Balancing the public interest against fairness to the parties showsthat anonymity is proper in BitTorrent copyright cases. First, the public interest in learning whose IP address was used to allegedly download pornography illegally from the Internet is presumably low. Second, because at the early discovery stage it is far from clear that the person whose name is associated with the IP address is the person who actually committed the illegal download,173 it is reasonable to keep the IP account holder’s identity private, particularly when embarrassing content such as pornography is the basis of the lawsuit.Finally, the “smell test” is also of use here. If the court has reason to believe that the plaintiff has no intention of actually litigating the copyright claim, it is reasonable to keep the identities anonymous in order to frustrate the “settlement letter factory” business model.Therefore, the court should err on the side of granting protective orders for all Doe defendants.