The fourth step is to learn the true identities of the anonymous“John Doe” defendants.59 This is perhaps the most crucial stepwithout this identifying information, the settlement letters cannot be
sent and the copyright troll business model would simply fall apart. As the provider of the IP address, Internet Service Providers61 (ISPs)are the only source of this identifying information.62 An ISP can
match a particular IP address with the name, address, telephonenumber, email address, and Media Access Control (MAC) address63 ofthe subscriber assigned to it when the alleged illegal downloading
took place. ISPs, however, often hesitate to comply with copyrighttrolls because of the “undue burden” of compliance, generallybecause of time and financial costs, as well as privacy concerns.64
Thus, in response to such hesitation, copyright trolls generally file anex parte motion for expedited discovery in conjunction with a requestto subpoena the ISPs to compel them to turn over the identifyinginformation.65 Courts generally grant these expedited discovery motions,66 especially because ISPs retain logs of the activity of IP addresses for only a limited time.6