believe you have received it in error please delete it immediately and inform the sender immediately.

 

Regulated by the Bar Standards Board.

 

From: Kelvin F.K. Low <kelvin.low@gmail.com>
Sent: 13 February 2025 11:31
To: Gerard McMeel KC <Gerard.mcmeel@quadrantchambers.com>; Lucas Clover Alcolea <lucas.cloveralcolea@monash.edu>
Cc: Wilde, Mark <Mark.Wilde@city.ac.uk>; Steve Hedley <S.Hedley@ucc.ie>; obligations@uwo.ca; Daniel Seng <danielseng@nus.edu.sg>
Subject: Re: Bitcoin and Restitution

 

Dear Gerard, 

 

First, given that his lawyers did not raise the A1P1 issue at trial, would he be allowed to raise it on appeal? Given that his claim was also dismissed because of limitation? I would think not. 

 

Secondly, I'm not sure that the jurisprudence is wide enough to cover information on a tangible, as opposed to the tangible itself. Surely A1P1 covers the hard drive but to stretch it to cover information on a tangible simply because the owner of the tangible had terrible data backup practices (the claimant claims to be a computer engineer which makes it even more inexcusable) seems like a terrible idea. Consider a scenario where he had a backup which is only subsequently lost, and his partner had taken the hard drive to the tip to spite him after a lovers' tiff. Surely he would not be able to prevail against the council to the value of the bitcoin even if A1P1 meant the legislation was void? I would think therefore that even if he prevailed on A1P1 in respect of the hard drive, the losses in relation to the bitcoins would be too remote.

 

Thirdly, and I think most neutral observers think this: even if this somehow went to trial, I find it hard to believe that he would actually be able to prove the facts necessary to sustain his claim. In addition to being a lousy computer engineer (no backup of important data), he's a lousy partner (too lazy to take out his own trash), and at the very least gave lousy instructions (leading his partner to take out the supposedly wrong hard drive). 

 

In earlier reports (eg https://www.theguardian.com/technology/2013/nov/27/hard-drive-bitcoin-landfill-site)), he admits:

 

""You know when you put something in the bin, and in your head, say to yourself 'that's a bad idea'? I really did have that," Howells, who works in IT, told the Guardian. "I don't have an exact date, the only time period I can give – and I've been racking my own brains – is between 20 June and 10 August. Probably mid-July". At the time he obliviously threw them away, the 7,500 Bitcoins on the hard-drive were worth around £500,000."

 

More likely than not, his "memory" suddenly improved to fit the facts of his claim. I mean, less than half a year after the hard disk was tossed, he couldn't even be sure of the date it happened. Now, he's sure his ex partner did it and it was unauthorised to boot. 🙄 Heck, do we even know (and I'm simply asking on the civil standard of proof) that the hard disk is in the tip?

 

Cheers,

 

Kelvin 

 

 


From: Gerard McMeel KC <Gerard.mcmeel@quadrantchambers.com>
Sent: Thursday, February 13, 2025 6:11:13 pm
To: Kelvin F.K. Low <kelvin.low@gmail.com>; Lucas Clover Alcolea <lucas.cloveralcolea@monash.edu>
Cc: Wilde, Mark <Mark.Wilde@city.ac.uk>; Steve Hedley <S.Hedley@ucc.ie>; obligations@uwo.ca <obligations@uwo.ca>; Daniel Seng <danielseng@nus.edu.sg>
Subject: Re: Bitcoin and Restitution

 

Dear Kelvin et al

 

I was reading this case yesterday on the back of this, and I see your discussion of information got a cite, and was followed. The core of the reasoning is that it is information "on" the hard drive that is at issue.

 

The statutory answer is brisk, but for me raised the question of whether it could stand with the UK Human Rights Act and the A1P1 protection of possessions. All title is overridden in things which arrive at a recycling/waste disposal centre whether authorised or not? The jurisprudence would seem wide enough to cover information on a tangible hard drive. I suspect that may feature in an appeal.

