Ipsos MMA, Inc. v. John Doe

Background

The court considered an unopposed letter motion by the defendant, identified in the case as “John Doe,” to continue proceeding permanently under that pseudonym. Doe also asked that his identifying information in the pleadings remain redacted. He argued that the case involved serious professional-misconduct claims that Ipsos MMA, Inc. had not established and that the action had settled early.

The court had previously allowed Doe to proceed pseudonymously at an early stage of the case. The opinion states that the case settled promptly, before formal discovery, and that no further motions practice or other litigation would occur.

Legal standard

Federal Rule of Civil Procedure 10(a) generally requires a complaint to name all parties. The court explained that pseudonymous litigation is permitted when a party makes a proper showing. Courts balance interests including the sensitivity of the issues, potential harm from disclosure, the public interest in knowing the parties’ identities, prejudice to the opposing party, whether the identity has remained confidential, and whether other confidentiality protections are available. These considerations may also apply to defendants seeking anonymity.

Court’s ruling

The court granted Doe’s motion. It found that continued pseudonymity was warranted because the professional-wrongdoing claims were not established and, because the case settled before discovery, would not be established through further litigation. The court also noted that Doe was not a public figure, disclosure would not independently serve the public interest in this case, Doe had not initiated the matter or sought to use the litigation for personal advantage, Ipsos did not oppose the motion on any ground including possible prejudice, and Doe’s identity had remained confidential.

Doe may continue to proceed under the pseudonym “John Doe,” the redactions of his identifying information will remain, and the case remains closed.