A federal court last week ruled that copyright owners can only sue multiple peer-to-peer users if all of the defendants participated in the same infringement scheme.

In recent years, copyright owners have sued people who have shared their movies, songs, and other content via peer-to-peer networks such as BitTorrent. The copyright owners use proprietary software to obtain the IP addresses of BitTorrent users who are downloading and sharing the copyright holders’ content. Rather than filing individual lawsuits against each user, the copyright owners often name dozens of alleged John Doe infringers in the same complaint. After filing the complaint, the copyright owners typically issue subpoenas to the customers’ Internet service providers to determine the identities of the John Doe defendants.

Although courts have generally approved the subpoenas for the identities of John Doe defendants in copyright infringement cases, plaintiffs are encountering a new obstacle, as illustrated in the September 27 opinion by Judge John Z. Lee, a district judge for the U.S. District Court for the Northern District of Illinois.

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