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S.D.N.Y.Procedural orderFiled June 16, 2022

Strike 3 Holdings, LLC v. Doe

Judge
Paul Crotty
Docket
1:22-cv-02729
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureDiscovery
In one sentence

In Strike 3 Holdings v. Doe, Judge Crotty authorized an early subpoena seeking the defendant’s identity from an internet provider.

Who this affects

Strike 3 Holdings, LLC, John Doe, Spectrum, and any other internet-service provider identified through the authorized subpoenas.

What happened

Strike 3 Holdings, LLC sued John Doe, identified in the complaint by an internet-protocol address, and asked to contact the internet provider before the usual early case conference.

The court found that Strike 3 Holdings had shown good cause to serve a subpoena on Spectrum, the internet provider, seeking the defendant’s true name and address. The court also allowed subpoenas to other internet-service providers identified through that process.

Judge Crotty ordered that any cable operator must notify the defendant of the order when required by federal law. Strike 3 Holdings may use the information only to protect and enforce the rights described in its complaint.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Strike 3 Holdings, LLC v. Doe · No. 1:22-cv-02729
Judge
Paul Crotty
Date
June 16, 2022

Background

Strike 3 Holdings, LLC filed a case against John Doe, described in the caption as the subscriber assigned Internet Protocol address 98.14.137.80. Strike 3 Holdings asked for permission to serve a subpoena on Spectrum before the parties held the conference ordinarily required by Rule 26(f) of the Federal Rules of Civil Procedure.

Court’s Analysis

The court found that Strike 3 Holdings had established “good cause” to serve a third-party subpoena. The subpoena may require Spectrum to provide the defendant’s true name and address. The court also authorized Strike 3 Holdings to serve the same type of subpoena on another internet-service provider identified in response to a subpoena as providing internet services to one of the defendants.

Order

The court authorized Strike 3 Holdings to serve a Rule 45 subpoena on Spectrum before the Rule 26(f) conference and required that a copy of the order be attached. If Spectrum qualifies as a cable operator under 47 U.S.C. § 522(5), it must comply with the notice requirement in 47 U.S.C. § 551(c)(2)(B) by sending a copy of the order to the defendant. Strike 3 Holdings may use information disclosed in response to the subpoena only to protect and enforce the rights described in its complaint.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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