(i) the likelihood that each John Doe defendant will assertdifferent defenses, thereby adding factual and legalquestions that are not common among all defendants, (ii)many John Doe defendants are proceeding pro se, and willtherefore incur significant expense serving papers and attending depositions of all other parties to the lawsuit, (iii) the likelihood that many of the John Doe defendants are not the actual individuals who illegally downloaded the motion pictures in question, (iv) the likelihood that joinder will facilitate coercive settlements among the John Doe defendants; and (v) plaintiff’s avoidance of paying filing fees by pursuing mass actions.152