In re Subpoena to Reddit, Inc. (RCN piracy commenters)
U.S. District Court for the Northern District of California (San Francisco Division)
- Court
- U.S. District Court for the Northern District of California (San Francisco Division)
- Docket
- No. 3:23-mc-80037-LB
- Parties
- Movants: fifteen film production companies (Bodyguard Productions, Millennium Funding, Voltage Holdings, et al.), plaintiffs in the underlying D.N.J. suit against RCN. Non-party respondent: Reddit, Inc.
- Claim type
- ip-scraping
- Filed
- 2023
- Outcome
- Motion to compel denied and subpoena quashed; Magistrate Judge Laurel Beeler held the First Amendment barred the discovery because the producers failed to show the requested identities were directly and materially relevant or unavailable from other sources such as RCN itself.
Summary
Fifteen film production companies suing ISP RCN in New Jersey for failing to terminate alleged repeat-infringer subscribers served a subpoena on non-party Reddit seeking identifying information for eight Reddit accounts whose comments referenced movie piracy, then moved to compel after Reddit refused. Magistrate Judge Laurel Beeler applied the First Amendment test for unmasking anonymous online speakers and, on April 28, 2023, denied the motion and quashed the subpoena. The court found the producers had not shown a compelling need outweighing the users' right to anonymous speech, noting the evidence could be obtained from RCN. This was the first of several similar disputes between these filmmakers and Reddit in the Northern District of California.