High-profile Crypto Case in English High Court: Issue of Identity as Satoshi Nakamoto Litigated

Citation: [2023] EWHC 3287 (Ch)
Judgment on


In the high-profile case of Crypto Open Patent Alliance v Craig Steven Wright & Ors, various significant legal issues were litigated in the English High Court concerning the ‘Identity Issue’—whether Dr. Craig Steven Wright is Satoshi Nakamoto, the pseudonymous creator of Bitcoin. This article provides a systematic analysis of the case, focusing on the key legal principles applied.

Key Facts

The case involved a pre-trial review (PTR) to address applications by Dr. Wright for permission to rely on recently discovered documents, referred to as the ‘Additional Documents’, and for an adjournment of the impending trial. The additional materials purportedly substantiated Dr. Wright’s claim to be Satoshi Nakamoto. However, they were discovered well after the case management-imposed deadlines for disclosure. The complexity of the case is increased by allegations by COPA that some of the documents already relied upon by Dr. Wright had been fabricated or altered.

The court’s analysis was primarily informed by the principles enshrined within the Overriding Objective which promotes justice, expediency, proportionality, and fair handling of cases. Pertinent to this case were considerations of ensuring a fair trial, active case management, and enforcing compliance with rules and orders.

Fair Trial and Adjournment

The court needed to balance the principles of fairness and expediency in determining whether to adjourn the trial. There is a consensus that, above all else, a fair resolution is paramount. A trial must offer the parties a reasonable opportunity to present their cases fully. This entails that a litigant must not be denied justice due to an inability to prepare their case adequately, for example, through illness or late discovery of critical evidence. Yet, this must be reconciled with the costs, inconvenience, and potential unfairness a delayed trial might bring to other parties and the wider justice system.

Permission to Rely on Late Documents

The court deliberated on whether to grant Dr. Wright permission to rely on the Additional Documents which were disclosed post the set deadlines. The Civil Procedure Rules stipulate that reliance on documents disclosed beyond deadlines requires the court’s permission or parties’ agreement. The significance of the documents to the core issue must be weighed against the reasons for the late disclosure and its impact on the trial timetable.

Costs, Expert Evidence, and Case Management

The court had to manage several applications concerning costs orders and fees, including whether costs incurred due to the additional ASD report should be paid by Dr. Wright. Additionally, the management of expert evidence and how differences in expert opinions impacted trial proceedings were reviewed. The parties’ duties to assist the court in case management were underscored, particularly when alterations to the trial timetable were a focal point.


The court allowed Dr. Wright to rely on the Additional Documents and some of the related evidence, given the materiality of these documents to the Identity Issue. However, the court denied Dr. Wright’s application for an adjournment to the extent sought, instead compromising by pushing the trial date to 5th February 2024 to allow a fair trial within the existing trial slot. Further security for the Developers’ costs was ordered given the potential financial risk if Dr. Wright lost the trial. COPA was awarded costs incurred in relation to the ASD report after Dr. Wright’s inadequate instructions to his expert were revealed.


This complex case elucidates the balancing act that courts must perform to serve the Overriding Objective while also addressing the multidimensional aspects of fair trial practice, disclosure of evidence, and case management. The outcomes reflect judicial efforts to ensure trial readiness without causing undue disadvantage to any party, while encouraging the parties to co-operate with the court’s need for expedition and efficiency. Legal professionals are reminded of the crucial role that thorough preparation, timely disclosure, and adherence to court orders play in the expeditious resolution of cases.