 

Whatever one thinks of the bin bags and ex-partner story - it surely does then become important whether the disposal was "authorised" (an issue the judge only commented on parenthetically). If that is right this whole bonkers tale should be going for trial.

 

Best,

 

Gerard 

 

 

 


From: Kelvin F.K. Low <kelvin.low@gmail.com>
Sent: 13 February 2025 01:34
To: Lucas Clover Alcolea <lucas.cloveralcolea@monash.edu>
Cc: Wilde, Mark <Mark.Wilde@city.ac.uk>; Steve Hedley <S.Hedley@ucc.ie>; obligations@uwo.ca <obligations@uwo.ca>; Daniel Seng <danielseng@nus.edu.sg>
Subject: Re: Bitcoin and Restitution

 

External Email

 

Yes, re scammers, you're mostly right. Though because intermediaries exist (banks), it is possible to allocate losses to them instead of the end consumer, which some jurisdictions do in relation to authorised push payment frauds. Also, again because banks exist and transfers are not instantaneous, it is possible to freeze transfers pending investigations, all impossible in the brave new crypto world - one of the reasons, I suspect, despite the advertising, intermediaries are everywhere in crypto. So whilst there are certainly similarities, crypto is an easier system for fraudsters to exploit. 

 

But one thing is clear, no one would be suing their local councils to dig up a rubbish tip to recover their banking password. 

 

Kelvin

 

Sent from Outlook for Android


From: Lucas Clover Alcolea <lucas.cloveralcolea@monash.edu>
Sent: Thursday, February 13, 2025 9:27:41 AM
To: Kelvin F.K. Low <kelvin.low@gmail.com>
Cc: Wilde, Mark <Mark.Wilde@city.ac.uk>; Steve Hedley <S.Hedley@ucc.ie>; obligations@uwo.ca <obligations@uwo.ca>; Daniel Seng <danielseng@nus.edu.sg>
Subject: Re: Bitcoin and Restitution

 

For sure, you can get a new password fairly easily (though with 2FA it is a little more complicated, particularly if you change your phone number and/or phone itself) but the issue of keeping copies, using the same password and weakening etc are what I was getting at. Certainly storing passwords and even credit card data across multiple websites, often with the same password, is not uncommon and creates multiple points of weakness either through hacking of the whole website (we've all seen several examples each year) or someone specifically targeting you. The issues with scammers etc are also endemic. 

 

-Lucas

 

On Thu, 13 Feb 2025, 11:20 Kelvin F.K. Low, <kelvin.low@gmail.com> wrote:

Actually, that's not quite true. If you lose your banking password, the bank can allow you to create a new one once you prove your identity. This is not possible with asymmetric cryptography where private key and public key are a mathematically linked pair. I expect this is one of the reasons why asymmetric cryptography - invented in the 1970s - was never applied to consumer banking in the sense of asking consumers to safeguard their private keys.

 

Kelvin

 


From: Lucas Clover Alcolea <lucas.cloveralcolea@monash.edu>
Sent: Thursday, February 13, 2025 9:14:46 AM
To: Kelvin F.K. Low <kelvin.low@gmail.com>
Cc: Wilde, Mark <Mark.Wilde@city.ac.uk>; Steve Hedley <S.Hedley@ucc.ie>; obligations@uwo.ca <obligations@uwo.ca>; Daniel Seng <danielseng@nus.edu.sg>
Subject: Re: Bitcoin and Restitution

 

In fairness that's the same with everything electronic, it's not unique to crypto (although total inability to access funds because you forgot your code/seed etc is). Take online banking, do you use a different password for each site or the same password everywhere? Or do you use a password that Google makes up for you but which is stored on your Google account (that also needs password, taking you back to square 1)? Do you write your password or pin down or tell someone (usually no, but could be an issue for people with bad memories etc)? 2FA doesn't necessarily solve these problems, and can also cause others, for example if you change your phone number or lose your phone (let's say it's stolen, as that will also raise the problems discussed above) it will be a pain to get access again. Moreover, text messages etc can be spoofed. Biometric security can likewise be overridenn easily through coercion or deceit. The constant arms race between banks/regulators and scammers is another example, the easier it is to bank electronically, and in particular if you start linking your bank account to other apps as you now can in some countries, the easier it is to get scammed or defrauded. Electronic banking can't be stopped altogether however, so instead banks use 2FA or pause transfers to a new account etc, but then scammers spoof 2FA or pretend to be your bank alerting you to a scam etc... 

