Blockchain law: ‘In rem’ and ‘quasi’ in rem jurisdiction in digital assets disputes

The “Blockchain Law” column first began seven years ago this month with a discussion of “Personal Jurisdiction in the Age of Blockchain”, R. Schwinger, N.Y.L.J., Nov. 20, 2018, an exploration of how participating in various activities on blockchain systems can create in personam jurisdiction over those participants.

But when ordinary in personam jurisdiction is not available in a dispute about digital assets, is there room for other kinds of personal jurisdiction, such as in rem and quasi in rem jurisdiction?

The Delaware Court of Chancery recently had occasion to grapple with the application of these jurisdictional concepts in the blockchain context in Timoria LLC v. Anis, et al., and 1064.994 ETH, In rem Defendant, 2025 WL 2827657 (Del. Ch. Oct. 6, 2025), an opinion by Vice Chancellor Laster. Timoria LLC concerned a dispute over allegedly misappropriated Ether tokens in a multi-national setting. Jurisdictional issues quickly came to the fore when expedited injunctive relief was sought at the start of this action.

Robert A. Schwinger explores recent developments in this edition of his New York Law Journal Blockchain Law column.

Read the full New York Law Journal article, "Blockchain law: ‘In rem’ and ‘quasi’ in rem jurisdiction in digital assets disputes."