Strike 3 Holdings, LLC v. Doe
- John Koeltl
- 1:25-cv-05667
- U.S. District Court · Southern District of New York
- 2
In Strike 3 Holdings v. Doe, Judge Koeltl allowed subpoenas seeking the defendant’s name and address from internet providers.
Strike 3 Holdings, LLC, John Doe, Spectrum, and any other internet service provider identified through the authorized subpoena process.
What happened
In Strike 3 Holdings, LLC v. John Doe, Strike 3 asked to subpoena Spectrum before the parties held their initial required conference. The subpoena seeks information identifying the defendant associated with the listed internet address.
The court found that Strike 3 had shown a sufficient reason to obtain the information early. It authorized Strike 3 to serve Spectrum with a subpoena for the defendant’s true name and address and to subpoena another internet provider identified through that process.
The order limits use of the information to protecting and enforcing Strike 3’s rights in this case. If Spectrum qualifies as a cable operator, it must notify the defendant by sending a copy of the order; Judge Koeltl did not decide the underlying claims.
The detailed version
- Strike 3 Holdings, LLC v. Doe · No. 1:25-cv-05667
- John Koeltl
- July 22, 2025
Background
Strike 3 Holdings, LLC moved for permission to serve a third-party subpoena before the parties’ required conference under Federal Rule of Civil Procedure 26(f). The proposed subpoena would be directed to Spectrum, identified in the order as the internet service provider, and would seek the true name and address of the defendant associated with the internet protocol address listed in the complaint.
Ruling
The court found that Strike 3 had established “good cause” for early discovery. It authorized Strike 3 to serve Spectrum with a subpoena under Rule 45 requiring Spectrum to provide 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 a similar Rule 45 subpoena on any service provider identified in response to a subpoena as providing internet services to the defendant. The order further states that, if Spectrum qualifies as a “cable operator” under 47 U.S.C. § 522(5), it must comply with 47 U.S.C. § 551(c)(2)(B) by sending the defendant a copy of the order as notice of the authorized disclosure.
Limits and scope
Strike 3 may use information disclosed in response to the Spectrum subpoena only to protect and enforce the rights asserted in its complaint. This order concerns early discovery and identification of the defendant; it does not decide the merits of Strike 3’s underlying claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.