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The seizures are analogous.

Per the document linked to Madoff's estate was put under an "order freezing assets" [1]. Dotcom's property is described as being "seized and restrained" [2], not confiscated or forfeited.

[1] http://www.sec.gov/news/press/2008/2008-293-order.pdf

[2] http://www.nzherald.co.nz/technology/news/article.cfm?c_id=5...



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