 

All the best,

Lucas

On Thu, 13 Feb 2025, 11:02 Kelvin F.K. Low, <kelvin.low@gmail.com> wrote:

Not ironic at all since all of our virtual world, whether digital files in the metaphorical cloud or this crypto nonsense is very much rooted in the physical world. Everything is on some hard disk somewhere and transmitted through some sort of cable for the most part, something Daniel Seng (NUS) and I emphasise in a forthcoming article for LIT: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4308631

 

If multiple copies exist, then this sort of situation (where you have to dig up your private key stored on a hard drive) will be less of an issue since in the tech lingo, there won't be a single point of failure. But of course, then you run into a different problem (in the crypto context) - thieves now have multiple hard drives to steal. So you avoid having a single point of failure for accidental loss by creating multiple points of failure for theft? This is the future of finance? 🙄

 

Kelvin 

 


From: Wilde, Mark <Mark.Wilde@city.ac.uk>
Sent: Wednesday, February 12, 2025 6:19:34 PM
To: Steve Hedley <S.Hedley@ucc.ie>; obligations@uwo.ca <obligations@uwo.ca>
Subject: Re: Bitcoin and Restitution

 

Somewhat ironic that something which is the epitome of our virtual brave new world ends up having to be dug up like buried treasure!

 

Mark

 

 


From: Steve Hedley <S.Hedley@ucc.ie>
Sent: Tuesday, February 11, 2025 6:50 PM
To: obligations@uwo.ca <obligations@uwo.ca>
Subject: Bitcoin and Restitution

 

CAUTION: This email originated from outside of the organisation. Do not click links or open attachments unless you recognise the sender and believe the content to be safe.

 

A postscript to Howells v Newport City Council, recently discussed in this forum.  As the article notes, the case is under appeal.

 

Man who binned 7,500 Bitcoin drive now wants to buy entire landfill to dig it up (The Register, 11/2/25)

 

 

 

Steve Hedley

9thlevel.ie

s.hedley@ucc.ie

private-law-theory.org

 

 

From: Samuel Beswick <sbeswick@sjd.law.harvard.edu>
Sent: Friday 10 January 2025 21:28
To: Robert Stevens <robert.stevens@law.ox.ac.uk>
Cc: obligations@uwo.ca
Subject: Re: Bitcoin and Restitution

 

[EXTERNAL] This email was sent from outside of UCC.

It also has a third thing, which I am interested in: the claimant's "desperate argument" to extend time for filing suit in reliance on section 32 of the Limitation Act 1980. There's been a flurry of case law on limitation discoverability over the past four years which I canvas in the next LMCLQ issue. The court here properly dismissed that argument.

 

On Thu, 9 Jan 2025 at 06:09, Robert Stevens <robert.stevens@law.ox.ac.uk> wrote:

An amusing case, combining two of the things I am interested in.

 

https://www.bailii.org/ew/cases/EWHC/Ch/2025/22.html

 

The claimant, by mistake, in 2013 deposits a hard drive containing the key to his Bitcoin wallet in a landfill site in Newport. Claims that the Bitcoin now worth in excess of £600m (more than the value of the landfill site. Or, indeed, Newport.)

 

Seeks a declaration that either the council digs up the site to find it, or allows his team of experts to do so.

 

Claim is struck out. Lots of “proprietary restitutionary” stuff.

 

Rob

 

 

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