Strike 3 Holdings, LLC v. Doe
- Kenneth Karas
- 7:25-cv-04669
- U.S. District Court · Southern District of New York
- 2
In Strike 3 Holdings v. Doe, Judge Karas allowed early subpoenas to identify the John Doe subscriber linked to an IP address.
Strike 3 Holdings, LLC may seek the identity and address of the John Doe subscriber from Spectrum and potentially other identified internet service providers. The subscriber may receive notice if the cable-privacy statute applies, and the disclosed information may be used only for the purposes stated in the order.
What happened
Strike 3 Holdings, LLC sued a John Doe subscriber associated with IP address 72.229.205.124. Before the usual early case-management conference, Strike 3 asked to subpoena Spectrum, the internet service provider, for the subscriber’s true name and address.
The court found that Strike 3 had shown good cause for the early subpoena. The order also permits subpoenas to other internet service providers identified in response to a subpoena.
Judge Kenneth Karas granted Strike 3 permission to serve the subpoenas. If Spectrum is a cable operator, it must send the defendant a copy of the order when disclosure is made under the federal cable-privacy statute. Strike 3 may use the disclosed information only to protect and enforce the rights described in its complaint.
The detailed version
- Strike 3 Holdings, LLC v. Doe · No. 7:25-cv-04669
- Kenneth Karas
- June 18, 2025
Background
Strike 3 Holdings, LLC sued John Doe, identified in the complaint as the subscriber assigned IP address 72.229.205.124. Strike 3 moved for permission to serve a subpoena on Spectrum before the parties held the conference normally required by Federal Rule of Civil Procedure 26(f).
Court’s Analysis
The court found that Strike 3 had established “good cause” for early discovery. It authorized Strike 3 to serve Spectrum with a subpoena under Federal Rule of Civil Procedure 45 seeking the defendant’s true name and address. Strike 3 must attach a copy of the order to the subpoena.
The court also authorized Strike 3 to serve the same type of subpoena on any service provider identified in response to a subpoena as providing internet services to one of the defendants.
If Spectrum qualifies as a “cable operator” under 47 U.S.C. § 522(5), the order requires it to comply with 47 U.S.C. § 551(c)(2)(B). That provision allows disclosure of personal identifying information under a court order if the subscriber is notified of the order by the person to whom the order is directed. The order therefore requires a copy to be sent to the defendant.
Order and Effect
Judge Kenneth Karas granted Strike 3 permission to serve the authorized subpoenas. Strike 3 may use information disclosed in response to a subpoena served on Spectrum only to protect and enforce the rights described in its complaint. The opinion does not decide the underlying claims against John Doe.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.