In re Subpoena to Reddit — film studios' RCN piracy unmasking quashed (2023)

In 2023, a group of film-production companies — including Bodyguard Productions, Millennium Media-affiliated entities, Voltage Holdings, and others, represented by attorney Kerry Culpepper — sought to subpoena non-party Reddit to identify six users who had posted comments discussing movie piracy. The producers were not suing the Redditors; instead they wanted the comments and any identifying information as evidence in a separate copyright suit against the internet service provider RCN (Astound Broadband), to argue the ISP tolerated infringement by its subscribers.

The matter was docketed in the U.S. District Court for the Northern District of California as 'In re Subpoena to: Reddit, Inc.' (No. 3:23-mc-80037-LB) and assigned to Magistrate Judge Laurel Beeler. Reddit moved to quash, arguing that the targeted comments were protected anonymous speech and that the First Amendment requires a heightened showing before a court compels a platform to unmask a speaker. Reddit's filings stressed that talking about piracy is not itself copyright infringement, and that even advocacy of unlawful acts falls within the core of First Amendment protection.

On 28 April 2023, Judge Beeler denied the motion to compel and quashed the subpoena. Applying the framework from cases such as Doe v. 2TheMart.com, she found that the First Amendment barred the discovery — particularly because the producers could obtain the evidence they actually needed elsewhere, and because several of the comments were years old and only tangentially related to the ISP at issue. The ruling was widely reported as a win for online anonymity.

The RCN subpoena was one in a recurring series. The same constellation of film companies pursued comparable subpoenas tied to copyright suits against other ISPs, and Reddit defeated those attempts as well at the district-court level. Press coverage frequently blends these cases together because the plaintiffs, the legal theory, and the outcome were so similar each time.

The case became a leading example of a platform actively resisting a third-party unmasking demand rather than quietly complying. Digital-rights advocates pointed to it as evidence that the First Amendment's protection for anonymous speech extends to ordinary forum comments, not just political or whistleblower speech, and that copyright litigation cannot be used as a shortcut around those protections.